COMMISSION STAFF WORKING DOCUMENT Accompanying the document Report from the Commission to the European Parliament and the Council Evaluation of the 2015-2019 action plan on firearms trafficking between the EU and the south-east Europe region
Date: 2019-06-27
Institutions: Directorate-General for Migration and Home Affairs, European Commission
Subjects: Europol, Western Balkans, action programme, arms trade, cross-border cooperation, exchange of information, fight against crime, firearms and munitions, illicit trade, non-proliferation of arms

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   EUROPEAN COMMISSION  Brussels, 27.6.2019  SWD(2019) 282 final  COMMISSION STAFF WORKING DOCUMENT Accompanying the document Report from the Commission to the European Parliament and the Council Evaluation of the 2015-2019 action plan on firearms trafficking between the EU and the south-east Europe region {COM(2019) 293 final}  
 
 
Evaluation of the 2015-2019 action plan on firearms trafficking between the EU and the 
south-east Europe region 

Contents 

TABLE OF ACRONYMS .................................................................................................. 3 

1. 

INTRODUCTION ....................................................................................................... 4 

2.  BACKGROUND TO THE INTERVENTION ........................................................... 5 

2.1.  Objectives of the action plan ............................................................................. 5 
2.2.  Legal nature of the action plan and governance ................................................ 7 
2.3. 
Intervention logic .............................................................................................. 8 
2.4.  Baseline ............................................................................................................. 9 
2.5.  Current policy and other developments ........................................................... 12 

3.  STATE OF PLAY ..................................................................................................... 14 

4.  METHODOLOGY .................................................................................................... 17 

4.1.  Sources and methods used ............................................................................... 17 
4.2.  Limitations and robustness of findings ........................................................... 18 

5.  ANALYSIS AND ANSWERS TO THE EVALUATION QUESTIONS ................ 19 

5.1.  Relevance ........................................................................................................ 19 
5.2.  EU Added value and sustainability ................................................................. 21 
5.3.  Effectiveness ................................................................................................... 24 
5.4.  Efficiency ........................................................................................................ 30 
5.5.  Consistency ..................................................................................................... 32 

6.  CONCLUSIONS ....................................................................................................... 36 

ANNEXES ........................................................................................................................ 38 

Procedural information ...................................................................... 38 
Annex 1. 
Annex 2. 
Stakeholder consultation ................................................................... 40 
General overview ...................................................................................................... 40 
Results of the questionnaire ...................................................................................... 41 
Meetings of the Joint Committee between European Union Firearms Experts and 

Annex 3. 
Annex 4. 
Annex 5. 

Annex 6. 
Annex 7. 

South East Europe Partners Experts ................................................................ 46 
Methods and analytical model ........................................................... 48 
Description of activities under the Firearms Platform ...................... 50 
Description  of  activities  carried  out  by  the  South  Eastern  and 
Eastern  Europe  Clearinghouse  for  the  Control  of  Small  Arms  and  Light 
Weapons .......................................................................................................... 54 
Training activities .............................................................................. 57 
Conclusions  of  the  meetings  of  the  Joint  Committee  between 
European  Union  Firearms  Experts  and  South  East  Europe  Countries 
Experts   ........................................................................................................... 59 

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Annex 8. 
Annex 9. 

List of National action plans adopted by Western Balkan Partners .. 70 
General overview of activities carried out ........................................ 71 

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TABLE OF ACRONYMS 

CEPOL 

EU Agency for Law Enforcement Training 

CFSP 

EFE 

EMPACT 

Europol 

EBCGA 

NATO 

OSCE 

SALW 

SEEFEN 

SEESAC 

SELEC 

SIENA 

Common Foreign and Security Policy 

European Firearms Expert Group – EU Experts 

European  Platform  Against  Criminal  Threats  -  the  Multidisciplinary 
Platform 

EU Law Enforcement Agency 

EU Border and Coast-Guard Agency ("Frontex") 

North Atlantic Treaty Organisation 

Organisation for Security and Cooperation in Europe 

Small arms and Light Weapons – small arms 

South  East  Europe  Firearms  Expert  Network    -  also  known  as  the 
Western Balkan Experts 

South  Eastern  and  Eastern  Europe  Clearinghouse  for  the  Control  of 
Small Arms and Light Weapons –also known as the Clearinghouse 

Southeast European Law Enforcement Centre 

Secure Information Exchange Network Application  

UNODC 

United Nations Office on Drugs and Crime 

UNDP 

United Nations Development Programme 

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1. 

INTRODUCTION 

At the end of 2014, the  Council  of the European Union and the Ministers of  Interior of the 
Western  Balkans  partners  agreed  on  an  action  plan  on  firearms  trafficking  between  the  EU 
and the south-east Europe region.1 

In  its  Communication  of  6  February  2018,  "A  credible  enlargement  perspective  for  and 
enhanced EU engagement with the Western Balkans",2 the Commission stressed the need to 
strengthen  its  efforts  against  firearms  trafficking.  During  their  meeting  in  Sofia  at  the  EU-
Western Balkan Summit, on 17 May 2018, heads of states and governments set as a priority to 
"prepare a renewed action plan for cooperation on firearms to address more effectively illicit 
firearms and the large stockpile of weapons". 

On 26 January 2018, the second meeting of the Joint Committee between EU firearms experts 
and experts from partners in south-east Europe partners experts was held. At this meeting, the 
Commission  and  representatives  from  both  the  EU  member  states  and  the  Western  Balkan 
partners underlined the need to assess the different initiatives that had been carried out to the 
implement the action plan, to inspire future policy developments. 

This  evaluation  aims  to  inform  policy  makers  about  the  functioning  of  the  action  plan  and 
possible future policy needs.    

Many players cooperate with the Western Balkans in the fight against firearms trafficking and 
this  evaluation  provides  an  overview  of  what  has  been  achieved  between  January  2015  and 
December  2018  in  the  region.  The  evaluation  assesses  the  functioning  of  the  action  plan, 
based on five evaluation criteria: the relevance, effectiveness, efficiency, consistency and EU 
added value of the action plan.  

The evaluation also aimed to identify needs and policy gaps that may need being addressed to 
respond to the threat of firearms trafficking in the Western Balkans and between the Western 
Balkans and the European Union. 

This  evaluation  takes  into  account  the  EU  member  states,  EU  agencies  and  international 
organisations that cooperate with the Western Balkans in the fight against firearms trafficking.  

It  analyses  the  implementation  of  the  action  plan  and  focuses  in  particular  on  a  series  of 
activities such as: 

  activities  of  the  South  Eastern  and  Eastern  Europe  Clearinghouse  for  the  Control  of 

Small Arms and Light Weapons (SEESAC – hereinafter 'the Clearinghouse');  

  activities  of  the  European  Platform  Against  Criminal  Threats  (EMPACT)  Firearms 

(hereinafter 'the Firearms Platform');  

1  

14  November  2014,  Council  Document  15516/14,  adopted  by  the  Council  of  4  and  5  December  2014  (Council  Document  16526/14);  EU  –  Western 
Balkans Ministerial Forum on Justice and Home Affairs of 12 December 2014 in Belgrade. 

2   COM(2018)65. 

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  actions by EU agencies such as the EU Law Enforcement Agency (Europol), the EU 
Border and Coast-Guard Agency (EBCGA) or the EU Agency for Law Enforcement 
Training (CEPOL);  
the bilateral actions of member states and Western Balkan partners;  

 
  activities  of  other  partners  such  as  the  North  Atlantic  Treaty  Organisation  (NATO), 
the  United  Nations  Office  on  Drugs  and  Crime  (UNODC)  or  the  Organisation  for 
Security and Cooperation in Europe (OSCE). 

For the purpose of this evaluation, the term 'small arms and light weapons'3 (hereinafter 'small 
arms')  is  used  to  describe  military-grade  weapons  and  the  term  'firearms'4  is  used  solely  to 
describe civilian firearms.  

The  evaluation  covers  the  Western  Balkan  region  and  in  particular  Albania,  Bosnia  and 
Herzegovina, Kosovo*, Montenegro, Serbia and North Macedonia.  Although the action plan 
formally concerns the broader south-east Europe, cooperation has in practice focused on the 
Western  Balkans.  The  assessment  therefore  does  not  include  the  Republic  of  Moldova  and 
Ukraine. The reasons for this are explained in Section 5.1 on relevance.  

2.  BACKGROUND TO THE INTERVENTION 

2.1.  Objectives of the action plan 

On 5-6 November 2012, ministers from the south-east Europe region met at the EU-Western 
Balkans  ministerial  forum  on  Justice  and  Home  Affairs  in  Tirana.    At  this  meeting,  the 
ministers  acknowledged  the  need  to  increase  efforts  to  counteract  the  illicit  trafficking  and 
accumulation of firearms, their parts and essential components and ammunition in the south-
east Europe region. They also stressed their desire to work together with EU partners towards 
a joint solution for the whole region.5  

3   Small arms and light weapons (SALW) and their ammunition are military-grade weapons; they include:  

a. 

b. 

small  arms:  assault  rifles;  military-grade  semi-automatic  rifles  and  carbines;  military-grade  revolvers 
and self-loading pistols; light machine guns; sub-machine guns, including machine pistols;  
light  weapons:  heavy  machine  guns;  cannons,  howitzers  and  mortars  of  less  than  100  mm  calibre; 
grenade launchers; recoilless  guns; shoulder-fired rockets and other anti-tank and air defence systems 
that fire projectiles, including MANPADS, all on condition they are man- or crew-portable;  

c.  SALW parts;  
d.  SALW accessories (such as night scopes, sound suppressors, etc.); and  
e.  SALW ammunitions.  
This definition does not prejudge any future internationally agreed definition of SALW. 

4   The  term  ‘firearms’  has  a  broader  scope  that  covers  both  civilian  and  military-grade  firearms.  The  UN 
firearms protocol defines a firearm as any portable barrelled weapon that expels, is designed to expel or may 
be converted to expel a shot, bullet or projectile by the action of an explosive, excluding antique firearms or 
their replicas. It should be noted that some light weapons, such as rocket launchers, are not firearms. Hence 
the term ‘firearms’ does not cover all Small Arms.   

*  

In this document, any reference to Kosovo is without prejudice to positions on status, is in line with Security 
Council Resolution 1244 (1999) and the ICJ Opinion on the Kosovo Declaration of Independence. 

5   15897/12, Council. 

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The ministers identified the following needs:  

  To  improve  the  exchange  of  criminal  information  and  intelligence  at  regional  level 
and  with  EU  member  states,  involving  Europol,  on  the  production,  stockpiling  and 
trafficking of firearms and ammunition;  

  To develop  more effective investigative and intelligence standards;  

  To improve operational law enforcement co-operation at regional level and with EU 
member  states  and  Europol.  This  should  focus  on  controlling  the  production, 
stockpiling and trafficking of firearms and ammunition;  

  To  improve  the  collection  and  exchange  of  statistics  on  the  production,  stockpiling 

and trafficking of firearms and ammunition;  

  To  promote  networking  at  all  levels,  exchange  of  best  practices  and  joint  training 

among experts in the south-east Europe region;  

  To harmonise national legislation on firearms with EU and international standards.  

To meet these needs, the action plan was set up. It contains a set of general objectives (goals) 
and specific measures (actions) to reduce and possibly halt the illicit flow of firearms to the 
EU in the period 2015-2019.  

Goal 1 focused on the modernisation of law enforcement agencies.  

Action  1  required  every  partner  in  the  south-east  Europe  region  to  create  a  firearms  focal 
point  by  the  end  of  2019.  This  focal  point  must  use  all  available  tools  for  tracing  firearms, 
including  the  weapon  tracking  database  iTRACE,6  Interpol's  iARMS  database,7  which  lists 
seized, stolen and lost weapons, and the Europol Information System.8 These focal points are 
required  to  coordinate  all  firearms-related  actions  and  work  on  a  similar  basis,  aligned 
through the best practice guidance for the creation of national firearms focal points. 

6  

iTrace is a European Union-funded project, which provides policy makers with dynamic, quantified data on 
transfers  of  diverted  conventional  weapons,  ammunition,  and  related  materiel.  Conventional  weapons  is  a 
term  used  for  arms  which  do  not  have  ‘mass  destructive’  capabilities,  such  as  nuclear,  chemical  and 
biological weapons.  The Arms Trade Treaty of 24 December 2014 mention as conventional weapons: battle 
tanks,  armoured  combat  vehicles,  large-calibre  artillery  systems,  combat  aircrafts,  attack  helicopters, 
warships, missiles and missile launchers and small arms and light weapons.  

7   The  INTERPOL  Illicit  Arms  Records  and  tracing  Management  System  (iARMS)  is  a  state-of-the  art  tool 
that  facilitates  information  exchange  and  investigative  cooperation  between  law  enforcement  agencies  in 
relation to the international movement of illicit firearms, as well as licit firearms that have been involved in 
a crime. 

8   The Europol Information System (EIS) is Europol’s central criminal information and intelligence database. 
It contains information on serious international crimes, suspected and convicted persons, criminal structures, 
and offences and the means used to commit them. It is a reference system that can be used to check whether 
information on a certain person or an object of interest (such as a  car, a telephone or an e-mail message) is 
available 
on 
https://www.europol.europa.eu/activities-services/services-support/information-exchange/europol-
information-system 

jurisdictions.  More 

organisational 

information 

national 

beyond 

or 

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Action 2 provided for a  pilot  project  on data collection. The Joint Committee committed to 
provide comprehensive data on seizures of weapons as part of the Global Firearms Study of 
the United Nations Office on Drugs and Crime, funded by the European Commission. 

Action 3 required a study to be conducted on systems for the exchange of information in order 
to improve the strategic and operational analysis of information. The Joint Committee stressed 
the need to improve the exchange of information at regional level and with member states. It 
also stressed the importance of involving different organisations in this information exchange, 
such as Europol. It said that the information exchanged should include ballistic identification 
and  it  was  important  to  make  better  use  of  the  Secure  Information  Exchange  Network 
Application (SIENA)9 

Goal 2 was dedicated to enhancing mutual trust. 

Action  1  called  for  joint  meetings  of  firearms  experts.  The  Joint  Committee  went  a  step 
further  by  recommending  that  representatives  of  southeast  Europe  should  be  invited  to 
meetings of the European firearms experts group. 

Action 2 was dedicated to organising joint operations (including yearly joint actions days),10 
and  to  involving  Western  Balkan  partners  the  European  Multidisciplinary  Platform  against 
Criminal  Threats  –  Firearms.  The  Joint  Committee  also  stressed  the  need  to  provide  a 
consistent framework for cooperation between the EU and the south-east Europe region in the 
fight against firearms trafficking. 

Goal 3 focused on capacity building. 

Action  was  designed  to  focus  on  organising  training  activities  on  firearms  trafficking.  The 
Joint  Committee  also  requested  a  feasibility  study  on:  (i)  the  continuation  of  voluntary 
surrenders of unregistered weapons; (ii) continuous support to destruction of surplus firearms; 
and (iii) improving the security and safety of stockpiles. 

2.2.  Legal nature of the action plan and governance 

The action plan was endorsed by the Council11 and included in a joint declaration of the EU – 
Western  Balkans  Ministerial  Forum  on  Justice  and  Home  Affairs  of  12 December  2014  in 
Belgrade.  This  action  plan  is  a  political  and  programmatic  document  that  is  not  based  on  a 
formal  Commission  proposal.  It  does  not  include  provisions  related  to  its  implementation, 
except  that  "senior  officials  of  the  south-east  Europe  partners  will  regularly  report  to  the 
European Commission on implementation of the above mentioned actions so as to allow the EU 
member states make the best use of this information in the context of the framework of the EU 
Policy  Cycle."  It  therefore  makes  a  link  between  the  European  Commission  and  the  EU  policy 
cycle, which is a policy process led by member states. The action plan also refers to the need to 

9 The Secure Information Exchange Network Application (SIENA) is a state-of-the-art platform that meets the 
communication needs of EU law enforcement. The platform enables the swift and user-friendly exchange of 
operational and strategic crime-related information among: Europol’s liaison officers, analysts and experts; 
member states; third parties with which Europol has cooperation agreements. 

10   JAD  is  a  day/s  of  coordinated  controls  carried  out  by  law  enforcement  agencies  of  different  countries 

targeting organised crime groups involved in firearms trafficking.  

11   14 November 2014, Council Document 15516/14, adopted by the Council of 4 and 5 December 2014 (Council Document 16526/14) 

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"call for regular joint meetings of firearms experts from the established groups and networks in 
the region to assess ways to exchange information, evaluate joint initiatives aiming at improving 
cooperation  and  reducing  the  risk  of  overlaps  among  different  actions  in  this  field"  (Goal  2, 
Action 1). However, the action plan does not mention the respective responsibilities of the various 
players (for instance on pilot projects, studies, organisation of meetings, coordination of activities, 
joint  actions  or  training  activities).  These  responsibilities  can  be  inferred  from  the  introductory 
references  to  the  Firearms  Platform,  to  the  European  Firearms  Expert  Group  and  to  the 
Commission. 

For this reason, the governance and implementation of the action plan mostly developed in a 
pragmatic  way,  with  the  Commission  and  various  stakeholders  taking  individual  initiatives. 
Because of this (see section 5.5 on consistency), the Commission has attempted to coordinate 
the  various  streams  of  work,  mostly  by  playing  an  active  role  in  the  Firearms  Platform, 
attending  all  firearms  expert  meetings  in  the  Western  Balkans  and  organising  the  joint 
meetings of firearms experts from the EU member states and Western Balkans partners. 

2.3. 

Intervention logic 

No structured intervention logic was decided upon before the drafting of the action plan.  

The aim of the action plan is to reduce all risks linked to the illegal use of firearms and more 
in general the fight against illicit trafficking in firearms. Reconstructing the intervention logic 
requires to set out the link with these risks and conversely, what it should be the impact of the 
action plan on these risks. It is difficult to assess the achievements of the action plan. It is also 
difficult  to  assess  if  any  progress  in  the  fight  against  firearms  trafficking  was  due  to  the 
implementation of the action plan or different factors.  

The  following  diagram  is  an  attempt  to  reconstruct  this  approach  in  hindsight.  It  takes  into 
account the conclusions of the meetings of the Joint Committee of EU firearms experts and 
firearms experts from south-east Europe partners. 

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2.4.  Baseline 

Illicit  trafficking of firearms is  the lifeblood  of organised crime  and terrorism  in  Europe.  In 
particular, it facilitates drug trafficking through intimidation and coercion, fuels turf conflicts 

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between  urban  gangs,  and  empowers  terrorists.  Firearms  pose  a  serious  threat  to  the  EU’s 
security.  It  is  only  by  recognising  this  threat  that  we  will  be  able  to:  (i)  prevent  and  fight 
serious  and  organised  crime;  (ii)  tackle  and  prevent  terrorism;  and  (iii)  strengthen  border 
security. 

The  EU  and  countries  in  south-east  Europe  have  always  had  a  shared  interest  in  increasing 
their cooperation to address the threats posed by illicit trafficking in firearms. This interest is 
underpinned  by  the  prospect  of  EU  accession  for  the  countries  of  south-east  Europe. 
However, before the adoption of the action plan, EU law enforcement agencies had no regular 
exchanges of best practices and intelligence with law-enforcement authorities in the Western 
Balkans. Regional cooperation within the Western Balkans was only starting, and there was 
no  long-standing  body  of  Western  Balkans  firearms  experts.  Legislation  in  the  Western 
Balkans was not aligned with EU law, and this opened up opportunities for criminals to avail 
of legislative discrepancies and easily buy and sell firearms.12 

Since  the  early  1990s,  the  firearms  trafficked  illicitly  in  the  EU  have  originated  from  three 
main  sources.  Firstly,  countries  in  the  former  Soviet  Union  and  Warsaw  Pact  bloc  were  a 
source of illicit firearms due to  the fall of the iron curtain. The ongoing conflict  in  Ukraine 
could increase the risk of firearms being diverted into the EU (especially following a possible 
peace process). Secondly, as a consequence of the wars of Yugoslav succession, the Western 
Balkans became and are still considered a significant source of illicit firearms. More recently, 
in the aftermath of the "Arab spring", ongoing conflicts and weak states present an increased 
risk of diversion from North Africa and the Middle East possibly following some of the main 
drug trafficking routes into the EU.13 

Several  reports  from  Europol  confirmed  the  threat  of  firearms14  and  mentioned  the  need  to 
increase the flow of information and intelligence between the EU and the Western Balkans. In 
2014, the first operational action plan on crime was produced as part of the EU Policy Cycle 
2014-2018 under the section on "Firearms".15 The action plan mentioned the need to increase 
the flow of information and intelligence between the EU and the Western Balkans. 

The  2015  terror  attacks  in  Paris,  Copenhagen  and  on  a  Thalys  train,  underlined  the  link 
between organised crime and terrorism. This link was especially clear in the issue of firearms 
trafficking.  These  attacks  were  clear  evidence  of  how  this  multidimensional  terror  threat 
involved different  areas  of crime. These events  showed why there was  a  need to  strengthen 
further  the  fight  against  trafficking  of  firearms,  through  a  coordinated  and  consistent 
approach. As the SAFTE research programme on firearms acquisitions by terrorists in Europe 
concluded,16  "today  the  main  source  countries  for  firearms  smuggled  into  the  EU  are 
generally  situated  in  the  Western  Balkans".  SAFTE  stressed  the  importance  of  increasing 

12   Europol  reports: Threat  Assessment  Report  on  Illicit Trafficking  in  Firearms  (EDOC#673806v7A  of  June 
in  Europe” 

the  hands  of  Terrorist 

Intelligence  Notification 

(19/2014);  “Firearms 

in 

2013), 
(EDOC:#759937v3; May 2015). 

