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

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 27.6.2019  COM(2019) 293 final  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    {SWD(2019) 282 final}  
 
 
Evaluation of the 2015-2019 action plan on firearms trafficking between the EU and the 
south-east Europe region 

Contents 

1. 

INTRODUCTION ....................................................................................................... 2 

1.1.  Context .............................................................................................................. 2 
1.2.  Content of the action plan ................................................................................. 3 
1.3.  Aims of the evaluation and methodology.......................................................... 4 

2. 

IMPLEMENTATION OF THE ACTION PLAN ....................................................... 5 

3.  CONCLUSIONS OF THE EVALUATION ............................................................... 6 

3.1.  Relevance .......................................................................................................... 6 
3.2.  EU Added value and sustainability ................................................................... 7 
3.3.  Effectiveness ..................................................................................................... 9 
3.4.  Efficiency ........................................................................................................ 12 
3.5.  Consistency ..................................................................................................... 13 

4.  CONCLUSIONS ....................................................................................................... 15 

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1. 

INTRODUCTION 

1.1.  Context  

The EU has taken firm action in the Security Union to deny terrorists and criminals the means 
to  act.  It  has  made  it  harder  for  them  to:  (i)  access  firearms  and  explosives  precursors,  (ii) 
finance their activities and (iii) travel without detection.1 An important aspect of this work are 
the  measures  to:  (i)  control  the  acquisition  and  possession  of  weapons2  and  (ii)  restrict  the 
supply  of  illegal  weapons  available  to  criminals  and  terrorists.3  Trafficking  in  firearms  and 
Small Arms and Light Weapons (SALW – hereafter small arms)4 is part of the core business 
of organised crime groups and is closely connected to terrorism  and requires an appropriate 
and strong response. The Western Balkans is the main source for firearms and arms smuggled 
into the EU5 and  has therefore been the focus  of increasing  cooperation on security matters 
between  the  EU  and  its  partners  in  the  region.  This  cooperation  occurs  through  policy 
dialogue, operational and technical assistance.6 

In  December  2014,  the  EU  and  its Western  Balkan  partners  endorsed  an  action  plan  on  the 
illicit  trafficking  of  firearms  between  the  EU  and  the  south-east  Europe  region  for  2015-
2019.7 The action plan aims  to  provide a consistent  framework for cooperation between the 
EU  and  the  region  by  setting  goals  and  actions  to  increase  cooperation,  based  on  those 
partners’ specific needs and help them to better fight against firearms trafficking. 

The need for more in depth cooperation in this field, led to the adoption in 2018 of a regional 
roadmap  by  south-eastern  European  partners  for  a  sustainable  solution  to  the  illegal 
possession, misuse and trafficking of Small Arms and Light Weapons and their ammunition 

1   For  an  overview,  see  the  Eighteenth  Progress  Report  towards  an  effective  and  genuine  Security  Union 

(COM(2019) 145 final, 20.3.2019). 

2   See  Directive  (EU)  2017/853  (175.2017)  amending  Council  Directive  91/477/EEC  on  control  of  the 

acquisition and possession of weapons.  

3   See  the  December  2015  action  plan  against  illicit  trafficking  in  and  use  of  firearms  and  explosives 

(COM(2015) 624 final, 2.12.2015). 

4    Small arms and light weapons and their ammunition are military-grade weapons (SALW); they include:  (a)  
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; (b)  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. 
The  term  ‘firearms’  has  a  broader  scope  that  covers  both  civilian  and  military-grade  firearms.  The  UN 
firearms protocol of 11 July 2001 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. 

5     Europol Serious and Organised crime Threat Assessment 2017, https://www.europol.europa.eu/socta/2017/    
6   Albania, Serbia, Bosnia Herzegovina, Montenegro, North Macedonia and Kosovo*. 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. 
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. 

7  

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in  the  Western  Balkans  by  2024,  developed  at  the  initiative  of  France  and  Germany  and 
endorsed by the Council.8  

The  South-Eastern  and  Eastern  Europe  Clearinghouse  for  the  Control  of  Small  Arms  and 
Light Weapons (SEESAC – hereafter the Clearinghouse), established in Belgrade in 2002 and 
funded by the European Union9 as a technical support unit, has always been one of the major 
players  in  ensuring  cooperation  between  different  initiatives  and  use  of  EU  funds  in  the 
Region.  It notably coordinates meetings of the  South-East Europe Firearms Expert Network 
(SEEFEN – hereafter Western Balkan Experts), involving representatives of police, customs, 
prosecutors  and  ballistics  experts.  It  also  embedded  a  subgroup  –  the  South-East  Europe 
Firearms Expert Group (SEEFEG) - that was set up following the adoption of the action plan.  

1.2.  Content of the action plan 

The action plan aims to: (i) improve the exchange of  criminal  information and intelligence; 
(ii)  improve  operational  law  enforcement  co-operation;  (iii)  improve  the  collection  and 
exchange  of  statistics;  (iv)  promote  networking  at  all  levels;  and  (v)  harmonise  Western 
Balkans’  partners  national  legislation  on  firearms  with  EU  and  international  standards.  It 
outlines  several  operational  actions  to  be  carried  out  in  2015-2019  to  reach  three  strategic 
goals. 

Goal 1 is the modernisation of law enforcement agencies in the Western Balkans. There are 
three different actions planned to achieve this goal:  

Action 1 requires 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 
iTRACE10, iARMS11 and the Europol Analysis System.  

