EUROPEAN COMMISSION Brussels, 29.4.2019 COM(2019) 196 final COMMUNICATION FROM THE COMMISSION Commission Anti-Fraud Strategy: enhanced action to protect the EU budget {SWD(2019) 170 final} - {SWD(2019) 171 final}



COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE, THE COMMITTEE OF THE REGIONS AND THE COURT OF AUDITORS Commission Anti-Fraud Strategy: enhanced action to protect the EU budget TABLE OF CONTENTS Key abbreviations2 1.Executive Summary 2.Introduction 2.1. The European Union’s fight against fraud 2.2. The 2011 Commission Anti-Fraud Strategy (CAFS) 2.3. Implementation and evaluation of the CAFS 2.4. The case for a new CAFS 2.5. The scope of the 2019 CAFS

3.Fraud risk assessment 4.Principles and priorities 4.1. Principles of the 2011 CAFS and of the 2019 CAFS 4.2. Priorities of the new CAFS 4.2.1. Objective No 1: data collection and analysis 4.2.2. Objective No 2: coordination, cooperation and processes 5.Further objectives 6.Monitoring and reporting Key abbreviations Abbreviation Meaning AOD Authorising Officer by Delegation CAFS Commission Anti-Fraud Strategy DG(s) Directorate(s)-General DG BUDG Directorate-General for Budget DG HR Directorate-General Human Resources and Security DG TAXUD Directorate-General for Taxation and Customs Union ECA European Court of Auditors EPPO European Public Prosecutor’s Office Eurojust EU Agency for Criminal Justice Cooperation Europol EU Agency for Law Enforcement Cooperation FPDNet Fraud Prevention and Detection Network FN Footnote FR Financial Regulation IAS Internal Audit Service IBOAs Institutions, bodies, offices and agencies of the EU IMS Irregularity Management System MFF Multiannual Financial Framework MS Member States OLAF European Anti-Fraud Office OLAF Regulation Regulation (EU, Euratom) No 883/2013 PIF Protection of the EU’s financial interests PIF Directive Directive (EU) 2017/1371 SG Secretariat-General SJ Legal Service SOCTA Serious and Organised Crime Threat Assessment SPP Strategic planning and programming TFEU Treaty on the Functioning of the European Union TOR Traditional own resources VAT Value added tax



1. Executive Summary EU citizens and taxpayers deserve EU institutions that operate with the utmost integrity. Their hard-earned contributions to the EU budget should be spent in a sound and efficient way and be protected from fraud. In 2017, the EU decisively stepped up the fight against fraud, by adopting the Directive on the fight against fraud to the Union’s financial interests by means of criminal law and the Regulation establishing the European Public Prosecutor’s Office (EPPO). To continue these positive developments beyond 2018 and prepare for a new generation of spending programmes in the Multiannual Financial Framework (MFF) 2021 - 2027, the Commission is updating its 2011 ‘Commission Anti-Fraud Strategy’ (CAFS) with this Communication. The CAFS is an internal policy document binding on the Commission services and executive agencies in their fight against fraud and corruption affecting the EU’s financial interests. An evaluation of the 2011 CAFS concluded that the CAFS is still relevant and effective as a policy framework for the Commission in protecting the EU budget but needs to adapt to an evolving situation (new funding schemes and fraud trends, development of IT tools, etc.). The Commission services have further carried out a fraud risk assessment, involving also the executive agencies. The two main vulnerabilities identified are (i) insufficient analysis of fraud data, which limits the Commission’s understanding of fraud, and (ii) certain gaps in the Commission’s supervision over fraud risk management at department level. These weaknesses have also been addressed in the recommendations of a recent Special Report from the European Court of Auditors entitled ‘Fighting fraud in EU spending: action needed’. The priority objectives of this 2019 CAFS are therefore to equip the Commission with a stronger analytical capability for purposes of prevention and detection and with a more centralised system of oversight for its anti-fraud action. In addition, the accompanying Action Plan, addressed to the Commission services and executive agencies, aims to improve anti-fraud cooperation and workflows across the board, for example the Commission’s and other EU bodies’ cooperation with OLAF and with the European Public Prosecutor’s Office (EPPO), currently being established. The Action Plan also carries forward the work of the 2011 CAFS, particularly in ensuring the soundness of public procurement and encouraging international cooperation. The Commission intends to tighten its internal monitoring systems for the 2019 CAFS and the accompanying CAFS Action Plan and develop indicators to make anti-fraud action more measurable. This will be reflected in the annual reports on the protection of the EU’s financial interests, in which the Commission regularly reports on the implementation of the CAFS. The objectives of the 2019 CAFS are listed in an annex to this Communication. The Communication is accompanied by two staff working documents, one that presents the results of the fraud risk assessment and another that sets out the updated Action Plan. The Evaluation of the 2011 CAFS is published simultaneously in a separate staff working document.