13   See relevant studies in section 4.1 

14   See footnote 12. 

15   doc. 16726/3/13 REV 3 RESTREINT UE/EU RESTRICTED 

16   Triggering Terror: Illicit Gun Markets and Firearms Acquisition of Terrorist Networks in Europe, ed. Nils 

Duquet, Flemish Peace institute, 17 April 2018; p.105 

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firearms checks in the EU neighbourhood area to strengthen EU internal security and prevent 
terrorism. 

To  compensate  for  the  absence  of  structured  law  enforcement  cooperation  against  firearms 
trafficking, the EU has for a long time been involved in various forms of technical support as 
part  of  the  Common  Foreign  &  Security  Policy  and  the  revised  European  Neighbourhood 
Policy.17  This  technical  support  has  aimed  at  blocking  trafficking  routes,  improving  the 
management  of  firearms  stocks,  and  preventing  the  diversion  of  firearms  from  the  legal 
market, especially in the Western Balkan region. 

The action plan tries to improve the situation before its adoption. Limited data were available 
at  the  start  of  that  action  plan’s  implementation  to  enable  an  analysis  of  the  evolutions. 
According to available figures for 2015, 2500 weapons were confiscated and 4800 destroyed 
throughout  the  Western  Balkans  in  2015.  In  terms  of  operational  cooperation,  in  2015,  75 
SIENA  messages  linked  to  the  Western  Balkans  were  exchanged  with  Europol,  which  is 
without proportion to the threat of firearms coming from the region identified by the agency. 
Only a negligible undetermined number of firearms were seized during the first joint targeted 
checks carried out in 2015. 

As mentioned above, on 5-6 November 2012, the ministers of the south-east  Europe region 
acknowledged  the  need  to  increase  efforts  to  counteract  the  illicit  firearms  trafficking.  This 
acknowledgment was reiterated on 19-20 December 2013, in Budva, Montenegro, where the 
ministers decided to set up a network of experts in firearms trafficking.  

Other  initiatives  were  also  taken  place,  which  are  referred  to  in  Section  5.5  Consistency. 
These  initiatives  included  the  2013  Commission  Communication  on  "Firearms  and  the 
internal  security  of  the  EU."18  This  Communication  stated,  "large  amounts  of  powerful 
military grade weapons have since the mid-1990s reached the EU from the Western Balkans". 
The Communication also referred to initial attempts to structure law enforcement cooperation 
before  the  establishment  of  the  EU  policy  cycle  and  of  the  Firearms  Platform.  It  said  that 
these  initial  attempts  sought  to  create  an  "overall  plan  for  coherent  operational  action" 
including  "police  control  operations  to  tackle  the  principal  sources  and  routes  of  illegal 
firearms, including the Western Balkans."  

In 2002, the risk of proliferation of weapons led the EU to begin providing its support to the 
Clearinghouse. This support has continued since 2002 and is given, under the joint mandate of 
the United Nations Development Programme (UNDP) and the Regional Cooperation Council. 
Funded  since  2002  by  the  European  Union,  it  has  been  working  to:  (i)  strengthen  the 
capacities of national and regional stakeholders; (ii) control and reduce the proliferation and 
misuse of small arms and light weapons; and (iii) facilitates coordination on small arms issues 
among  governments  and  other  stakeholders.  At  policy  level,  The  Clearinghouse  facilitates 
regional processes through meetings of small arms commissions and of the south-east Europe 
firearms  expert  network  (SEEFEN  –  hereafter  Western  Balkan  Experts),  involving 
representatives  of  police,  customs,  prosecutors  and  ballistics  experts.  In  addition,  a 
"Memorandum  for  cooperation  and  for  establishing  an  expert  group  for  measures  against 

17   Joint Report to the European  Parliament,  the  Council, the  European Economic and  Social Committee and 
the  Committee  of  the  Regions  on  Implementation  of  the  European  Neighbourhood  Policy  Review, 
JOIN/2017/018 final. 

18   COM(2013) 716 final. 

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illegal  trading  of  firearms  in  south-eastern  Europe  and  promotion  of  the  joint  cooperation" 
(SEEFEG)  was  signed  in  October  2015  in  North  Macedonia,  by  high  police  officials  from 
North Macedonia, Serbia, Bosnia and Herzegovina, Montenegro, Albania and Kosovo*. This 
group  was  embedded  as  a  subgroup  of  SEEFEN  and  it  was  composed  by  police 
representatives only. 

2.5.  Current policy and other developments 

Even though Europe has some of the toughest rules on firearms in the world, criminals always 
find new ways to circumvent the rules, which led to continued misuse of weapons, with direct 
and indirect impacts on the security of citizens. This had led the Commission to adopt in 2013 
a  Communication  on  Firearms19  and  the  European  Agenda  on  Security  on  28  April  201520. 
This integrated policy aimed at addressing this threat, through legislation, operational action, 
training and EU funding. This policy is built around four priorities: 

  Safeguarding the licit market for civilian firearms through new European Union (EU) 
standards  on  which  firearms  can  be  sold  for  civilian  use,  how  firearms  should  be 
marked, and how to licence persons who wish to possess and to use firearms. This led 
to  the  revision  of  the  Directive  N.  91/477/EEC  on  control  of  the  acquisition  and 
possession of weapons in 201721; 

  Reducing  diversion  of  firearms  into  criminal  hands  through  the  development  of 
effective  standards  on  safe  storage  of  civilian  firearms  and  on  how  to  deactivate 
civilian  and  military  firearms,  and  greater  efforts  to  reduce  illicit  trafficking  of 
firearms (whether civilian or military) from outside the EU22; 

  Increasing  pressure  on  criminal  markets  through  better  cross-border  cooperation 
between police, customs and border guards and by assessing the need for common EU 
rules on which offences  linked to  firearms should be criminalised and what  level  of 
criminal sanctions should be imposed by member states;23 

19   Communication on "Firearms and the internal security of the EU: protecting citizens and disrupting illegal 

trafficking", COM/2013/0716 of 21.10.2013. 

20   COM (2015) 185 final of  28.4.2015. 

21   Directive  (EU)  2017/853  of  17  May  2017  amending  Council  Directive  91/477/EEC  on  control  of  the 

acquisition and possession of weapons, OJ L 137, 24.5.2017, p. 22–39. 

The European Parliament had also considered the issue of firearms trafficking on a number of occasions. On 
11 February 2015, the European Parliament adopted a Resolution on anti-terrorism measures (EP reference 
no: 2015/2530(RSP) of 11 February 2015)  in which it called "…on the Commission to evaluate as a matter 
of urgency the existing EU rules on the movement of illegal firearms, explosive devices and arms trafficking 
linked to organised crime." 

22   During the informal European Council  meeting of 12 February 2015, the Heads of State and Government 
requested that all competent authorities increase the level of cooperation in the fight against illicit trafficking 
of  firearms,  including  through  the  swift  review  of  relevant  legislation,  and  a  renewed  dialogue  with  third 
countries on security issues, particularly in the Middle East and North Africa, and with the Western Balkans. 
(6112/15 Statement of the Members of the European Council). 

23    This  was  supported  in  2014,  by  the  Council  who  invited  member  states  to  enhance  the  exchange  of 
information  and  improve  the  tracing  of  lost,  stolen  and  in  particular  trafficked  and  smuggled  firearms,  by 

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  Building  better  intelligence  by  gathering  and  sharing  more  information  on  firearms 

crimes, and by targeted training of law enforcement officers.24 

Since 2015, the Commission has organised four joint meetings of firearms experts of the EU 
member  states  and  Western  Balkans  partners25  that  adopted  operational  conclusions  to 
implement the action plan. 

On 10 July 2018, Western Balkan partners subscribed to a Regional Roadmap (hereafter the 
Roadmap) for a sustainable solution to the illegal possession, misuse and trafficking of Small 
Arms  and  Light  Weapons  and  their  ammunition  in  the  Western  Balkans  by  2024.  This 
Roadmap was drafted and developed at the initiative of the French and German Ministries of 
Foreign  Affairs  in  the  context  of  the  "Berlin  Process",  an  intergovernmental  work  stream 
aimed at stepping up regional cooperation in the Western Balkans and aiding the integration 
of the region into the European Union with the involvement of selected EU member states.26 
This Roadmap essentially amounts to a needs assessment and a set of general objectives to be 
achieved by 2024, with the identification of 14 Key Performance Indicators. On 19 November 
2018,  the  Council  adopted  a  Decision27  endorsing  the  Roadmap  and  entrusting  the  South 
Eastern and Eastern Europe Clearinghouse for the Control of Small Arms and Light Weapons 
to support its implementation until December 2019. This action is funded under the Common 
Foreign and Security Policy (CFSP) budget. 

On  18  June  2018,  the  Commission  and  the  High  Representative  of  the  Union  for  Foreign 
Affairs  and  Security  Policy  adopted  a  Joint  Communication  on  Elements  towards  an  EU 
Strategy against illicit Firearms, Small Arms & Light Weapons and their Ammunition.28 The 

optimising  the  use  of  Interpol  databases  and  through  cooperation  with  Europol  and  its  Focal  Point  on 
Firearms. The Council also recommended that Interpol's Ballistic Information Network (IBIN) be adapted to 
support this objective. (Council Document 5195/7/14 REV7 Firearms and the internal security). 

Finally, on 8 October 2015, the Council adopted conclusions on strengthening the use of means of fighting 
trafficking of firearms, inviting the member states, the European Commission, Europol and Interpol to take 
measures  including  revising  the  current  legislation,  and  monitoring  the  threats  posed  by  firearms  through 
coordinated cross-border investigations and operations. This also covers the trafficking of firearms online. 
(12892/15 Council conclusions). 

24   At  the  Riga  Council  meeting  of  29-30  January  2015,  Europol  was  specifically  requested  to  provide  a 
suitable information-exchange mechanism and data-matching environment to streamline current procedures, 
avoiding duplications. (5855/15 Riga Joint Statement). 

At the Justice and Home Affairs Council meeting of 12-13 March 2015, Ministers invited the Commission 
to  propose  ways  to  combat  the  illicit  trafficking  of  firearms  and,  together  with  Europol,  to  enhance 
information exchange and operational cooperation. (178/15 Press release of the JHA Council). 

25   26 January 2016, 30 November 2016, 26 January 2018 and 24 September 2018. 

26   Austria, Croatia, France, Germany, Italy, Poland, Slovenia and the United Kingdom. 

27   Council  Decision  (CFSP)  2018/1788  of  19  November  2018  in  support  of  the  South-Eastern  and  Eastern 
Europe Clearinghouse for the Control of Small Arms and Light Weapons (SEESAC) for the implementation 
of  the  Regional  Roadmap  on  combating  illicit  arms  trafficking  in  the  Western  Balkans,  OJ  L  293, 
20.11.2018, p. 11–23. 

28   JOIN(2018) 17 final. 

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Council adopted this Strategy on 19 November 2018.29 According to it, the EU continues to 
support the Clearinghouse "to maintain cooperation with relevant regional organisations in the 
field  of  Small  Arms  control  and  take  into  account  regional  initiatives  such  as  the  Roadmap 
addressing illicit Small Arms in the Western Balkans."  

3.  STATE OF PLAY 

Stakeholders have always expressed their commitment to implement the different goals of the 
action plan. Nevertheless, on a number of occasions, political commitments were not always 
translated in operational  actions. Certain challenges of information, involvement of Western 
Balkan partners in the EU policy cycle and the development of national focal points had to be 
stressed repeatedly during joint meetings before they could be addressed. However, most of 
the activities announced in the action plan (see Section 2.1) were implemented during these 
years. 

Goal 1 - related to the modernisation of the law enforcement agencies.  

Under Action 1, countries of the region worked to set up national firearms focal points. The 
Clearinghouse has provided assistance using the financial and political support  channeled to 
the  region  through  the  EU.30  The  Clearinghouse  provided  targeted  equipment,  training  and 
advice. In parallel, the EU adopted best practice guidance for the creation of national firearms 
focal  points.31  As  of  31  December  2018,  4  focal  points  were  established  in  the  Western 
Balkans (the focal point in Kosovo* was fully operational, and the focal points in Albania, the 
Republic of North Macedonia, Serbia had been set up but were not yet operational). 

Under Action 2, the Clearinghouse developed a regional small arms survey methodology for a 
survey. The aim of this was to promote: (i) capacity building of law enforcement agencies, (ii) 
and  better  data  flow  for  coordinated  assessment.  The  methodology  sought  to  ensure  that 
consistent and harmonised data that were disaggregated by gender and age would be provided 
on possession (legal and illegal), legal distribution, stockpiles and surplus reduction, exports 
and  on  the  impact  of  firearms  misuse.  All  six  Western  Balkan  partners  covered  by  this 
evaluation already provided input to the survey and they are now using this methodology for 
the  threat  assessment.  In  the  meantime,  the  United  Nations  Office  on  Drugs  and  Crime 
(UNODC)  started  tan  EU  financed  project  for  collection  of  data  on  firearms  seizures 
involving Western Balkans partners. 

Under Action 3, the Clearinghouse developed a feasibility study on linking small arms & light 
weapons registration systems in south-east Europe. The study sought to improve the strategic 
and operational analysis of information of legal firearms and prevent diversion.  

Goal 2 – related to enhancing mutual trust 

29   Council Document 13581/1. 

30   Council Decision (CFSP) 2016/2356 of 19 December 2016 in support of SEESAC disarmament and arms 
control activities in South-East Europe in the framework of the EU Strategy to combat illicit accumulation 
and trafficking of SALW and their ammunition, OJ L 348, 21.12.2016, p. 60–71. 

31   15 May 2018, Council Document N. 8586/18. 

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Under  Action  1,  the  Commission  organised  four  meetings  of  the  Joint  Committee.  Twice  a 
year the Clearinghouse has organised regional meetings for strategic and policy level decision 
makers  (regional  meetings  of  the  small  arms  commissions)  and  meetings  of  tactical-
operational level representatives of Western Balkan law enforcement and judiciary authorities 
(SEFEN). The meetings was an opportunity for the Commission to introduce and explain the 
EU legislative framework on the control of acquisition, possession, transfers, exports, imports 
and  transit  authorizations  for  firearms,  and  for  EU  member  states  to  explain  how  those 
provisions were transposed into national legislation.  

In  the  conclusions  of  these  meetings,  EU  and  Western  Balkan  partners  said  that  it  was 
important to more systematically exchange information, carry out dedicated checks and make 
full  use  of  available  tools  for  tracing  firearms,  such  as  iTRACE,  iARMS  and  the  Europol's 
databases. Intelligence sharing between EU and Western Balkans remains an issue, as well as 
the implementation of more effective investigative and intelligence standards. Penal policy in 
the  Western  Balkans  should  be  strengthened  and  better  enforced.  Works  must  be  done  to 
improve  stockpile  management  and  prevent  theft.  Finally,  the  collection  of  statistics  on  the 
illicit  production,  and  trafficking  of  firearms  remains  a  challenge.  Representatives  of  the 
European Commission, the European Firearms Expert Group, the Firearms Platform, Europol, 
and  the  European  Border  and  Coast  Guard  Agency  (the  EBCGA)  are  regularly  invited. 
Similarly,  Western  Balkan  experts  are  now  invited  to  the  annual  meeting  of  European 
Firearms  Experts  Group;  and  all  Western  Balkan  Partners  have  been  invited  as  full 
participants in all Firearms Platform Activities. The participation of Western Balkan partners 
in these meetings is fully funded from the budget of the Firearms Platform. 

Under Action 2, the core of operational  cooperation was carried out  as  part of the Firearms 
Platform. The action leaders were Sweden in 2015 and 2016, the UK in 2017 and Spain since 
2018.  Joint  coordinated  checks  operations  were  organized  every  year,  mostly  at  selected 
border crossing points (checks on international coaches) and registered firearms dealers (see 
annex 4 for more details). These checks were heavily supported by Europol's Analysis Project 
"Weapons and Explosives", and in particular by Europol’s team of analysts, its joint operation 
centre  and  its  Europol  mobile  office.  The  European  Border  and  Coast  Guard  Agency 
(EBCGA)  also  provided  substantial  support  to  strengthen  border  checks  in  and  around  the 
region, since firearms trafficking falls under the definition of "cross-border crime" for which 
it  is  responsible.  The  EBCGA  has  notably  identified  the  Western  Balkans  as  an  important 
operational area. It notably supported the coordinated data collection on firearms trafficking 
(linked to Action 2) by working together with the Western Balkan Risk Analysis Network set 
up  by  the  Agency  to  elaborate  a  booklet  containing  a  set  of  common  risk  indicators.  To 
facilitate its use, the booklet was translated into three regional and local languages. 

Exchanges  of  information  were  enabled  by  the  signature  of  operational  cooperation 
agreements between Europol and Serbia, Albania, Bosnia and Herzegovina, North Macedonia 
and  Montenegro.  These  agreements  provide  the  opportunity  to  exchange  information  and 
intelligence  and  to  cooperate  on  operation.  For  example,  this  cooperation  could  take  place 
within joint investigation team with third countries outside the EU.  

Goal 3 – related to capacity building 

The  Clearinghouse  developed  specialised  training  course  modules  for  operational  analysts, 
criminal  investigators,  criminal  intelligence  analysts,  and  forensic  investigators.  It  assisted 
government  institutions  in  coordinating  the  small  arms  control  activities,  promoting  EU 
standards  in  small  arms  control.  The  Clearinghouse  also  assisted  government  institutions  in 

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the  implementation  of  the  national  strategic  master  plans  and  action  plans  covering  illicit 
trafficking in firearms and ammunition. It also assisted Western Balkan partners to adapt their 
national legal framework and bring it into line with EU and international standards. The EU 
Agency  for  law  enforcement  training  -  CEPOL  developed  working  arrangements  with  all 
Western Balkan countries, except North Macedonia, for which negotiations are ongoing. The 
Agency  organised  residential  activities,  webinars,  online  modules  and  an  exchange 
programme.  Training  and  legal  assistance  was  also  provided  by  the  EU  "Partner  to  Partner 
Export Control Programme" for arms managed by the German Federal Office for Economic 
Affairs  and  Export  Control  BAFA.  This  training  and  legal  assistance  was  funded  from  the 
Common  Foreign  and  Security  Policy  budget.32  Consulted  stakeholders  recognised  that  all 
these  activities  contributed  in  a  general  movement  of  legislative  upgrades  throughout  the 
region. 

Work  has  continued  on  voluntary  surrenders  of  unregistered  weapons  owned  by  civilian 
across  the  region.  The  goal  of  this  work  is  to  reduce  the  number  of  illicit  firearms  by 
encouraging firearms owners to return their weapons without fear of prosecution. Surrendered 
weapons  are  either  legalised  and  duly  registered,  subject  to  authorisation,  destroyed,  or 
returned to police or army stockpiles. In 2016, the Commission funded a study on  voluntary 
surrender/legalisation  of  firearms  programmes  throughout  the  Western  Balkans.33  Several 
voluntary  surrenders  campaigns  have  taken  place  since  2015  (Serbia  from  March  to  June 
2015, Montenegro from June 2015 to June 2016, Albania from the end 2016 to March 2017, 
and in Kosovo* from December 2018 to June 2019; the results of these campaigns were not 
made public). Nevertheless, stockpiles of weapons remain significant.  

Finally, EU member states and Western Balkan  partners continued to  develop  their existing 
bilateral  cooperation,  notably  through  the  network  of  security  liaison  officers  in  embassies. 
Although this bilateral cooperation is not part of the implementation of the action plan, it is 
worth  mentioning  because  it  will  inform  relationship  between  the  action  plan  and  other 
initiatives.  Sweden,  for  instance,  signed  strategic  bilateral  cooperation  agreements  on  joint 
combating of cross-border criminality notably with Kosovo* and Bosnia and Herzegovina. In 
September  2016,  France  and  Serbia  signed  a  protocol  creating  a  permanent  Serbian-French 
criminal intelligence unit to combat international trafficking of arms and explosives. Germany 
provided  substantive  support  by  giving  technical  equipment,  legal  training  and  capacity 
building  to  Bosnia  and  Herzegovina  in  the  project  "Countering  Illicit  Arms  Trafficking  in 
Bosnia  and  Herzegovina"  (implemented  by  the  Clearinghouse).  The  UK  set  up  a  regional 
"Western  Balkans  firearms  capacity  building  programme"  which  involved  the  British 
National Ballistic Intelligence Service. 

METHODOLOGY 

Sources and methods used 

This evaluation relies primarily on an extensive consultation of member states’ enforcement 
authorities,  Western  Balkan  partners,  EU  agencies,  and  the  international  organisations 

32   Most recent decision: Council Decision (CFSP) 2018/101 of 22 January 2018 on the promotion of effective 

arms export controls, OJ L 17, 23.1.2018, p. 40–47. 

33   Firearms buyback in the Western Balkans,  Terry Pattar, Shaun Romeril, Chris Jagger, 3 November 2016, 

IHS Consulting. 

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involved on the ground. The Commission, due to its easy access to restricted information and 
its participation in all expert meetings, carried it out.  

