International organizations have increasingly become engaged in developing transnational memory frames for the Holocaust. Based on document analysis and interviews with transnational norm entrepreneurs, this article explores the role and interaction of three organizations: the European Union, the International Holocaust Remembrance Alliance and UNESCO. It employs the multi-level governance approach to analyze how Prime Minister Göran Persson and a ‘progressive’ alliance of Western politicians initially ‘uploaded’ a Swedish initiative to the EU and the UN system. In the EU, however, East-Central European norm entrepreneurs have increasingly pushed for greater emphasis on Stalinist crimes, which has reinforced the totalitarian paradigm and effectively undermined Holocaust remembrance. In contrast, the battle over the possible link between Holocaust remembrance, collective identity and political legitimacy is absent from the UN system. The UN and UNESCO have transformed the Holocaust into a universal code for the need to protect human rights and democracy.