COMMISSION STAFF WORKING DOCUMENT Annual overview with information on the results of the Hercule III Programme in 2017 Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLEMENT AND THE COUNCIL 29th Annual Report on the Protection of the European Union's financial interests - Fight against Fraud - 2017
Date: 2018-09-03
Institutions: European Anti-Fraud Office, European Commission
Subjects: EU programme, activity report, common strategy, crime, fight against crime, financial control, fraud, fraud against the EU

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 3.9.2018  SWD(2018) 381 final  COMMISSION STAFF WORKING DOCUMENT Annual overview with information on the results of the Hercule III Programme in 2017 Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLEMENT AND THE COUNCIL 29th Annual Report on the Protection of the European Union's financial interests - Fight against Fraud - 2017 {COM(2018) 553 final} - {SWD(2018) 382 final} - {SWD(2018) 383 final} - {SWD(2018) 384 final} - {SWD(2018) 385 final} - {SWD(2018) 386 final}  
 
 
1. 

Introduction .................................................................................................................................... 2 

1.1  Hercule III Programme ................................................................................................ 2 

1.2  Hercule III: eligible actions, beneficiaries and budget ................................................ 3 

1.3 

Purpose and scope of this overview ............................................................................ 3 

2.  Budget implementation in 2017 ...................................................................................................... 4 

2.1  Budget implementation by type of financial intervention ........................................... 4 

2.2  Budget implementation by type of eligible action ....................................................... 6 

2.2.1   Technical Assistance grants ................................................................................. 7 

2.2.2  

IT Support: Databases, IT tools and analyses of samples from tobacco seizures 8 

2.2.3  Conferences, seminars and digital forensics training ........................................ 10 

3.  Achievements 2017 ...................................................................................................................... 11 

3.1  To  improve  the  prevention  and  investigation  of  fraud  and  other  illegal  activities 
beyond current levels by enhancing transnational and multi-disciplinary cooperation ....... 12 

3.2  To  increase  the  protection  of  the  financial  interests  of  the  Union  against  fraud  by 
facilitating  the  exchange  of  information,  experiences  and  best  practices,  including  staff 
exchanges ............................................................................................................................. 13 

Strengthening  the  fight  against  fraud  and  other  illegal  activities  by  providing 
3.3 
technical  and  operational  support  to  national  investigation,  and  in  particular  customs  and 
law enforcement, authorities ................................................................................................ 15 

Examples  of  operational  results  obtained  from  the  use  of  the  AMT  and  ConTraffic-SAD 
tools and the tobacco analyses laboratory (developed with the JRC) .................................. 18 

3.4  To  limit  the  currently  known  exposure  of  the  financial  interests  of  the  Union  to 
fraud, corruption and other illegal activities with a view to reducing the development of an 
illegal  economy  in  key  risk  areas  such  as  organised  fraud,  including  cigarette  smuggling 
and counterfeiting ................................................................................................................. 20 

3.5  To enhance the degree of development of the specific legal and judicial protection of 
the financial interests of the Union against fraud by promoting comparative law analysis . 21 

4.  Communication ............................................................................................................................ 22 

4.1 

Informing potential applicants ................................................................................... 22 

4.2  Dissemination of results ............................................................................................ 22 

4.3 

Publicity ..................................................................................................................... 22 

5. 

Feedback from participants of the programme ............................................................................. 23 

6.  Mid-term evaluation of the programme ........................................................................................ 23 

7.  Conclusions and way forward ...................................................................................................... 24 

Annex 1: Grants and contracts awarded and finalised under the 2017 Financing Decision ................. 25 

1 

 
 
1. 

Introduction 

1.1  Hercule III Programme  

The  aim  of  the  Hercule  III  Programme  (hereinafter  referred  to  as  “the  Programme”)  is  to 
protect  the  financial  interests  of  the  European  Union  by  fighting  fraud,  corruption  and  any 
other  illegal  activities.  The  Programme  provides  support  to  national  and  regional 
administrations,  as  well  as  research  and  educational  institutes  and  other  non-profit  making 
entities  which  “promote  the  strengthening  of  action  at  Union  level  to  protect  the  financial 
interests of the Union”. The financial support mostly consists of grants awarded to competent 
authorities in the Member States to strengthen their operational and technical capacity to carry 
out  investigations  into  activities  detrimental  to  the  financial  interests  of  the  Union.  The 
financial  support  is  used  for  the  purchase  of  technical  equipment,  such  as  x-rays  scanners, 
soft-  and  hardware  for  securing  evidence  from  computers  or  smartphones  (digital  forensics 
examinations)  or  the  purchase  and  installation  of  integrated  systems  for  number  plate 
recognition  (Automated  Number  Plate  Recognition  Systems-ANPRS).  The  Programme  also 
finances trainings and conferences as well as comparative studies and scientific publications. 
The  legal  basis1  of  the  Programme  requires  the  Commission  to  adopt  an  annual  work 
programme  for  the  implementation  of  the  Programme  and  to  submit  a  report2  on  the  main 
results and achievements  every year to  the European Parliament and to  the Council. This  is 
the fourth annual overview of the achievements and results3.  

The  Programme  is  implemented  in  accordance  with  Regulation  (EU,  Euratom)  No. 
966/20124. 

The  Programme  is  the  only  instrument  specifically  dedicated  to  protecting  the  Union’s 
financial interests and is administered by the European Anti-Fraud Office (OLAF), which in 
the field of anti-fraud policy operates as a Directorate-General of the European Commission. 

The general objective of the Programme is “to protect the financial interests of the Union thus 
enhancing  the  competitiveness  of  the  Union's  economy  and  ensuring  the  protection  of  the 
taxpayers'  money”5,  whereas  the  Programme’s  specific  objective  is  “to  prevent  and  combat 
fraud,  corruption  and  any  other  illegal  activities  affecting  the  financial  interests  of  the 
Union”6. The five operational objectives7 of the Programme are described in section 3 of this 

1  

2  

3  

4  

5  
6  
7  

Regulation 250/2015 of the European Parliament and of the Council of 26 February 2015, OJ L 84 of 
20  March  2015.  The  Regulation  entered  into  force  on  21  March  2015  and  was  applicable  from  1 
January 2015 onwards.  
Article 13 of Regulation 250/2015 (Monitoring and Evaluation) requires the Commission “to provide 
the European Parliament and the Council, on an annual basis, with information on the implementation 
of the Programme, including on the achievement of the objectives of the Programme and the results”.  
The  fourth  annual  work  programme  was  adopted  by  Financing  Decision  C(2017)1120  final  of 
22 February 2017. 
Regulation (EU, Euratom) 966/2012 of the European Parliament and of the Council of 25 October 2012 
on the financial rules applicable to the general budget of the Union (Financial Regulation – FR), OJ L 
298  of  26  October  2012,  as  amended  by  Regulation  (EU,  Euratom)  2015/1929  of  28 October 2015, 
OJ L 286 of 30 October 2015 and Commission Delegated Regulation 1268/2012 of 29 October 2012 on 
the rules of application of Regulation (EU, Euratom) No. 966/2012 of the European Parliament and of 
the  Council  on  the  financial  rules  applicable  to  the  general  budget  of  the  Union,  OJ  L  362  of 
31 December 2012  (Rules  of  Application  –  RAP),  as  amended  by  Commission  Delegated  Regulation 
(EU) 2015/2462 of 30 October, L 342 of 29 December 2015. 
Article 3 of Regulation 250/2015. 
Article 4 of Regulation 250/2015. 
Article 5 of Regulation 250/2015. 

2 

 
 
 
                                                 
report,  together  with  an  overview  of  the  main  results  of  the  actions  carried  out  under  the 
Programme and their contribution to the operational objectives. 

1.2  Hercule III: eligible actions, beneficiaries and budget   

There are three types of eligible actions8 supported by the Programme: 

1.  “Technical  Assistance”9:  support  aimed  at  providing  specific  knowledge,  equipment 
and  information  technology  (IT)  tools  to  national  authorities,  as  well  as  providing 
specific databases and IT tools facilitating data access and analysis; 

2.  “Training”: support for training activities, conferences and legal studies focused on the 

protection of the Union’s financial interests; 

3.  “Any  other  action”:  actions  necessary  for  attaining  the  general,  the  specific  and  the 

operational objectives of the Programme.  

The beneficiaries10 of the Programme are eligible bodies that are:  

1.  National or regional administrations of a Member State; 
2.  Research  and  educational  institutes  and  non-profit-making  entities  in  the  Member 

States. 

Both  types  of  beneficiaries  shall  “promote  the  strengthening  of  action  at  Union  level  to 
protect the financial interests of the Union”. Costs incurred for persons from third countries to 
enable  their  participation  in  an  event  funded  under  the  Programme,  such  as  conferences, 
seminars or training sessions, can be considered eligible for funding under certain conditions. 

The budget for the implementation of the Programme in 2017 amounted to EUR 14.95 million 
in  commitment  appropriations  and  EUR 13.2  million  in  payment  appropriations  and  is 
financed under item 24.0201 of the European Union budget for 2017. 

1.3  Purpose and scope of this overview 

The  annual  overview  is  intended  to  fulfil  the  requirement  under  Article  13.1  of  Regulation 
(EU)  250/2015  to  "provide  the  European  Parliament  and  the  Council,  on  an  annual  basis, 
with information on the implementation of the Programme, including on the achievement of 
the  objectives  of  the  Programme  and  the  results".  To  this  end,  this  overview  covers 
information  on  actions  (section  2)  for  which  financial  commitments  were  made  under  the 
2017 Annual Work Programme, as well as the results of actions that were finalised in 2017, 
but committed under the Hercule Programme in previous years (section 3).   

8  

9  

10  

Article  8  of  Regulation  250/2015.  Article  8(a)  lists  7  types  of  actions  for  Technical  Assistance  and 
Article 8(b) lists 7 types of actions for Training. 
It is important to underline that “Technical Assistance” as defined in Regulation 250/2015 differs from 
the  term  “Technical  Assistance”  used  in  Article  121(7)  of  the  Rules  of  Application,  which  defines 
Technical Assistance as “support and capacity-building activities necessary for the implementation of a 
programme  or  an  action,  in  particular  preparatory,  management,  monitoring,  evaluation,  audit  and 
control activities”.  
Article 6 of Regulation 250/2014. Article 7 of Regulation 250/2015 defines the geographical scope of 
the Programme. The participation of national and regional administrations from non-EU countries, such 
as  EEA  countries,  Switzerland,  candidate  countries  and  European  Neighbourhood  Policy  countries  is 
subject to an agreement between the respective countries and the Union on the former’s participation in 
Union Programmes. For the time being, no such agreement is in force.  

3 

 
 
 
 
                                                 
2. 

Budget implementation in 2017 

The  budget  for  the  implementation  of  the  Programme  amounted  to  EUR  14.95  million  in 
commitment  appropriations.  Table  1  gives  an  overview  of  the  available  budget  and  the 
commitments made in 2017. 

Table 1: Available budget and commitments made in 2017 

TYPES OF ELIGIBLE ACTIONS 2017 
TECHNICAL ASSISTANCE (min. 70%) 
Grants: Cigarettes and Investigation support  Grants 

IT Databases 

IT tools and tobacco analysis (JRC) 

Purchase of technical equipment 

Procurement 

Procurement 

Procurement 

ANTI-FRAUD TRAINING (max. 25%) 
Grants: Anti-fraud training 

Grants 

Procured conferences  

Digital Forensics Training sessions 

Procurement 

Procurement 

Grants: Law Training and Studies 

Grants 

Study: Illicit tobacco trade 
OTHER ACTIONS (max. 5%) 
P.M. 

TOTAL 2017 

Procurement 

P.M. 

BUDGET11  COMMIT12 
11 596 501 
 11 300 000 
10 211 196 
9 150 000 

1 500 000 

600 000 

50 000 

3 650 000  
1 000 000 

1 000 000 

1 000 000 

500 000 

150 000  
0 
0 

745 590 

612 575 

27 140 

3 089 831  
1 013 694 

425 713  

959 284 

541 140 

150 000 
0 
0 

% 
103 
111 

50 

102 

54 

85 
101 

43 

96 

108 

100 
0 
0 

14 950 000 

14 686 332 

98.23 

The information in the table above only relates to commitments made in 2017.  The amount 
committed for technical assistance was higher than the earmarked budget in the annual work 
programme.  At  the  end  of  2016,  appropriations  that  were  not  committed  for  other  types  of 
eligible  actions  were  transferred  to  technical  assistance.  The  payments  under  the  grant 
agreements and most of the contracts signed in 2017 cannot be reported as most of them will 
only be made in 2018 and beyond. 