The evaluation takes into account the content and outcome of all the meetings that have taken 
place  with  these  stakeholders  between  2015  and  late  2018.  These  meetings  include  joint 
meetings of EU and Western Balkans firearms experts, the meetings of the Western Balkan 
Experts,  the  meetings  of  the  European  Firearms  Experts  Group  (EU  Experts),  the  Firearms 
Platform  meetings  (including  the  debriefing  meetings  following  joint  actions  days),  and  the 
meetings of Small arms and Light Weapons commissions in the Western Balkans.  

The  desk  research  relied  on  several  types  of  sources.  First,  the  Commission  took  into 
consideration a number of external studies conducted by independent organisations.34 Second, 
it used all the data included in the presentations made by national authorities at each meeting 
of  firearms  experts  mentioned  above  (the  Firearms  Platform,  Western  Balkan  Experts,  EU 
Experts,  Small Arms  commissions). Documents produced by the Clearinghouse also  proved 
particularly  valuable.  On  operational  cooperation,  a  major  source  of  information  was  the 
debriefing of joint coordinated targeted controls  35 and the reports of the action leaders. The 
meeting documents and presentations made during meetings of the Western Balkan Experts36 
also contributed greatly to building a comprehensive picture of the achievements of countries 
and stakeholders. However, due to a lack of organised steering in the implementation of the 
plan, available information remains patchy. 

The Commission relied heavily on the continuous feedback from law enforcement authorities 
themselves, who made presentations and adopted conclusions during the meetings of the Joint 
Committee (see Annex 7 for the detail of the conclusions of each meeting). 

The Commission also took as a valuable source of information the needs assessment for the 
region, and the analysis of current challenges developed during the preparation of the regional 
roadmap for a sustainable solution  to  the illegal  possession, misuse and trafficking of small 
arms  and  light  weapons.  The  elaboration  of  the  Roadmap37  was  carried  out  between  1st 
February 2018 and 29 May 2018 at the initiative of the ministries of Foreign Affairs of France 
and Germany, coordinated by the Clearinghouse and to which the Commission, the Firearms 
Platform,  the  EBCGA  and  Europol  were  closely  associated.  For  each  of  its  Goals,  the 
Roadmap  includes  a  short  description  of  the  baseline  in  May-June  2018,  which  effectively 
describes the current situation; i.e. the needs analysis.  

34   Firearms buyback in the Western Balkans,  Terry Pattar, Shaun Romeril, Chris Jagger, 3 November 2016, 
IHS  Consulting;  Life-cycle  Management  of  Ammunition  –  Lessons  from  Bosnia  and  Herzgovina,  Jovana 
Carapic  and  Paul  Holtom,  March  2018,  Briefing  Paper;  Triggering  Terror:  Illicit  Gun  Markets  and 
Firearms  Acquisition  of  Terrorist  Networks  in  Europe,  ed.  Nils  Duquet,  Flemish  Peace  institute,  17  April 
2018; SEPCA Region Threat Assessment, Europol, 12 April 2018, EDOC#958451; Strengthening Resilience 
in the Western Balkans: Mapping Assistance for SALW Control, Small Arms Survey, September 2018. 

35   22-23 March 2017, 19 March 2018 

36   23-24 September 2014, 19-20 May 2015, 26-27 November 2015, 18-20 April 2016, 27-28 September 2016, 
8-9 December 2016, 18-19 May 2017, 23-24 November 2017, 30 May - 1 June 2018, 20-21 November 2018 

37   The  Goals  of  the  Roadmap  are:  harmonization  of  national  legislation  with  EU  law,  evidence-  and 
intelligence-based enforcement, awareness-raising, decrease in the numbers of illicit weapons and of army 
stockpiles, reduction of the risk of diversion. 

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This  exercise  complemented  the  information  gathered  through  a  targeted  consultation  of 
stakeholders.  This  consultation  took  the  form  of  a  questionnaire.  On  26  January  2018,  the 
Joint Committee between European Union Firearms Experts and South East Europe Partners 
Experts had requested that the Commission  circulate a questionnaire to  all  EU and Western 
Balkan  competent  administrations  to  collect  information  about  the  initiatives  carried  out  by 
the countries according to the action plan, the Firearms Platform activities and the conclusions 
of all relevant meetings. On that basis, the questionnaire was sent to members of the European 
Firearms Experts (EFE) Group, of the South East Europe Firearms Expert Group (SEEFEG), 
to European Agencies and other stakeholders (such as the Clearinghouse) on 27 July 2018.  

No  specific  public  consultation  took  place,  since  the  action  plan  was  addressed  to  public 
authorities  only,  and  all  information  on  the  actions  implemented  under  the  action  plan 
(trainings,  coordination  meetings,  exchange  of  information  between  law  enforcement 
agencies, investigations  etc.)  was  available only  to  the specific stakeholders involved in  the 
implementation  of  the  action  plan,  and  to  which  the  general  public  does  not  have  access. 
Therefore,  a  public  consultation  would  not  have  provided  any  additional  data  for  the 
evaluation of the action plan compared to the targeted consultation. 

Limitations and robustness of findings 

The Commission relied mostly on qualitative reporting. This qualitative reporting was made 
more necessary because of the absence of a defined intervention logic at the time of adoption 
led  to  a  lack  of  performance  indicators  and  of  a  scoreboard  in  the  action  plan.  This  was 
reinforced by an uneven detail of reporting. The analysis was also hampered by a lack of data 
at  the  EU  level  and  limitations  in  the  comparability  of  information.  First,  the  absence  of  a 
clear baseline, with reliable data, made it difficult to compare any evolution. Second, access 
by  the  Commission  to  operational  information,  including  for  operations  where  Europol  was 
involved,  was  limited.  Sometimes,  the  Commission  also  received  contradicting  data  from 
different sources which made it difficult to evaluate the involvement of countries. Statistics on 
seizures,  voluntary  surrenders  and  destructions  or  weapons  are  not  sufficiently  detailed  to 
allow  a  trend  analysis  and  a  comparison  between  jurisdictions.  Even  data  collected  during 
joint  coordinated  targeted  checks  over  the  years  were  often  too  dissimilar  from  one  year  to 
another  to  enable  comparison,  even  though  all  such  checks  were  coordinated  within  the 
Firearms Platform and with the involvement of Europol. This has made it difficult to gather a 
comprehensive picture during the research.  

The  assessment  made  by  stakeholders  consulted  in  the  targeted  questionnaire  sometimes 
refers to the overall European framework for cooperation against firearms trafficking and was 
not  always  limited  to  cooperation  in  and  with  Western  Balkan  partners.  Responses  to  the 
questionnaire sent were of varying quality and length, which sometimes made it necessary to 
interpret  replies  or  infer  answers  to  ensure  comparability  between  them.  Details  on  the 
limitations can be found in Annex 3. 

The  assessment  of  the  various  firearms-related  workshops  financed  by  the  Technical 
Assistance and Information Exchange (TAIEX) instrument of the European Commission was 
made  impossible.  This  was  because  applicants  were  not  required  to  submit  reports  on  the 
workshops  until  2018.  It  also  proved  a  challenge  to  evaluate  changes  in  the  funding  of  the 
Firearms  Platform  for  activities  in  or  with  the  Western  Balkans  over  the  years  (for  joint 
coordinated targeted checks, other operational meetings, equipment and informants), since the 
management team does not have this information for the years 2015 to 2017. 

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Taking into account all the limitations, the evidence was based on testimonies and qualitative 
assessments rather than figures.  However, when available, figures did confirm the opinions 
of stakeholders. Besides, the convergence of these contributions guarantees the reliability of 
the conclusions and replies to evaluation questions. 

ANALYSIS AND ANSWERS TO THE EVALUATION QUESTIONS 

Relevance 

To assess the relevance of the action plan, the evaluation examined whether the action plan 
was  adapted  to  the  past  and  current  security  needs,  in  terms  of  geographical  scope  and 
content.  The  evaluation  also  examined  whether  it  is  still  adapted  to  current  security 
considerations.  

As regards the geographical coverage, although the action plan formally concerns south-east 
Europe, cooperation has in practice been focusing on the Western Balkans. 

Firearms trafficked to, in and from the Western Balkan were considered a threat for the whole 
continent at the inception of the action plan, as explained in section 2.4. The threat remains 
acute.  This  is  confirmed  by  law-enforcement  agencies.  It  is  also  demonstrated  by  regular 
terrorist  or  criminal  attacks,  and  by  seizures  in  which  firearms  (converted  or  not)  can  be 
tracked down to this region. The ongoing threat  was confirmed by several studies, the most 
recent  of  which  38  stresses  that  weapons  used  in  recent  terrorist  attacks  "were  acquired 
through  local  illicit  firearm  markets  and  were  found  to  originate  from  the  Balkans".  This 
study also said that "the Balkans were identified as the main supplier of firearms in Europe" 
and  spoke  of  "the  link  between  the  Balkans  and  small  arms  used  in  EU  member  states  in 
various types of criminal activity." In addition the study said that, "the comparison of ballistic 
information from Swedish and Serbian police investigation showed that the firearms found in 
Sweden  were  used  first  in  Serbia  before  being  smuggled  into  Sweden  to  commit  other 
crimes."  

Representatives from law enforcement authorities in the EU and Western Balkans point to a 
decrease in the number of illicit firearms owned in the Western Balkans. However, new trends 
are  also  emerging  in  the  region.  These  new  trends  include  changes  in  the  conversion 
techniques  for  turning  blank-firing  or  gas  and  alarm  weapons  into  firearms,  concealment 
methods,  and distribution patterns which have resulted in  a shift  from exports of traditional 
conflict weapons to imports of new weapons. 

The Western Balkans region appears to be the most relevant for fighting firearms trafficking 
in  the  medium  term  and  for  the  continent's  stability  as  a  whole.  It  also  has  a  European 
perspective,  recognised  most  recently  by  the  Commission  Communication  of  6  February 
2018,39 which encouraged approximation of national laws with EU standards. Besides, due to 
their shared history and common culture, strong links remain between the partners, which also 
facilitated cooperation.  

However,  according  to  several  stakeholders’  reports  during  meetings,  the  Western  Balkan 
source of illicit weapons is starting to decrease in importance thanks to the combined efforts 

38   Strengthening Resilience in the Western Balkans, op.cit. 

39   COM(2018)65. 

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of law enforcement authorities. Therefore, Ukraine or Moldova, where control of firearms is 
not  as  rigorous  as  in  the  EU  or  in  the  Western  Balkans,  is  likely  to  become  a  new  area  of 
interest.  Therefore,  cooperation  with  Belarus,  the  Republic  of  Moldova  and  Ukraine  needs 
developing, and expansion of the activities of  the Clearinghouse point in this direction. The 
Firearms  Platform  is  also  reflecting  on  the  expansion  of  the  current  Operational  Action 
"cooperation with the Western Balkan" to those two countries. 

In  the  consultation,  stakeholders  confirmed  this  overall  assessment,  and  considered  that  an 
action  plan  is  needed,  but  said  that  the  current  action  plan  was  not  fully  adapted  to  current 
security  challenges  and  emerging  threats  and  trends.  This  was  also  confirmed  by  the  needs 
assessment  and  the  discussion  taking  place  between  all  players  under  the  adoption  of  the 
regional roadmap.  

Chart 1.  Relevance of the action plan for current needs40 

The  perception  of  the  relevance  of  the  action  plan  was  substantially  different  between 
Western  Balkan  partners  and  the  EU  member  states.  The  first  are  generally  more  positive 
about  it  than  EU  member  states,  many  of  which  seem  often  not  concerned  by  EU-Western 
Balkans  co-operation:  a  large  number  of  EU  member  states  either  did  not  reply  to  the 
questionnaires (10 countries) or did not reply to specific questions, while all Western Balkans 
returned the questionnaire. This indicates the fact that not all EU member states are equally 
affected by firearms trafficking from or to the Western Balkans (e.g. Cyprus, Latvia, Ireland, 
Malta and Portugal). It may also reflect the fact that a lack of staff may have prevented some 
EU  member  states  from  engaging  further  in  operational  cooperation  at  a  multilateral  level 
(e.g. Austria, Germany, Greece and France). 

To assess  whether the action plan is  still relevant  and adapted to  current  security  risks,  it is 
necessary  to  compare  initial  needs  and  current  needs.  As  mentioned  in  Section  2.1,  the 
starting  point  that  led  to  the  adoption  of  the  action  plan  was  the  need  to:  (i)  improve  the 
exchange of criminal information and intelligence; (ii)improve operational co-operation;  (iii) 
improve the collection and exchange of statistics concerning the production, stockpiling and 
trafficking  of  firearms  and  ammunition;  (iv)  promote  networking  ,  the  exchange  of  best 
practices  and  training  and  (v)  bring  national  legislation  on  firearms  closer  to  EU  and 
international standards.  

These  overarching  needs  have  not  changed.  As  will  be  discussed  in  the  following  sections, 
there is still room for improvement in operational cooperation, exchange of information, data 
collection,  training  and  approximation  of  legislation.  This  is  confirmed  by  the  work,  which 

40   Responses to the questionnaire sent to law enforcement Agencies in June 2018. 

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led to the adoption of the roadmap, by the answers received during the targeted stakeholder 
consultation and by the conclusions of the joint meetings of EU and Western Balkans firearms 
experts.  

However, the evaluation also pointed at gaps in the current action plan. 

The action plan focused on structures, law enforcement cooperation and technical assistance 
and  training.  However,  it  neglected  aspects  such  as  the  strengthening  of  criminal  sanctions, 
criminal  procedures  and  criminal  policy.  These  three  issues  appeared  to  be  significant: 
according to law enforcement officials, available figures on convictions, criminal sanctions in 
the  Western  Balkans  often  do  not  adequately  address  trafficking  of  firearms  as  a  separate 
crime. Trafficking in firearms is rarely prosecuted. Similarly, the action plan did not focus on 
awareness-raising activities regarding stockpile management, surplus reduction or the gender 
perspective (such as the underrepresentation of women, awareness of gender-based violence 
etc.). 

Key findings 

  The action plan focused the main issues of the fight against firearms trafficking by 
considering  common  administrative  structures,  agreed  way  of  working  and 
common training needs;  

  The  action  plan  promoted  the  collection  of  data  for  threat  assessment  in  a 

coordinated way and identified common threats. 
It promoted joint coordinated targeted controls supported by EU Agencies.  

 
  The action plan gave insufficient attention to criminal policy, the reinforcement of 

 

criminal sanctions and criminal procedures. 
 The  action  plan  does  not  address  new  emerging  threats  and  trends  of  firearms 
trafficking.  

  The  action  plan  does  not  sufficiently  tackle  future  possible  threat  linked  to 

trafficking to or from Ukraine and Moldova. 

  Not  all  EU  member  states  feel  the  need  to  increase  multilateral  cooperation  with 

the Western Balkans, due to more pressing priorities or lack of staff. 

  The action plan does  not  sufficiently take into consideration the issue of criminal 
sanctions  and  policies,  and  of  stockpile  management  and  destruction  of  surplus 
arms and ammunition. 

EU Added value and sustainability 

To assess the EU added value of the action plan, the evaluation examined whether the actions 
envisaged  under  the  action  plan  were  better  achieved  than  through  bilateral  cooperation  or 
intergovernmental initiatives. It also examined whether the results were sustainable. Finally, it 
considered  whether  the  termination  of  the  action  plan  would  have  negative  impacts  on  the 
objectives pursued. 

The quantitative analysis of the EU added value could not be carried out. As explained later 
(Section  5.4),  the  composition  of  potential  indicators  such  as  firearms  seizures,  number  of 
voluntary surrenders of weapons, size of stockpiles, etc., still vary across the region and over 
time.  Statistics  are  either  not  systematically  available  or  still  insufficiently  harmonised, 
especially in countries that still rely on paper archives rather than centralised analytical tools. 
For instance, central firearms registers are being developed, but the backlog of data will take 

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several years to process. In addition, registers of firearms traders are not yet computerised and 
interconnected with centralised registers. There is a similar lack of harmonisation in national 
infringement  databases,  where  firearms  seized  and  the  context  of  the  seizure  (both  in  the 
Western Balkans and in the EU) are still not systematically centrally registered. Instead, this 
information  often  remains  in  the  local  police  station  or  on  individual  files.  Therefore,  no 
direct  causal  link  can  be  drawn  between  the  activities  mentioned  in  the  action  plan  and  the 
trends in firearms trafficking, which are influenced by a variety of other factors. 

The analysis therefore relies on the qualitative assessment made by stakeholders themselves, 
and on perception of the evolution of the trends, with respect to the various needs identified at 
the time of inception of the action plan. 

With  these  limitations, it  appears  that  the  action  plan  provided  a  global  framework  for  EU-
Western  Balkan  cooperation  to  address  the  challenge  of  firearms  trafficking.  Without  the 
action plan, there would not have been any such a framework cooperation. The vast majority 
of stakeholders involved in the consultation recognised the added value of this action plan, in 
particular  because  it  created  a  forum  for  law  enforcement  agencies  to  meet,  develop 
connections and improve cooperation. To some extent, EU involvement was instrumental in 
providing  a  forum  for dialogue and cooperation  between law enforcement  authorities of the 
Western Balkans. This in itself can be considered a major achievement in a region where the 
scars of the wars remain visible and political tensions remain significant. 

Chart 2.  Main areas of added value of the action plan41 

Without  the  action  plan,  individual  member  states  would  have  continued  carrying  out  un 
coordinated  bilateral  activities  for  operational  cooperation  with  Western  Balkan  partners. 
Although such activities did take place despite the Action plan, it provided an overall strategic 
framework  and  a  forum  for  dialogue  and  multilateral  cooperation.  Similarly,  individual 
international organisations, possibly financed by the European Union, would have carried out 
their  own  activities.  Besides,  there  would  not  have  been  a  strong  incentive  to  establish 
firearms national focal points, to bring national laws closer to EU legislation and standards or 
participate in EU-provided trainings. 

On operational cooperation, the organisation of joint coordinated checks operations42 has been 
mostly  praised  by  stakeholders  for  its  ability  to  identify  bottlenecks  facilitate  dialogue,  test 
processes of information sharing. Outside of the action plan, these would have been a one-off 

41   Ibid. 

42   Joint  control  operations  can  take  place  outside  of  a  specific  investigation  (coordinated  checks  at  border 
crossing  points,  for  instance).  They  are  multilateral  (notably  Joint  Action  Days  under  the  Firearms 
Platform),  while  joint  investigations  often  involves  a  limited  number  of  countries  linked  to  a  specific 
organised crime group. 

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process, not linked to the establishment of national structures and the implementation of EU 
law in the Western Balkans. Most Western Balkans partners recognized Europol’s support for 
the  operational  cooperation  through  the  involvement  of  its  operation  centre  and  its  24/7 
intelligence  reporting,  which  could  not  have  been  provided  without  Europol’s  involvement. 
Half  of  Western  Balkan  partners  however  criticised  the  Agency  for  not  providing  timely 
feedback  and  useful  intelligence  and  analysis,  because  a  very  few  intelligence  cases  were 
related to the Western Balkans (5.4% in 2017, 7.6% in 2018).43 This could be addressed if the 
Analysis  Project  Weapons  and  Explosives  received  regular  information  directly  through 
SIENA both on actual seizures and on follow-up investigations.  

The  contribution  of  other  structures  was  more  limited.  In  particular,  no  joint  investigation 
team  on  firearms  trafficking  was  organised  by  Eurojust  in  the  Western  Balkans.  Besides, 
unlike  the  joint  coordinated  targeted  checks  or  individual  police  operations  (to  which  the 
EBCGA participated as well), there was no broad appliance of the Eurosur44 Fusion Services 
and  not  many  successful  stories  with  major  seizures  of  firearms,  due  to  a  lack  of  border 
detections. 

The meetings (both  the  Joint  Committee and other meetings  such as  of the Western  Balkan 
Experts, the EU Experts and the Firearms Platform) were a great step towards building trust, 
confidence  and  greater  understanding  of  the  opportunities  and  obstacles  for  the  closer 
cooperation between the EU and the Western Balkans. Meeting of the Western Balkan experts 
helped  the  establishment  of  national  focal  points  in  the  Western  Balkans.  Since  2018,  all 
Western Balkan countries have been invited to be full participants in the Firearms Platform. 
For the Firearms Platform2019 operational action plan 5 Western Balkan countries45 already 
signed up  to participate in 16 out of the 19 operational actions. 

The approaches to training varied between EU member states and Western Balkan countries. 
Only  30%  of  member  states,  promoted  joint  training  courses  compared  to  67%  of  Western 
Balkan partners. Western Balkan partners therefore seem to have a higher awareness of and 
need for firearms-related capacity building. 

On the sustainability of the outcomes achieved under the action plan, it is unclear whether its 
termination would have a negative impact. The answer to this question very much depends on 
whether and how the action plan will continue in future (is considered as a static or as a living 
document). 

Its  mere  extension,  without  taking  into  account  the  new  realities  and  needs  identified  in 
Section 5.1, would probably not have any discernible effect. The main current challenges and 
needs  have  now  been  properly  identified  in  the  regional  roadmap;  and  Western  Balkan 
partners are now fully involved in all relevant activities of the Firearms Platform. These can 
continue to be rolled-out, as they have started to, outside of the strict implementation of the 
action plan. Its mere extension would simply enable the continuation of the current situation. 