2. Introduction 2.1. The European Union’s fight against fraud Fraud that affects the EU budget can cause EU funds to be siphoned off from their legitimate purposes and thereby compromise the effectiveness of EU measures. When fraudsters succeed, they call the integrity of EU action into question and undermine the public’s trust in EU policies. Under Article 317 of the Treaty on the Functioning of the European Union (TFEU) and Article 36 of the Financial Regulation (FR) , the Commission implements the EU budget, complying with sound financial management principles and applying effective and efficient internal control, which includes preventing, detecting, correcting and following-up on fraud and other irregularities. The Commission does so in cooperation with the Member States, which collect and spend up to 80 % of the EU budget. Accordingly, Article 325(1) TFEU requires both the EU and the Member States to counter fraud and any other illegal activities affecting the financial interests of the EU. Every year the Commission’s report on the protection of the EU’s financial interests – the PIF Report – gives an overview of how the EU budget is affected by detected irregularities, including fraud. Though amounts and numbers fluctuate from year to year, it is clear that the level of known and reported fraud requires sustained EU action. Irregularities reported as fraudulent, 2014 - 2017 2014 2015 2016 2017 Budget sector Number of fraudulent irregularities Amounts involved (EUR m) Number of fraudulent irregularities Amounts involved (EUR m) Number of fraudulent irregularities Amounts involved

(EUR m) Number of fraudulent irregularities Amounts involved

(EUR m) Natural resources 519 68.6 444 74.1 413 61.8 276 59.9 Cohesion policy 306 274.2 371 477.5 407 236.9 345 320.4 Pre-accession 31 14.47 29 7.8 28 3.0 19 3.2 Direct expenditure 83 4.7 5 0.2 49 6.3 65 7.3 Own resources 710 176.2 612 78 513 83 441 76.4 Total 1 649 538.2 1 461 637.6 1 410 391.0 1 146 467.1 Source: Protection of the EU’s financial interests — Fight against fraud annual reports 2014 to 2017 .



Every year, the European Parliament examines the PIF Report and comments on it in a resolution, emphasising the importance of the fight against fraud . Most recently, the European Court of Auditors (ECA) produced a special report about the institutional framework and working methods behind the Commission’s fight against fraud in EU spending. The report underlined the importance of the subject and recommended further action. Against this backdrop, the revised Commission Anti-Fraud Strategy sets out a comprehensive approach to combating fraud affecting the EU’s financial interests and guides the Commission, its departments and its executive agencies, as they discharge their legal, political and managerial responsibilities, respectively, to protect the EU budget. The Member States are not directly addressed, but the Commission calls on them to also take appropriate measures to prevent, detect and correct fraud affecting the EU’s financial interests, in line with their obligation under the Treaty. The responsible Commission departments and OLAF will continue to support and monitor the action taken by Member States to tackle fraud. 2.2. The 2011 Commission Anti-Fraud Strategy (CAFS) On 24 June 2011, the Commission adopted its current anti-fraud strategy. This comprised: (i) a Communication from the Commission to the other institutions, describing strategic objectives and key operational steps to attain them, and (ii) a more detailed internal Commission Action Plan . The 2011 CAFS set out three priorities: (i) introducing anti-fraud provisions in Commission proposals on spending programmes under the MFF for 2014 – 2020; (ii) implementing anti-fraud strategies at service level; and (iii) revising the public procurement directives. 2.3. Implementation and evaluation of the CAFS Since 2013, the Commission has reported on the implementation of the 2011 CAFS in the PIF Reports . The priority actions and all measures set out in the internal action plan have been completed or are continuing in the case of those of a repetitive nature, e.g. training. The Commission services carried out an evaluation to assess the relevance, effectiveness, efficiency and coherence of the 2011 CAFS and its implementation. Its results are presented in detail in a Commission staff working document, published together with this Communication. 2.4. The case for a new CAFS The Commission’s current anti-fraud framework, based on the 2011 CAFS, already provides a good strategic basis for fighting fraud. However, the preparation of the next MFF post-2020 is the right time for the Commission to adapt and strengthen its anti-fraud activities where appropriate, for example in relation to new ways of financing. Moreover, the 2019 CAFS strengthens the fight against fraud that harms the budget on the revenue side (e.g. by preventing tax fraud and tackling smuggling) . To guide the review of its anti-fraud policies, the Commission services carried out a fraud risk assessment, summarised in the following chapter. The 2019 CAFS also takes account of the Evaluation of the CAFS for 2011 – 2017 and the results of the recent ECA performance audit ‘Fighting fraud in EU spending: action needed’ , among other sources.