2.1  Budget implementation by type of financial intervention 

The Programme was implemented by making use of public procurement (for contracts) and 
calls  for proposals  (for grants)13. The Commission  concluded contracts  for the purchase of 
goods  and  services,  such  as  access  to  databases,  the  development  of  IT  systems  or  the 
organisation  of  training  and  conferences.  The  contracts  were  concluded  on  the  basis  of 
existing framework contracts (FWC)14, establishing the terms governing specific contracts to 
be  awarded  during  a  given  period.  In  2017,  the  overall  amount  spent  on  contracts  was 
EUR 2 920 302 (as shown in graph 1). 

11  

12  

13  

14  

The budget corresponds to the Summary Table in the Annual Work Programme 2017 as adopted by the 
Financing Decision 2017 C(2017)1120 final of 22 February 2017. 
Commitments cover the total costs in 2017 of legal obligations (contracts, grant agreements/decisions) 
entered into for operations extending over more than one year (Article 7, FR).  
Article 10 of Regulation 250/2015. Title V of Regulation 966/2012, as amended. Title V (Articles 101-
120) determines the rules on public procurement, whereas Title VI (Articles 121-137) contains the rules 
in relation to the award of grants. 
Article 101(2) FR. 

4 

 
 
 
 
                                                 
Grants are direct financial contributions to finance an action intended to help achieve a Union 
policy  objective.  The  overall  budget  spent  on  grants  was  EUR 11  766  030.  Grants  are 
awarded following a call for proposals, inviting applicants to submit proposals for an action 
that contributes to the achievement of the Programme's objectives. The beneficiary of a grant 
becomes the legal and economic owner of the goods or services that are purchased with the 
help of the grant. Under the Programme, grants may cover up to 80% of the eligible costs15 of 
the action and up to 90% in exceptional and duly justified cases. In 2017, the Commission did 
not approve any 90% grant requests.   

In  June  2017,  the  Commission  launched  three  calls  for  proposals:  "Technical  Assistance", 
"Law Training and Studies" and "Training and Conferences". The deadline for submission of 
applications was set for 9 August 2017. The Commission published a notice on the calls in the 
Official Journal16 and on its website.  

Moreover, it informed the members of the Advisory Committee for the Coordination of Fraud 
Prevention  (COCOLAF)  and  invited  them  to  inform  potential  applicants  about  the 
Programme's funding opportunities.  

2017  was  the  first  year  when  OLAF  began  to  use  the  Horizon2020  Participant  Portal, 
developed  by  the  European  Commission  for  the  electronic  submission  of  applications  for 
grants and for the management of grant agreements. Applicants were required to use the Call 
Application  Procedure  for  the  submission  of  their  application.  This  electronic  system  has 
considerably shortened the time for notifying applicants about the outcome of the evaluation 
procedure.  Importantly,  the  grant  signing  process  has  been  streamlined.  Questions  from 
applicants were treated rapidly and efficiently.  
Under  the  three  calls,  the  Commission  received  104  applications17  that  were  subsequently 
examined  by  three  different  Evaluation  Committees.  Each  application  was  examined  on  the 
basis of four sets of criteria: eligibility, exclusion, selection and award that were listed in the 
specifications of the call. The award criteria were ranked on the scores obtained for: 

  Added value of the application for the protection of the financial interests of the 

Union; 

  Conformity with the operational objectives of the Programme; 
  Quality; 
  Value for money.  

The examination of the applications led to the award of 46 grants18 at the end of 2017. Tables 
9, 10 and 11 provide an overview of the successful and rejected applications, broken down by 
Member State, call, amount requested and awarded grant. 

Graph 1 below gives a breakdown of the planned budget and achieved commitments in 2017 
by type of financial intervention (grants and procurement).   

15  

16  
17  
18  

Article  10  (4)  of  Regulation  250/2015.  The  annual  work  programme  2017  contained  the  criteria  as 
required under Article 11 of Regulation 250/2014 for the definition of these cases and applicants for a 
"Technical Assistance" and a "Law Training and Studies" grant were given the possibility to indicate 
whether  or  not  their  applications  should  be  considered  for  the  maximum  co-financing  percentage  of 
90%.   
OJ C 196 of 20 June 2017. 
Technical Assistance: 53, Law Training: 18 and Training and Conferences: 33. 
Technical Assistance: 22, Legal Training: 9 and Training and Conferences: 15. 

5 

 
 
 
                                                 
Graph 1: Hercule III budget and commitments in 2017 by type of financial intervention 

Budget 2017 (Planned) 

Commitments 2017 (Achieved) 

4,300,000,   
28.76% 

2.920.302 
19,60% 

Grants

Procurement

10,650,000 
71.24% 

Grants

Procurement

11.980.688 
80,40% 

2.2  Budget implementation by type of eligible action 

Graph 2 below gives a breakdown of the planned budget and achieved commitments in 2017 
by  type  of  action.  The  "Technical  Assistance"  actions  identified  in  Regulation  250/2014 
encompass "Technical Assistance" activities, as well as "IT support", whereas the "Training 
Actions" include "Training and Conferences" and "Law Training and Studies". The planned 
budget for technical assistance support represented 75.58% of the total and the commitments 
represented  78.96%.  These  percentages  are  well  above  the  minimum  percentage  of  70% 
foreseen for Technical Assistance in the annex to Regulation 250/2014. 

Graph 2: Hercule III budget and commitments in 2017 by type of eligible action 

Budget 2017 (Planned) 

Commitments 2017 (Achieved) 

3.000.000 
20,07% 

650.000 
4,35%  42,300 
0.29% 

2.398.691 
16,33% 

691.140 
4,71% 

0 
0,00% 

2.150.000 
14,38% 

1.385.305 
9,43% 

9.150.000 
61,20% 

10.211.196 
69,53% 

Technical assistance
Anti-fraud Training

IT Support
Law Training

Technical assistance
Anti-fraud Training

IT Support
Law Training

Graph 3 gives an overview of the committed budget as well as the number of awarded grants 
for technical assistance, antifraud training and law training in 2017. The information is broken 
down by Member State. The graph shows that grants were awarded to applications from 20 
Member States.  There were no grants awarded to applications from:  AT,  BE,  CY,  DK, EE, 
SE, SK and UK.   

6 

 
 
 
 
 
 
 
 
Graph 3: Hercule III commitments (in EUR) and number of grants in 2017 by Member 
State and by sector of activity 

4 

12 

1 

2.500.000

2.000.000

1.500.000

1.000.000

500.000

0

LAW

TRAIN

TA

2 

1 

1 

1 

1 

2 

1 

1 

5 

2 

4 

3 

1 

1 

1 

1 

1 

LT RO PT

EL

ES

FI NL

LV

IE

PL

SI

IT

CZ DE HU FR

LU HR MT BG

2.2.1   Technical Assistance grants 

The budget for technical assistance grants was EUR 9 150 000. It was available for funding 
actions proposed by national and regional authorities, such as: 

1.  The  purchase  and  maintenance  of  investigation  tools  and  methods  used  in  the  fight 
against irregularities, fraud and corruption perpetrated against the financial interests of 
the Union, including specialised training needed to operate the investigation tools; 

2.  The  purchase  and  maintenance  of  devices  and  animals  to  carry  out  inspections  of 
containers,  trucks,  railway  wagons  and  vehicles  at  the  Union's  external  borders  and 
within the Union in order to detect smuggled and counterfeited goods imported into the 
Union  with  the  aim  or  consequence  to  evade  customs  and  excise  duties  (detection 
devices); 

3.  The  purchase,  maintenance  and  interconnection  of  systems  for  the  recognition  of 
vehicle number plates (Automated Number Plate Recognition Systems) or container 
codes  for  purposes  related  to  the  protection  of  the  financial  interests  of  the  Union, 
including specialised training needed to operate these systems; 

4.  The  purchase  of  services  to  support  Member  States’  capacity  to  store  and  destroy 

seized cigarettes and tobacco. 

The  Commission  received  53  applications  from  20  Member  States  by  the  deadline  of 
9 August 2017.  The  total  budget  of  the  proposed  actions  was  EUR 30.1  million  and  the 
requested  financial  support  amounted  to  EUR 24.3 million.  This  amount  exceeded  the 
available budget of EUR 9.1 million more than 2.5 times. The Evaluation Committee adopted 

7 

 
 
 
 
its recommendations in November 2017 and the decision to award a grant for 22 actions was 
adopted in December 2017.  

All applicants were informed of the outcome of the evaluation procedure. The overall amount 
approved  for  technical  assistance  grants  was  EUR 10.2 million19.  The  average  co-financing 
percentage for the awarded grants was 78.6% of the eligible costs20 of the action. Grants were 
awarded  for  the  purchase  of  investigation  equipment  (including  forensics  equipment),  the 
purchase of x-rays  scanners, the  purchase and training  of sniffer dogs and  the purchase and 
installation of Automated Number Plate Recognition  Systems.  Table 1 in  Annex 1 gives  an 
overview of the beneficiaries, the project title,  the grant amount and the co-financing rate of 
awarded grants.  

2.2.2   IT Support: Databases, IT tools and analyses of samples from tobacco seizures 

Databases 

The  Programme  provides  funds  to  procure  databases,  or  subscriptions  to  databases,  for  law 
enforcement  authorities  in  Member  States  in  order  to  support  operations  and  investigations. 
The  Commission  procures  and  manages  the  access  to  these  databases  enabling  substantial 
economies of scale. Within the framework of investigations that are jointly undertaken with 
its Member State partners and for its own investigations, OLAF staff also makes a limited use 
of these databases.  

Databases  for  trade  and  company  data  and  vessel  movements  were  purchased  in  2017  by 
concluding specific contracts under existing framework contracts21. Table 3 in Annex I gives 
an overview of the contracts awarded in 2017.  

Development of specific IT tools for data analyses  

Two  projects  for  the  analysis  of  “big  data”  were  continued  in  2017:  the  Automated 
Monitoring Tool (AMT, for an amount of EUR 627 372) project and a project which followed 
up the earlier Container Traffic project (ConTraffic-REG-2, for an amount of EUR 222 791) 
carried out by the Joint Research Centre (JRC) of the European Commission in Ispra (Italy) 
under  administrative  arrangements.  A  new  project  on  data  analysis  for  customs  anti-fraud 
purposes (for an amount of EUR 311 432) was launched at the end of 2017 with the JRC.    

The AMT generates automated alerts for outliers in trade data. It can be used to monitor trade 
flows  relevant  for  intelligence  analyses  and  targeted  controls  by  Member  State  customs 
authorities,  providing  more  realistic  and  effective  scenarios  for  joint  customs  operations.  It 
also  generates  reference  prices  for  each  combination  of  product,  third  country  origin  and 
Member  State  destination.  The  AMT  has  improved  authorities’  ability  to  detect  the 
undervaluation of imported goods and thus helped to reduce the level of losses to the EU and 
Member States' budgets in customs duties and taxes. The administrative arrangement for the 

19   

20  

21    

This amount was higher than the earmarked budget in the annual work programme. At the end of 2017, 
appropriations that were not committed for other types of eligible actions were transferred to technical 
assistance. 
The maximum co-financing percentage is 80%, but the Commission may award in exceptional and duly 
justified cases a grant covering up to 90% of the eligible costs. Following a careful examination of the 
reasons  put  forward  by  applicants,  and  taking  account  of  the  available  budget,  no  applicants  were 
awarded 90% co-financing.   
Two framework contracts concluded by Eurostat for trade and company data in 2015 and 2016 and a      
framework contract concluded by OLAF for vessel movements information in 2016. 

8 

 
 
 
                                                 
 
AMT  project  was  extended  until  October  2019  to  further  develop  and  implement  specific 
statistics for analysis of trade data and tools for the statistical detection of patterns of fraud to 
support Member States, especially in view of Regulation (EC) No 515/9722.  

An  administrative  arrangement  for  a  project  to  facilitate  the  use  of  the  Container  Status 
Messages  (CSMs)  based  on  Regulation  (EC)  No  515/97  (ConTraffic-REG-2)  with  the  JRC 
was  started  in  2016  and  was  concluded  at  the  end  of  2017.  The  project  aimed  to  provide 
support  for  verifying  carriers'  compliance  with  the  obligation  to  report  CSMs  to  national 
customs authorities, as well as to provide support for the detection of customs fraud through 
the implementation of an EU-wide system for the automatic and systematic origin verification 
of  import  declarations  based  on  CSMs.  The  new  system  uses  the  ConTraffic  Single 
Administrative  Document  (ConTraffic-SAD)  analysis  tool  developped  by  the  Commission 
(OLAF  and  JRC)  in  collaboration  with  customs  authorities  in  Member  States.  Section  3 
provides examples of the results obtained in 2017 using the AMT and ConTraffic-SAD tools. 

