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INTERNATIONAL EXTRADITION · EUROPE

Extradition from Albania to the United States.

Extradition Treaty Between the United States of America and Albania controls the request. The 1933 treaty does not create an absolute nationality bar. The arrest clock and local review path decide what happens next.

Counsel working on the international federal record
FIG. - COUNSEL · THE ALBANIA FILE
WRITTEN BYTodd A. Spodek
LEGAL REVIEWAttorney review pending
RESEARCH VERIFIED2026-07-14

THE SHORT ANSWER

draft.

draft No reliable general duration published. DOJ's Deme Nikqi case records arrest on 2011-10-04, ministerial approval on 2011-12-20, and arrival in the United States on 2012-01-06; that single case is not a forecast.

TREATY ON THE RECORD

Extradition Treaty Between the United States of America and Albania

Effective: 1935-11-14

Own nationals
The 1933 treaty does not create an absolute nationality bar. Albania's Constitution permits extradition only when an international agreement expressly provides for it and only by judicial decision. Nationality and the modern Albanian implementing law therefore require case-specific review; the treaty's broad 'any person' language was upheld as still in force in Hoxha.
Dual criminality
This is an old list treaty, not a modern across-the-board dual-criminality treaty. The conduct must fit an Article II listed offense (including participation/accessory rules) and satisfy the requested state's evidentiary standard.
Rule of specialty
The treaty limits prosecution after surrender to the offense for which extradition was granted until the person has had an opportunity to leave; consent and later conduct may alter the analysis.
Provisional arrest
A diplomatic or consular application may seek a preliminary warrant. If the formal requisition and evidence are not produced within two months after arrest, the person may be released; release does not necessarily bar a later treaty-compliant request.
Appeal path
Domestic criminal-procedure remedies and constitutional/ECHR claims may be available. Exact route and deadlines require Albanian counsel because the 1933 treaty does not define appellate procedure.

WHAT COUNSEL CHECKS FIRST

The active paper. The country. The clock.

Warrant or noticeCustody and location in AlbaniaHearing or filing deadlineLocal-counsel requirement

THE RESPONSE ROOM

What has to be established first.

CUSTODY · PAPERS · CLOCK · COUNSEL

01

FIRST HOURS

Identify the legal basis for custody

Record the arresting authority, court, case number, custody location, interpreter need, and any hearing date. Ask for counsel before discussing the foreign accusation.

02

WHO DECIDES

The local record controls

Request through diplomatic channels; prosecutor/court review under Albanian criminal procedure; a judicial decision is constitutionally required; the Ministry of Justice/executive then arranges surrender if authorized.

03

THE CLOCK

Deadlines are event-specific

A diplomatic or consular application may seek a preliminary warrant. If the formal requisition and evidence are not produced within two months after arrest, the person may be released; release does not necessarily bar a later treaty-compliant request. No reliable general duration published. DOJ's Deme Nikqi case records arrest on 2011-10-04, ministerial approval on 2011-12-20, and arrival in the United States on 2012-01-06; that single case is not a forecast.

04

DOCUMENT AUDIT

Build the file before the argument

Preserve the notice or warrant, charging papers, identity records, release terms, travel documents, medical records, and every dated communication. Do not alter or delete evidence.

FOR FAMILIES COORDINATING ACROSS BORDERS

Confirm the exact legal name, detention location, medication needs, next hearing, local lawyer, and one reliable contact channel. A consulate may assist with welfare and contact; it cannot cancel the local case.

Tell the intake team where the person is now →

02 · THE PROCESS

How the Albania process moves.

REQUEST · COURT · REVIEW · SURRENDER

Judicial and executive stages

Request through diplomatic channels; prosecutor/court review under Albanian criminal procedure; a judicial decision is constitutionally required; the Ministry of Justice/executive then arranges surrender if authorized.

Appeal and review

Domestic criminal-procedure remedies and constitutional/ECHR claims may be available. Exact route and deadlines require Albanian counsel because the 1933 treaty does not define appellate procedure.

Diagram separating judicial eligibility review from the executive surrender decision
FIG. - COURT CERTIFICATION AND EXECUTIVE ACTION ARE DIFFERENT DECISIONS

03 · DEFENSES

The request still has to survive the record.

Put the papers in front of counsel →

ISSUE

Treaty coverage

The charged conduct, punishment threshold, documents, and identity must fit the controlling treaty and local implementing law.