The 2019 CAFS also adjusts to two significant additions to EU anti-fraud legislation adopted in 2017. These are: (i) the PIF Directive , which sets stricter common standards for Member States’ criminal laws to protect the EU’s financial interests; and (ii) the Regulation that established the European Public Prosecutor’s Office (EPPO) , by way of enhanced cooperation among 22 Member States at this stage. Once operational (in 2021), the EPPO will prosecute more effectively those criminal offences that harm the EU’s financial interests. Finally, the framework for an integrated policy of criminal and administrative investigations includes a proposal to amend the OLAF Regulation . The amendments proposed will allow OLAF to cooperate closely with the EPPO and to carry out its own investigations more effectively. Smooth and strong cooperation between the EPPO, OLAF, Eurojust, Europol and the Member States is essential for ensuring that the scope of investigations is comprehensive and that the new institutional design for the fight against fraud is fully effective . The implications of the EPPO’s establishment for Commission departments are also mirrored in the 2019 CAFS Action Plan . 2.5. The scope of the 2019 CAFS The 2019 CAFS focuses on protecting the EU’s financial interests from fraud, corruption and other intentional irregularities and on the risk of serious wrongdoing inside the EU’s institutions and bodies. These areas are also central to the legislator in the fight against fraud. As a result, the new CAFS covers: oFraud – including VAT fraud –, corruption and misappropriation affecting the EU’s financial interests, as defined in Articles 3 and 4 of the PIF Directive; oOther criminal offences affecting the Union’s financial interests, e.g., offences linked to an abuse of procurement procedures where they affect the EU budget; oIrregularities as defined in Article 1(2) of Regulation (EC, Euratom) No 2988/95 (insofar as they are intentional but not already captured by the criminal offences referred to above); oSerious breaches of professional obligations by staff or Members of the Union’s institutions and bodies, as referred to in Article 1(4) of the OLAF Regulation and in the second subparagraph of Article 2(1) of Commission Decision (EC, ECSC, Euratom) No 352/1999 . When the 2019 CAFS refers to "fraud", it uses this word as an umbrella term for various types of criminal and non-criminal wrongdoing, as set out above. More detail and context is provided in the Fraud Risk Assessment . Where this Communication and the accompanying staff working documents refer to the protection of the EU budget, financial interests of the EU outside the legal framework of the general budget, such as the European Development Fund , are included, mutatis mutandis.