The  administrative  arrangement  with  the  JRC  for  a  new  project  to  provide  scientific  and 
technical support to EU customs' anti-fraud data analysis capacity was launched at the end of 
2017.  This  project  aims  to  provide  technical  support  to  identify  and  share  best  practices, 
increasing  awareness  and  making  best  use  of  data  sources  including  those  related  to 
Regulation  (EC)  No  515/97.  Facilitating  an  efficient  use  of  data  and  analytical  methods  to 
refine  the  investigative  capacity  of  customs  authorities  should  support  Member  States  to 
better target customs controls and perform investigations. 

Tobacco analyses  

The  illicit  trade  of  tobacco  products  in  large  volumes  is  almost  exclusively  the  domain  of 
organised criminal groups operating across borders. These tobacco products are for the most 
part  not  produced  in  accordance  with  requirements  of  the  EU  tobacco  products  legislation. 
The new European Agenda on Security adopted by the Commission in 201523 recognises the 
need to cut off criminal groups from this revenue source. Fighting the illicit tobacco trade is 
therefore key to protecting the financial interests of the EU and Member States as well as to 
protecting public health and security. 

In  this  context,  Hercule  funds  were  used  to  set  up  a  laboratory  for  the  analysis  of  tobacco 
products to analyse whether seized cigarettes were genuine or counterfeit and, also, to support 
investigations. The setting up of an independent tobacco testing facility also appeared as an 
objective of the Action Plan accompanying the Commission communication of 6 June 2013 
"Stepping up the fight against cigarette smuggling and other forms of illicit trade in tobacco 
products".  

Hercule provided for financial support to enable Member States' customs authorities to carry 
out analyses of samples taken from cigarettes and tobacco seizures. In 2017, the Commission 
(OLAF)  renewed  the  administrative  arrangement  with  the  JRC's  Institute  for  Reference 
Materials  and  Measurements  in  Geel  (Belgium)  for  an  amount  of  EUR 171 771  to  perform 

22  

23  

Regulation  (EU)  No  2015/1525  of  the  European  Parliament  and  of  the  Council  of  9  September  2015 
amending  Council  Regulation  (EC)  No  515/97  on  mutual  assistance  between  the  administrative 
authorities of the Member States and cooperation between the latter and the Commission to ensure the 
correct application of the law on customs and agriculture matters (OJ L 243, 18 September 2015, p. 1). 
COM(2015)185 final of 28 April 2015. 

9 

 
 
 
 
 
 
                                                 
chemical  analyses  on  samples  from  tobacco  and  cigarettes  seizures.  Section  3  describes 
concrete results. 

2.2.3  Conferences, seminars and digital forensics training 

Training, conferences and staff exchanges organised under grants 

Training  activities  financed  under  the  Programme  aim  to  provide  grants  to  beneficiaries  for 
the  organisation  of  targeted  specialised  trainings,    conferences  and  staff  exchanges.  These 
activities  aim  to  strengthen  cross-border  cooperation  and  networking  activities  between 
experts  and  law  enforcement  staff  and  to  facilitate  the  exchange  of  information  on  best 
practices  in  relation  to  the  protection  of  the  financial  interests  of  the  Union.  The  priority 
topics  addressed  in  the  call  for  proposals  2017  emphasised  the  further  development, 
improvement  and  update  of  staff's  skills  and  competences  through  specialised  trainings  and 
risk-analysis workshops. Training on the analysis of fraud patterns and indicators as well as 
smuggling were also featured. 

The  Commission  received  33  applications  from  15  Member  States  by  the  deadline  of 
9 August 2017.  The  total  amount  of  requested  grants  was  EUR  2.8  million,  whereas  only 
EUR 1 180 000  was  available.  The  Commission  selected  the  16  projects  for  the  amount  of 
EUR 1 092 621 (however, for one of the selected projects a grant agreement was not signed 
by the potential beneficiary). Table 4 in Annex 1 gives an overview of the awarded grants and 
co-financing rate. 

Conferences organised under procurement  

In addition to funding grants, the Programme also finances high-level conferences and ad-hoc 
training activities focused on the protection of the Union’s financial interests organised by the 
Commission.  Using  the  services  of  a  framework  service  contract24  the  Commission  funded 
eight  events  in  2017.  The  overall  budget  available  for  procured  conferences  was 
EUR 1 million.  Table  5  in  Annex  1  provides  an  overview  of  the  eight  events  that  were 
procured in 2017.  

Training organised under procurement: digital forensics training  

Digital forensics training was conceived in 2007 to underpin the capacity of law enforcement 
agencies assisting to combat fraud including cigarette smuggling and counterfeiting. Its aim 
has been threefold: to detect digital financial fraud by enhancing the skills in law enforcement 
agencies, to create a  network  of  qualified  digital forensic training specialists throughout  the 
Union and  to provide certification for acquired knowledge and competences with a view to 
providing  a  harmonised  level  in  Member  States  and  neighbouring  countries.  The  typical 
progression  of  those  trained  is  to  attend  a  two-week  basic  course  instructing  methods  to 
secure  evidence  from  digital  information  carriers  and  networks  in  a  lawful  manner.  These 
'topic'  trainings  (intermediate,  advanced  and 
may  then  be  followed  by  specialised 
specialised).  16 Digital Forensic Training sessions, offering 113 individual classes, have been 
financed  2007-2017.  One  significant  achievement  of  this  10-year  project  is  the  'Network  of 
Digital Forensic & Analyst Specialists', now comprised of 900 trainees, from 42 EU Member 
States and neighbouring countries. Third countries having agreements on mutual assistance in 
customs  matters  may  also  apply.  This  network  concretely  contributes  to  increased 
transnational cooperation and coordination at EU level between competent authorities.  

24  

MCI Benelux S.A located in Brussels. 

10 

 
 
 
                                                 
In 2017, 255 persons attended the trainings financed by HERCULE III. These sessions were 
managed by a service provider in Zagreb, Croatia. 105 participants attended 'topic' sessions, 
for EUR 336 346.  Approximately 150 participants attended the second session for an amount 
of EUR 589 398. The participants from this year's training came from 37 countries, 78 LEAs.  

The growing number of digital forensic examinations results in an increased volume of data to 
process by intelligence officers. Consequently, there is a growing need for training analysts. 
For this reason, the new call for tender to be published in 2018 will include a dimension for 
analysts' training.  This will complement digital forensics investigations by ensuring that data 
will  be  processed  with  a  view  to  enhancing  the  quality,  accuracy  and  efficiency  of 
investigations related to EU funds. 

2.2.4  Law training and studies 

The law training and studies grants aim at enhancing the development of the legal and judicial 
protection of the financial interests of the Union. In 2017, the Commission awarded grants to 
applications that proposed actions covering three types of specific topics: 

1.   Developing high-profile research activities, including studies in comparative law; 

2.    Increasing  cooperation  and  awareness  among  practitioners  and  academics  (through 
conferences, including the organisation of the annual meeting of the presidents of the 
Associations  for  European  Criminal  Law  and  for  the  Protection  of  EU  Financial 
Interests); 

3.    Developing  periodical  scientific  publications  and  other  tools  for  the  dissemination  of 

scientific knowledge. 

The Commission received 18 applications from 10 Member States by the deadline of the call 
for  proposals  on  9 August 2017.  The  aggregated  budget  of  the  18  actions  totalled 
EUR 1.7 million  and  the  Commission  was  asked  to  contribute  for  an  amount  of  EUR 1.4 
million (79% co-funding), where only EUR 500 000 was available. The Commission decided 
to  award  a  grant  to  nine  applications  for  an  overall  amount  of  about  EUR 541  000  with  an 
average co-financing rate of 77%. The grants were awarded, amongst others, for conducting 
studies  on  the  cases  of  incompatibility  and  conflict  of  interest  concerning  the  financial 
interests of the European Union, cyber fraud, new institutional setting for the protection of the 
financial interests of the EU, as well as for the publication of a periodical on the protection of 
the Union’s financial interests. Table 7 in Annex 1 gives an overview of the awarded grants in 
2017. 

3. 

Achievements 2017 

This section provides an overview of the main results achieved by beneficiaries implementing 
awarded grants. It presents the results of actions that came to an end in 2017, but that were 
initiated before 2017. As condition for final payment, grant beneficiaries must submit a final 
technical report outlining the main achievements and results of their actions. These results are 
examined  in  the  light  of  the  contribution  made  to  the  achievement  of  the  operational 
objectives of the Programme. 

All  beneficiaries  (grants  and  procured  contracts)  have  also  to  report  any  problems 
encountered  during  the  implementation  of  the  action,  such  as  delays  in  procurement 
procedures  or  staff  changes.  The  final  report  has  to  indicate  how  these  problems  were 

11 

 
 
addressed  and  whether  or  not  the  problems  eventually  had  an  impact  on  the  outcome  or 
results.  

Beneficiaries  of  grants  for  training  activities  (conferences,  seminars  and  training  sessions) 
also  conduct  a  participant  survey  to  measure  the  relevance,  quality  and  overall  user 
satisfaction  of  the  event.  The  findings  of  these  surveys  are  included  in  the  final  technical 
report submitted at the end of the action. 

Beneficiaries  of  technical  assistance  grants  submit  a  final  implementation  report  one  year 
after  the  closing  date  of  their  actions.  This  requirement  was  introduced  since  beneficiaries 
were  often  unable  to  report  on  these  results  at  the  end  of  their  actions:  technical  assistance 
grants are awarded for the purchase and installation of technical equipment that, by the end of 
an action, has only been operational for a short period of time. The first tangible results of the 
use  of  technical  equipment,  such  as  the  seizures  of  cigarettes,  arrests  made  of  suspected 
persons  or  estimates  of  prevented  losses  to  the  national  or  the  Union  budget,  can  only  be 
reported several months after the closing date of the action.  

3.1  To  improve  the  prevention  and  investigation  of  fraud  and  other  illegal 
activities  beyond  current  levels  by  enhancing  transnational  and  multi-
disciplinary cooperation25 

The  training  activies  finalised  in  2017  consisted  mainly  of  conferences  and  trainings  with  a 
small  number  of  staff  exchanges.  A  wide  range  of  disciplines  including  combating 
irregularitities in the use of EU funds,  VAT fraud,  combatting  illegal trade,  smuggling, and 
financial  crime  were  covered.  They  contributed  to  improve  the  analyses  of  specific  fraud 
patterns, to identify indicators of fraud, to share experience and to disseminate best practices 
while fostering cooperation between authorities to fight fraud detrimental to the EU budget. 
Significantly, nearly half of the projects aimed to enhance the fight against the counterfeiting 
and  smuggling  of  tobacco  and  tobacco  products.  Fraud  risk  indicators  and  tools  to  prevent 
fraud emerged as new elements in 2017. 

While  most  of  projects  addressed  representatives  of  law  enforcement  agencies  (police, 
customs,  prosecution  office),  the  participation  of  professionals,  NGO's  and  educational 
institutions  was  also  noteworthy.  A  total  of  1  879  persons  attended  anti-fraud  trainings  and 
conferences  and  1  604  post-event  evaluations  were  received.  The  feedback  received  was 
overwhelmingly  positive,  showing  that  95%  of  the  participants  assessed  the  events  as 
'excellent' or 'good'26. Participants particularly appreciated the events having a pratical impact 
on their daily work. Some participants noted that, while events generally had an international 
dimension,  contact  with  participants  from  other  Member  States  could  be  increased.  Since 
similar observations were also made in 2016, the Commission, in its 2017 call for proposals, 
highlighted  those  applications  aiming  to  strengthen  networks  through  the  exchange  of  best 
practices.  To  assess  the  mid-term  impact  of  training  actions,  a  "post-event"  survey  of 
participants is now requested six months after the implementation of events financed in 2017.  

25  
26  

Article 5(a) of Regulation 250/2014. 
Participants are asked to give their opinion on several statements, where their replies may vary between 
'excellent', 'good', 'average', 'below average', and 'poor'. 

12 

 
 
 
                                                 
The main results of these actions were: 

 

 

 

Improved  investigation  abilities  of  law  enforcement  officials  involved  in  the 
protection of the financial interests of the European Union through the acquisition of 
new skills, knowledge and competences; 

Increased awareness on fraud risk indicators and EU anti-fraud policy; 

More  widespread  use  of  specialised  methodologies,  tools  and  techniques  to  fight 
against fraud affecting the Union’s financial interests.  

A  comprehensive  overview  of  the  finalised  training  events  is  given  in  Annex  1,  Table  6 
(Training and Conferences) and Table 8 (Law Training and Studies). 

The  Agenzia  Veneta  per  i  Pagamenti  in  Agricoltura  (AVEPA)  organised  a  three-day 
roundtable  in  February  2017,  in  Padua  (Italy).  The  roundtable  led  to  the  development  of 
common guidelines on implementing best practices of anti-fraud procedures to be shared with 
European paying agencies and decision makers.  

Participants were lawyers, researchers, and representatives of national and regional ministries, 
local administrations or European bodies from 12 Member States (AT, HR, CZ, EE, FI, IT, 
LV, LT, MT, PL, RO, SL).  