However, the action plan has been a dynamic document, in the sense that it provided general 
objectives and targets, but also enabled the Joint Committee between EU firearms experts and 

43   Source: Europol. 

44   European Border Surveillance System. 

45   Albania, Bosnia and Herzegovina, North Macedonia, Montenegro and Serbia. 

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south-east Europe partners experts to build on it and set out specific objectives and activities 
to  implement  it.  The  simple  non-renewal  of  the  action  plan  and  the  absence  of  a  fully 
modernised  action  plan  would  put  to  a  halt  the  synergies  and  coordination  that  have 
developed so far. This would also fail to address the main weaknesses of overall governance 
at regional level, as identified later in this document. If the action plan was not renewed the 
EU  would  mainly  be  considered  as  a  donor,  with  no  contribution  to  ensuring  proper 
consideration  of  common  challenges  or  steering  of  overall  strategy.  Moreover,  if  the  action 
plan was not renewed, individual member states and organisations would turn to the EU only 
for  financial  support,  but  would  revert  back  to  separate  and  most  likely  overlapping 
initiatives. 

Key findings  

  The  Action  plan  provided  an  overall  framework  for  cooperation  by  ensuring  a 
forum  for  law  enforcement  agencies  to  meet,  develop  connections  and  improve 
cooperation. 

  Peer review and encouragement to set up National Focal Points and to receive joint 

training courses. 

  Full  involvement,  on  an  equal  footing,  with  EU  member  states  in  EMPACT 

Firearms. 

  Modest  involvement  of  EU  Agencies  (Europol,  Eurojust  and  EBCGA)  to  the 

activities of the action plan.   

  Unsatisfactory  exchanges  of  information  between  Europol  and  Western  Balkan 

partners. 

  Low  added  value  of  other  available  tools,  either  underused  (Joint  Investigation 
Teams),  or  with  low  operational  results  (Eurosur  Fusion  services  and  EBCGA 
activities). 

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Effectiveness 

Assessing  the  progress  made  towards  achieving  the  objectives  of  the  action  plan  proved  a 
challenge in the course of this evaluation. This was notably the case for two reasons. First, the 
action plan did not set key performance indicators against which to evaluate progress towards 
achieving  its  objectives.  Second,  the  action  plan  was  developed  in  a  context  where  several 
other  initiatives  (national,  regional,  European  and  international)  took  place  in  parallel,  and 
where the overall impact on the reduction of firearms trafficking would have been too indirect 
or  hypothetical  to  draw  any  conclusion.  Nevertheless,  it  is  impossible  to  draw  initial 
conclusions  based  on  the  patchy  quantitative  information  available  and  on  the  qualitative 
contributions made by stakeholders during the evaluation and over the duration of the action 
plan's implementation.  

Consulted  stakeholders  expressed  mixed  feelings  about  the  effectiveness  of  the  action  plan. 
Activities related to the modernisation of law enforcement agencies (Goal 1) were generally 
considered more effective than those related to mutual trust and actual cooperation (Goal 2). 

Such  a  mixed  feeling  was  also  expressed  for  activities  on  enhancing  training  and  capacity 
building (Goal 3). 

Chart 3.  Effectiveness of Actions under Goal 146 

Under  Goal  1,  harmonised  data  collection  on  firearms  seizures  remains  one  the  main 
stumbling blocks both in the EU and in the Western Balkans. Only 16 EU member states and 
four Western Balkan partners stated that they participated in the UNODC's Global Firearms 
Study  and  this  limited  the  effectiveness  of  this  study.  The  reason  for  this  low  level  of 
participation  is  that  only  one  of  the  four  focal  points  in  the  Western  Balkans  is  fully 
operational.  Similarly,  in  the  EU,  only  a  few  focal  points  have  sufficient  access  to  the 
information  required  to  provide  the  data  required.  A  template  with  minimum  standard 
intelligence  requirements  was  not  developed,  because  different  players  disagreed  over  what 
include  on  the  template.  Enforcement  agencies  often  considered  that  this  limited  the 
usefulness  of  the  information  exchanged.  Finally,  while  all  countries  of  the  region  are 
connected  to  Interpol's  iARMS  database,  which  lists  seized,  stolen  and  lost  weapons, 
consulted  stakeholders  did  not  confirm  whether  this  database  is  systematically  populated. 
Cases of seizures and joint operations presented very rarely provided information on tracing. 
This  made  it  difficult  to  assess  the  trafficking  routes  and  modus  operandi  of  traffickers. 
Taking  those  limitations  into  consideration,  it  was  nevertheless  possible  to  compile  overall 
figures  of  confiscated  weapons  in  the  Western  Balkans  (including  in  purely  internal 
situations), but the data shows no specific trend and which does not make it possible to draw a 
conclusion as to the effectiveness of the action plan.  

46   Source: Responses to the questionnaire sent to law enforcement Agencies in June 2018. 

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Since  2014,  circa  25  000  small  arms  and  light  weapons  were  destroyed,  6  000  parts  and 
components  and  250  000  rounds  of  ammunition  in  Bosnia  and  Herzegovina,  Montenegro, 
Kosovo*  and  Serbia  only.  However,  statistics  are  not  sufficiently  detailed  to  assess  to  what 
extent these activities derive directly from the action plan. 

Chart 4.  Number of confiscated firearms47 

It was one of the objectives of the action plan to ensure that legislation in the Western Balkans 
was  in  concordance  with  EU  law.  This  concordance  is  well  under  way.  Each  meeting 
organised  was  an  occasion  for  benchmarking  between  various  countries,  and  for  the 
Commission  to  clarify  aspects  linked  to  the  legislation.  The  Clearinghouse  also  provided 
continuous support to help countries adapt their national legislative framework (by providing 
training, technical and legal advice). Of course, the latest changes to EU legislation48 are yet 
to  be  fully  reflected  in  national  law,  as  recognised  by  most  stakeholders  during  expert 
meetings. However, more work remains to be done with legislation on criminal sanctions and 
criminal  policy, or with  bylaws on deactivation  or marking of  firearms.  This  need for more 
work to be done was mentioned by many stakeholders both in response to the questionnaire 
and during firearms experts meetings. Respondents often pointed to the lack of a sufficiently 
stringent  criminal  policy,  with  traffickers  being  often  more  easily  prosecuted  for  illicit 
possession  than  for  trafficking.  On  deactivation  and  marking  standards,  although  the  basic 
principles of the legislation in the Western Balkan partners are generally in line with EU law, 
according to  experts from  the Clearinghouse and national  firearms experts during meetings, 
not all countries of the region have adopted administrative rules to fully implement of those 

47   Source: SEESAC, Commission's own elaboration. 

48   Directive  (EU)  2017/853  of  17  May  2017  amending  Council  Directive  91/477/EEC  on  control  of  the 

acquisition and possession of weapons, OJ L 137, 24.5.2017, p. 22–39. 

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principles.  This  is  partly  due  to  the  fact  that  some  changes  are  very  recent  in  EU  law 
(deactivation  standards  of  December  201549  were  amended  in  March  201850  and  marking 
requirements were harmonised in January 201951). 

Chart 5.  Effectiveness of Actions under Goal 252 

Under Goal 2, stakeholders were generally satisfied with the effectiveness of joint meetings. 
According  to  the  assessment  of  the  Commission,  which  chaired  those  meetings,  and 
confirmed  by  stakeholders  during  the  consultation  exercise,  the  effectiveness  of  these 
meetings  was  sometimes  hampered  by  the  fact  that  participants  were  mid-ranking 
investigators  who  required  authorisations  and  instructions  to  address  international  meetings. 
Moreover,  they  were  not  always  aware  of  broader  developments  within  their  respective 
institutions.  Overall,  however,  stakeholders  appeared  satisfied  with  their  usefulness  of  these 
meetings, especially in terms of enabling dialogue between firearms experts. 

Chart 6.  Effectiveness joints EU-WB meetings53 

Daily  cooperation  and  exchanges  of  information  were  made  difficult  by  a  high  turnover  of 
staff  in  the  national  law-enforcement  agencies  of  Western  Balkans  partners.  Nevertheless, 
available  data  demonstrated  the  ability  of  participants  to  learn  from  the  difficulties 
encountered  during  joint  coordinated  targeted  checks.  This  is  illustrated  by  the  number  of 
SIENA messages exchanged within the joint checks operations, which substantially increased 
(before, during and after the action). The number of seized firearms (during the joint action 

49    Commission  Implementing  Regulation  (EU)  2015/2403  of  15  December  2015  establishing  common 
guidelines  on  deactivation  standards  and  techniques  for  ensuring  that  deactivated  firearms  are  rendered 
irreversibly inoperable; OJ L 333, 19.12.2015, p. 62–72.  

50   Commission Implementing Regulation (EU) 2018/337 of 5 March 2018 amending Implementing Regulation 
(EU) 2015/2403 establishing common guidelines on deactivation standards and techniques for ensuring that 
deactivated firearms are rendered irreversibly inoperable; OJ L 65, 8.3.2018, p. 1–16. 

51   Commission Implementing Directive (EU) 2019/68 of 16 January 2019 establishing technical specifications 
for the marking of firearms and their essential components under Council Directive 91/477/EEC on control 
of the acquisition and possession of weapons; OJ L 15, 17.1.2019, p. 18–21. 

52   Source: Responses to the questionnaire sent to law enforcement Agencies in June 2018. 

53   Responses to the questionnaire sent to law enforcement Agencies in June 2018. 

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days  and  in  the  follow-up  investigations)  has  also  been  steadily  increasing.  Both  figures 
demonstrate  the  effectiveness  of  this  activity  in  improving  the  exchange  of  criminal 
information and intelligence and operational law enforcement co-operation. 

Chart 7. 

54 

Chart 8. 

55 

On  the  ground,  border  checks  across  the  region  have  demonstrated  their  own  inadequacy. 
Although there is evidence that firearms travel  across the Western Balkans, from and to  the 
EU, as recognised by all stakeholders and intelligence assessments, seizures of firearms rarely 
take  place  at  borders,  but  mostly  inland,  not  in  relation  to  international  trafficking.  This  is 
confirmed by law enforcement agencies across the region, as well as the EBCGA, who rarely 
ever report border seizures. According to several stakeholders, this is because border guards 
and customs officers (i) are not fully aware of problem of firearms trafficking and the ways in 
which  firearms  are  trafficked,  (ii)  do  not  sufficiently  rely  on  risk  profiling  and  prior 
intelligence,  (iii)  are  not  specifically  trained  to  detect  firearms,  (iv)  are  not  adequately 
equipped (they do not use mobile scanners, and have no firearms-trained sniffer dogs), (v) and 
focus on border crossing points with no clear strategy to control the other land borders used 
by smugglers.  

The  operational  cooperation  between  the  EU  and  the  Western  Balkans  revealed  several 
weaknesses  in  criminal  procedures  in  both  areas.  One  of  the  weakness  is  that  special 
investigative  techniques  (phone  tapping,  under-cover  operations)  differ  widely  across 
countries and this can create difficulties when setting up cross-border operations. Such special 
investigative techniques can sometimes only be used in particularly serious cases of organised 
crime,  of  which  weapons  trafficking  is  not  always  considered  to  belong.  According  to 
discussions held during firearms expert meetings, checks on suspected deliveries of weapons 
(both in the Western Balkans and in the EU) are limited by a general reluctance to authorise 
those  operations  in  the  transit  countries.  This  is  sometimes  because  (i)  the  national  legal 
framework  makes  it  compulsory  to  seize  any  illicit  weapon  on  the  national  territory  (e.g. 
Austria);  (ii)  prosecutors  do  not  trust  other  countries  to  carry  out  the  investigations  (a 
recurring  complaint  both  from  law  enforcement  and  several  prosecutors  attending  firearms 
expert meetings); or (iii) such operations are time and staff-consuming, with no direct impact 
of the trafficking  for the country of transit. This  has affected the  effectiveness  of the cross-
border  cooperation  and  made  it  harder  to  dismantle  international  firearms  trafficking  rings. 
Stakeholders,  during  meetings  and  in  the  replies  to  the  consultation,  unanimously  regretted 
the  lack  of  prosecutors  aware  of  the  challenges  of  firearms  trafficking.  They  also  point  out 

54   Sources: Europol, EMPACT. Figures for 2018 are not final. 

55   Ibid. 

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constraints  put  on  their  work  by  legislation,  which  hampers  exchanges  of  information  for 
intelligence  purposes  outside  of  specific  investigations.  Similarly,  during  the  joint  checks 
operations,  Preparation  and  debriefing  of  Joint  Action  Days  (i.e.  joint  control  operations) 
under  the  Firearms  Platform  showed  that  member  states  with  strong  connections  to  the 
Western  Balkans  did  not  actively  help  law  enforcement  agencies  to  detect  traders  were 
trafficking  gas  and  alarm  weapons,  which  were  not  considered  as  firearms  in  their  national 
legislation.56  As  another  illustration  of  the  limits  in  operational  cooperation,  within  the 
Firearms  Platform,  Operation  Bosphorus  was  dedicated  to  the  threat  of  gas  and  alarm 
weapons  but  did  not  include  customs  checks  or  the  participation  of  border  guards.  This 
limited  the  effectiveness  of  the  operation.  On  exchanges  of  information  through  SIENA, 
several stakeholders complained that the system was not sufficiently user-friendly to replace 
traditional emails. 

Significant  challenges  remain  in  forensics  (notably  ballistics).  Technologies  vary  widely 
across  the  region  and  this  impedes  exchanges  of  information  and  cross-comparison  beyond 
national borders. According to the works carried out in this field in the Firearms Platform and 
in  the  discussions  during  expert  meetings,  in  most  EU  member  states,  ballistic  analysis  and 
international comparisons are carried out on a case-by-case basis, and are neither systematic 
nor  fully  automatised.  In  the  Western  Balkans,  only  one  partner  (Kosovo*)  performs  a  gun 
crime analysis report and has forensic laboratory which achieved the ISO 17025 accreditation 
for its ballistic investigation and other related processes. All partners face a large backlog of 
bullets and casings, which have never been checked for ballistic information even though they 
could enable connections between crimes across Europe and movements of illicit firearms. 

Under Goal 3, the greatest challenge was assessing the effectiveness of activities to improve 
training and capacity-building. This is because the effectiveness of these activities cannot be 
evaluated simply by counting the numbers of trainees or workshops that were held. However, 
the  participation  of  Western  Balkan  partners  in  trainings  provided  by  CEPOL  substantially 
increased from 2015 and 2018. Figures show uneven participation in training by EU member 
states,  with  no  specific  identifiable  trend,  the  rate  of  participation  is  stable  and  low.57  Two 
countries  stand  out  for  their  participation:  Greece  and  Portugal.  Both  these  countries  had  a 
substantially  above-average number of trainees attending webinars. On average,  Greece had 
66 webinar trainees per year and Portugal had 15.  

The Clearinghouse provided useful practical training for law enforcement officers across the 
region58,  including  by  developing  for  all  agencies  of  the  region  a  weapon  identification 
platform  to  help  identify  seized  weapons,  ammunition  and  explosives,  and  generate  reports 
for further criminal investigation. The Clearinghouse (as well as individual member states and 
international  organisation  such  as  UNODC,  but  not  in  the  context  of  this  action  plan)  also 

56   The legal situation has substantially improved since the entry into force of Directive (EU) 2017/853 of 17 
May  2017  amending  Council  Directive  91/477/EEC  on  control  of  the  acquisition  and  possession  of 
weapons, OJ L 137, 24.5.2017, p. 22–39, and the subsequent adoption of the Implementing Directive (EU) 
2019/69  of  16  January  2019  laying  down  techncial  specification  for  alarm  and  signal  weapons  (O.J.  L15 
17.1.2019, p.22-26) which has yet to be fully implemented. 

57   member  states  have  sent  on  average  3.8  participants  each  year  to  all  trainings  (residential  trainings  and 

webinars), while Western Balkan Partners sent 2.7 participants. 

58   For instance at a large scale in the context of the project "Countering Illicit Arms Trafficking in Bosnia and 

Herzegovina". 

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provided  capacity-building  support  to  raise  firearms-control  standards  of  Western  Balkan 
countries.  According  to  information  provided  by  the  Clearinghouse  and  law  enforcement 
representatives, all Western Balkan partners now have in place functioning registers of legally 
owned  firearms,  databases  on  external  trade  of  weapons  and  databases  on  denials  to  grant 
authorisations.  

However,  the  lack  of  sufficiently  practical  training  was  raised  by  several  stakeholders,  who 
identified needs in the establishment of Joint investigation teams and on specific issues such 
as convertible firearms, as well as specific awareness-raising activities for customs and border 
guards. The lack of implementation of the United Nations Firearms Protocol, for instance with 
respect  to  marking  or  the  definition  of  firearms  trafficking,  calls  for  trainings  on  criminal 
codes. 

Key findings 

 

 Activities carried-out under the action plan for modernization of law enforcement 
agencies compared to other actions. 

  Approximation of legislation in the Western Balkans towards EU standards is well 

 

on track. 
 The  organization  of  joint  meetings  for  creating  a  unique  space  for  dialogue  and 
exchange of best practices between firearms experts. 

  Steady  improvement  in  the  exchange  of  information  and  operational  cooperation 

during joint coordinated targeted controls.  

  Positive  responsiveness  of  Western  Balkan  countries  to  training  and  capacity-

building opportunities. 

  Lack  of  key  performance  indicators  that  would  have  enabled  a  comprehensive 

assessment of progress towards achieving the objectives. 

  National Focal Points still not established in all countries, and as a consequence: 

iArms database not systematically populated 

o  still no harmonized data collection firearms seizures. 
o 
o  no systematic tracing of weapons seized 
o  no  systematic  or  automatized  ballistics  analysis  and  cross-border 

comparisons 

  No noticeable reduction of stockpiles. 
 

Inefficiency of border checks, which do not yield results in comparison with inland 
checks. 
 
Insufficiently stringent criminal sanction and criminal policies. 
  Difficult use of criminal proceedings during cross-border operations. 

Efficiency 

Conducting a cost-benefits analysis of the action plan was limited by the fact that figures and 
hard data are almost non-existent, especially with respect to financial costs. Similarly, neither 
the Firearms Platform nor Europol have provided a financial analysis of their operations. As 
far  as  EU  financial  programmes  are  concerned,  notably  the  Instrument  for  Pre-Accession 
Assistance  (IPA  II),  supports  actions  against  firearms  trafficking.  Under  the  current  budget 
structure, it is therefore not possible to identify exactly how much funds are used specifically 
for  the  fight  against  firearms  trafficking.  In  terms  of  outcomes  (such  as  firearms  seizures, 

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number  of  voluntary  surrenders  of  weapons,  size  of  stockpiles  etc.),  figures  are  still 
insufficiently  harmonised  or  nor  systematically  available  to  allow  a  quantitative  analysis. 
Besides,  where  specific  figures  could  be  identified,  as  explained  in  section  5.3  on 
effectiveness,  the  link  between  the  activities  mentioned  in  the  action  plan  and  the  outcome 
would  be  too  indirect  to  enable  a  reliable  cost-benefit  analysis.  This  means  that  it  is  not 
possible  to  draw  a  direct  causal  link  between  a  headline  and  the  addition  of  individual 
seizures, operations and investigations against firearms trafficking. 

The  Firearms  Platform59  can  in  principle  provide  substantive  support  to  EU  member  states 
and Western Balkan partners for the costs of participation in action days (even bilateral ones), 
information  rewards,  funding  of  special  equipment,  rental  of  premises  for  covert  operations 
etc. However, a dedicated meeting for local EU liaison officers in Belgrade on 19 March 2018 
demonstrated a general lack of knowledge about this facility and about the Firearms Platform 
in general and a widespread reliance on national funding and purely bilateral cooperation. The 
country in charge of coordinating the Firearms Platform is also aware of many ongoing joint 
investigations  that  could  benefit  from  the  Firearms  Platform  support  and  do  not  rely  on  it. 
Information  linked  to  the  Firearms  Platform  is  not  properly  transmitted  to  those  who  might 
need it.  

The  criticism  of  several  Western  Balkan  partners  against  the  added  value  of  exchanges  of 
information with Europol (see section 5.2), is unsurprisingly reflected the overall decrease of 
secure  SIENA  messages  which  Western  Balkan  partners  exchange  with  Europol  and  EU 
member  states  (outside  of  joint  control  operations,  where  an  increasing  trend  can  be 
observed).  Their  SIENA  contributions  amounted  in  2018  to  29%  of  all  contributions,  down 
from 67% in 2017 notably due to a strong increase of direct contributions from EU member 
states  (from  67  to  111).  The  same  trend  can  be  observed  for  cases  contributed  to  Europol: 
while  the  number  increased  between  2017  and  2018  for  EU  member  states  (26  to  29),  it 
decreased  for  Western  Balkan  Partners  (4  to  2).60  Discussions  during  meetings  of  firearms 
experts  have  shown  that  the  reason  for  this  decrease  was  a  lack  of  added  value  of  such 
exchanges through Europol, as identified in section 5.2.  