3. Fraud risk assessment A qualitative fraud risk assessment was carried out in close consultation with all Commission services and executive agencies. It focused on vulnerabilities to fraud in the Commission’s internal control systems and identified two areas for improvement: oTo improve fraud risk assessment and fraud risk management, the Commission needs a more comprehensive central analytical capability so that it can scan data on fraud patterns, fraudsters’ profiles and vulnerabilities in EU internal control systems. A substantial boost to the Commission’s analytical capabilities should provide support and advice to financial actors, auditors and investigators in preventing and fighting fraud and help the Commission: (i) develop anti-fraud policies based on facts and evidence; (ii) use its control mechanisms and resources as effectively and efficiently as possible; and (iii) enable fraud to be detected. oIn line with the Commission’s decentralised model of financial management, fraud risk assessment and management is undertaken by authorising officers by delegation , i.e. they are the prime responsibility of Commission services and executive agencies. The main advantage of this model is the possibility to tailor anti-fraud strategies to the policy area or field of operations of the individual department concerned. However, to ensure consistency and to optimise efficiency and effectiveness, decentralised assessment and management of fraud risks need to be coordinated and monitored by a strong central review system. Apart from systemic vulnerabilities, the fraud risk assessment also analysed fraud patterns. Cost overcharging through false declarations and/or falsified supporting documents is one of the most frequent fraud patterns detected. This type of fraud risk is expected to become less significant because the new Financial Regulation and the sector-specific programmes in the MFF 2021–2027 aim to increase the proportion of EU funding not linked to costs or based on simplified cost options, which have proven to be less prone to attempts at fraud . Potential new risks posed by those types of funding – linked to verifying the results of the funding measure – will be monitored and mitigated as necessary. The new 2019 CAFS Action Plan therefore calls for control strategies to be optimised . In the area of traditional own resources (TOR), customs fraud — committed through smuggling, misdeclaration or undervaluation — causes considerable damage to the EU budget. In 2016, the fraud detection rate of 0.33 % in TOR exceeded the 0.21 % fraud detection rate on the expenditure side of the budget . Even though the ‘gap’ was narrower , this trend continued in 2017 (0.30 % against 0.29 %). In the area of VAT, it is estimated that cross-border fraud, such as ‘missing trader’ or ‘carousel’ fraud , generates budgetary losses of around EUR 50 billion a year . However, most of this is borne by the Member States. In revenue fraud, the harm caused by organised crime groups is very significant , although such criminal groups are also active in procurement and subsidy fraud . The EU has a policy cycle in place for tackling organised and serious international crime which involves coordination between the EU institutions and agencies and the Member States . Several of the policy priorities for 2018 - 2021 for this type of crime are on fighting fraud . The EU strategy for fighting cigarette smuggling and other forms of illicit trade in tobacco products , whose action plan was recently updated, also has a strong focus on tackling organised crime.



CAFS Evaluation and Fraud Risk Assessment

– strengths and weaknesses

in the Commission’s fraud risk management Strengths: Weaknesses: ·corporate anti-fraud strategy laying down coherent overarching principles;

·tailor-made anti-fraud strategies at service level, management plans and reporting, embedding fraud prevention and detection in internal control;

·support from OLAF and other ‘central services’ and exchange of best practices in dedicated fora for cooperation. ·gaps in IT-supported collection and strategic analysis of fraud-related data;

·lack of relevant and reliable indicators to make success in the fight against fraud more measurable;

·potential for more effective central coordination and oversight.

4. Principles and priorities 4.1. Principles of the 2011 CAFS and of the 2019 CAFS The overall objective of the 2011 CAFS is still fully relevant. The new CAFS reiterates it and emphasises the comprehensive approach required to counter EU-fraud. This comprehensive approach covers the complete anti-fraud cycle and comprises: (i) improving prevention, detection and the conditions for investigating fraud; and (ii) ensuring there is sufficient reparation and deterrence, with proportionate and dissuasive sanctions. As such, the guiding principles and target standards for Commission services and executive agencies in the fight against fraud remain valid . As an additional principle of the 2019 CAFS , the Commission commits to effective internal and external communication on the EU’s fight against fraud. While internal communication is instrumental in steering and supporting the institution’s anti-fraud action, external communication serves to protect the EU’s reputation and to reassure the public about the integrity and sound financial management of EU operations. Communicating about the EU’s fight against fraud may also deter potential fraudsters. Fight against fraud:

Guiding principles and target standards ● zero tolerance for fraud; ● fight against fraud as an integral part of internal control; ● cost-effectiveness of controls; ● professional integrity and competence of EU staff; ● transparency on how EU funds are used; ● fraud prevention, notably fraud-proofing of spending programmes; ● effective investigation capacity and timely exchange of information; ● swift correction (including recovery of defrauded funds and judicial/administrative sanctions); ● good cooperation between internal and external players,

in particular between the EU and national authorities responsible, and among the departments of all EU institutions and bodies concerned; To resolve possible conflicts between the first and third principle,

two factors are key: ·effective internal and external communication on the fight against fraud. –It is imperative to take the reputational aspect fully into account when applying the requirement of cost-effectiveness to anti-fraud controls, especially in cases of internal fraud.