The participants were tasked to: 

- analyse  the  different  fraud  prevention  systems  currently  adopted  in  European  paying 
agencies;  
- compare  experiences  on  significant  cases  in  order  to  point  out  mutual  strengths  and 
weaknesses;  
- promote mutual exchange of techniques, staff exchange and trainings.  

3.2  To  increase  the  protection  of  the  financial  interests  of  the  Union  against 
fraud  by  facilitating  the  exchange  of  information,  experiences  and  best 
practices, including staff exchanges27  

The anti-fraud and law training activities contributed to the achievement of this objective.  

27  

Article 5 (b) of Regulation 250/2014. 

13 

 
 
 
                                                 
Transparency International Czech Republic conducted a study on tracing corporate control 
structures  of  companies  and  identifying  companies  which  form  groups  engaged  in  tax 
avoidance. Following the  study,  a handbook  was  produced  (in  four  languages:  CZ,  EN,  DE 
and  FR)  providing  a  detailed  description  on  how  to  reveal  and  evidence  complex  global 
corporate  ownership  structures  in  ten  selected  jurisdictions  and  how  to  monitor  the  funds 
flowing through these corporate ownership structures to tax havens and/or countries providing 
anonymity to ultimate beneficial owner(s).  

The  results  of  the  study  and  the  guide  were  presented  during  both  a  workshop  held  on  19 
September  2017 
institutions, 
administrations  and  business  associations  and  at  a  conference  held  on  24  October  2017  in 
Prague  with  international  participants  from  business  associations,  academics  and    civil 
society.  

in  Prague  with  representatives  of  Czech  companies, 

The annual AFCOS seminar organised by OLAF took place in Budva (Montenegro) from 
7 to 9 of June 2017. Its main objectives were to:  

- enhance the investigative and policy cooperation of AFCOS and other relevant authorities 
with OLAF; 
- provide a regional forum for the exchange of best practices on anti-fraud matters; 
- clarify  the  implementation  of  the  accession  requirements  regarding  the  protection  of  the 

EU's financial interests; 

- discuss and clarify how to detect and report fraud. 

The conference focused on the specific needs of target audience by: 

-  clarifying the differences between reporting in the Irregularity Management System (IMS) 

and informing OLAF of suspicions in order to trigger an OLAF investigation; 
-  providing practical examples from Member States (Italy, Spain and Romania); 
- providing participants with clarifications on the practical cooperation with OLAF. 

The conference contributed to the protection of the EU's financial interests by:  

- bringing together OLAF's focal points from candidate countries (i.e. the AFCOS and similar 
authorities) to discuss practical issues regarding investigative and policy cooperation with 
OLAF;  

-  providing practical examples on how to detect and report fraud to EU Delegations and 

national authorities in enlargement countries;  

- supporting candidate countries to implement the accession requirements under acquis 

Chapter 32 regarding the protection of the EU's financial interests;  

- involving  representatives  from  countries  that  signed  association  agreements  with  the  EU 
(Georgia,  Moldova  and  Ukraine)  as  observers  to  benefit  from  the  exchanges  and 
presentations. 

The overall satisfaction rate of the participants was 4.9 points out of 5 points. 

14 

 
 
 
 
 
 
3.3  Strengthening  the  fight  against  fraud  and  other  illegal  activities  by 
providing  technical  and  operational  support  to  national  investigation,  and  in 
particular customs and law enforcement, authorities28   

Beneficiaries received grants for the purchase of technical equipment in order to: 

a)  Strengthen  the  operational  and  investigative  capacity  by  improving  the  quality, 
efficiency  and  effectiveness  of  technical  hardware  and  technical  support  used  in 
detecting and monitoring any illegal activity affecting the EU budget. It aims at a faster 
and  more  efficient  detection  of,  e.g.  smuggled  cigarettes  and  tobacco,  illicit  goods  or 
the identification of new fraud schemes and modi operandi; 

b)  improve skills and qualifications of the beneficiary's staff that are tasked with the daily 

operations of the new equipment; 

c)  improve  the  quality  of  evidence  gathered  during  operations  in  support  of  fraud 
investigations. The improvements should speed-up legal proceedings in Member States 
and to reduce the number of dismissals during the prosecution or trial stages. 

Technical assistance grants can also cover the expenditure for the maintenance of equipment 
as  well  as  specific  technical  training  for  operational  staff  to  ensure  its  optimal  usage  and 
management. Beneficiaries of technical  assistance grants  send a final  implementation report 
on the results one year after the closing date of the agreement, thus enabling a better overview 
and  understanding  of  the  longer  term  impact  of  the  Programme.  Beneficiaries  report,  for 
example,  on  the  number  and  amount  of  cigarettes  and  tobacco  seizures,  estimates  of  the 
prevented losses to the national and the Union’s budget, the emergence of new fraud schemes, 
the detection of networks of organised crime groups or the number of arrests made.  

The Commission received reports on the implementation of grants that were funded under the 
Hercule  II  and  Hercule  III  budgets  of  previous  years.  Though  it  is  difficult  and  sometimes 
impossible to establish a direct causal relationship between the grant, on the one hand, and the 
results achieved with the equipment purchased with financial support from the grant, on the 
other hand, it can certainly be assumed that without the financial support a substantially lower 
number of arrests, seizures and convictions would have been made. The seizures made with 
the help of x-rays scanners, for example, allow for a clear demonstration of this relationship, 
whereas this relationship is more difficult to demonstrate for support given for the purchase of 
digital forensics software or devices to monitor vehicles or persons suspected of involvement 
in  illicit  activities.  The  equipment,  nevertheless,  enables  the  beneficiaries  to  improve  the 
overall  efficiency  and  effectiveness  of  the  operations  they  carry  out  in  support  of 
investigations to protect the Union's financial interests, as shown in the examples below. 

Among  the  technical  assistance  grants  finalised  (final  reports  received)  in  2017,  two    cases 
stand out as particulary illustrative of the aims of the Hercule programme: 

28  

Article 5 (c) of Regulation 250/2014. 

15 

 
 
 
 
 
 
 
 
                                                 
The  Customs  Department  under  the  Ministry  of  Finance  of  the  Republic  of  Lithuania 
was  awarded  a  grant  for  the  development  and  implementation  of  an  IT  system  linking 
customs offices in Lithuania, Latvia and Estonia for the exchange of information and images 
generated by 12 X-ray scanners located at internal and external border crossing points. The IT 
tool was deployed in the second half of 2017 and it has already been used to assist authorities 
in Lithuania to make two different seizures of more than 12 million cigarettes and to prevent 
potential  losses  of  almost  EUR  2  million  in  October  2017.  The  action  was  a  project  of  the 
Lithuanian  customs,  in  conjunction  with  the  Latvian  and  Estonian  customs.  Furthermore,  it 
remains  an  example  of  best  practices  in  information  sharing  between  customs  and  law 
enforcement agencies in the Member States. 

The National Anticorruption Directorate of Romania received a grant for the purchase of 
high  performance  audio  and  video  recording  devices  (cameras,  microphones)  for  operations 
aimed  at  observing  and  monitoring  conversations  and  movements  of  persons  under 
investigation.  Digital  forensic  equipment  was  also  purchased  to  be  used  for  processing  and 
analysing  data  recorded  during  operational  activities  of  the  beneficiary.  The  final  technical 
report  contained  information  on  33  operations  related  to  investigations  into  allegations  of 
corruption,  bribing,  leaking  of  confidential  information,  fraud,  irregularities  in  public 
procurement procedures, VAT and tax evasion and insurance fraud perpetrated by individuals, 
including civil servants and members of law enforcement groups. The estimated amounts in 
several investigations reported amounted to more than EUR 50 million. 

Technical  assistance  implementation  reports  submitted  during  2017  describe  the  results 
obtained  after  12  months  of  using  purchased  equipment.  Fourteen  implementation  reports 
were  received  in  2017.  These  grants  were  awarded  under  the  annual  budgets  of  2014  and 
2015.  

After  one  year  of  implementation,  the  Polish  Customs  Service  reported  that  the  use  of  the 
forensic  equipment  co-financed  by  Hercule  led  to  seizures  of  EUR  117  million,  287 
investigated persons and 35 convictions.  

The National Service for Intelligence and Customs Investigations (FR) indicated that the 
localisation and surveillance equipment acquired contributed to EUR 73 million seizures and 
six arrests.  

Portuguese  Judicial  Police  report  enhancements  to  the  communication  interception  system 
in Portugal have led to improved investigation results especially those concerning organised 
crime.  The  purchase  of  special  investigation  technical  equipment  for  electronic  and  mobile 
surveillance has contributed to the development in both hardware and software use. Reports 
following  a  year  of  implemtation  show  that  recoveries  of  more  than  EUR  30  million  have 
been made including seizures of real estate, luxury  vehicles and other goods.  Significantly, 
more than 100 suspects were identified and 31 persons convicted. Cases of money laundering 
and tax fraud using stolen documents and "ghost" companies have also been reported. 

Examples of procured access to external databases  

The  Commission  procured  access  to  external  databases  for  use  by  Member  States'  law 
enforcement authorities. The databases containing trade information, company data or vessel 
movements provide essential operational information for joint investigations carried out with 
OLAF.  The  databases  also  provide  input  for  risk  analyses  used  by  customs  authorities  to 
target their controls.  

16 

 
 
A  commercial  database  of  worldwide  trade  statistics  with  aggregated  figures  is  used  by 
both  the  Member  States  and  OLAF  to  analyse  trade  flows  (imports  and  exports)  and  to 
identify  potentially  suspicious  trade  and  cross-check  allegations  of  customs  fraud.  The 
statistics  database  is  an  essential  part  of  a  risk  analysis  system  and  is  in  regular  use  by 
customs  analysts  and  investigators,  enabling  them  to  confirm  or  dispel  any  doubts,  for 
instance, about misrepresentation of the declared origin of goods imported into the EU and 
circumvention of anti-dumping duties.  

The trade database is primarily used by Member State customs services in connection with 
anti-dumping  cases  to  confirm  suspicion  of  a  suspected  misdeclaration  of  the  country  of 
origin.  Using  the  database  it  is  possible  to  compare  exports  from  a  non-EU  country  to  a 
Member  State  with  the  imports  by  a  Member  State  from  the  same  third  country.  These 
figures should balance. If exports are less than imports, this is an indication that the imported 
goods  do  not  actually come  from  the  third country;  for  instance,  the true  origin  could  be  a 
country  on  which  anti-dumping  duties  are  imposed.  This  analysis  was  used  to  reveal 
incorrect  reporting  of  imported  goods  from  third  country  A.  While  there  were  no  official 
exports from  third country A to the Member State, the Member State had imports of goods 
declared  as  originating  in  third  country  A.  Investigations  revealed  that  the  goods  actually 
came from another third country B, and that anti-dumping duty should be paid. 

The  Member  States'  customs  authorities  also  use  information  on  exports  with  a  view  to 
investigating whether other EU Member States have imports of the same kind of goods from 
a concerned country. For example, information on exports of a product from a third country 
to a Member State was used in order to take appropriate action in conjunction with OLAF as 
the  problem  also  affected  other  Member  States.  Finally,  a  comparison  of  information  on 
imports  and  exports  may  also  indicate  wrong  tariff  classification,  or  wrong  declaration  of 
customs value. 

Trade statistics data is used by a Member State customs service as one of the key elements to 
estimate  reference  prices,  and  is  part  of  a  system  widely  used  to  fight  undervaluation  of 
textile  products.  It  is  also  used  to  estimate  average  prices  in  Member  States  used  for 
comparison  purposes.  The  database  allows  identification  of  goods  imported  to  a  Member 
State at significantly lower prices than other Member States, indicating possible nationwide 
undervaluation. This identification is difficult to do at purely national level, especially if the 
undervaluation has consistently taken place over time. 

Member States customs authorities use a database with  information on vessel movements 
in  supporting  risk  analysis  on  commercial  vessel  traffic  and  in  this  way  the  information 
contained in the database contributes to combatting fraud affecting the financial interests of 
the EU, including cigarette smuggling. The database is used in vessel tracking analyses and 
finding data on vessels in combination with other databases. Furthermore, it is used to check 
the  actual  routes  of  vessels  in  order  to  verify  the  origin  of  goods,  especially  when  fraud  is 
detected  in  anti-dumping  duty  evasion  in  risky  and  potentially  suspicious  cases  of  import 
transactions. This database was used, for instance, to verify certificates of origin suspected of 
being unduly issued from a third country, which was confirmed by further checks. In another 
case, the database was used to determine the avoidance of anti-dumping and countervailing 
duties on imports of a  product originating from a third country, which was transhipped via 

17 

 
 
 
another country and the origin was misdeclared as being the latter country.  