On ballistic analysis, respondents stated that ballistics analysis was not efficiently carried out. 
Respondents  says  that  it  was  due  to  a  lack  of  harmonised  standard  procedures  and  lack  of 
detail about the type of information needed by investigators. These problems were identified 
in several meetings of firearms experts, in particular meetings of the Western Balkan Experts 
that are regularly attended by ballistics analysts. The Western Balkan Experts raised the issue 
of a lack of dialogue between forensics analysts (of which ballistics is part) and investigators: 
the  former  do  not  know  what  type  of  information  to  provide  to  investigators,  and  the  latter 
rarely  provide  feedback  about  how  the  information  is  used.  Another  problem  is  that 
techniques for ballistics analysis vary from  country to  country making difficult to  exchange 
ballistics information across borders and conduct transnational investigations.  

On  trainings,  CEPOL  decided  to  cover  the  expenses  of  participants  from  Western  Balkan 
partners  in  its  activities  (6  in  2016  and  2017  and  4  in  2018),  and  they  sent  twice  as  many 
participants than they received funding for.61 This indicates a greater commitment and interest 

59   The  Firearms  Platform  is  funded  through  Europol's  general  budget  and  specific  Europol-managed  EU-

funded low-value and high-value grants.  

60   Source: Europol. 

61   Source: CEPOL. 

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from Western Balkan partners than EU member states in transnational training opportunities, 
and  hence  a  high  value  for  money.  The  Clearinghouse  also  provided  important  practical 
training  for  law  enforcement  officers  across  the  region,  including  by  developing  for  all 
agencies a  weapon identification platform to  help identify  seized weapons, ammunition  and 
explosives,  and  generate  reports  for  further  criminal  investigations.  However,  the  efficiency 
of trainings is difficult to assess, since no analysis of cascading trainings (i.e. further trainings 
at  national  level  provided  by  participants  in  regional  training  courses)  was  provided  by  the 
organisers.  Most  of  the  consulted  trainees  did  not  express  any  opinion  about  trainings  they 
received (either on efficiency or in general).  

In  two  countries  (Albania  and  Bosnia  and  Herzegovina),  the  efficiency  of  voluntary 
surrenders  campaigns  was  limited  by  the  need  to  adopt  new  legislation  for  each  new 
programme  of  surrenders  and  legalisation  of  weapons,  but  an  overall  assessment  was 
impossible by the unavailability of data. 

Key findings 

  Useful support of EMPACT firearms to operational cooperation. 
  High  interest  and  participation  rate  of  Western  Balkan  partners  to  trainings 

provided by CEPOL and SEESAC. 

  Not enough data to assess the cost of activities. No detailed budgeting or financial 

reporting. 

  No harmonized data on concrete outcomes. 
  Lack of awareness of the financial support provided by EMPACT or by other EU 

tools. 

  Exchanges  of  information  between  Europol  and  Western  countries  not  providing 

satisfactory results to all parties concerned. 

  Cross-border exchanges of ballistic information is not considered worth the effort 
because  of  complex  legal  procedures  and  the  fact  that  ballistics  information 
systems are not interoperable. 

  Not sufficiently practical trainings and no information on cascading trainings. 
  No data to assess the efficiency of voluntary surrender campaigns.  

Consistency 

Under this heading, the evaluation first focused on internal consistency, i.e. how the various 
components of the action plan operate together to achieve its objectives. The evaluation also 
sought  to  assess  the  action  plan’s  consistency  with  other  interventions  that  have  similar 
objectives, its relations with international law and strategies, with wider EU policy.  

On internal consistency, the action plan did not establish a direct link between the objectives 
pursued  and  the  goals  and  actions.  The  objectives,  goals  and  actions  often  intertwined  and 
overlapping, thus increasing the complexity of the assessment. For example, the establishment 
of national firearms focal points envisaged in Action 1 of Goal 1, in practice was carried out 
by capacity building and training activities, which falls under Goal 3. Similarly, the work on 
exchange  of  information  was  directly  linked  to  the  actual  conditions  of  operational 
cooperation, and the newly created firearms focal points were meant to  enhance operational 
cooperation.  Some  of  the  needs  were  reflected  in  several  actions  (exchange  of  criminal 
information  and  intelligence,  improving  cooperation  in  operational  law  enforcement;  and 
networking and joint training), while the collection and exchange of statistics was mentioned 
in one action only. 

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Although  ministers  mentioned  expressly  "harmonising  national  legislation  on  firearms  with 
EU  and  international  standards"  as  one  of  the  six  measures  they  identified  and  committed 
themselves to implement, this was not specifically translated into one of the Goals and Actions of 
the action plan. It was rather referred to at the end of the action plan as "continue helping in 
bringing legislation up to EU standards and implementing it", among the many activities not 
specifically related to one of the three main goals. 

On  the  external  consistency,  the  connection  between  the  action  plan  and  EU  legislation 
related  to  the  control  of  weapons  was  analysed.62  The  perspective  of  European  Union 
membership has acted as a major incentive for partners of the region to implement this part of 
the action plan and bring their national legislation in line with EU standards. 

On  other  aspects  of  external  consistency,  the  action  plan  itself  already  mentioned  that 
cooperation would be based on:  

 
 

 

respect for international law, human rights and fundamental freedoms;  
the guidelines set in the EU firearms strategy and the EU firearms operational action 
plans;  
the  existing  stabilisation  and  association  agreements  between  the  EU  and  the  south-
east Europe region;  

  an integrated and balanced approach based on partnership;  
  EU support to the south-east Europe partners in meeting the commitments they have 

made to combat firearms trafficking;  

  Council Decision of 15 February 2007 to combat in an effective way organised forms 
of criminality through Europol with Albania, Bosnia and Herzegovina, Croatia, former 
Yugoslavia Republic of Macedonia, Serbia and Montenegro and the establishment of a 
Firearms  Focal  Point  in  Europol  for  facilitating  the  exchange  of  information  on 
firearms." 

Those  commitments  were  reaffirmed  through  several  initiatives,  mentioned  in  Section  2.5, 
such as the Joint Communication “Elements towards an EU strategy against illicit Firearms, 
Small Arms & Light Weapons and their Ammunition”.63 The Communication also refers to a 
number of international agreements, which have been duly taken into account by all players 
when  implementing  the  action  plan.  Some  of  international  agreements  that  have  been  taken 

62   Council  Directive  91/477/EEC  on  control  of  the  acquisition  and  possession  of  weapons,  OJ  L  256 
13.9.1991,  p.  51);  Commission  Implementing  Regulation  (EU)  2018/337  of  5  March  2018  amending 
Implementing  Regulation  (EU)  2015/2403  establishing  common  guidelines  on  deactivation  standards  and 
techniques for ensuring that deactivated firearms are rendered irreversibly inoperable; OJ L 65, 8.3.2018, p. 
1–16;  Commission  Implementing  Directive  (EU)  2019/68  of  16  January  2019  establishing  technical 
specifications  for  the  marking  of  firearms  and  their  essential  components  under  Council  Directive 
91/477/EEC  on  control  of  the  acquisition  and  possession  of  weapons;  OJ  L  15,  17.1.2019,  p.  18–21; 
Commission Implementing Directive (EU) 2019/69 of 16 January 2019 laying down technical specifications 
for  alarm  and  signal  weapons  under  Council  Directive  91/477/EEC  on  control  of  the  acquisition  and 
possession  of  weapons;  OJ  L  15,  17.1.2019,  p.  22–26;  Regulation  (EU)  No 258/2012  of  the  European 
Parliament and of the Council of 14 March 2012 implementing Article 10 of the United Nations’ Protocol 
against the illicit manufacturing of and trafficking in firearms, their parts and components and ammunition, 
supplementing  the  United  Nations  Convention  against  Transnational  Organised  Crime  (UN  Firearms 
Protocol), and establishing export authorisation, and import and transit measures for firearms, their parts and 
components and ammunition; OJ L 94, 30.3.2012, p. 1–15. 

63   JOIN(2018) 17 final; endorsed by the Council on 19 November 2018 by Council Document 13581/1. 

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into account include the UN Programme of Action on Small Arms and Light Weapons,64 the 
International  Tracing  Instrument,65  the  Arms  Trade  Treaty,66  and  the  Protocol  against  the 
illicit  manufacturing  of  and  trafficking  in  firearms,  their  parts  and  components  and 
ammunition, supplementing the UN Convention against transnational organised crime.67  

The action plan did not provide for any set structure to implement governance. Therefore, the 
European Commission took it upon itself to steer the implementation of the action plan and 
support  a  consistent  coordination  between  the  players  involved  in  this  implementation.  The 
European  Union  has  therefore  worked  to  ensure  that  the  actions  of  all  players  are 
complementarity.  In  particular,  it  has  worked  to  integrate  the  activities  of  the  Firearms 
Platform  and  the  Clearinghouse  into  the  Integrative  Internal  Security  Governance  (IISG)  in 
the  Western  Balkans  and  its  three  pillars  on  counter-terrorism,  fight  against  serious  and 
organised  crime  and  border  security.68  The  Clearinghouse  coordinates  a  small  arms  control 
activities in the region and all activities aimed at combatting illicit trafficking of firearms in 
the region.  This work by the Clearinghouse was mandated by the  Regional Implementation 
Plan on Combatting Proliferation of Small  Arms  and  Light  Weapons in  South  East  Europe. 
The Clearinghouse is now in charge of implementing the regional roadmap for a sustainable 
solution to the illegal possession, misuse and trafficking of small arms and light weapons.  

On  the  roadmap,  Section  4.1  on  methodology  explains  how  the  Commission  used  the 
Roadmap as a valuable source of information for the needs assessment for the region. During 
the  drafting  of  the  roadmap,  the  Commission  ensured  that  the  roadmap  would  be  fully 
consistent  with  the  content  and  objectives  of  the  ongoing  action  plan,  even  if  its  structure 
might differ in parts. The fact that the Clearinghouse has been in charge of coordinating the 
implementation  of  the  roadmap  ensures  a  strong  convergence  between  the  various  work 
streams. 

Firearms  trafficking  was  also  included  in  the  joint  action  plan  on  counter  terrorism  for  the 
Western  Balkans  of  5  October  2018.69  In  practice,  while  the  Commission  has  attempted  to 
ensure the comprehensiveness of the activities and provide general oversight over them,  the 
Firearms  Platform  has  focussed  on  operational  cooperation  and  the  Clearinghouse  on 
providing capacity training and development of national strategies.  

Nevertheless,  the multiplicity of bodies of cooperation can be considered  a downside of the 
overall management of the EU’s fight against illicit firearms trafficking. Various groups and 
bodies  often  overlap.  International  players  like  the  Small  Arms  Survey,  the  Southeast 
European Law Enforcement Centre (SELEC), North Atlantic Treaty Organisation, the United 
Nations  Office  on  Drugs  and  Crime  or  the  Organisation  for  Security  and  Co-operation  in 
Europe are also active in the region. However, there is unclear coordination of these groups’ 

64   http://www.un.org/events/smallarms2006/pdf/192.15%20(E).pdf 

65   http://www.poa-iss.org/InternationalTracing/InternationalTracing.aspx 

66   https://www.un.org/disarmament/att 

67   http://www.unodc.or g/unodc/en/firearms-protocol/the-firearms-protocol.htm 

68   https://wb-iisg.com/ 

69   https://ec.europa.eu/home-affairs/sites/homeaffairs/files/news/docs/20181005_joint-action-plan-counter-

terrorism-western-balkans.pdf ; see objective 5. 

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activities  with  the  Clearinghouse,  the  Firearms  Platform,  or  within  the  Integrative  Internal 
Security  Governance.  These  international  players  were  not  directly  involved  in  the 
implementation  of  the  action  plan.  As  an  illustration  of  the  overlapping  nature  of  the  work 
done  by  different  organisations,  activities  of  operational  cooperation  (joint  investigations, 
exchange of information) in the region can be supported by the Firearms Platform, Europol, 
Eurojust  and  the  Southeast  European  Law  Enforcement  Centre  or  within  the  Multi-
Beneficiary  Regional  IPA  2017  "Countering  Serious  Crime  in  the  Western  Balkans".70 
Trainings for border detection are provided by the Clearinghouse, the EBCGA and UNODC. 
Similarly, training and legal assistance provided by the EU Partner to Partner Export Control 
Programme  for  Arms  managed  by  the  German  Federal  Office  for  Economic  Affairs  and 
Export Control BAFA71 took place outside the coordination framework of the Clearinghouse / 
the Firearms Platform /Commission. 

EU funding can be sought – and obtained – through various channels (Common Foreign and 
Security Policy funding, the Instrument for Pre-accession Assistance including the Technical 
Assistance  and  Information  Exchange  instrument  (TAIEX)  modality,  the  Internal  Security 
Fund) without a central coordinating authority. This initially created inconsistencies and lack 
of  coordination  between  several  Commission  departments,  which  have  been  addressed  and 
overcome through systematic exchange of information between them, sharing of reports, joint 
participation  to  external  meetings,  regular  internal  meetings,  and  joint  and  coordinated 
drafting of notes and briefings. However, the Commission is only informed and consulted on 
funding  received  through  Council  Decisions  in  the  Common  Foreign  and  Security  Policy 
framework. This means that funding (for instance for the Clearinghouse or the EU "Partner to 
Partner"  Export  Control  Programme  for  Arms)  can  be  granted  without  a  clear  overview  of 
other similar or overlapping activities in the region. 

The  lack  of  dialogue  and  coordination  has  led  to  operations  taking  place  at  the  same  time. 
Many  stakeholders  have  noted  an  unnecessary  duplication  of  meetings,  with  similar 
participants  having  the  same  discussions.  Conversely,  in  other  cases,  representatives  attend 
different  meetings  with  no  prior  knowledge  of  similar  discussions  or  presentations  having 
already  taken  place  in  similar  formats.  This  is  due  to  a  lack  of  internal  coordination  and 
information sharing.  

Key findings 

  strong consistency with other overarching strategies, including EU strategy on small 

arms and light weapons and the Regional Roadmap; 

  close coordination ensured with legislative developments inside the EU on firearms 

control to ensure approximation of Western Balkan laws with EU standards; 

  consistency ensured with international instruments.  

  weak internal coherence between activities; many overlaps; 
 
 
 

lack of integ 
rated steering structure; 
lack of integrated budgetary approach. 
and he Center for International Legal Cooperation (CILC). 

70   Co-managed by the German Company for International Cooperation GIZ, the Italian Ministry of the Interior 

71   Most recent decision: Council Decision (CFSP) 2018/101 of 22 January 2018 on the promotion of effective 

arms export controls, OJ L 17, 23.1.2018, p. 40–47. 

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CONCLUSIONS  

The European Union and Western Balkan partners are facing common challenges.  

Changing realities mean that there is still a need for an action plan but the current action plan 
has lost some of its relevance as it is not longer fully adapted to developing needs. According 
to the consultation of stakeholders and drawing lessons from the development of the regional 
Roadmap, what appears to be lacking is a set of operational objectives, detailed performance 
indicators and a clear steering structure. On geographical scope, the activities have correctly 
been focusing on the Western Balkan, but future challenges may justify covering all of south-
east  Europe,  including  the  Republic  of  Moldova  and  Ukraine,  to  develop  future-proof 
solutions in the EU's Eastern neighbourhood.  

The action plan mostly provided added value by improving networking and the exchange of 
information and by putting in place the building blocks of future cooperation. It encouraged 
multilateral cooperation and a coordinated strategic approach which purely bilateral relations 
and  individual  initiatives  would  not  have  enabled.  Other  tools  have  not  been  made  use  of, 
such as joint investigation teams. 

The  effectiveness  of  the  action  plan  has  been  uneven,  depending  on  its  various  objectives. 
Data collection of firearms seizures is not sufficiently widespread or harmonised. This made 
difficult  to  conduct  a  proper  and  reliable  assessment  of  trafficking  trends,  and  produce 
evidence-based policies. The setting up of national focal points (and in the Western Balkans 
the setting up of small arms commissions) is well under way, but not yet completed. This still 
prevents  proper  enforcement  strategies,  coordination,  intelligence  and  exchanges  of 
information, both nationally and at European level. 

Efficiency is also hampered. Taking into account the lack of available data that would have 
enabled  a  proper  assessment,  it  is  nevertheless  possible  to  note  that  efficiency  has  been 
limited. Under the current budget structure, it is therefore not possible to identify exactly how 
much  funds  are  used  specifically  for  the  fight  against  firearms  trafficking.  In  terms  of 
outcomes  (such  as  firearms  seizures,  number  of  voluntary  surrenders  of  weapons,  size  of 
stockpiles  etc.),  figures  are  still  insufficiently  harmonised  or  nor  systematically  available  to 
allow a quantitative analysis. Besides, where specific figures could be identified, as explained 
in  Section  5.3  on  effectiveness,  the  link  between  the  activities  mentioned  in  the  action  plan 
and the outcome would be too indirect to enable a reliable cost-benefit analysis. This means 
that  it  is  not  possible  to  draw  a  direct  causal  link  between  a  headline  and  the  addition  of 
individual seizures, operations and investigations against firearms trafficking. 

Consistency and complementarity with other EU action has consistently improved, especially 
in  the  last  years.  However,  several  bilateral  or  intergovernmental  initiatives  created  a 
challenge  to  avoid  overlaps  and  conflicting  activities.  Closer  co-ordination  between  the 
Commission,  the  Firearms  Platform  and  the  Clearinghouse  is  needed  to  ensure  a  better  use 
and allocation of funds. 

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ANNEXES 

Annex 1. Procedural information 

The  evaluation  was  led  by  the  Directorate  General  for  Migration  and  Home  Affairs  (DG 
HOME),  in  close  association  with  the  Directorate  General  European  for  Neighbourhood 
Policy and Enlargement Negotiations (DG NEAR) and the European External Action Service 
(EEAS).  

The evaluation process started during the Joint Committee between firearms experts from EU 
and south-east Europe partners Experts of 26 January 2018. The Joint Committee agreed that: 

"In order to assess the different initiatives carried out between EU member states and Western 
Balkans partners as defined in the EU/WB action plan 2015-2019, an in-depth evaluation will 
be carried out in 2018. The Commission will circulate a questionnaire by the end of February 
2018 to all EU and WB competent administrations to collect information about the initiatives 
carried out by the partners according to the action plan, the Firearms Platform activities and 
the  conclusions  of  all  relevant  meetings.  The  relevant  partners  will  send  the  replies  to  the 
Commission by the end of June 2018. The Commission will draft a report to inspire the draft 
new action plan to be adopted in 2019." 

DG  HOME  consulted  DG  NEAR  on  the  draft  questionnaire  on  22  June  2018.  The 
questionnaire was  then sent  to  members of the European Firearms Experts (EFE) Group, of 
the  South  East  Europe  Firearms  Expert  Group  (SEEFEG),  to  European  agencies  and  other 
stakeholders (such as the Clearinghouse) on 27 July 2018. 

An  Inter-service  Group  composed  of  DG  HOME,  DG  NEAR,  DG  DEVCO,  the  FPI,  DG 
TRADE, DG TAXUD, the Commission’s legal  service  and the Secretariat  General,  was  set 
up  and  met  on  23  January  2019.,  The  inter-service  consultation  on  this  staff  working 
document and on the Commission report were then launched. 

No  specific  public  consultation  took  place,  since  the  Action  plan  was  addressed  to  public 
authorities  only,  and  all  relevant  information  on  the  actions  implemented  under  the  action 
plan  (trainings,  coordination  meetings,  exchange  of  information  between  law  enforcement 
agencies, investigations  etc.)  was  available only  to  the specific stakeholders involved in  the 
implementation  of  the  action  plan.  The  public  does  not  have  access  to  this  action  plan  so  a 
public  consultation  would  not  have  provided  any  additional  data  for  the  evaluation  of  the 
action plan compared to the targeted consultation carried-out. 

An  evaluation  roadmap  was  published  on  the  Commission's  Better  Regulation  Portal  on 
29 January 2019,72 and was open for feedback from the public until 27 February 2019. One 
stakeholder  from  Mexico  provided  feedback,  stressing  the  need  to  improve  border  controls 
and fight against corruption. 

During its meeting of 24 September 2018, the Joint Committee  between firearms experts of 
the EU and of the south-east Europe partners discussed the outcome of this consultation. The 

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meeting focused on the evaluation of the action plan and experts identified measures to help 
improving cooperation in the fight against firearms trafficking. 

In  parallel,  the  preparation  of  the  regional  roadmap  for  a  sustainable  solution  to  the  illegal 
possession,  misuse  and  trafficking  of  Small  Arms  and  Light  Weapons  was  carried  out 
between  1st  February  2018  and  29  May  2018  at  the  initiative  of  the  Ministries  of  Foreign 
Affairs  of  France  and  Germany,  and  coordinated  by  the  Clearinghouse.  Other  organisations 
were also closely associated with the preparation of the analysis, including the Commission, 
the  Firearms  Platform,  the  EBCGA  and  Europol.  The  roadmap  focussed  on  developing  a 
needs  assessment  for  the  region,  and  therefore  contributed  greatly  to  the  analysis  of  current 
challenges.  The  roadmap  also  complemented  the  information  gathered  through  the 
questionnaire. 

DG HOME, DG NEAR and the External Action Service were in close and permanent contact 
to coordinate the position of the European Union in various external meetings. This conduct 
included  (i)  inviting  all  relevant  Commission  DGs  and  the  External  Action  Service  to  the 
meetings of the Joint Committee; (ii) the work on the regional roadmap leading to the London 
Ministerial  Summit  of  10  July  2018;  (iii),  the  drafting  of  the  Joint  Communication  on 
Elements towards an EU Strategy against illicit Firearms, Small Arms & Light Weapons and 
their  Ammunition;73  (iv)  the  continued  financial  support  to  the  Clearinghouse74  and  (v)  the 
preparation  for  the  high-level  meeting  of  the  French-German  Co-ordination  Initiative  on 
Small Arms and Light Weapons in the Western Balkans of 11 December 2018, to which both 
DG HOME and DG NEAR took the floor. 