–It is not possible to prevent fraud entirely, but as soon as there are indications that fraud may have occurred, quick action is essential: OLAF should be informed without delay, precautionary measures may have to be taken, and recovery should begin as soon as possible. 4.2. Priorities of the new CAFS Based on the Fraud Risk Assessment and taking into account the recommendations of the ECA Special Report mentioned above , the Commission has set out two priority objectives, related to improving (i) data collection and analysis and (ii) coordination, cooperation and processes. 4.2.1. Objective No 1: data collection and analysis Further improve the understanding of fraud patterns, fraudsters’ profiles and systemic vulnerabilities relating to fraud affecting the EU budget. Data collection and analysis serve financial actors, auditors and investigators and contribute to the EU’s fight against fraud, notably through: oobserving the ‘(anti-)fraud landscape’ in the EU and beyond, and providing insight into emerging fraud patterns and innovative ways of combating fraud; ocollecting and analysing data on established and suspected cases of fraud, deepening knowledge about vulnerabilities, fraud patterns and fraudsters’ profiles, and helping to deploy or adjust control mechanisms and resources in the most effective and efficient way possible; and oprocessing data on risk profiles and fraud indicators, to detect and prevent fraud in the future. On the expenditure side of the budget, the Commission already maintains two databases that are crucially important for the fight against fraud: othe Early Detection and Exclusion System (EDES) database, which records administrative sanctions imposed on unreliable businesses in direct and indirect management and flags up potential risks posed by individual entities; and othe Irregularity Management System (IMS), managed by OLAF, through which Member States report irregularities, including fraud, detected in shared management of EU funds. Among a variety of measures detailed in the Action Plan, improved monitoring of the completeness and quality of data and further developing the IMS as an analytical tool will increase the added value of the IMS, both for the Commission and the Member States. The Commission is committed to improving the quality and completeness of the data retrieved, and the analysis of the nature or methods of detected fraud, both: oin general (through continued development of the analysis of IMS data and the use of other data available); and oin relation to specific sectors and/or Member States (through more in-depth analyses based on much broader, yet tailored, data collection and intense cooperation with the relevant stakeholders).

In this context, the Commission is committed to developing specific and comparable knowledge about the anti-fraud framework in the different Member States, which is the background against which data on detection should be interpreted. Ultimately, this strengthened analysis aims to improve prevention (e.g. better data on fraud patterns and systemic vulnerabilities, which can be acted upon), detection (e.g. developing risk indicators, tailored to specific sectors or regions) and investigation (e.g. widening knowledge about fraudulent activities). A new intelligence scanning function will feed into the overall process by proactively exploring the (anti-)fraud landscape for emerging cross-cutting or sector-specific fraud risks. In particular, the Commission intends to use risk-scoring tools more comprehensively in direct management and to further explore and promote their use in indirect and shared management. On the revenue side, in the area of TOR, the Commission maintains the OWNRES database for irregularities reported by the Member States. The Commission’s Anti-Fraud Information System (AFIS) provides a platform for secure contacts with the competent authorities in the Member States and enables effective transnational cooperation in fighting customs fraud. Moreover, the Commission has developed several tools to monitor and identify suspicious activities . This work is shared with Member States. The Commission will further boost its analytical capabilities in this area. The aim is to research, support and facilitate the sharing of knowledge, good practice and lessons learnt in data analysis for the benefit of customs officials who fight fraud. The ultimate objective is to build a community of experts in the field, improve collaboration among all players concerned and bring genuine EU added value. The increased availability of data and the continuous refinement of analysis techniques and IT tools may also improve the quality and quantity of incoming information of investigative interest for OLAF. Ultimately, this might lead to more, and better targeted, investigations being opened in the medium to long term. It goes without saying that any collection and processing of data will respect data protection legislation and other applicable provisions. Collection and analysis of fraud related data Information sources: Scientific studies OLAF investigations Improved Irregularity ManagementSystem Commission audits and databases Public and commercial databases Other info provided by EU institutions and bodies and Member States