Databases  with  information  on  companies  are  very  useful  tools  to  support  investigations 
related to fraud affecting the financial interests of the EU. For example, one investigation led 
two Member States' customs authorities to find and seize large quantities of illegal cigarettes 
in a container imported into the EU, two persons arrested, and prevented significant losses in 
customs duties and taxes.  

Examples of operational results obtained from the use of the AMT and ConTraffic-SAD 
tools and the tobacco analyses laboratory (developed with the JRC) 

The Automated Monitoring Tool (AMT) is used as part of a suite of risk analysis tools by 
the  Member  States'  customs  authorities  to  identify  cases  of  potential  fraud,  such  as 
undervaluation  (tax  evasion),  which  affect  the  national  and  EU  budgets.  It  provides 
objective  statistical  values  for  imports  of  goods,  known  as  cleaned  average  prices, 
providing  reference  EU  prices  for  the  determination  of  the  customs  value  of  imported 
goods.  Customs  authorities  use  these  AMT  values,  for  example,  when  they  have  doubts 
concerning the declared customs value of goods or to challenge understated values declared 
by importers. The scale of undervaluation has decreased in those Member States using the 
AMT,  thereby  reducing  the  level  of  losses  to  the  EU  and  Member  States'  budgets  in 
customs duties and taxes.  

In  2017,  a  joint  customs  operation  was  conducted  by  several  Member  States'  customs 
authorities targeting criminal networks importing textiles and footwear from a third country 
into one Member State. Over 275 physical and documentary controls were  carried out  by 
nine Member States and the data gathered is being analysed. Initial analysis shows that the 
value  of  imported  goods  from  this  third  country  was  significantly  understated,  leading  to 
substantial losses to the EU and Member States' budgets in customs duties and taxes.  

A Member State customs service used the AMT tool in an experimental methodology that 
aims  to  highlight,  analyse  and  control  customs  declarations  with  statistical  anomalies  in 
terms  of  values  declared  for  imported  goods.  Using  this  tool  the  customs  service  has 
registered  467  risk  profiles  from  2014-2017.  The  method  has  proved  efficient  (out  of 
approximately  1  300  controls  in  2017,  30%  of  the  selections  led  to  the  discovery  of 
irregularities).  The  customs  service  uses  the  AMT  tool  to  guide  controls.  The  types  of 
irregularities  identified  are  mainly  misclassification,  undervaluation  or  misdescription  of 
value  (typing  error).  Controls  of  suspicious  imports  revealed  a  significant  rate  of 
irregularities in 2017. This system has led to the discovery of many cases of undervaluation 
since 2014 and to increased customs duties and VAT collected.  

Using  the  AMT  tool  to  identify  undervaluation  and  excise  duty  fraud,  one  Member  State 
reports that the procedure gave  rise to  the selection of 31 companies for  a customs  audit. 
The estimated  total customs duties  at risk in  the identified cases  was approximately EUR 
350 000. 

18 

 
 
 
 
In  2017,  the  JRC  developed  a  new  ConTraffic-SAD  data  analysis  system  which  can  be 
used  to  detect cases of potential customs fraud related to  declarations of origin  at import. 
The  system  performs  an  automatic  and  systematic  verification  of  the  origin  of  goods 
declared in the customs import declarations (Single Administrative Documents-SAD) with 
the information on the itinerary followed by cargo container(s). The new system is based on 
the results of the ConTraffic-SAD analysis pilot, which was developped by OLAF and JRC 
in  collaboration  with  several  Member  States'  customs  authorities,  and  it  makes  use  of  a 
database  containing  container  movements  data  (Container  Status  Messages-CSMs).  The 
system analyses the SAD customs declarations related to cargo containers imported into the 
EU by sea, submitted by participating customs authorities, in view of identifying new cases 
of  customs  fraud  involving  misdeclarations  of  product  origin.  As  a  result  of  this  type  of 
analysis,  fraud  signals  related  to  potential  misdeclarations  of  origin  were  generated  and 
reported to the participating Member States' customs authorities. The identified signals are 
used  by  customs,  to  support  risk  analyses  and  decisions  to  make  document  or  physical 
controls or to open investigations.  

During 2017, almost 4 million import declarations from 10 Member States' authorites have 
been  analysed  and  2%  of  them  presented  potential  irregularities  concerning  the  declared 
origin  of  goods.  As  a  result,  more  than  one  hundred  fraud  signals  were  identified  and 
communicated to Member States for further investigation. 

The use  of  the analysis of data on cargo container traffic helped  Member States  to detect 
cases of customs fraud related to false declarations of country of origin, for example:   

A Member State customs service has reported that the signals of potential fraud produced 
by Contraffic-SAD in  the  period 2012-2016 were analysed and a  number of these signals 
were found as true positive. One signal about imported goods resulted in the detection of a 
customs fraud of significant value. It has also reported that in 2017, resulting from an initial 
investigation  of  the  fraud  signals  reported,  three  important  positive  cases  were  found.  All 
concerned  false  origin  and/or  anti-dumping  duty  evasion.  For  instance,  in  one  case,  the 
commodities are subject to anti-dumping duties with a potential evasion of about EUR 1.5 
million.  

The  laboratory  for  testing  tobacco  at  the  JRC-Geel  facility  became  operational  in  April 
2016  and  has  been  used  by  Member  States'  customs  services.  Moreover,  a  dedicated  IT 
module on the OLAF Anti-Fraud Information System (AFIS) platform handling requests for 
analysis  became  operational  in  June  2016.  JRC  carries  out  various  chemical  analyses  of 
seized cigarettes and tobacco at  the request of Member States' authorities and, from time to 
time,  OLAF.  The  results  of  the  analyses  allow  identifying  the  geographical  origin  of  the 
tobacco in illegal consignments of tobacco products, linking seizures from a common source, 
comparing the chemical composition of seized tobacco products against reference samples to 
determine  whether  they  are  genuine  or  counterfeit.  A  database  with  information  on  the 
chemical composition and origin of seized smuggled and counterfeit tobacco products is also 
maintained and updated. The information is compared to profiles from a reference database in 
order to help with the identification of the origin of a seizure and to check the authenticity of 
tobacco. The reference database has been enhanced. The number of profiles of both seizures 
as well as legally traded tobacco products continue to increase, facilitating the identification 
of  counterfeits  and  smuggled  tobacco.  Testing  of  nearly  one  hundred  seized  cigarette  and 

19 

 
 
 
tobacco samples was carried out during 2017. The information obtained from these analyses 
facilitated  the  establishment  of  links  between  seizures  within  the  EU.  This  allowed  tobacco 
investigators  to  share  intelligence  and  draw  useful  conclusions  on  on-going  investigations 
carried out in different Member States. 

3.4  To  limit  the  currently  known  exposure  of  the  financial  interests  of  the 
Union  to  fraud,  corruption  and  other  illegal  activities  with  a  view  to  reducing 
the development of an illegal economy in key risk areas such as organised fraud, 
including cigarette smuggling and counterfeiting29 

Several actions contributed to achieving this objective in 2017. The widespread availability of 
illicit tobacco within the EU has led to the loss of considerable tax and duty revenues (losses 
to the EU and Member States' budgets as a result of cigarette smuggling are estimated to be at 
least EUR 10 billion per year30). One feature of the illicit market for cigarettes in the EU is the 
significant  quantity  of  counterfeit  products  available  at  a  lower  cost  than  the  genuine 
products.  

The Financial Directorate of the Slovak Republic organised two five-day training sessions, 
in Belá. They were attended by customs officers and experts from five Member States (CZ, 
DE, ES, HU, SK). The topics of the training courses were: (i) the elimination of corruption 
and 
tobacco  products,  (ii)  psychology  of 
communication, and (iii) protection of intellectual property rights.  

in  cigarettes, 

tobacco  and 

illicit 

trade 

The project focused on the detection of illegally imported tobacco products in Slovakia and 
on its financing. It contributed: 
- to  minimize  the  influx  of  illegal  cigarettes  on  the  domestic  market  and  related  money 

laundering adversely impacting the State budget;  

- to  an  increased  professionalism  in  the  fight  against  the  customs  fraud  with  the  support  of 

special non-destructive methods during customs controls;  

- a strengthened detection of illegal smuggling of cigarettes, tobacco and tobacco products.  

The project aims to increase the number of cigarettes, tobacco and tobacco products seized. In 
addition,  the  e-learning  course  designed  for  the  project  can  still  continue  to  be  used  for 
training  customs  officers  in  Slovakia.  The  exchange  of  new  information,  experiences  and 
knowledge  reinforces  efforts  in  the  fight  against  fraud  and  the  detection  of  smuggled  and 
counterfeit  tobacco  and  tobacco  products,  improving  international  cooperation  between 
Slovakia, other Member States and OLAF. 

OLAF  co-organised  with  Estonian  Tax  Customs  Board  the  22nd  Task  Group  Cigarettes 
Conference  in  June  2017  in  Tallinn  (Estonia).  During  this  three-day  conference,  OLAF 
shared  best  practices  about  international  cooperation  concerning  the  fight  against  cigarette 
smuggling  involving  OLAF,  Member  States  and  the  third  countries.  It  provided  an 
opportunity to strengthen relationships with key third countries including Moldova, Ukraine, 
Russia,  Georgia  and  Turkey  and  to  create  new  relationships  with  Lebanon,  Kosovo  and 

29  
30  

Article 5(d) of Regulation 250/2014. 
COM(2013)324 final of 6 June 2013: Stepping up the fight against cigarette smuggling and other forms 
of illicit trade in tobacco products – A comprehensive EU strategy. 

20 

 
 
 
 
 
 
 
                                                 
Montenegro. OLAF presented its most significant investigations. The following main topics 
were also highlighted: 
- the  new  laboratory  facility  and  associated  data  management  for  the  analysis  of  tobacco 

products;  

- the  emerging  phenomenon  of  water  pipe  tobacco,  in  particular  in  the  northern  region  of 

Europe; 

- the recurring phenomenon of illicit factories.   

3.5  To  enhance  the  degree  of  development  of  the  specific  legal  and  judicial 
protection  of  the  financial  interests  of  the  Union  against  fraud  by  promoting 
comparative law analysis31  

This  operational  objective  is  mainly  achieved  through  law  training  grants  awarded  for 
comparative law studies, legal conferences, seminars and periodical publications.  

The  Programme  continued  funding  the  publication  of  “eucrim  –  The  European  Criminal 
Law Associations’ Forum", which was published in four issues during 2017 by the German 
Max  Planck  Institute.  The  periodical  addressed  current  developments  in  the  reform  of 
European Criminal Law, the newly adopted Directive of the European Parliament and of the 
Council on the fight against fraud to the Union's financial interests by means of criminal law, 
the  individual  rights  in  the  area  of  freedom,  security  and  justice,  the  European  Public 
Prosecutor's Office and the evaluation of the OLAF Regulation No. 883/2013. Each issue was 
printed  in  2000  copies  and  distributed  to  universities,  libraries,  courts,  law  enforcement 
authorities  and  individual  subscribers.  The  articles  were  published  on  the  internet  as  well32, 
free of charge.  

The  Centro  di  Diritto  Penale  Europeo  in  Catania  conducted  a  comparative  law  study  on 
the common general principles and legal standards concerning criminal law having an impact 
on the protection of the financial interests of the EU. The beneficiary carried on a systematic 
analysis of the provisions of the Treaties and other relevant EU legal texts, as well as of the 
national provisions and legal cases in the selected seven Member States (DK, FR, DE, IT, PL, 
ES  and  UK)  and  identified  the  main  issues  practitioners  face  when  dealing  with  concrete 
cases where these principles are in question. 

Following  the  study,  a  proposed  European  curriculum  for  legal  training  of  practitioners 
specialised in the protection of the Union's financial interests was prepared, conceived to be 
integrated and implemented by European and national institutions involved in the training of 
judges and prosecutors, as well as of defence lawyers. A workshop with experts (practitioners, 
representatives of national training authorities, etc.) was organised in Catania on 16-17 June 
2017. The results of the discussions were incorporated into the final version of the proposed 
guidelines.   

31  
32  

Article 5(e) of Regulation 250/2014. 
https://eucrim.mpicc.de/   

21 

 
 
 
 
 
                                                 
  Utrecht  University conducted a study on OLAF's legislative framework  compared to other 
EU  law  enforcement  authorities  (European  Competition  Network,  European  Securities  and 
Markets Authority and European Central Bank).  The report compared the investigative role 
and interaction with national partners in six Member States (DE, HU, IT, LU, NL and UK) of 
these  EU  authorities.  The  project  led  to  the  identification  of  different  models  of  interaction, 
highlighting the advantages and disadvantages of each. OLAF's position was then compared to 
the  selected  EU  authorities  in  terms  of  power  to  conduct  autonomous  investigations  and  to 
steer  and  guide  cooperation  with  national  partners.  The  report  also  identified,  in  varying 
degrees, the EU legislative shortcomings in the legal design of the EU authorities analysed.    