ISSUE

Dual criminality

This is an old list treaty, not a modern across-the-board dual-criminality treaty. The conduct must fit an Article II listed offense (including participation/accessory rules) and satisfy the requested state's evidentiary standard.

ISSUE

Political and protected offenses

No surrender for a political offense or where the request is made to try or punish a person for a political offense. Purely military and fiscal treatment is not stated in the modern formula and must be tested against the listed-offense structure and current Albanian/ECHR law.

ISSUE

Evidence and process

The request can be tested against the treaty standard, authentication requirements, limitation rules, and procedural guarantees that apply locally.

ISSUE

Human rights and punishment

Albania has abolished capital punishment and is bound by the ECHR. A U.S. capital case ordinarily requires assurances sufficient under Albanian law and ECHR Articles 2 and 3; prison-condition, torture, persecution, and flagrantly unfair-trial claims are fact-specific.

ISSUE

Specialty and assurances

The treaty limits prosecution after surrender to the offense for which extradition was granted until the person has had an opportunity to leave; consent and later conduct may alter the analysis.

04 · PUBLIC EXAMPLES

Recent public extradition records.

GOVERNMENT RECORDS · NOT FIRM MATTERS

These examples come from public government records and are not presented as Spodek Law Group matters or results.

2012-11-16

Arif Kurti

drug trafficking and money laundering

United States
2012-01-06

Deme Nikqi

international human smuggling; 28-count indictment

United States

05 · THE CHARGES

What appears in the requests.

PUBLIC CASE PATTERN
Fraud and money laundering
PUBLIC CASE PATTERN
Drug trafficking and conspiracy
PUBLIC CASE PATTERN
Cybercrime and identity offenses
PUBLIC CASE PATTERN
Violence and organized-crime charges

A Red Notice is not the extradition order.

A Red Notice asks police worldwide to locate and provisionally arrest a person, subject to each country's law. It is not an international arrest warrant, and it does not replace the treaty papers or the local extradition case.

The notice, the provisional-arrest request, and the surrender proceeding are separate records. Each can carry different defects, deadlines, and remedies.

Read the Red Notice file →

07 · THIRD-COUNTRY RISK

A new border changes the law. It does not erase the file.

Transit can expose a person to another country's arrest rules, immigration powers, or provisional request. This page gives no route or evasion advice. Review the actual warrant, notice, release conditions, and jurisdictions with counsel before travel.

08 · QUESTIONS

What families and targets ask first.

FULL ANSWERS · SOURCE REVIEWED

IMMEDIATE EXTRADITION QUESTIONS

It can. Border screening may expose a national warrant, INTERPOL data, immigration authority, or a provisional request under another country's law. This is not travel or evasion advice; the actual records and jurisdictions require review before travel.

AUTHORITIESwww.interpol.int

COUNTRY PROCEDURE

Yes. The 1933 treaty entered into force on November 14, 1935, and the State Department confirmed it remained in force in the Hoxha litigation.

AUTHORITIEShistory.state.gov2009-2017.state.gov

09 · RESEARCH LIMITS

What the public record does not settle.

NO FACTS INVENTED TO CLOSE THE GAP

Open item 01
Current official English text of Albania's implementing extradition provisions and the exact ordinary appellate route were not located in an authoritative Albanian government source.
Open item 02
No public official source was found for five recent completed extraditions; only the verified cases listed are included.

10 · SOURCES

Every material claim should have a file behind it.

VERIFIED 2026-07-14

U.S. Department of State, Office of the Historian
U.S. Department of State
Venice Commission / text supplied by Albanian authorities
U.S. Department of Justice
official international source
Todd A. Spodek at the conference table
FIG. - TODD A. SPODEK · MANAGING PARTNER

WHO REVIEWS THE FIRST CALL

Start with the paper, the posture, and the first deadline.

Todd A. Spodek leads the firm's federal defense work. The team identifies the active U.S. matter, the country and custody posture, and where appropriately licensed local counsel is required. No webpage can replace review of the actual request.

Todd Spodek - biography and record →

SECURE CONSULTATION REQUEST

Put the actual extradition record in front of counsel.

Tell us whether this is an inquiry, Red Notice, detention, hearing, or appeal. The intake team will identify conflicts and the right next step. Urgent custody and hearing matters should call.

212 300 5196 - urgent matters →
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