U.S. Privacy Laws Haven’t Reached European Levels…Yet. Ask Marcin P.

There’s privacy, and there’s privacy. And this post, unlike the last one, is set on the other side of the Atlantic.

In October 2025, Interpol issued a red notice for the Chief Executive Officer of currency exchange Cinkciarz after Polish authorities charged him with orchestrating a fraud and money laundering scheme.

In May, United States authorities detained the CEO pending a Polish extradition request.

Naturally, the ongoing affair is being heavily reported in the Polish media…minus one teeny tiny detail.

The CEO’s last name.

Polish publications only identify him as “Marcin P.” due to Polish privacy laws.

The U.S. Marshals Service is under no obligation to comply with these laws, and printed the CEO’s last name in its media release. But on the slight chance that a Polish citizen may be reading the Bredemarket blog, I won’t reprint it here.

But Marcin P. is only a suspect

Of course, Marcin has not been convicted of a crime. But if he is eventually convicted. Polish law WILL allow publication of his last name.

Unless he lodges a request for GDPR “right of erasure,” a right that has been upheld in Luxembourg.

“The case concerns the former president of a trade union organisation from 1985 to 2002, against whom charges were brought for forgery, abuse of trust, fraud and theft. The case involved several million ‘Luxembourg Francs’ (the Euro banknotes were introduced in 2002) and hundreds of victims. The individual had confessed and was sentenced in 2007 for various offences to a prison sentence of six years, with a two-year suspended sentence….

“A TV program was broadcast in 2018, followed by a radio show in 2022. In the meantime, the individual filed a legal request in 2020 to prohibit the media outlet ‘from mentioning the name and publishing the image of the claimant on its TV broadcasts, radio programs, and websites in connection with its activities related to […], under penalty of a fine’….

“[T]he Court of Appeal found that the dissemination of the image and the publication of the name and surname were not necessary to achieve the goal of information.”

To date, I know of no case in the United States in which a convicted criminal’s name has been suppressed.

To date.

“The Woman in Pink” Identified via INTERPOL’s “Identify Me”

It’s challenging enough to identify a unknown deceased body found in the person’s home city.

It’s more challenging to identify one somewhere else in the person’s home country.

And when the body is found outside the person’s home country…that’s when organizations such as INTERPOL step in.

“Identify Me is a public appeal to identify women whose bodies were found in six European countries, many of whom are believed to have been murdered.

“Most are cold cases; women who died 10, 20, 30 or even 40 years ago. They were found in Belgium, France, Germany, Italy, the Netherlands, or Spain.

“Despite extensive police investigations, these women were never identified, and evidence suggests that some of them could have come from other countries. Who they are, where they are from and why they were in these countries is unknown.”

INTERPOL issues a variety of colored notices to its member countries, including the “Black Notice” to seek information on unidentified bodies. The “Identify Me” program is a public appeal for a small subset of these people.

Source: INTERPOL.

Here’s one of INTERPOL’s success stories, “The woman in pink“:

“On 3 July 2005, the body of a woman was found at the 84 km mark on the Vila road in the town of Viladecans (province of Barcelona). The woman had been dead for less than 24 hours; the cause of death was suspicious….

“A breakthrough came in 2025 when police in Türkiye ran the fingerprints associated with ‘The woman in pink’ through a national biometric database, resulting in a match with Russian national Liudmila Zavada, aged 31 at the time of her death. The match was subsequently confirmed through kinship DNA analysis using the DNA of one of Liudmila Zavada’s close relatives.”

So follow the trail:

  • There was a woman from Russia.
  • A deceased woman’s body was found in Spain.
  • Decades later, the deceased women was identified as the Russian woman via biometrics (fingerprints) in Türkiye.
  • The identification was confirmed via DNA analysis.

A true case of cross-national collaboration.