4. 

Communication  

The  successful  implementation  of  the  programme  required  a  structured  way  to  inform 
potential  beneficiaries  on  funding  opportunities,  and  to  provide  answers  to  questions  from 
(potential) applicants. Moreover, the Commission is required33 to disseminate information on 
the achievements and the results of the actions that received funding. 

4.1 

Informing potential applicants 

Notices concerning the launch of Calls for proposals were published in the Official Journal34 
and the full texts of the documents were made available on the Commission's website35. The 
professional  networks  were  actively  informed.  Potential  applicants  were  also  informed  via 
emails  sent  to  the  members  of  the  Advisory  Committee  for  the  Coordination  of  Fraud 
Prevention  (COCOLAF),  the  OLAF  Anti-Fraud  Communicators  Network  (OAFCN)  and 
European Judicial Training Network (EJTN).  

4.2 

Dissemination of results 

The dissemination of the results of actions under Hercule programme, in particular technical 
assistance, is  rather  sensitive  as  most  of  the  achievements  relate  to  investigations  for  which 
information  cannot be disclosed. The dissemination on training activities was made  through 
the distribution of electronic and/or paper reports summarising the event. Some beneficiaries 
posted the training materials on their websites or created dedicated websites.   

4.3 

Publicity 

Under the training type of actions,  all beneficiaries of grants were  requested to  mention the 
support from the Hercule III programme: 

 

In every publication (title page) or related material developed (e.g. studies, booklets, 
newsletters, leaflets); 
In electronic information (e.g. websites, audio-visual material, videos, software); 

 
  At information events (conferences, seminars); 
 

Insert a link from their website to the Hercule III programme's site.  

33  

34  
35  

Article  13(1)  of  Regulation  250/2015:  The  Commission  shall  on  an  on-going  basis  disseminate, 
including on relevant websites, the results of the activities supported under the Programme to increase 
transparency on the use of the funds”.   
OJ C 196 of 20 June 2017. 
http://ec.europa.eu/anti-fraud/policy/hercule_en  

22 

 
 
 
 
 
 
                                                 
The  Commission  continued  its  efforts  to  improve  the  readability  of  the  website  with 
information  on  the  Hercule  Programmes.  Beneficiaries  of  technical  assistance  grants  were 
requested  to  mention  the  Hercule  support  in  their  reports  and  any  other  document  or  press 
release that reported on the results: press releases issued following seizures of counterfeited or 
smuggled  cigarettes  made  with  Hercule  funded  equipment,  for  example,  should  refer  to  the 
Union's  funding.  There  is  no  requirement  to  include  a  reference  to  Hercule  funding  on 
equipment  purchased  with  a  grant,  in  particular  if  this  might  endanger  operations  or 
investigations. 

5. 

Feedback from participants of the programme  

As  indicated  in  section  3.1,  beneficiaries  of  grants  for  trainings,  conferences  and  seminars 
carry out surveys among the participants to collect information on the perceived quality and 
relevance of the event. A total number of 1 879 participants attended Hercule training events 
in  2017.   The  Commission  received  1  604  completed  questionnaires  (85%  response  rate), 
most  of  which  indicated  a  high  level  of  satisfaction.  More  than  95%  of  the  participants 
considered the event 'good' or 'excellent'. Written feedback confirmed the target audience, the 
event’s relevance for the participants' professional activities, the quality of the organisation, 
the speakers, venue and other relevant aspects. 

6. 

Mid-term evaluation of the programme  

The Commission carried out a mid-term evaluation of the Programme covering the first half 
of its duration, 1 January 2014 until June 201736. As the Regulation requires an independent 
assessment, the evaluation was supported by a study carried out by an external contractor.  

The evaluation highlighted that the drivers of the Commission's proposal for the Hercule III 
Programme  are  still  prevalent,  in  particular,  the  occurrence  of  fraud  to  the  EU  financial 
interests. The mid-term evaluation has demonstrated that the Programme, in its current form 
and at this stage of its implementation, has largely fulfilled its mission. It has proven relevant, 
mechanisms  are  in  place  to  ensure  its  coherence,  and  it  has  been  effective  and  efficient. 
Moreover, there is a clear added-value to have such a programme at the level of the EU, and 
the activities of the Programme have been found largely sustainable.  

It has financed actions which clearly contributed to the protection of the EU financial interests 
(e.g. by financing scanners to detect smuggled goods, or supporting digital forensic trainings 
to the benefit of national services in charge of investigating cases involving the EU financial 
interests).  The  evaluation  clearly  demonstrated  the  EU  added-value  of  the  programme.  The 
stakeholders  almost  unanimously  recognised  its  added  value  and  essential  contribution  to 
generating  benefits.  The  majority  of  stakeholders  also  considered  that  the  benefits  from  the 
programme  would  not  materialise  without  the  support  of  Hercule  III  or  equivalent  EU 
funding. 

During  the  external  evaluation  process,  some  ideas  have  been  tabled  for  possible  new 
objectives and activities for the programme going forward for the next three years of the life 
of the Programme. Particular areas identified were cross-border cooperation between Member 

36  

COM(2018) 3 final and SWD(2018) 3 final of 10.01.2018. 

23 

 
 
 
 
                                                 
States, cooperation with non-EU partners, as well as new technological developments. These 
ideas will also feed into the wider reflection about the support to anti-fraud activities in the 
context of the preparations for the future multi-annual financial framework post-2020. 

7. 

Conclusions and way forward 

The Hercule III programme continues to be an important and effective tool in the protection 
of the financial interests of the Union. The results outlined above demonstrate that the actions 
undertaken with support from the Programme contributed  to the prevention and fight against 
fraud, corruption and other illegal activities affecting the financial interests of the Union.  

The  relevance  of  the  programme's  aims  and  objectives  is  supported  by  the  findings  of  the 
mid-term evaluation carried out in 2017. In particular because of the relatively modest size of 
the programme, the demand for financing from eligible bodies consistently exceeds available 
funds.  

The  introduction  of  the  electronic  submission  and  processing  of  grant  applications  is  an 
important  development  in  2017  which  has  considerably  shortened  the  time  for  notifying 
applicants  about  the  outcome  of  the  evaluation  procedure.  As  its  full  implementation 
continues,  this  electronic  system  is  expected  to  reduce  the  administrative  burden  for 
applicants,  grant  beneficiaries  and  the  Commission.  The  revised  EU  Financial  Regulation, 
expected to enter into force in July 2018, will further simply the beneficiaries' access to EU 
funds. The new rules will emphasise the achievement of results, reducing the administrative 
burden  for  both  beneficiaries  and  authorities,  who  will  be  able  to  focus  on  policy 
achievements rather than collecting and checking financial documents. The risk of error will 
also decrease and it will become easier for small beneficiaries with limited resources to access 
EU  funds.  These  significant  changes  will  be  reflected  upon  the  2019  calls  for  proposals 
onwards,  facilitating  the  access  to  the  programme  of  potential  beneficiaries  from  Member 
States. 

The Hercule III programme will come to an end on 31 December 2020. Acknowledging the 
contribution of the Hercule III programme, the Commission has adopted on 30 May 2018 a 
proposal  for  a  new  anti-fraud  programme  under  the  financial  framework  2021-2027.  The 
proposal is essentially to replicate the Hercule programme, and combine it with two activities 
carried out by OLAF: the Anti-Fraud Information System (AFIS) which supports, essentially, 
operational activities in the area of mutual administrative assistance between Member States’ 
customs authorities, and the Irregularity Management System (IMS), an IT system that allows 
the  Member  States  to  report  detected  irregularities  to  EU  funds  and  which  supports  the 
management  and  analysis  of  these.  This  combination  will  allow  creating  synergies  and 
flexibility between the three components of the new programme. 

24 

 
 
 
 
Annex 1: Grants and contracts awarded and finalised under the 2017 Financing Decision 

Table 1 - Technical Assistance grants awarded under the 2017 Financing Decision 

MS 

Beneficiary 

Subject 

Awarded 
Grant in Euro 

Co-fin 
% 

1 

2 

NL 

The National Police of the 
Netherlands 

TSO Innovative Operational Network 

 460 307 

80 

PT  Autoridade Tributária e Aduaneira 

Scanner –Setubal Port 

1 520 000  

80 

3 

LT 

Customs Department under the 
Ministry of Finance of the Republic 
of Lithuania 

Strengthening of operational and technical 
capacities of the Lithuanian Customs to detect 
smuggled goods in particular cigarettes 

1 603 306  

80 

4 

PL 

Komenda Wojewódzka Policji w 
Olsztynie 

5 

RO 

Inspectoratul General al Politiei 
Romane 

Improving the effectiveness of detecting and 
combating tobacco crime  and financial fraud - 
mobile unit 

Electronic System for Investigating Financial 
and Economic Crimes which affect the 
financial interests of the Union 

6 

LT 

Valstybes sienos apsaugos tarnyba 
prie Lietuvos Respublikos vidaus 
reikalu ministerijos 

The use of unmanned aerial vehicles in the 
Sate Border Guard Service's activity against 
tobacco smuggling 

 465 678  

80 

 400 000  

80 

 79 168  

80 

7 

FI 

Tulli 

LIPRE (Licence Plate and Container 
Recognition System)-Protection and reliability 

 655 360  

80 

8 

RO 

Directia de Investigare a 
Infractiunilor de Criminalitate 
Organisata si Terorism  

Improved special investigation methods in 
tackling high-profile OCG smuggling at the 
EU Eastern border (EASTEROS) 

9 

CZ  Generalni reditelstvi cel 

10 

RO  Anticorruption General Directorate 

Mobile X-Ray unit for inspection of personal 
luggage  and parcels transported in road, train 
and air transport 

Raising Efficiency of action to fight Against 
Corruption Threat and any type of Fraud - 
REACT to Fraud. 

 420 328  

80 

 246 485  

80 

 116 072  

80 

11 

DE 

Der Polizeiprasident in Berlin 

Preventing and combating identity fraud and 
related crime 

 86 534  

80 

12 

IE 

The Revenue Commissioners 

Procurement of Mobile Back Scatter X-Ray 
Scanning Van 

 515 057  

50 

13 

LV  Valsts tiesu ekspertizu birojs 

Operational capacity building of the forensic 
document examination 

 563 104  

80 

25 

 
 
 
 
14 

RO  Direcţia Naţională Anticorupţie 

Improving the Capacity of the National 
Anticorruption Directorate in Investigating 
Fraud and Corruption detrimental to the 
Financial Interests of the EU 

15 

RO 

Inspectoratul de Politie Judetean 
Brasov 

Fraud investigation in Brasov County with 
digital forensic hard and software 

16 

LT 

Customs Criminal Service 

17 

EL  Ministry of Citizens Protection 

18 

LT 

Financial Crime Investigation 
Service 

Development of Criminal Intelligence 
Technical Tools 

Find – Fix – Finish – Exploit – Analyse – 
Disseminate 

 259 618  

80 

 105 478  

80 

 483 347  

80 

 397 019  

80 

Procurement of intelligence equipment 

 102 979  

80 

19 

ES  Ministerio del Interior 

Sunrise Hawk 

20 

EL 

Special Secretariat Financial and 
Economic Crime Unit 

Plan for REinforced Defence Against 
Fraudulent Activities - PREDAFA 

21 

SI  Ministrstvo za Notranje Zadeve  

22 

RO 

National Agency for Fiscal 
Administration 

Technical Assistance for SI mobile ANPR and 
the setting up of a Advanced Investigation 
Platform (AIP) 

Increasing the role of mobile teams in 
preventing and combating smuggling and 
customs fraud so as to protect national and 
Community economic interests 

 604 174  

80 

 347 298  

80 

 460 680  

80 

 319 200  

80 

Total 

10 211 195 

78.6 

26 

 
 
 
 
 
 
 
 
 
Table 2 - Technical Assistance grants finalised in 2017 

MS 

Beneficiary 

Subject 

Amount 
paid 

Amount 
paid as % 
to initial 
commit-
ment37

General Inspectorate of the 
Romanian Police 

Direction Nationale du 
Renseignement et des Enquêtes 
Douanière - DNRED 

Office of the Revenue 
Commissioners 
Research Institute of Forensic 
Sciences - Ministry of Interior - 
RIFS 
Fiscale Inlichtingen- en 
Opsporingsdienst - FIOD 
Federal Ministry of Finance - 
BMF 
Swedish Customs - Unit Law 
Enforcement 
Service Public Fédéral Finances - 
Administration des douanes et 
accises 
Swedish Customs - Unit Law 
Enforcement 
Customs Department under the 
Ministry of Finance of the 
Republic of Lithuania 
State Revenue Service of the 
Republic of Latvia 
Republic of Latvia Ministry of 
Interior State Police 
Customs Criminal Service - 
MKT 
Chamber of Tax Administratin in 
Olsztyn 
National Anticorruption 
Directorate within the 
Prosecutor's Office attached to 
the High Court of Cassation and 
Justice - DNA 
Special Service for National 
Security - SSNS 
Belgian Customs and Excise 
Administration 