73   JOIN(2018) 17 final. 

74   Council  Decision  (CFSP)  2018/1788  of  19  November  2018  in  support  of  the  South-Eastern  and  Eastern 
Europe Clearinghouse for the Control of Small Arms and Light Weapons (SEESAC) for the implementation 
of  the  Regional  Roadmap  on  combating  illicit  arms  trafficking  in  the  Western  Balkans,  OJ  L  293, 
20.11.2018, p. 11–23. 

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Annex 2. Stakeholder consultation  

General overview 

The consultation strategy relied on three main sources: 

  A stakeholder questionnaire; 
  Meetings of the Joint Committee between firearms experts from the EU  and south-

east Europe partners; 

  Meetings and documents for the elaboration of the regional roadmap for a sustainable 
solution  to  the  illegal  possession,  misuse  and  trafficking  of  Small  Arms  and  Light 
Weapons. 

In  addition,  an  evaluation  roadmap  was  published  on  the  Commission's  better  regulation 
website on 29 January 2019,75 and was open for feedback from the public until 27 February 
2019. One stakeholder from Mexico provided feedback, stressing the need to improve border 
checks and fight corruption. 

Participation: 

The  questionnaire  was  sent  to  members  of  the  European  Firearms  Experts  (EFE)  Group,  of 
the  South  East  Europe  Firearms  Expert  Group  (SEEFEG),  to  European  Agencies  and  other 
stakeholders (such as the Clearinghouse) on 27 July 2018. 

The rate of response  to the questionnaire was as follows: 

Replies Received 
EU/EEA 
Western Balkans 
Total 

18 
6 
24 

60% 
100% 
71% 

Method of interpretation of the questionnaire: 

Respondents  to  the  stakeholder  consultation  often  left  blanks  to  certain  questions,  thus 
increasing the proportion of "don't know/no opinion". However, were information related to 
these member states was available through other channels (such as whether a National Focal 
Point had been established), this was nevertheless reflected in the analysis, in order to ensure 
accurate figures. 

Most  replies  went  beyond  the  strict  assessment  of  the  EU-Western  Balkan  action  plan,  and 
cover the general EU activities against firearms trafficking (including the Firearms Platform). 

The quality and length of responses was uneven. It was often necessary to interpret replies or 
infer answers to ensure comparability between answers. Besides, most questions were drafted 
in qualitative terms, which meant that not all of them could be translated into a quantitative 
assessment.  The  qualitative  assessment  is  reflected  in  the  body  of  the  Staff  Working 
Document, under each evaluation question. 

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Some replies did not enable a proper assessment, since they did not respond to the question. 
For  instance,  some  replies  to  questions  such  as  "how  do  you  assess  the  efficiency  of  the 
activities  under  this  goal"  took  the  form  of  the  provision  of  factual  data  (organisation, 
figures),  but  no  judgement  on  the  efficiency  (high,  low,  negative  etc.).  Others  replied  to 
several  questions  in  a  single  answer  of  a  few  lines,  or  simply  ignored  the  question,  which 
made the analysis difficult. 

The analysis of replies  showed in  several instances different  approaches  and point of views 
between the EU and Western Balkan Partners, which explains why the two groups are often 
presented separately. 

Results of the questionnaire 

The questionnaire only included open questions to provide as much freedom to respondents as 
possible and spur the  reflection. The questionnaire included two parts, on the assessment of 
the  action  plan  and  on  suggestions  for  the  future.  Although  the  second  part  was  forward-
looking,  it  facilitated  the  assessment  of  current  needs  and  gaps.  The  first  part  included 
questions on each main goal of the Action plan, both with requests for factual information and 
request for a qualitative assessment. The second part included questions on the relevance and 
added  value  of  the  action  plan,  as  well  as  requests  for  suggestions  for  specific  aspects 
(multilateral  cooperation,  operational  cooperation,  exchange  of  information,  training  and 
exchanges of best practices). 

Summary of replies 

Strategic Goal 1: To modernise the law enforcement agencies and their operating methods by 
improving the strategic and operational analysis of information, with particular regard to risk 
analysis,  investigative  procedures,  data  collection,  exchange,  dissemination  and  use  of 
information. 

a)  Have you set up in your competent administration a National Firearms Focal Point to 
coordinate the fight against illicit firearms trafficking in  your country and liaise with 
other international partners?  

b)  Have you participated or are you participating in United Nations on Drugs and Crime 
(UNODC) data collection project on the seizures of firearms (project financed by the 
European Commission)?   

Participation  to  UNODC 

EU/EEA 
16 

% 
53% 

WB 
4 

% 
67% 

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Data collection exercise 

c)  How do you assess the overall effectiveness and the impact of the activities under this 

goal? 

In  order  to  accomplish  Strategic  Goal  2:  "To  enhance  mutual  trust  among  law  enforcement 
agencies of the South East Europe region and the authorities in the other EU member states. 
[…] To promote inter-regional cooperation between law enforcement agencies, including the 
exchange of information and operational cooperation." 

a)  Have  you  regularly  attended  EU/Western  Balkan  meetings  on  the  fight  against 
firearms trafficking (Joint meetings of European Firearms Experts (EFE) and of South 
East Europea Firearms Experts (SEEFEN), EMPACT meetings) ? 
% 

EU/EEA 

WB 

% 

Participation 
EFE/SEEFEN meetings 

to 

Joint 

18 

60% 

Participation  to  EMPACT 
meetings 

17 

57% 

6 

6 

100% 

100% 

b)  How do you assess the relevance and the outcomes of these meetings? 

EN 

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c)  How  do  you  assess  the  participation  of  EU  member  states  and  Western  Balkan 
partners  in  the  work  of  EU  Agencies  (Europol)  or  their  involvement  with  the  EFE? 
What would you suggest to improve it? 

d)  How do you assess the overall effectiveness and the impact of the activities under this 

goal? 

In order to accomplish Strategic Goal 3: "To enhance capacity building for the prevention of 
illicit trafficking in  firearms by raising awareness, cooperation and sharing of best  practices 
and expertise amongst all stakeholders." 

a)  Have  you  promoted  EU  member  states/Western  Balkans  partners  joint  training 
course?    If  yes,  how  many  and  how  many  participants  per  year?    Are  you  satisfied 
with the results of such courses? What could be done to improve them? 

Figures and replies on the satisfaction on courses were rarely provided by respondents;  

EN 

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b)  Amongst  Western  Balkans  partners,  have  you  continued  helping  in  bringing 
legislation  up  to  EU  standards  and  implementing  it?  Please  quote  the  relevant 
legislation  (imports,  exports,  acquisition  and  possession,  marking  requirements, 
criminal sanctions, deactivated firearms, gas, alarm and acoustic expansion weapons).  

Yes for all 

c)  How do you assess the overall effectiveness and the impact of the activities under this 

goal? 

 Ideas for the future  

 

In view of a possible revision of the action plan for the period 2020-2025, still to be 
decided at the political level: 

a)  To  what  extent  are  objectives  and  instruments  mentioned  in  the  current  action  plan 

still adapted to current needs?  

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b)  To  what  extent  have  EU  measures  offered  added  value  by  supporting  or  facilitating 
European  cooperation,  by  improving  national  capabilities  or  by  complementing, 
stimulating or leveraging member states' action? 

  Specific suggestions on multilateral vs bilateral cooperation 

a)  Are  you  satisfied  by  the  coordinating  role  of  the  south-eastern  and  eastern  Europe 
Clearinghouse  for  the  Control  of  Small  Arms  and  Light  Weapons  (SEESAC),  the 
South  East  European  Firearms  Experts  Network  (SEFFEN)  and  the  South  East 
Europea Firearms Experts Group (SEEFEG)? How could this role be enhanced? 

Most of the replies did  not  provide suggestions on how to enhance the role of those 
structures. 

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  Specific suggestions on improving operational cooperation 
a)  What  could  be  the  main  obstacles  for  increasing  the  current  level  of  cooperation, 
including Joint Investigation teams (lack of legal basis, administrative capacity of the 
partners, etc.)? 

Meetings  of  the  Joint  Committee  between  European  Union  Firearms 
Experts and South East Europe Partners Experts 

At  the  first  meeting  on  26  January  2016  the  Joint  Committee  decided  to  enlarge  the  above 
mentioned  Joint  action  plan  to  illicit  explosives.  They  noted  the  common  achievements  in 
2015 and agreed, among others, to improve their efforts in the fight against illicit trafficking 
in firearms to improve cooperation among agencies; draft a template with minimum standard 
intelligence  requirements  in  line  with  similar  initiatives  (European  regional  Initiatives, 
Interpol, UNODC) and test it by organising a dedicated Pilot Project on data collection. They 
considered important to carry out at least one joint action focused on the illicit trafficking in 
firearms,  components  and  ammunition  and  explosives  with  a  regional  approach.  Assess 
previous  training  initiatives  and  organise  dedicated  common  training  actions  to  improve 
awareness  about  the  fight  against  illicit  trafficking  in  firearms,  updated  trends  and  best 
practices to tackle it. Develop Standard Operative Procedures to trace all seized firearms and 
ammunition  in  strong cooperation with  SEESAC and using relevant  databases. Evaluate the 
recent EU legislation on the deactivation standards and assess the possibility for the inclusion 
of similar standards in the national legislations of SEEC.  

Propose  a  dedicated  action  to  study  the  impact  of  new  technologies  in  the  fight  against 
firearms trafficking 

At  the  second  meeting  on  30  November  2016,  the  Joint  Committee  considered  it  was 
important to coordinate the structure of the European Firearms Expert Group and South-East 
Europe  Expert  Network  to  ensure  a  mirror  approach  in  choosing  topics  and  developing 
analysis  between  EU  and  South  East  Europe  experts.  The  need  to  improve  exchanges  of 
information was stressed again, as well as the need to involve more Western Balkan partners 
in the Firearms Platform. Further harmonisation of legislation was mentioned, as the need to 
accelerate  the  establishment  of  Firearms  Focal  Points.  Participants  agreed  to  support  the 

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UNODC  mapping  project  on  minimum  standard  data  collection  with  regard  to  seized 
firearms.  It  also  identified  the  need  to  work  more  on  the  risk  of  convertible  gas  and  alarm 
weapons.  

This confirmed data from a 2014 study according to which “there is evidence on the existence 
of several organised criminal groups operating in the western Balkans committed to convert 
and illicitly trade Turkish made (blank) pistols, sold in the black markets of western European 
MS, including countries such as Denmark and Sweden (criminal group dismantled in 2011 in 
Macedonia)."76 

At  the  third  meeting  on  26  January  2018,  participants  stressed  the  need  for  more  synergies 
and coordination between various initiatives to reduce overlaps. Real involvement of Western 
Balkan  partners  in  the  Firearms  Platform  was  again  identified  as  a  necessity,  as  the 
improvement of exchanges of information (notably the use of Europol's SIENA system), the 
establishment  of  Firearms  Focal  Point  in  each    partner  (with  reference  to  the  Guidance 
developed  by  European  Firearms  Experts)  and  the  contribution  to  the  UNODC  mapping 
project.  The  participants  in  the  third  meeting  also  stressed  the  need  to  set  up  Joint 
Investigation Teams. 

Finally, at their fourth meeting on 24 September 2018, firearms experts mostly discussed the 
results of the questionnaire sent  during the summer (see below the reference to  the targeted 
consultation). They identified specific actions to improve the involvement of Western Balkan 
Partners  in  the  multilateral  approach  to  the  fight  against  firearms  trafficking,  to  step  up 
operational  cooperation  (with  Europol  liaison  officers,  systematic  joint  risk  profiling, 
common  standards  for  exchange  of  ballistic  information),  and  more  training  through  expert 
visits, trainings on investigations, training of judges and prosecutors.  

76   Technopolis,  Ernst&Young,  VVA  Consulting,  Evaluation  of  the  Firearms  Directive,  15  December  2014, 

p.46 

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Annex 3. Methods and analytical model 

This  evaluation  relies  primarily  on  a  consultation  of  member  state  enforcement  authorities, 
Western  Balkan  partners,  EU  agencies,  and  the  international  organisations  (such  as  the 
Clearinghouse the United Nations Organisation on Drugs and Crime) involved on the ground.  

 Further analysis was hampered due to: 

 

 

the absence of harmonised, comparable and systematically collected data on firearms 
seizures, confiscations, destructions, surrenders and tracing activity,  

the  impossibility  to  identify  a  direct  causal  link  between  the  Action  plan  and  the 
expected outcomes of the reduction in firearms trafficking, firearms-related crime, and 
number of illicit weapons in circulation. 

The  evaluation  therefore  depended  mostly  on  qualitative  analysis.  It  took  into  account  the 
content and outcome of all the meetings that have taken place with these stakeholders during 
those  years,  such  as  the  Joint  meetings  of  EU  and  Western  Balkans  firearms  experts,  the 
meetings of the Western Balkan Experts, the meetings of the Firearms Platform (including the 
debriefing meetings following joint actions days), and the meetings of Small arms and Light 
Weapons  commissions  in  the  Western  Balkans.  Documents  produced  by  the  Clearinghouse 
were particularly valuable. 

The Commission relied heavily in the continuous feedback from law enforcement authorities 
themselves, within the Joint Committee between European Union Firearms Experts and South 
East Europe Partners Experts (see Annex 8 for the detail of the conclusions of each meeting). 

Responses  to  the  stakeholder  questionnaire  required  much  interpretation.  Respondents  often 
left blanks to certain questions, thus increasing the proportion of "don't know/no opinion". It 
was  often  necessary  to  interpret  replies  or  infer  answers  to  ensure  comparability.  Besides, 
most questions were drafted in qualitative terms, which meant that not all of them could be 
translated into a quantitative assessment. Some replies did not respond to the question asked. 
To mitigate the risks caused bythese problems, a meeting was called of the Joint Committee 
of firearms experts from the EU and south-east Europe partners. This meeting was held on 24 
September  2018  in  Brussels.  At  this  meeting  the  outcome  of  the  consultation  and  a  first 
analysis  of  the  replies  were  presented  and  discussed  and  the  Joint  Committee  confirmed  its 
results.  

The preparation of the  regional  roadmap  for a sustainable solution  to  the illegal  possession, 
misuse and trafficking of small arms and light weapons took place between 1st February 2018 
and 29 May 2018 at the initiative of the Ministries of Foreign Affairs of France and Germany, 
and was coordinated by  the Clearinghouse. Other organisations were also closely associated 
with  the  preparation  of  the  analysis,  including  the  Commission,  the  Firearms  Platform,  the 
EBCGA  and  Europol.  The  roadmap  focussed  on  developing  a  needs  assessment  for  the 
region,  and therefore  contributed to  a large extent in  the analysis of  current  challenges, and 
complemented the information gathered through the questionnaire. 

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On operational cooperation, a major source of information was the debriefing of Joint Action 
Days77 and the reports of the Action Leaders. The meeting documents and presentations made 
during  Western  Balkan  Experts  meetings78  also  vastly  contributed 
to  building  a 
comprehensive picture of the achievements of countries and stakeholders. 

Finally, the Commission also took into consideration a number of external studies conducted 
by independent organisations. They are listed below: 

  Firearms buyback in the Western Balkans,  Terry Pattar, Shaun Romeril, Chris Jagger, 

3 November 2016, IHS Consulting 

  Life-cycle  Management  of  Ammunition  –  Lessons  from  Bosnia  and  Herzgovina, 

Jovana Carapic and Paul Holtom, March 2018, Briefing Paper 

  Triggering  Terror:  Illicit  Gun  Markets  and  Firearms  Acquisition  of  Terrorist 

Networks in Europe, ed. Nils Duquet, Flemish Peace institute, 17 April 2018 

  SEPCA Region Threat Assessment, Europol, 12 April 2018, EDOC#958451 

  Strengthening  Resilience  in  the  Western  Balkans:  Mapping  Assistance  for  SALW 

Control, Small Arms Survey, September 2018. 

77   22-23 March 2017, 19 March 2018 

78   23-24 September 2014, 19-20 May 2015, 26-27 November 2015, 18-20 April 2016, 27-28 September 2016, 
8-9 December 2016, 18-19 May 2017, 23-24 November 2017, 30 May - 1 June 2018, 20-21 November 2018 

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Annex 4. Description of activities under the Firearms Platform 

Cooperation  with  the  Western  Balkans  has  been  part  of  the  Firearms  Platform  since  2013. 
Under the 2018 operational action plan, cooperation with the Western Balkans fell under the 
code  O.A.  4.1,  its  mission  was  described  as  to  "Continue  cooperation  with  Western  Balkan 
partner,  with  special  attention  to  Registered  Firearms  Dealer  (RFD)  and  their  potential  to 
supply into the criminal market." 

Over the years, the participation of member states and other players in this operational action 
evolved as set out in  the grid below: 

COM: European Commission 
AP W&E: Europol's Analysis Project 
Weapons and Explosives 
EEAS: European External Action 
Service 
EBCGA: European Border and Coast-
Guard Agency 
AL: Action Leader 
CAL: Co-Action Leader 
P: Participant 

2015 

2016 

2017 

P 

P 

P 
P 
P 
P 

P 

P 
AL 
P 

P 

AT 
BE 
BG 
CY 
CZ 
DE 
DK 
EE 
EL 
ES 
FI 
FR 
HR 
HU 
IE 
IT 
LT 
LU 
LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 
UK 
NO 
CH 
COM 
AP W&E 
EEAS 
EBCGA 

P 
P 

P 
P 

P 
P 

P 
CAL 
P 

P 
CAL 
P 

P 

P 

P 
AL 
CAL 

P 

CAL 

P 

CAL 
CAL 

AL 

CAL 
CAL 

P 

2018 
P 
P 
CAL 
P 
P 
P 
P 
P 
P 
AL 

P 
P 
P 

P 

P 
P 

P 
CAL 
CAL 

CAL 

CAL 
CAL 
P 
P 

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The information  contained  in  the operational  action  plans is  restricted, so the description of 
the activities mentioned here may not be comprehensive. 

In  2015,  the  objective  was  to  carry  out  one  joint  action  between  the  EU  and  the  Western 
Balkans. In 2016, the scope of the cooperation expanded to increase preparatory work for the 
joint action (intelligence phase) and step up cooperation with EU agencies. The Joint Action 
itself  focussed  on  buses  and  mini-vans  crossing  borders.  In  2017,  the  scope  was  further 
enlarged. Cooperation now attempted to improve the intelligence-led approach, and the joint 
action  focused  on  registered  firearms  dealers,  with  special  attention  given  to  checked 
deliveries and darknet investigations. In 2018, there was a substantial increase in the number 
of participants in the Action. At the same time, the Spanish Driver had to take over the role of 
Action Leader, in the absence of a volunteering Member State. This reflects the low degree of 
commitment in the Firearms Platform of several countries, who still favour bilateral action to 
multilateral cooperation. The Joint Action, while still focussing on the development of prior 
intelligence gathering, took place in  coordination with  the Firearms Platform in the areas of 
investigating Drugs Trafficking, Facilitation of Illegal Immigration and Document Fraud. 

The Joint Action Days  are testimony  to  the  changes in  operational  cooperation between the 
EU and the Western Balkans. The following table attempts to describe these changes. 

2015 

2016 

2017 

2018 

Focus 

 Partners involved 

Border controls on 
firearms 
smuggling in the 
bus/coach traffic 

6 WB 
10 MS: BE DE DK 
EL ES FR, HR,  NL 
RO SI SE UK 
+ NO 

Border controls 

Western Balkan 
region, EU 
member states  

Border crossing 
points and 
registered 
firearms dealers 

Joint activity 
(Firearms, Illegal 
Immigration and 
Drugs). 