4.2.2. Objective No 2: coordination, cooperation and processes Optimise coordination, cooperation and workflows for the fight against fraud, in particular among Commission services and executive agencies Since its administrative reform in 2000 , the Commission has followed a decentralised model of financial management, which holds managers in the different departments accountable and allows the Commission to tailor anti-fraud controls to different policy areas and operations, thus increasing their effectiveness and efficiency. Therefore, the current legal framework gives authorising officers by delegation (AODs) the responsibility for internal control, which includes preventing, detecting, correcting and following-up on fraud and other irregularities, while OLAF helps to develop the methods that prevent and combat fraud. Under the 2011 CAFS, the Commission departments and executive agencies adopted anti-fraud strategies for their respective areas of responsibility. These strategies are based on sectoral fraud risk assessments and focus on cost-effective anti-fraud controls in risk-prone fields. OLAF provides methodological guidance and, upon request, individual advice for services’ anti-fraud strategies, which are embedded in the Commission’s internal control system and its annual strategic planning and programming cycle. In this context, OLAF systematically reviews the anti-fraud aspects of the Commission departments’ management plans and annual activity reports. Moreover, the Fraud Prevention and Detection Network (FPDNet), chaired by OLAF, provides a forum for exchange among the anti-fraud correspondents in the Commission and its executive agencies. Despite this significant support at Commission level, OLAF’s support role remains at an advisory level, which means that department-level approaches may diverge in scope and ambition. Therefore, corporate oversight should be strengthened from an institutional point of view, to ensure that the Commission’s anti-fraud policies are consistent and backed by strong analysis, taking them to the forefront of the fight against fraud. To that end, OLAF’s support should be developed to provide flexible corporate oversight for fraud risk management that respects the responsibilities of the AODs but can challenge their assessments and managerial approaches where appropriate. In practice, this concept implies the following. oWhere possible, anti-fraud strategies of Commission services and executive agencies with similar profiles should be merged into joint anti-fraud strategies. Examples set by departments responsible for the European Structural and Investment Funds, for research funding and for external aid have proven useful in streamlining anti-fraud policies in those fields. Other service-level anti-fraud strategies should be updated to reflect the approach set out in this Communication. oBased on needs to be analysed, subgroups of the FPDNet should be set up, bringing together departments with similar profiles. OLAF and DG BUDG should be included in these subgroups, to stimulate exchange of best practice and to facilitate a peer review of anti-fraud strategies. The first subgroup of this kind was created for the TOR area in 2017. oMandatory review by OLAF of draft service-level anti-fraud strategies and updates : OLAF will systematically advise services on the design of their anti-fraud strategies, which should include issuing recommendations when needed. oAn AOD who decides not to follow such recommendations needs to justify that decision in writing. Any issues that cannot be resolved bilaterally between OLAF and the department concerned may be discussed in the relevant subgroup of the FPDNet and/or in other suitable formats, without prejudice to the AOD’s ultimate responsibility. oBased on detailed annual reporting by the Commission services and executive agencies and regular exchanges with them, OLAF should monitor the implementation of service-level anti-fraud strategies and issue recommendations on these when necessary. Such recommendations are to be followed up as set out in the previous point. However, OLAF’s role in reviewing and monitoring does not include carrying out anti-fraud audits. Audits in the anti-fraud area remain the prerogative of the Internal Audit Service of the Commission (IAS) and the ECA, based on the legal framework (e.g. the Financial Regulation) and their respective methodologies and risk assessment approach. A yearly discussion and evaluation of the follow-up to OLAF’s recommendations on the Commission’s service-level anti-fraud strategies, and to the implementation of the 2019 CAFS Action Plan should take place in a dedicated meeting of the Commission’s FPDNet at Directors’ level. Another important aspect of the Commission’s anti-fraud work is the follow-up, by the Commission and its executive agencies, to OLAF’s recommendations issued as a result of OLAF investigations. In cooperation with the authorising officers concerned, OLAF will improve the monitoring of the follow-up to its recommendations and regularly provide the central services with an overview of the monitoring results. The follow-up to OLAF’s financial and administrative recommendations will also be supported by regular systematic discussion at working level in line with the Administrative Arrangements on co-operation and timely exchange of information agreed between the Commission and OLAF , as well as by systemic follow-up in the FPDNet and by the Corporate Management Board. At strategic level, the Corporate Management Board (CMB) will, on an annual basis, discuss and review the Commission’s anti-fraud policies, based on preparatory work to be done by OLAF, the FPDNet and the central services. Other ad-hoc discussions at the CMB may also take place when necessary. This strategic approach to corporate fraud risk management, with the CMB and OLAF as key players, is also reflected in the "governance package", which was adopted by the Commission on 21 November 2018 and assigns a strategic role regarding corporate aspects of the fight against fraud in the Commission to the CMB and designates OLAF as the lead service in the conception and development of a European anti-fraud policy . 5. Further objectives Further objectives, which are spelled out more fully in the Annex and supported by action points detailed in the Action Plan, cover the following areas: Øintegrity and compliance; Øknow-how and equipment;