1 

2 

3 

4 

5 

6 

7 

8 

9 

RO 

FR 

IE 

BG 

NL 

AT 

SE 

BE 

SE 

10 

LT 

11 

12 

13 

14 

LV 

LV 

LT 

PL 

15 

RO 

HU 

BE 

16 

17 

18 

PT 

Policia Judiciaria  

19 

LT 

Financial Crime Investigation 
Service under the Ministry of the 
Interior of the Republic of 
Lithuania - FCIS 

88 

94 

39 

24 

95 

89 

Strengthening of operational capacity 

902 601 

98 

Renforcement du dispositif opérationnel 
d'identification et de surveillance des véhicules 
et mise en place d'une analyse automatisée des 
informations 

150 355 

100 

Purchase of mobile X-ray scanner  

750 000 

100 

Strengthening of operational capacity 

283 841 

100 

Upgrade IMSI catcher 

Purchase of mobile x-rays scanners 

Purchase of Automated Vehicle Number Plate 
Recognition System  

454 960 

471 843 

62 749 

Strengthening of operational capacity of TSU 

10 320 

IMSI catcher 

Joint  data  exchange  network  between  X-ray 
scanners  used  by  customs  services  of  Baltic 
States 

Strengthening the Technical Capacity 

373 340 

1 967 110 

669 870 

100  

Strengthening the Technical Capacity 

110 482 

100 

Purchase of IT forensic equipment 

288 110 

100 

Purchase of equipment  for detecting illicit 
cigarettes 

783 527 

78 

Improving the operational and technical 
capacity 

161 973 

94 

Improving technical capacity electronic 
surveillance  
Technical assistance for the fight against EU-
fraud 
Purchase of computer forensic anti-fraud 
collaborative system 

332 279 

956 774 

759 533 

85 

94 

97 

Procurement of Intelligence Equipment 

100 299 

100 

37  

Final  payment  as  percentage  of  the  awarded  grant.  A  percentage  lower  than  100%  means  that  the  action  was  not  fully 
implemented or that the beneficiary managed to achieve considerable cost savings.  

27 

 
 
 
 
                                                 
20 

PL 

21 

FI 

22 

FR 

Chamber of Fiscal 
Administration in Bialystok 
Tulli - Finnish Customs - 
Valvontaosasto 
Forensic and Criminal 
Intelligence Agency of the 
French Gendarmerie - PJGN 

Modernisation and expansion of the cross-
border traffic control system 

358 183 

100 

MobileX - Protection with Flexibility 

1 257 796 

78 

Advanced digital forensic analyses 

333 840 

97 

Total  

11 539 774 

89 

28 

 
 
 
 
 
 
 
 
Table 3 - Databases that were contracted under the Hercule III budget in 2017 

Name 

Content 

Commitment in Euro 

1 

2 

3 

IHS Maritime Portal 

  Information on ship movements 

GTA 

ORBIS 

Global Trade Atlas: trade statistics data 

Bureau van Dijk: contains basic 
company information and financial 
details of companies all over the world 
Total committed under 2017 budget 

239 530 

206 060 

300 000 

745 590 

29 

 
 
 
 
  
 
 
 
 
 
 
Table 4 – Anti-Fraud Training and Conferences grants awarded in 2017 

MS 

Beneficiary 

Subject 

1  HR 

Ministry of Finance, Service for combating 
irregularities and fraud 

Further strengthening of the competent 
institutions in the area of managing on 
irregularities with the aim of protection of 
EU financial interests 

Co-fin 
Commitment          
% 

in Euro 

 66 169  

80 

2 

FR  Fondation Robert Shuman 

Fighting Transit Fraud in the European Union 

 93 709  

79 

3 

IT 

Agenzia Veneta per i Pagamenti in 
Agricoltura 

Strengthening Actions to Fight Frauds in 
Procurement 

4 

IT 

Fondazione Lelio E Lisli Basso-Onlus 

5  RO  Centrul de Resurse Juridice 

International Conference on Enhanced 
Cooperation for the  Establishment of the 
EPPO.   

Corruption in EU financed projects: a review 
of corruption schemes, prevention 
mechanisms and investigation strategies 

 68 877  

79 

 64 910  

80 

 80 193  

79 

6 

IT  Ministero Dell Economia E Delle Finanze 

Cooperation project  

 99 938  

80 

7 

IT 

Istituto Europeo Per Lo Sviluppo Socio 
Economico Associazione 

EU Funded actions: Detecting, Handling, 
Learning how to prevent Frauds and 
Irregularities in International Cooperation 
and Development Projects (IPA and ENI)  

 91 951  

80 

8  DE  Generalzolldirektion 

International fight against water pipe tobacco 
smuggling   

 55 085  

80 

9  CZ 

Transparency International - Ceska 
Republika Ops 

Clean Contraction in the European Funds 

 44 378  

80 

10  HU  Nemzeti Ado- Es Vamhivatal 

Anti-Cigarette Smuggling Staff Exchange 
Program 

 84 992  

80 

11  HU 

Transparency International Magyarország 
Alapítvány 

Exchange of expertise in identifying fraud 
risks to protect EU financial interests  

 40 506  

80 

12  RO  National Agency for Fiscal Administration 

Improving NAFA’s administrative capacity 
in fighting VAT intra-community fraud 
through an increased knowledge and 
awareness of the risks and a better use of 
fraud prevention and combating tools 

 59 943  

80 

13  BG  Center For the Study of Democracy 

Innovative Methods to Investigate Fraud and 
Corruption in EU funding for agriculture 

 52 702  

80 

14  RO  Academia De Politie Alexandru Ioan Cuza 

15 

RO  Freedom House Romania 

Eliminating fraud and preventing 
incompatibilities, a safe way towards 
successful access to European funds 

Enhancing the Legal Protection for EU's 
Financial Interests in Romania 

 34 942  

80 

75 399 

80 

Total 

 1 013 694  

80 

30 

 
 
 
 
 
 
 
Table 5 – Anti-Fraud procured conferences organised by the Commission in 2017 

Dates 

Conference Title 

Location 

No of 
participants 

Amount 
paid (1) 

1 (1) 

29 March 2017 

OLAF  Training  meeting  on  strengthening 
cooperation to combat transhipment fraud  

Hong-Kong 

16 

29 052 

Results:  The  purpose  of  the  meeting  was  to  increase  the  effectiveness  and  efficiency  of  the  special  watch  of  suspicious 
containers  subject  to  transhipment  fraud  by  enhancing  international  cooperation,  facilitating  the  exchange  of  information, 
experiences  and  best  practices  and  by  providing  operational  support  to  regional  customs  authorities.  It  aimed  to  deliver  a 
training  session  regarding  the  installation  and  the  use  of  the  Virtual  Operational  Coordination  Unit  (V-OCU)  application 
(AFIS) to the customs services of pre-selected ports in Asia with a view to track and trace deep sea containers loaded in Asia 
and  discharged  in  the  EU.  The  meeting  addressed  abuses  of  transhipment  procedures  an  issue  of  common  concern  for  the 
customs authorities in both Asia and in the EU.  The meeting strongly contributed to the prevention and the fight against the 
transhipment  fraud.  It  also  enhanced  the  international  cooperation  in  the  anti-fraud  sector  in  facilitating  the  exchange  of 
intelligence and the implementation of operational actions. 

2 

7- 9 June 2017 

AFCOS seminar 2017 

Budva. 
Montenegro 

59 

59 999 

Results:  This  event  brought  together  AFCOS  and  other  relevant  authorities  from  candidate  countries,  potential  candidate 
countries,  as  well  as  Eastern  Partnership  countries  (Georgia,  Moldova  and  Ukraine)  with  whom  the  EU  has  concluded 
association agreements.  This annual event sought to  present the work of OLAF and AFCOS authorities, to discuss challenges 
in their cooperation, and to share best practices and experience in the areas of the protection of the EU's financial interests 
(e.g. functioning of AFCOS, investigative cooperation, preparation of an antifraud strategy, irregularity reporting).  
The  event  featured  practical  examples  of  how  to  detect  and  report  fraud  to  EU  Delegations  and  to  national  authorities  in 
enlargement countries. It also provided guidance to candidate countries on the implementation of the accession requirements 
under acquis Chapter 32 regarding the protection of the EU's financial interests. 

3 

12-13 June 2017 

Fight  against  the  import  into  the  EU  of 
Counterfeit Fast Moving Consumer Goods 
(FMCG) 

Brussels 
Belgium  

60 

43 627 

Results:  The  participants  exchanged  operational  information  related  to  the  import  into  the  EU  of  counterfeit  FMCG  (e.g. 
washing powder). They gathered available information from the right-holders, identified possible new fraud patterns and new 
threats,  increased  enforcement  capabilities  of  the  participating  customs  administrations,  consolidated  network  of  point  of 
contacts and shared information aiming at better targeting system based on common approach on risk profiling. Finally, they 
agreed on further steps to be taken. 

4  

20-21 June 2017 

JCO RENEGADE de-briefing meeting 

Lisbon          
Portugal 

54 

103 992 

Results:  The  participants  to  the  debriefing  analysed  the  results  of  the  operation  and  agreed  on  the  final  report.  The  meeting 
summarised various elements of the operation, agreed on a press communication, and led to discussions for further cooperation 
and the identification of potential improvements to IT-applications. 

5 

26-29 June 2017 

22nd Task Group Cigarette conference  

Tallinn             
Estonia 

70 

98 124 

Results:  This event confirmed the role of OLAF in its coordination and investigation activities concerning the smuggling of 
cigarettes  into  EU.  This  conference  focussed  particularly  on  third  countries  as  key  partners  in  the  fight  against  cigarette 
smuggling  into  EU  (Moldova,  Ukraine,  Russia,  Georgia  and  Turkey).    It  higlighted  important  relationships  with  Lebanon, 
Kosovo and Montenegro. 

6 

15 December 2017 

Workshop on an amendment of Regulation 
883/2013 

Brussels 
Belgium 

19 

6 517  

Results: The particpants discussed options for the amendment of Regulation 883/2013. The results of the workshop fed into the 
discussions on the amendment of the Regulation. 

31 

 
 
 
 
7 (2) 

25-26 January 2018 

14th  OLAF  Anti-Fraud  Communicators 
Network (OAFCN) Training Seminar 

Brussels 
Belgium 

55 

41 003  

Results:  This  event  provided  hands-on  training  for  anti-fraud  communicators  from  the  OLAF  partner  services  on  the  most 
recent techniques to communicate to deter fraud. Communication kits were created and distributed to OLAF partners to prevent 
and deter fraud.  

8 (2) 

23 March 2018 

EESC  Conference  -  fighting  the  illicit 
tobacco trade 

Brussels 
Belgium 

200 

49 009  

Results:  The  Tobacco  Implementation  Report  foresaw  a  further  consultation  with  stakeholders  (tobacco  industry,  consumer 
association,  health  non-governmental  organisations  and  academia).  Emphasising  the  stakeholder  perspective,  the  event  was 
organised  to  deter  illicit  tobacco.  An  important  feature  of  the  event  was  the  cooperation  with  the  European  Economic 
Social  Committee (EESC). 

 (1)  For event n° 1, we have not yet received the final invoice. Since the amounts paid and the actual number of participants are 
not known yet, the amounts indicated correspond to the provisional number of participant and the committed amount.  

(2)  Event n° 7 and 8 were committed under Hercule Budget 2017, but implemented in 2018. Since the amounts paid and the actual 
number of participants are not known yet, the amounts indicated correspond to the provisional number of participant and the 
committed amounts.  