6 WB 
13 MS: BG, DE, DK, 
EL, ES, FR, HR, HU, 
NL, RO, SE, SI, UK 
CH 

6 WB  
20 MS: AT, BE, CZ, 
DE, DK, EL, ES, FR, 
HU, HR, LV, PL, PT, 
RO, SI, SK. 

Europol, the 
EBCGA, CH, 
USATF, Interpol, 

June 2018 

TISPOL operation 
on land traffic 

Europol, the 
EBCGA 

MS Liaison 
Officers to get 
involved in the 
search for ongoing 
investigations that 
could be 
coordinated with 
the JAD 

Third parties and 
EU Agencies 
involved 

the EBCGA, 
USATF, 
Commission 

Intelligence phase 

June-August 2015 

Intelligence 
around bus tour 
operators on the 
routes WB – EU 
with focus on 
earlier seizures of 
firearms and 
known criminal 
links of the 
companies and 
company owners 

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2015 

2016 

2017 

2018 

Preparation 

September 2015 

August 2016  

May 2018 

Number of SIENA 
messages sent 
prior to JAD 

62 

85 

153 

340 

Dates 

1-4/10/2015 

27-29/01/2017 

17-18/11/17 

5-9/09/2018 

Technical facilities  Operation centre 

in Stockholm 
(Europol Mobile 
Office) 

Shared Operation 
Centre with 
TISPOL 

the EBCGA 
deployed in BG, 
EL, HR, HU 

Type of checks 

checks of vehicles 
and passengers 
(buses) 

border crossing 
points 

border crossing 
points and against 
registered 
firearms dealers 

Operation Centre 
The Hague + 
Europol mobile 
office in BiH. 44 
the EBCGA officers 
on the ground. 

border crossing 
points 

negligible 

95 

100 

257 

2 

48 

136 (26 during the 
JAD) 

Number of arrests 

1 

Unknown 

63 (illegal 
immigration 
facilitators and 
overstaying 
mainly) 

102 during prior 
investigations, 25 
during the JAD 
itself, 159 overall 

50 overall (9 for 
firearms during 
the JAD itself) 

Investigation 
between 4 EU 
Members (Croatia, 
Slovenia, Italy and 
Spain) on firearms, 
60 house searches 

24 investigations 

Not available 

Not available 

Not available 

Not available 

13 

56 

84 

66 

Number of SIENA 
messages sent 
during the JAD 

Number of 
seizures of 
firearms 

Follow-up 
investigations 

Number of 
convictions 

Number of SIENA 
messages sent as 
a follow-up to the 
JAD 

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Participants  to  the  Firearms  Platform  have  expressed  a  high  degree  of  satisfaction,  with  the 
results  of  the  Joint  Action  in  terms  of  cooperation.  This  demonstrates  that  the  Firearms 
Platform  has  the  capacity  to  coordinate  a  large  number  of  participants.  The  connections 
between  the  criminal  threats  that  were  involved  in  the  joint  action  dayswere  also 
demonstrated,  especially  the  connections  between  drugs  and  firearms  trafficking.  The 
significant  result  from  the  joint  action  days  is  the  large  amount  of  information  exchanged 
through the Operational Centre, and therefore cross-checked by the Western Balkan partners, 
EU  member  states,  third  Operational  parties,  Europol  and  Interpol.  The  joint  action  days 
helped Europol to confirm its status as the main analytical tool, for the investigative Units in 
the  EU.  Interpol  also  provided  substantial  added  value  through  its  powerful  databases  and 
world-wide  connections.  The  EBCGA  demonstrated  its  capacity  to  support  the  operational 
activities of the partners participating in the joint action days. 

The overview reflects a lack of harmonized reporting mechanism, which prevents comparison 
between the successive operations. 

EN 

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Annex 5. Description  of  activities  carried  out  by  the  South  Eastern  and  Eastern 

Europe Clearinghouse for the Control of Small Arms and Light Weapons 

Coordinating role of the Clearinghouse 

Since  2014  the  Clearinghousehas  organized:  (i)  regional  meetings  for  Strategic  and  policy 
level  decision  makers  (Regional  meetings  of  the  Small  Arms  Commissions  of  South  East 
Europe); (ii) meetings of tactical-operational level representatives from the judiciary and law 
enforcement  agencies  of  the  Western  Balkan  (the  South  East  Europe  Firearms  Expert 
Network). Representatives of the European Commission, EU Experts, the Firearms Platform, 
Europol,  and  the  EBCGA  are  regularly  invited  to  attend  and  shape  the  discussions  and 
outcomes of the meetings. 

With  the  political  and  financial  support  of  the  European  Union,79  SEESAC  has  been 
organizing the regional network of senior expert practitioners from Police Services, Customs 
Administrations  and  Prosecutors’  Offices  under  the  name  of  the  south-east  Europe  firearms 
experts network (Western Balkan Experts) since 2014.  

To date nine meetings of the Western Balkan Experts have been successfully organised across 
the  region.  All  of  these  meetings  have  provided  a  platform  for  improving  cooperation  and 
coordination  of  actions  among  the  institutions  involved  in  combating  firearms  trafficking  – 
both  at  the  national  and  regional  level.  Since  its  establishment  the  South-East  Europe 
Firearms  Experts  Network  was  used  to  promote  direct  cooperation  and  confidence  building 
amongst the EU and Western Balkan.  

National Focal Points 

The Clearinghouse uses financial and political assistance channeled to the region through the 
EU,80 to  help  all jurisdictions  in  the Western Balkans to  set  up the National  Firearms Focal 
Point.  This  assistance  is  being  handled  by  the  Ministries  of  Interior  of  Albania,  Bosnia  and 
Herzegovina, Kosovo*, Montenegro, Republic of Moldova, Serbia and North Macedonia.  

The Clearinghouse assessed the human resources, technology and processes in place in each 
one of the seven jurisdictions, in 2017. Based on this assessment, the Clearinghouse drafted a 
bespoke report recommending steps to be taken to establish the Firearms Focal Point. The key 
findings of the assessment are that it is absolutely possible to set up functioning Focal Points 
in each of the Western Balkans jurisdictions, under the auspices of the Ministries of Interior. 
To  accomplish  this  the  Clearinghouse  proposed  to  provide  targeted  equipment,  training  and 
advices. This would aim at improving the collection, use, analysis and sharing of information 
on the legal and illegal possession, use and trafficking of small arms.  

The Clearinghouse provided individual advice how to staff each Focal Point, where it should 
be located and how it should be structured. The cornerstone of the recommendations provided 
to the Western Balkan partners was the Best Practice Guidance for the Creation of National 

79   Council Decision (CFSP) 2016/2356 of 19 December 2016 in support of SEESAC disarmament and arms 
control activities in South-East Europe in the framework of the EU Strategy to combat illicit accumulation 
and trafficking of SALW and their ammunition, OJ L 348, 21.12.2016, p. 60–71. 

80   Council Decision (CFSP) 2016/2356 of 19 December 2016 in support of SEESAC disarmament and arms 
control activities in South-East Europe in the framework of the EU Strategy to combat illicit accumulation 
and trafficking of SALW and their ammunition, OJ L 348, 21.12.2016, p. 60–71. 

EN 

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Firearms Focal Points (NFP). This guidance was developed by the European Firearms Experts 
Group  which  had  originally  issued  guidance    for  the  creation  of  National  Firearms  Focal 
Points within EU member states in support of the EU Commission Report dated 02.12.2015 
COM  (2015)  624,  and  EU  Policy  Cycle  2014  –  2017  Operational  Action  OA 1.3  of  the 
Firearms Platform.  

On training, based on the assessments of all seven jurisdictions a set  of  specialised training 
course  modules  was  developed  for  operational  analysts,  criminal  investigators,  criminal 
intelligence  analysts,  and  forensic  investigators.  Future  Focal  Points  staff  from  all 
jurisdictions were trained in Advanced Ballistic Intelligence & Threat and Risk Assessment; 
Core  Intelligence  Analysis  Training;  IBM  i2  Analyst’s  Notebook  Training,  and  Intelligence 
Collection Plan & Intelligence Analysis.  

The trainings and newly acquired skills will be supported by providing: (i) cost-effective IT 
analytical tools (i2, Analyst Notebook, iBase, etc.), (ii) basic IT equipment necessary for the 
fusion  of  data  (such  as  servers,  etc.),  technical  advice  on  how  to  enable  fusion  of  data 
necessary for the Firearms Platform, and  basic equipment and tools for the forensic ballistic 
investigators (double casting kits, forensic tools and equipment).  

As  of  10  September  2018,  the  Clearinghouse  received  official  written  notifications  from 
several  police  directorates  saying  that  they  accepted  the  assessment  reports  and  its 
recommendations and would nominate people from their organization to serve in the firearms 
focal points. These organizations are : Albanian State Police, Kosovo* Police Service, Police 
Directorate of Montenegro, the General Police Inspectorate of the Republic of Moldova, and 
the Ministry of Interior of North Macedonia. 

Training activities conducted by SEESAC 

Goal  3,  Action  1,  point  1  –  Through  the  platform  that  convenes  all  the  Small  Arms 
Commissions of the South East Europe (the inter-ministerial body convening all institutions 
relevant  for  Small  Arms  control  at  the  national  level)  the  Clearinghouse  is  assisting  the 
government institutions in South East Europe in coordinating the small arms control activities, 
promoting  EU  standards  in  Small  Arms  control,  and  the  implementation  of  the  of  national 
strategic master plans and action plans covering illicit trafficking in firearms and ammunition.  

Goal 3, Action 1, point 2 – The Clearinghouse helped governments to collect information on 
existing national strategies in the fight against illicit trafficking in firearms. It did this through 
the  comprehensive  data  collection  contained  in  the  impact  and  perception  survey  on  Small 
Arms control. A detailed analysis of data from this survey will be completed by mid-2019.  

Goal  3,  Action  1,  point  3  –  the  Clearinghouse  continues  to  support  national  Small  Arms 
commissions  –  horizontal  firearms  coordination  bodies,  as  well  as  the  establishment  of  the 
Firearms Focal Points – an enforcement structure combining the resources of Police, Customs 
and Prosecutors’ offices.  

Goal  3,  Action  1,  point  4  –The  Clearinghouse  helps  national  and  international  actors  to 
coordinate  their  efforts  in  non-proliferation  and  anti-trafficking.  Since  2014,  its  the  most 
noteworthy  coordination  efforts  are:  the  Clearinghouse  coordinating  all  firearms  related 
actions  in  South  East  Europe  under  the  Integrative  Internal  Security  Governance;  the 
Clearinghouse  supporting  the  Franco-German  local  coordination  efforts  in  Western  Balkan; 
and the Clearinghouse supporting the Western Balkan institutions in developing the Roadmap 

EN 

  EN 

 
 
and  their  individual  action  plans  while  at  the  same  time  coordinating  contribution  from 
international actors to the roadmap and national action plans.  

On  the  development  and  implementation  of  the  overall  regional  strategy,  since  2002  the 
Clearinghouse has been the executive arm of the Regional Implementation plan  – a regional 
Small  Arms control strategy. Besides this document under the  Franco-German initiative the 
Clearinghouse  has  helped  international  partners  and  institutions  in  the  Western  Balkans  to 
develop  a  regional  Roadmap  (Roadmap  for  a  sustainable  solution  to  the  illegal  possession, 
misuse  and  trafficking  of  Small  Arms  in  the  Western  Balkans  by  2025).  This  regional 
roadmap  has  clear  benchmarks  and  indicators  agreed  by  all  actors  developed  in  order  to 
monitor and assess the level of national/regional cooperation progress.  

Goal  3,  Action  1,  point  5  –  Since  2014,  the  Firearms  Platform  and  the  Clearinghouse  have 
organized  twice-yearly  meetings  of  the  south-east  Europe  Firearms  Expert  Network  
throughout the south-east Europe region. These meetings have received the financial support 
from the EU. They have also receive political support from local EU delegations and expert 
contribution  from  the  EFE  and  DG  HOME.  The  Clearinghouse  makes  extensive  efforts  to 
ensures that the experts of this network contribute their knowledge and expertise in all EU-led 
meetings and operations (meetings organized by DG HOME, the Firearms Platform, Europol, 
TAIEX, etc.).  

Goal  3,  Action  1,  point  6  –  The  Clearinghouse  continuously  uses  all  of  its  meetings 
(especially Regional  Small Arms Commissions Meetings) to practically help the  institutions 
of  South  East  Europe  to  harmonize  their  legislation  with  the  EU  standards,  as  well  as  to 
successfully implement the EU standards.  

Goal  3, Action 1, point 7  – All  of the meetings  organized and documents  developed by the 
Clearinghouse  are  practically  contributing  to  the  institutions  of  South  East  Europe  to 
implement  the  relevant  United  Nations  Conventions,  including  the  United  Nations  Firearms 
Protocol. 

EN 

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Annex 6. Training activities 

Firearms-related training amount to a modest part of all trainings provided by CEPOL (chart 
below).  Among  those,  Western  Balkan  partners  have  been  participating  since  2016.  This 
assessment is therefore based on the years 2016, 2017 and 2018 (with figures up to date until 
01/10/2018).  Figures  show  an  uneven  participation  in  CEPOL  trainings  by  member  states, 
with no specific identifiable trend, and a stable and low rate of participation. Two countries 
stand out in participation: Greece and Portugal, with a substantially higher number of trainees 
attending  webinars  (respectively  63  and  13  webinar  trainees  on  average).  Having  adjusted 
figures  to  take  into  consideration  those  exceptions,  member  states  have  sent  on  average  3.8 
participants  each  year  to  all  trainings  (residential  trainings  and  webinars),  while  Western 
Balkan Partners sent 2.7 participants. The differential appears to be relatively limited. Figures 
show  however  that  the  number  of  participants  sent  is  not  proportional  to  the  size  or  the 
relative wealth of partners.  

CEPOL covered the expenses of participants of each Western Balkan partners to its activities 
(6 in 2016 and 2017 and 4 in 2018), and they sent twice more participants than the amount 
funded.81  By  comparison,  EU  member  states  sent  1.62  to  1.69  times  more  trainees  than  the 
number of participants funded by CEPOL.  

Source: CEPOL, 2018 

81   Source: CEPOL. 

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Participation of EU member states and Western Balkan partners in firearms-related residential trainings and webinars 

Source: CEPOL figures.    * figures for 2018 are based on data provided until 01/10/2018. 

Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111 

 
 
 
 
Annex 7. Conclusions  of  the  meetings  of  the  Joint  Committee  between 
European  Union  Firearms  Experts  and  South  East  Europe  Countries 
Experts 

The First meeting of the Joint Committee between the European Union's and South 
East Europe Countries'82  Firearms Experts. 

Bruxelles, 29 January 2016 

The  European  Union  and  South  East  Europe  Countries  national  firearms  experts 
exchanged  views  in  a  spirit  of  openness  about  the  main  actions  related  to  the 
implementation  of  different  goals  which  are  included  in  the  Joint  action  plan  on  illicit 
trafficking in firearms (2015-2019) adopted in December 2014. 

They noted that illicit trafficking in firearms is a serious trans-border crime at the nexus 
of  other  forms  of  illicit  traffic  (drugs,  smuggling,  THB…)  and  terrorism  that  can 
therefore be tackled more efficiently only by a strong and effective cooperation amongst 
neighbouring countries by sharing intelligence, best practices and expertise. For example, 
particularly in case of  serious crime or major terrorist attacks threat, regional dedicated 
ad hoc operative joint teams can be set up between two or several countries, as proposed 
during the last WB/UE forum of Sarajevo (December 2015). 

They have decided to enlarge the above mentioned Joint action plan to illicit explosives. 

They noted the common achievements in 2015 and agreed to improve their efforts in the 
fight against illicit trafficking in firearms to: 

1) Cooperation among agencies. 

  Ensure that Europol and Frontex and all their services and tools such as SIENA 
are  utilized  by  all  relevant  national  administrations.  Further  efforts  should  be 
made  in  particular  to  participate  in  EUROPOL  Focal  Point  Firearms  and  to 
provide  relevant  information  related  to  specific  threats  on  illicit  firearms 
trafficking with those Agencies.  

  Strongly  advise  member  states  and  third  countries  to  share  their  weapon 
trafficking  related  intelligence  during  on-going  operation.  This  transparency  of 
intelligence sharing could prevent armed attacks in all participating countries. 
Increase  the  insertion  of  information  on  firearms  into  Interpol's  Illicit  Arms 
Records and tracing Management System (iARMS).  

 

  Call for a joint meeting EFE/Western Balkans will be called every year to discuss 
topics  of  common  interest  in  the  fight  against  illicit  trafficking  of  firearms  by 
using possibly the EU funds to ensure proper participation of firearms experts.  

82 The use of the term "countries" does not imply recognition of statehood. 

Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111 

 
 
 
 
                                                 
  Call  for  additional  coordination  and  complementarity  of  activities  amongst,  the 
South East Europe Firearms Expert Group (SEEFEG) and the South Eastern and 
Eastern  Europe  Clearinghouse  for  the  Control  of  the  Small  Arms  and  Light 
Weapons  (SEESAC)  together  with  other  EU  funded  projects  in  the  area  of 
trafficking of firearms.  

  Assure the commitment of all partners involved in this plan in operational actions 
related to Western Balkans within EMPACT FIREARMS and to study possibility 
to be part of EMPACT FIREARMS of countries interested on it. 

2) Operational Cooperation 

  Draft  a  template  with  minimum  standard  intelligence  requirements  in  line  with 
similar initiatives (European regional Initiatives, Interpol, UNODC) and test it by 
organising a dedicated Pilot Project on data collection. 

  Launch  a  study  on  exchange  information  systems  in  order  to  make  an  in-depth 
evaluation  of  legal  obstacles  which  tackle  the  information  collection  and  define 
possible  solutions 
the  strategic  and  operational  analysis  of 
information. 

to  improve 

  Carry  out  at  least  one  joint  action  focused  on  the  illicit  trafficking  in  firearms, 
components  and  ammunition  and  explosives  with  a  regional  approach. 
Considering the importance of a best preparatory phase to define way of working 
and  reduce  the  risk  of  shortcoming,  at  least  one  preparatory  meeting  and  a 
debriefing will be organised by the coordinator of the operation.  

  Launch  a  feasibility  study  of  a  proposal  for  the  continuation  of  voluntary 
surrender/legalisation  of  firearms  programs  throughout  Western  Balkans  with 
possibility for a financial assistance of the EU. 

3) Training 

  Assess  previous  training  initiatives  and  organise  dedicated  common  training 
actions to improve awareness about the fight against illicit trafficking in firearms, 
updated trends and best practices to tackle it.  

  Study possibility for partners involved in this plan to attend CEPOL courses 

dedicated to firearms, especially the one is going to be organised in 2016 about 
Western Balkans. The exchange programme for officials will be a particular 
option to be considered.  

4) Traceability of weapons  

  Develop  Standard  Operative  Procedures  to  trace  all  seized  firearms  and 
ammunition in strong cooperation with SEESAC and using relevant databases. 
  Extend  the  use  of  iTRACE,  the  European  Bomb  Data  System  (EBDS)  and  the 
Europol  Analysis  System  while  ensuring  the  full  use  of  its  Focal  Point  on 
firearms. 
5) Reactivated Weapons 

  Evaluate  the  recent  EU  legislation  on  the  deactivation  standards  and  assess  the 
possibility  for  the  inclusion  of  similar  standards  in  the  national  legislations  of 
SEEC.  

58 

 
  Evaluate the threat and modus operandi of convertible weapons within and from 

South East Europe. 

6) Forensic examination 

  Consider  the  use  and  benefits  of  ballistic  examination  for  operational  and 
strategic  purposes.  Assess  possible  option  for  an  exchange  of  ballistics' 
information  through  a  dedicated  platform,  studying  possibilities  to  join  IBIN 
system. 

  Launch a feasibility Study exchanging the forensic capabilities of the participants  

to investigate the explosives and to share the relevant intelligence.   

  Propose  a  dedicated  action  to  study  the  impact  of  new  technologies  in  the  fight 

against firearms trafficking. 

59 

 
 
 
Second meeting of the Joint Committee between European Union Firearms Experts 
(EFE) and South East Europe Countries Experts (SEEFEG) 

Bruxelles, 30 November 2016  

Following  the  conclusions  of  the  Joint  Committee  between  the  European  Union's  and 
South  East  Europe  Countries'83  Firearms  Experts  which  was  held  in  Bruxelles  on 
29 January  2016,  the  members  of  the  EU  Firearms  Experts  (EFE)  and  the  South  East 
Europe Firearms Experts Group (SEEFEG) had the first joint meeting to discuss topics of 
common interest in the fight against illicit trafficking in firearms.  

They  presented  the  structures  of  the  two  groups  and  relevant  actions  which  have  been 
developed  in  2016.  They  considered  important  to  coordinate  the  structure  of  the  two 
groups to ensure a mirror approach in choosing topics and developing analysis between 
EU and SEE experts. They noted the important activity run by SEESAC within the South 
East Europe Firearms Expert Network (SEEFEN) and acknowledged the need to ensure a 
continuous  and  effective  cooperation  with  SEEFEN  to  improve  complementarity 
amongst neighbours. 

They  favourably  considered  the  support  of  EU  Members  States  under  EU  Policy  cycle 
Firearms Priority (EMPACT). 

They noted the common achievements in 2016 and agreed to continue their efforts in the 
fight against illicit trafficking in firearms to: 

  Support  EMPACT  operational  action  3.5  continue  enhancing  cooperation  in 
investigations  of  transborder  crimes,  coherently  with  the  initiatives  aiming  at 
enhancing  operational  law  enforcement  cooperation,  promoted  within  the 
Integrative Internal Security Governance (IISG). 

  Enhancing the exchange of information at regional level and with member states 
involving  different  organisations  including  Europol  on  the  production  and 
stockpiling  and  trafficking  in  firearms  and  ammunition  aiming  also  to  develop 
more effective investigative and intelligence standards 

 

Improve cooperation with Europol and Frontex by: 

  Facilitating the secondment by Europol  of liaison officers in the region; 
  Exchanging strategic information with Europol and Frontex in order to enable 

the two agencies to draft  strategic report and conduct risk analysis; 

  Ensuring that Europol and Frontex and all their services are fully utilized by 
all  relevant  national  administrations.  Special  focus  will  be  given  to  take 
advantage of EUROSUR related services for example to monitor vessels and 
prevent illegal trafficking in firearms to/from conflict and post conflict zones 
or countries under embargo.  

83 The use of the term "countries" does not imply recognition of statehood. 

60 

 
 
 
 
 
 
                                                 
 

 In order to improve joint work on main topics of common interest, to share 
strategic objectives and working groups between EFE and SEEFEG/SEEFEN. 
EFE will invite  members of SEE partners to joint the relevant working groups 

  Carry  out  at  least  one  joint  action  per  year  focused  on  the  illicit  trafficking  in 
firearms,  components  and  ammunition  and  explosives  with  a  regional  approach 
and  send  the  assessment  to  Europol  and  Frontex  and  all  relevant  partners  to 
improve knowledge and intelligence.  