Total(3) 

262  

312 259  

32 

 
 
 
 
 
 
 
Table 6 - Anti-Fraud Training and Conferences grants finalised in 2017 

MS 

Beneficiary 

Title 

Partici
pants 

Total 
paid 

Amount paid 
as % to initial 
commitment38 

Cooperation  Project 
Sector 

in 

the  Anti-Fraud 

221 

 70 890  

1 

2 

3 

IT 

UK 

CY 

Presidency of Council of 
Ministers — Department 
of European Policies 
Royal United Services 
Institute (RUSI) 
European University — 
Cyprus Ltd 

4 

PL 

Border Guard 
Headquarters 

5 

6 

CZ 

HU 

Transparency 
International 

Transparency 
International HU 

7 

PL 

Ministry of Finance, 
Treasury Intelligence 
Department 

8 

RO 

Ministry of Internal 
Affairs 

9 

SK 

Financial Directorate of 
the Slovak Republic 

10 

BG 

National Revenue 
Agency (NRA) 

11 

EL 

Hellenic School of 
Judges 

12 

IT 

Agenzia Veneta per i 
Pagamenti in 
Agricoltura- AVEPA 

in 

investigation  coordination 

Conference  on  organised  crime  and  illicit 
trade in Europe 
Financial 
Cyprus 
Crime  analysis  as  a  tool  to  combat  illegal 
international  trade  and  to  fight  against 
smuggling  of  excise  goods  aimed  at  fraud 
prevention  affecting  the  financial  interests 
of the European Union 
Towards  better  fraud  risk  management  in 
EU funds 
Knowledge  and  experience  sharing  on  the 
use of the red flag signalling tool for cleaner 
and more transparent EU spending  
‘Chasing  beyond  borders’  —  joint  training 
of  Polish  Treasury  Intelligence  and  Czech 
Custom Service 
Enhancing  the  capacity  of  the  Romanian 
ministry  of  internal  affairs  to  prevent  and 
investigate 
financial 
interests  of  the  European  Union,  through 
training and partnership 
Training 
the 
focused  on 
effectiveness  of  customs  controls  in  the 
fight  against  fraud  and  detection  of  illegal 
and 
practices 
counterfeiting  of 
tobacco 
products  at  the  external  border  and  inland 
by 
and 
available 
communications means 
Increasing  NRA’s  administrative  capacity 
in  the  intracommunity  trade  control  by 
improving  the  interaction  between  the  EU 
member 
in 
combating tax fraud 
Fraud against the EU by illegal subsidies in 
agricultural 
tobacco 
smuggling 

administrations 

tobacco  and 

smuggling 

increasing 

technical 

affecting 

products 

states’ 

frauds 

using 

and 

the 

in 

77 

 72 202  

485 

 48 254  

80 

95 

79 

157 

 36 893  

46 

121 

 26 683  

69 

 43 033  

114 

 69 136  

83 

90 

77 

125 

 35 423  

59 

103 

 59 670  

82 

118 

 42 939  

72 

117 

 45 014  

72 

83 

83 

SafeNet:  Strenghten  Anti  Fraud  European 
Network 

55 

 56 955  

Total 

1 762 

 607 092  

38  

Final payment as percentage of the awarded grant. A percentage lower than 100% means that the action was not fully 
implemented or that the beneficiary's managed to achieve considerable cost savings.  

33 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Table 7 - Law Training & Studies grants awarded in 2017 

  MS 

Beneficiary 

Subject 

Commit-
ments in 
Euro 

Co-fin % 

1 

LU  University of Luxembourg 

2 

RO 

"Alexandru Ioan Cuza" 
Police Academy 

3 

4 

DE 

Max Planck Society for the 
Advancement of Science 

IT  Modena University 

5 

HU  Miskolci University 

6  MT  Malta University 

7 

RO 

Anticorruption National 
Directorate 

8 

NL  University of Utrecht 

9 

DE  European Law Academy 

the  capacity 

Admissibility of OLAF final reports as evidence 
in criminal proceedings 
Developing 
to  prevent  and 
investigate  situations  of  incompatibility  and 
conflict  of 
the  financial 
interest  affecting 
interests of the European Union 
eucrim: The European Criminal Law 
Associations' Forum - publication of a 
periodical on the protection of the EU’s 
financial interests 
Europe Against Cyber VAT Frauds 
Criminal law protection of the financial interests 
of the EU – Focusing on money laundering, tax 
fraud, corruption and on criminal compliance in 
the  national  legal  systems  with  reference  to 
cybercrime 
Implementing    Enforcing  EU  Criminal  Law  – 
Theory and Practice 
Promoting 
the  financial 
interests of the EU by supporting the actions of 
the member states and the European institutions 
in the transition towards the EPPO 
OLAF  and  the  EPPO  in  the  new  institutional 
setting  for 
the  financial 
the  protection  of 
interests of the EU 
Understanding  each  step  of  the  “anti-fraud 
investigation, 
cycle”:  prevention,  detection, 
sanctioning  and 
the 
recovery 
irregularities  affecting  the  financial  interests  of 
the European Union 

the  protection  of 

to  combat 

78 000 

42 115 

74 146 

66 323 

74 144 

58 562 

65 595 

40 032 

63 

80 

80 

80 

80 

80 

80 

80 

42 224 

80 

Total 

541 140 

77 

34 

 
 
 
 
 
 
 
 
 
 
 
Table 8 - Law training and studies grants finalised in 2017 

MS 

Beneficiary 

Title 

1 

DE 

Max Planck Institute for 
Foreign and International 
Criminal Law  

2 

IT  Centro di Diritto Penale 
Europeo Catania 

the  environment  for 

Periodical publication  
"eucrim"  -  The  European  Criminal 
Law Associations' Forum  
Comparative law study 
the 
Preparing 
trust  by 
EPPO:  Fostering  mutual 
improving  existing  common 
legal 
heritage  and  enhancing  common  legal 
understanding. 
a 
preliminary  study  and  guidelines  for  a 
model  "framework  curriculum"  for 
legal training of practitioners in the PIF 
sector. 

Proposal 

for 

N° of 
part. 

Total paid 

Amount paid 
as % to initial 
commitment39 

N/A 

49 682  

78 

N/A 

84 860  

82 

3 

NL 

Utrecht  University, School 
of Law, Utrecht Centre for 
Regulation and 
Enforcement in 
Europe/RENFORCE  

4 

IT  Transparency International 

Italy 

5 

IT 

Alma Mater Studiorum - 
University of Bologna - 
Center for Research and 
Training for the Public 
Sector - European School 
of Advanced Fiscal Studies 

Comparative law study 
OLAF's legislative framework through 
a comparison with other EU law 
enforcement authorities  

Comparative law study 
Impact of statute of limitations in 
corruption cases affecting EU 
Financial Interests – A European 
Comparison  

Comparative law study, workshop and 
conference 
Investigations and Sanctions for VAT 
frauds: Fundamental Principles and 
Comparison across EU Member States 

N/A 

69 987 

93 

N/A 

41 859 

96 

64 

payment 
ongoing 

payment 
ongoing 

Total 

64 

246 388 

87 

39  

Final payment as percentage of the awarded grant. A percentage lower than 100% means that the action was not fully 
implemented or that the beneficiary's managed to achieve some cost savings.  

35 

 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Table 9 - Technical Assistance - Overview of awarded grants and rejected applications in 2017 

MS 

BE 

BG 

CZ 

DK 

DE 

EE 

IE 

EL 

ES 

FR 

HR 

IT 

CY 

LV 

LT 

LU 

HU 

MT 

NL 

AT 

PL 

PT 

RO 

SI 

SK 

FI 

SE 

UK 

Total 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

Received 
application 
number 

Request 
for 90% 

Grant 
requested 
(EUR) 

Awarded 
grants  
(Number) 

Awarded 
grants 
90% 
(number) 

Grants 
awarded 
(EUR) 

 - 

1 

1 

 - 

2 

 - 

1 

3 

1 

1 

-  

1 

-  

2 

5 

-  

3 

1 

1 

 - 

14 

2 

10 

1 

1 

1 

 - 

1 

53 

-  

0 

0 

-  

1 

-  

0 

2 

0 

0 

-  

0 

-  

2 

3 

-  

0 

1 

1 

 - 

2 

1 

1 

1 

0 

1 

-  

0 

- 

 353 059  

 246 486  

- 

 554 245  

- 

 515 058  

1 201 769  

 842 174  

 113 858  

- 

 480 000  

-  

 984 200  

2 750 042  

-  

1 340 759  

1 286 358  

 520 161  

 - 

6 288 302  

2 212 650  

2 712 012  

 538 115  

 331 164  

 796 855  

-  

 261 085  

16 

24 328 351  

 - 

0 

1 

-  

1 

-  

1 

2 

1 

0 

-  

0 

-  

1 

4 

-  

0 

0 

1 

 - 

1 

1 

6 

1 

0 

1 

-  

 0 

22 

-  

0 

0 

-  

0 

-  

0 

0 

0 

0 

-  

0 

-  

0 

0 

-  

0 

0 

0 

 - 

0 

0 

0 

0 

0 

0 

-  

0 

0 

- 

0 

 246 486  

- 

 86 534  

- 

 515 058  

 744 317  

 604 174  

- 

0 

0 

-  

 563 105  

2 268 800  

-  

        0  

0 

 460 307  

-  

 465 678  

1 520 000  

1 620 698  

 460 680  

0  

 655 360  

-  

0  

10 211 196  

Average amount requested: EUR 459 025 (Overall amount requested/number of applications) 

Average amount awarded:  EUR 464 145 (Overall amount awarded/number of grants) 

36 

 
 
 
Table 10 - Training and Conferences 2017 - Overview of awarded grants and rejected applications  

  MS 

Received 
application 
number 

Request 
for 90% 

Grant 
requested 
(EUR) 

Awarded 
grants  
(number) 

Awarded 
grants 
90% 
(number) 

Grants 
awarded 
(EUR) 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

BE 

BG 

CZ 

DK 

DE 

EE 

IE 

EL 

ES 

FR 

11  HR 

12 

IT 

13  CY 

14 

15 

16 

LV 

LT 

LU 

17  HU 

18  MT 

19  NL 

20  AT 

21 

22 

PL 

PT 

23  RO 

24 

25 

26 

SI 

SK 

FI 

27 
SE 
28  UK 

 - 

4  

1  

 - 

1  

1  

 - 

 - 

2  

1  

1  

7  

1  

1  

1  

 - 

3  

 - 

1  

 - 

 - 

 - 

7  

 - 

1  

 - 

 - 
 - 
33 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 
- 

- 

275 368  

53 015  

 - 

64 303  

63 193  

 - 

 - 

268 383  

99 829  

66 439  

703 620  

222 902  

66 237  

67 713  

 - 

165 724  

 - 

78 927  

 - 

 - 

 - 

575 247  

 - 

46 169  

 - 

 - 

 - 
2 817 069 

- 

1  

1  

 - 

1  

 - 

 - 

 - 

 - 

1  

1  

4  

 - 

 - 

 - 

 - 

2  

 - 

0  

 - 

 - 

 - 

4  

 - 

 - 

 - 

 - 
 - 
15 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 
- 

- 

52 702  

44 378  

 - 

55 085  

0  

 - 

 - 

0  

93 709  

66 169  

325 676  

0  

0  

0  

 - 

125 498  

 - 

0  

 - 

 - 

 - 

250 477  

 - 

0  

 - 

 - 

 - 
1 013 694  

Average amount requested: EUR 85 365 (Overall amount requested/number of applications) 
Average amount awarded:  EUR 67 580 (Overall amount awarded/number of grants) 

37 

 
 
 
 
 
 
 
 
 
 
 
Table 11 - Law Training and Studies 2017 - Overview of awarded grants and rejected applications  

MS 

BE 

BG 

CZ 

DK 

DE 

EE 

IE 

EL 

ES 

FR 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11  HR 

12 

IT 

13  CY 

14 

15 

16 

LV 

LT 

LU 

17  HU 

18  MT 

19  NL 

20  AT 

21 

22 

PL 

PT 

23  RO 

24 

25 

26 

25 

SI 

SK 

FI 

SE 

28  UK 

Received 
applications 
(Number) 

Requests 
for 90% 
funding 
(Number) 

Grants 
requested 
(EUR) 

Awarded 
grants 
(Number) 

Awarded 
grants 90% 
(Number)  

Grants 
awarded 
(EUR) 

- 

1 

1 

- 

2 

- 

- 

- 

1 

- 

- 

4 

- 

- 

- 

1 

1 

1 

1 

- 

- 

- 

5 

- 

- 

- 

- 

- 

- 

0 

0 

- 

0 

- 

- 

- 

0 

- 

- 

0 

- 

- 

- 

0 

1 

0 

0 

- 

- 

- 

0 

- 

- 

- 

- 

- 

-  

69 767  

47 751 

-  

116 929  

-  

-  

- 

80 683 

-  

-  

262 912 

-  

- 

-  

83 046 

88 249  

66 852 

40 032 

-  

- 

-  

501 915 

-  

-  

-  

-  

-  

18 

1 358 136 

- 

0 

0 

- 

2 

- 

- 

- 

0 

- 

- 

1 

- 

- 

- 

1 

1 

1 

1 

- 

- 

- 

2 

- 

- 

- 

- 

- 

9 

- 

0 

0 

- 

0 

- 

- 

- 

0 

- 

- 

0 

- 

- 

- 

0 

0 

0 

0 

- 

- 

- 

0 

- 

- 

- 

- 

- 

-  

0   

0  

- 

116 370  

- 

- 

-  

0  

- 

- 

66 323  

- 

- 

- 

78 000 

74 144  

58 562 

40 032 

- 

- 

- 

107 710 

- 

- 

- 

- 

- 

541 140 

Average amount requested: EUR 75 452 (Overall amount requested/number of applications). 
Average amount awarded:  EUR 60 195 (Overall amount awarded/number of grants). 

38