  Assure the commitment  of partners   involved in  this  plan in  operational  actions 
related to Western Balkans within EMPACT FIREARMS (OA 2.1) and associate 
Western Balkans  partners to be part of EMPACT FIREARMS in the context of 
the EU policy cycle priorities on the fight against firearms trafficking. 

  Make more efficient the coordination and complementarity of activities amongst, 
the  South  East  Europe  Firearms  Expert  Group  (SEEFEG),    the  South  East 
Firearms Expert Network (SEEFEN)  with the EFE by: 

  Carrying  on  a  joint  project  to  map  out  all  the  obstacles  in  deepening 
cooperation  and  consequently  pursuing  further  harmonization  of  legislation 
and  developing  good  practices  in  the  area  of  operational  cooperation  and 
risk/threat analysis, as well as judicial cooperation. 

  Encouraging  the  South  East  Europe  partners  to  continuously  destroy  all  the 
surplus  firearms.  Emphasis  should  be  given  to  the  public  destruction  of 
firearms  confiscated  through  policing  and  amnesty  in  order  to  reinforce  the 
awareness raising and reduce unauthorized access. 

  Emphasizing  the  security  and  safety  of  stockpiles  with  a  view  that 
unauthorized  access  to  firearms,  ammunition,  explosives,  and  it  precursors 
should  be  vigorously  prevented  and  all  transgressions  promptly  investigated 
and sanctioned. Towards that end, as well as in order to further strengthen the 
investigative  capacities  in  the  region,  the  EU  will  provide  the  necessary 
assistance to further advance the establishment of Firearms Focal Points.  

  Extend the use of all available tools for tracing firearms, including iTRACE, 

iARMS and the Europol Analysis System while ensuring the full use of the Focal 
Point on firearms. 

  Continue and assess previous training initiatives and organise dedicated common 
training actions to improve awareness about the fight against illicit trafficking in 
firearms, updated trends and best practices to tackle it. The exchange programme 
for  officials  will  be  a  particular  option  to  be  considered  (i.e.  specific  analysts 
training).  

61 

 
 
 
 
 
 
 
 
 
 
  Support  UNODC  mapping  project  on  minimum  standard  data  collection  with 
regard  to  seized  firearms      by  organising  a  dedicated  Pilot  Project  on  data 
collection. 

  Launch  a  feasibility  study  of  a  proposal  for  the  continuation  of  voluntary 
surrender/legalisation of firearms programs throughout Western Balkans and the 
EU  member  states  with  possibility  for  a  financial  assistance  of  the  EU.  Special 
emphasis shall be given to the inputs from the SEE and SEESAC taking into the 
account the post-conflict proliferations specificities.   

  Evaluate the threat and modus operandi of convertible weapons within and from 
South East Europe based on the outcome of the Bosphorous operation organised 
under EMPACT Programme.  

  Evaluate an agreed procedure for an exchange of ballistics' information through a 
dedicated  platform,  studying  possibilities  to  join  an  automated  network  ballistic 
identification system. 

62 

 
 
 
 
 
 
 
Third meeting of the Joint Committee between European Union Firearms Experts and 
South East Europe Countries Experts  

Bruxelles, 26 January 2018 

In  the  framework  of  the  EU  Policy  cycle  2018-2021,  EMPACT  FIREARMS,  the 
members of the EU Firearms Experts and the South East Europe Firearms Experts Group 
have  had  the  second  joint  meeting  to  discuss  topics  of  common  interest  in  the  fight 
against illicit trafficking in firearms.  

They assessed the common achievements in 2017 and agreed to continue their efforts in 
the fight against illicit trafficking in firearms by developing the actions as follows: 

  Provide a coherent framework for cooperation between the European Union and 
the  South  East  Europe  region  by  ensuring  permanent  and  comprehensive 
inclusions  of  the  initiatives  to  fight  against  firearms  trafficking  as  defined  by 
EMPACT Firearms and EU/WB action plan into the Integrative Internal Security 
Governance  (IISG)  in  the  Western  Balkans  and  its  three  pillars  on  counter-
terrorism, fight against serious and organised crime and border security.  

 

In order to assess the different initiatives carried out between EU member states 
and Western  Balkans  partners as defined in  the  EU/WB action plan 2015-2019, 
an in-depth evaluation will be carried out in 2018. The Commission will circulate 
a  questionnaire  by  the  end  of  February  2018  to  all  EU  and  WB  competent 
administrations  to  collect  information  about  the  initiatives  carried  out  by  the 
countries  according  to  the  action  plan,  EMPACT  Firearms  activities  and  the 
conclusions of all relevant meetings. The relevant countries will send the replies 
to the Commission by the end of June 2018. The Commission will draft a report 
to inspire the draft new action plan to be adopted in 2019. 

  Ensure the commitment of countries involved in this plan in operational  actions 
related to Western Balkans within EMPACT FIREARMS and associate Western 
Balkans partners to EMPACT FIREARMS in the context of the EU Policy cycle 
priorities on the fight against firearms trafficking. 

  Support EMPACT operational actions and ensure a strict coordination with other 
different  bilateral,  regional  or  multilateral  initiatives  to  reduce  the  risk  of 
overlapping and improve an efficient cooperation in investigations of trans-border 
crimes,  coherently  with  the  initiatives  aiming  at  enhancing  operational  law 
enforcement  cooperation,  in  line  with  the  Council  Conclusions  of  13  December 
201684  and according to the following EMPACT guidelines:   

o  Carry out at least one Joint Action Day supported by Firearms EMPACT, 
in  strong  coordination  with  other  EMPACT  Threats  such  as  fighting 

84 

 13 December 2016 Council Conclusions which encourage "the need for effective and intense regional 
and  international  cooperation,  including  with  EUROPOL  and  EUROJUST,  without  prejudice  to 
member states' positions on status".   

63 

 
 
 
 
 
                                                 
illegal immigration and drug trafficking, based on the intelligence shared 
by  the  WB  partners  and  EU  member  states  with  Europol’s  Analysis 
Project Weapons and Explosives. In particular a standard operational plan 
to define the JAD will be drafted by Spain. This Operational action plan 
will map out all the obstacles in deepening cooperation and consequently 
developing  good  practices  in  the  area  of  operational  cooperation  and 
risk/threat  analysis,  as  well  as  judicial  cooperation.  A  JAD  coordinator 
should be appointed in each country in order to steer and improve tactical 
coordination of operational  activities. Special consideration can be  given 
in  the  business  case  to  develop  parallel  investigations  in  the  EU  and  the 
Western Balkan according to the information gathered during the JAD. To 
provide assistance, an Operation Centre will be set up in Europol HQ, in 
order  to  gather  and  analyze  the  intelligence  received,  having  a  real-time 
exchange of information.  
improve the use of SIENA as a real practical tool to exchange information 
in a secure way at multilateral and bilateral level carried out between WB 
partners and the EU. WB partners (beyond Albania and Serbia) are invited 
to  join  as  associated  members  the  Analysis  Project  Weapons  and 
Explosives  so  as  to  make  better  use  of  Europol’s  tools  and  support 
services. 

o 

  Put  in  place  by  the  end  of  2019  in  all  EU  member  states  and  Western  Balkans 
partners a National Focal Point on firearms trafficking, as stated in the action plan 
2015-2019 and EMPACT Firearms’ OA 1.2. These Focal  Points will coordinate 
all firearms-related actions and will work on a similar basis, standardized through 
the EFE Best Practices Guidance. 

  Make good use of the police cooperation and prosecutors network components of 
the  IPA  Multi-Country  project  supporting  the  IISG,  managed  by  GIZ  and  the 
Italian Ministry of Interior, aimed at supporting WB partners in investigations. 

  Support the UNODC mapping project on minimum standard data collection with 
regard to seized firearms, which is funded by the EU. All EU member states and 
Western Balkans partners will provide comprehensive data on seizures of 
weapons. 

  EMPACT’s  Action  leader,  in  cooperation  with  WB  partners,  will  evaluate  the 
threat  and  modus  operandi  of  convertible  and  reactivated  weapons  within  and 
from  South  East  Europe  based  on  the  outcome  of  the  “Bosphorus”  and  “Mars” 
operations organised under the EMPACT Programme. Particular attention will be 
paid  to  registered  firearms  dealers  and  their  potential  to  supply  the  criminal 
market. 

  Continue and assess previous training initiatives and organise dedicated common 
training actions to improve awareness about the fight against illicit trafficking in 

64 

 
 
 
 
 
 
firearms,  updated  trends  and  best  practices  to  tackle  it.  The  CEPOL  exchange 
programme for officials will be a particular option to be considered (i.e. specific 
analysts training). 

Improve  cooperation  with  Europol,  Eurojust  and  Frontex  by  involving  them, 
together  with  EU  member  states  and  Western  Balkan  partners 
the 
implementation of Joint Investigation Teams (JIT), notably enabling new funding 
possibilities  and  enhancing  police  and  judicial  cooperation,  and  where  possible 
using the support to IISG project where appropriate in the pre-JIT work. 

in 

In  order  to  improve  joint  work  on  main  topics  of  common  interest,  to  share 
strategic  objectives  and  working  groups  between  EFE  and  SEEFEG/SEEFEN, 
EFE  will  invite  members  of  South  East  Europe  partners  to  participate  in  the 
relevant meetings and work streams. 

 

 

65 

 
 
 
 
 
 
Fourth meeting of the Joint Committee between European Union Firearms Experts 
and South East Europe Countries Experts  

Bruxelles, 24 September 2018 

In  the  framework  of  the  EU  Policy  cycle  2018-2021,  EMPACT  FIREARMS,  the 
members of the EU Firearms Experts and the South East Europe Firearms Experts Group 
met  for  the  third  time  to  discuss  topics  of  common  interest  in  the  fight  against  illicit 
trafficking in firearms.  

The meeting focused on the evaluation of the action plan on firearms trafficking between 
the EU and the South East Europe Region.85 

The  European  and  South  East  Europe  Firearms  experts  consider  that  the  following 
measures  would  help  towards  improving  cooperation  in  the  fight  against  firearms 
trafficking: 

Process and involvement of Western Balkan Partners in the multilateral approach 
to the fight against firearms trafficking: 

  Translate at operational level the commitments taken at political level.  
  Establish  a  specific  firearms-related  Serious  and  Organised  Crime  Threat 

Assessment (SOCTA) for the Western Balkans. 

  Western  Balkan  Partners  can  attend  all  EMPACT  strategic  meetings  (including 
OAP drafting) and can become (in agreement with the EMPACT Driver) Action 
Leader, Co-leader or participant. Involve them immediately. 

Operational cooperation 

  Finalise the establishment of National Firearms Focal Points in all countries, with 

 

appropriate direct connection and access rights to SIENA. 
Inform  EMPACT  systematically  about  bilateral  activities:  twinnings,  trainings, 
exchanges, joint investigations.  

  To  improve  exchanges  of  information  with,  and  the  quality  of  the  work  of 
Europol, mainstream the use of SIENA for their exchanges between countries and 
with Europol (through direct involvement of the Analysis Project "Weapons and 
Explosives").  

  Step up the role of Europol liaison officers in the Western Balkans, to reach out to 
Western Balkan partners and national EU liaison officers in the Western Balkans 
and raise awareness about the role of EMPACT and of Europol. 

  Enhance the supportive role of EMPACT and Europol for sharing of information 

and JITs taking place between Western Balkan partners only. 

  Step up and systematise Joint Risk profiling, in order to provide improved input 
for  future  Joint  Action  Days  and  Joint  Investigations.  Encourage  posting  of  EU 
officers in control teams in the Western Balkans during JADs, and vice-versa. 

85

  14 November 2014, Council Document 15516/14. 

66 

 
 
                                                 
 
  Agree  on  common  standards  to  increase  the  exchange  of  ballistics  information 
exchanges  and  systematic  tracing  of  weapons  seized  between  the  EU  and  the 
Western Balkans.  

Capacity-building 

  Carry  on  and  increase  expert  visits,  within  EMPACT  Firearms,  through  the 

 

 

TAIEX twinning programmes.  
Increase  exchanges  of  law  enforcement  officers  to  enable  mutual  learning  and 
develop networks. 
Increase  the  trainings  on  firearms  investigations.  Ensure  full  complementarity 
between SEESAC-managed trainings and CEPOL ones. Improve the selection of 
trainees to focus on the investigators. 

  Step  up  the  training  of  prosecutors  and  judges  and  develop  operational 
agreements  with  Eurojust.  Set  up  a  network  of  national  firearms  specialist 
prosecutors. 

  Complete  the  upgrade  of  national  legislation  to  close  up  any  legal  loopholes, 
ensure  full  traceability  of  firearms  and  their  essential  components,  and  avoid 
illicit conversion of reactivation of weapons. 

Recommendations on the outcome of the action plan 2015-2019 and proposal for the 
future 

A possible future renewed action plan for the period after 2019 should: 

-  be merged with the Regional Roadmap on combatting illicit arms trafficking in 

- 

the Western Balkans 
include a dedicated budget with clear budget lines for individual actions, 
managed partly by EMPACT and partly by SEESAC and provide for a more 
efficient use of available EU funds (EMPACT, IPA, SEESAC funding) 

-  Engage  into  a  reflexion  on  streamlining  existing  structures  (EFE,  EMPACT, 
SEEFEN, SEEFEG, SALW Commissions), to ensure that operational cooperation 
takes place within EMPACT Firearms.   

67 

 
 
 
 
 
Annex 8. List of National action plans adopted by Western Balkan Partners 

Albania 

Strategic Master Plan 

National action plan 

National Roadmap 

Bosnia and Herzegovina 

Strategic Master Plan 

National action plan 

National Roadmap 

Kosovo* 

Strategic Master Plan 

National action plan 

National Roadmap 

Montenegro 

Strategic Master Plan 

National action plan 

National Roadmap 

North Macedonia 

Strategic Master Plan 

National action plan 

National Roadmap 

Serbia 

Strategic Master Plan 

National action plan 

National Roadmap 

Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111 

 
 
 
 
Annex 9. General overview of activities carried out 

Date 

Category 

Organiser 

Subject 

11-13 May 2015 

Study Visit 

Sweden 

TAIEX  Study  Visit  for  RS  on  fighting  the  illicit  trafficking  in  firearms 
(Stockholm) 

23-24 September 2014 

SEEFEN/SEEFEG 
Meeting 

SEESAC 

1st SEEFEN Meeting (Durres) 

25-26 February 2015 

Workshop 

17-19 March 2015 

Workshop 

BiH 

BiH 

TAIEX Workshop on the harmonisation of regulations on weapons (Sarajevo) 

TAIEX  Workshop  on  the  Fight  against  Illicit  Trafficking  in  Firearms  (Banja 
Luka) 

23-24 April 2015 

Expert Mission 

RS 

TAIEX Expert Mission on the fight against trafficking in firearms (Belgrade) 

19-20 May 2015 

SEEFEN/SEEFEG 
Meeting 

SEESAC 

2nd SEEFEN Meeting (Belgrade) 

20-21 October 2015 

Study Visit 

21-22 October 2015 

Study Visit 

IT 

SL 

TAIEX Study Visit for RS on Legal Framework of Deactivated Firearms (Italy) 

TAIEX Study Visit for ME on traces of the fire, explosives and incidents related 
criminal offences (Ljubljana) 

26-27 November 2015 

SEEFEN/SEEFEG 
Meeting 

SEESAC 

3rd SEEFEN Meeting (Budva) 

Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111 

 
 
 
 
Date 

Category 

Organiser 

Subject 

29 January 2016 

Joint Committee 

European 
Commission 

Joint  Committee  between  European  Union  Firearms  Experts  and  South  East 
Europe Countries Firearms Experts (Brussels) 

18-20 April 2016 

SEEFEN/SEEFEG 
Meeting 

SEESAC 

4th SEEFEN Meeting (Sarajevo) 

18-19 April 2016 

Joint Action 

INTERPOL 

Operation Balkan Trigger 

25-26 April 2016 

Workshop 

BiH 

TAIEX Workshop on the Fight against Illicit Trafficking in Firearms (Sarajevo) 

20-23 June 2016 

Training 

CEPOL 

(Portugal) 

August 2016 

JAD 

EMPACT (Action 
Leader SE) 

JAD 2016 planning meeting  

13-16 September 2016 

Training 

CEPOL 

WB Firearms course (Zagreb) 

27-28 September 2016 

SEEFEN/SEEFEG 
Meeting 

SEESAC 

5th SEEFEN Meeting (Chisinau) 

17 November 2016 

Webinar 

22-24 November 2016 

Training 

CEPOL 

CEPOL 

(Budapest) 

29-30 November 2016 

Workshop 

RS 

TAIEX Workshop on Cooperation within the South East European Expert Group 
on Firearms (Belgrade) 

30 November 2016 

Joint Committee 

European 
Commission 

Joint  Committee  between  European  Union  Firearms  Experts  and  South  East 
Europe Countries Firearms Experts (Brussels) 

70 

 
 
Date 

Category 

Organiser 

Subject 

8-9 December 2016 

SEEFEN/SEEFEG 
Meeting 

SEESAC 

6th SEEFEN Meeting (Budva) 

14 March 2017 

Webinar 

CEPOL 

22-23 March 2017 

JAD 

EMPACT (Action 
Leader UK) 

JAD 2016 debrief (Bosnia)  

4-7 April 2017 

Training 

CEPOL 

(Portugal) 

18-19 May 2017 

SEEFEN/SEEFEG 
Meeting 

SEESAC 

7th SEEFEN Meeting (Jahorina) 

3-5 July 2017 

Training 

CEPOL 

(Croatia) 

July 2017 

JAD 

August 2017 

Seminar 

EMPACT (Action 
Leader UK) 

EMPACT (Action 
Leader UK) 

JAD Coordination meeting (Europol HQ) 

Knowledge-sharing seminar (UK)?? 

12-15 September 2017 

Training 

CEPOL 

(Budapest) 

14-15 September 2017 

Workshop 

BiH 

TAIEX Workshop  on the Harmonisation  of Weapons  Legislation in  Bosnia and 
Herzegovina with the International Standards (Sarajevo) 

September 2017 

JAD 

EMPACT (Action 
Leader UK) 

JAD Preparation meeting (Bosnia) 

71 

 
 
Date 

Category 

Organiser 

Subject 

17-18 November 2017 

JAD 

EMPACT (Action 
Leader UK) 

Joint Action Day  

Study visit 

EMPACT (Action 
Leader UK) 

UK 

23-24 November 2017 

SEEFEN/SEEFEG 
Meeting 

26 January 2018 

Joint Committee 

SEESAC 

8th SEEFEN Meeting (Skopje) 

European 
Commission 

Joint  Committee  between  European  Union  Firearms  Experts  and  South  East 
Europe Countries Firearms Experts (Brussels) 

1 February 2018 

Roadmap 

FR/DE 

High-Level  Conference  of  Deputy  Ministers  of  the  Interior  and  Foreign  Affairs 
(Podgorica) 

19 March 2018 

JAD 

23 March 2018 

3-6 April 2018 

17-23 April 2018 

May 2018 

Webinar 

Training 

Training 

JAD 

30 May – 1 June 2018 

SEEFEN/SEEFEG 
Meeting 

EMPACT (Action 
Leader ES) 

CEPOL 

CEPOL 

JAD 2017 Debrief and JAD 2018 Preparation 

(Spain) 

SEESAC 

Advanced Ballistic Intelligence & Threat and Risk Assessment (Tirana) 

EMPACT (Action 
Leader ES) 

JAD Preparation meeting (Europol HQ) 

SEESAC 

9th SEEFEN Meeting (Tirana) 

72 

 
 
 
Date 

Category 

Organiser 

Subject 

4-5 / 11-15 June 2018 

Training 

SEESAC 

Core Intelligence Analysis Training (Sarajevo / Belgrade) 

5-6 June 2018 

Training 

EMPACT (Action 
Leader ES) 

TAIEX-funded training on information exchange (North Macedonia) 

10 July 2018 

Roadmap 

FR/DE 

London Summit 

9-13 / 16-20 July 2018 

Training 

SEESAC 

IBM i2 Analyst’s Notebook Training (Skopje / Podgorica) 

17-18 July 2018 

Workshop 

UNODC 

Monitoring  Illicit  Firearms  Trafficking:  Meeting  for  South  East  European, 
Eastern European and Neighbouring member states (Vienna) 

September 2018 

Exchanges 

EMPACT (Action 
Leader ES) 

TAIEX-funded  exchange  on  Cross-Border  checks  TAIEX  on  hiding  places  in 
means of transport 

24 September 2018 

Joint Committee 

European 
Commission 

Joint  Committee  between  European  Union  Firearms  Experts  and  South  East 
Europe Countries Firearms Experts (Brussels) 

8-12 October 2018 

Training 

SEESAC 

Intelligence Collection Plan & Intelligence Analysis (Tirana) 

20-21 November 2018 

SEEFEN/SEEFEG 
Meeting 

December 2018 

Study visit 

SEESAC 

10th SEEFEN Meeting (Budva) 

EMPACT (Action 
Leader ES) 

TAIEX-funded visit on the establishment of NFPs 

73