Action 2 is the creation of a pilot project on data collection.  

Action  3  requires  a  study  to  be  conducted  on  systems  for  the  exchange  of  information  to 
improve the strategic and operational analysis of information.  

Goal 2   is to increase mutual trust. 

Action 1 calls  for joint  meetings of firearms  experts to  be organised. A Joint Committee of 
firearms  experts  from  the  EU  and  Western  Balkans  partners  went  a  step  further  by  inviting  

8   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. 

9   Council  Decision  2002/842/CFSP  of  21  October  2002  concerning  the  implementation  of  Joint  Action 
2002/589/CFSP with a view to a European Union contribution to combating the destabilising accumulation 
and spread of small arms and light weapons in South East Europe (OJ L 289, 26.10.2002, p. 1), extended 
and  amended  several  times  and  lastly  by  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  Small  Arms  and  Light  Weapons  and  their 
ammunition, OJ L 348, 21.12.2016, p. 60–71. 
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. 

10  

11   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 
the commission of a crime. 

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firearms  experts  from  south  east  Europe    to  a  meeting  of  the  European  Firearms  Experts 
group. 

Action  2  was  dedicated  to  the  yearly  organisation  of  joint  actions  days12,  and  to  the 
involvement of Western Balkan partners in the European Multidisciplinary Platform Against 
Criminal Threats in the context of the EU’s policy cycle (EMPACT, hereinafter 'the Firearms 
Platform').  

Goal 3 is to build capacity by organising training activities related to firearms trafficking. The 
Joint Committee also requested a feasibility study on the continuation of voluntary surrenders 
of unregistered weapons. 

1.3.  Aims of the evaluation and methodology 

This  report  presents  the  action  plan’s  achievements  in  addressing  the  illicit  trafficking  of 
firearms and small arms between the EU and the south-east Europe Region since 2015. This 
evaluation  relies  primarily  on  the  consultation  of  Member  State  enforcement  authorities, 
Western Balkan partners, EU agencies such as the EU Law Enforcement Agency (Europol), 
the  EU  Border  and  Coast-Guard  Agency  (EBCGA),  the  EU  Agency  for  Law  Enforcement 
Training  (CEPOL)  and  the  international  organisations  involved  on  the  ground  such  as  the 
Clearinghouse and the United Nations Office on Drugs and Crime. This consultation included 
a questionnaire sent to these groups by the European Commission, in June 2018. 

The Commission also organised four dedicated meetings organised by the Commission,13 the 
outcome of which informed the evaluation of the Commission.   

The  report  also  takes  into  account  the  outcome  of  the  meetings  of  the  Western  Balkan 
Experts; operational law-enforcement meetings; and the meetings of small arms commissions 
in the Western Balkans. 

The  Commission  also  took  into  consideration  a  number  of  external  studies  conducted  by 
independent organisations. 

The  absence  of  performance  indicators  in  the  action  plan  made  the  evaluation  of  its 
implementation challenging. The analysis was also hampered by an uneven detail of reporting 
and  limitations  in  terms  of  comparability  of  information  at  the  EU  level.    The  Commission 
relied  mostly  on  qualitative  reporting,  based  on  testimonies  rather  than  figures.  However, 
when available, figures did confirm stakeholders’ opinions, and their convergence guarantees 
the conclusion’s reliability of and responds to the evaluation’s questions. 

2. 

IMPLEMENTATION OF THE ACTION PLAN 

Under  Action  1,  EU  Member  States  and  countries  in  the  region  worked  to  set  up  firearms 
national  focal  points.  Assistance  was  given  by  the  Clearinghouse,  which  provided  targeted 
equipment, training and advice. In parallel, the EU adopted the best practice guidance for the 
creation of firearms focal points.14 As of 31 December 2018, there were  four focal points in 
the Western Balkans (the focal point in Kosovo* was fully operational; and the focal points in 
Albania, North Macedonia, Serbia had been set up but were not yet fully operational). 

12   A Joint Action Day is a day/s of coordinated controls carried out by law enforcement agencies of different 

countries targeting organised crime groups involved in firearms trafficking.  
13   26 January 2016, 30 November 2016, 26 January 2018 and 24 September 2018. 
14   15 May 2018, Council Document Nr  8586/18. 

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Under Action 2, the Clearinghouse developed a methodology for regional small arms surveys. 
The aim of this was to promote: (i) capacity building in the law- enforcement agencies and (ii) 
better data flow for coordinated assessment. All six partners provided input and they are now 
using  this  methodology.  In  order  to  implement  this  action,  the  European  Commission 
allocated 1.5 M€  from the  Internal  Security  Funds 2016 to  UNODC for  collecting data and 
generating relevant values to measure indicators involving Western Balkans partners.15 

Under Action 3, the Clearinghouse conducted a feasibility study16 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. 

As  part  of  Goal  2  on  improving  mutual  trust,  the  Commission  organised  four  coordinating 
meetings  from  2016  to  2018  to  assess  the  operational  measures  undertaken  and  steer  the 
different activities to ensure better-coordinated intervention in the region.  

The  core  of  operational  cooperation  was  carried  out  within  the  EU’s  policy  cycle  Firearms 
Platform  17.  Coordinated  checks  on  borders  and  in-land,  targeting  long-distance  buses  and 
firearms dealers, were organised every year and supported by Europol. The European Border 
and Coast Guard Agency (EBCGA) also provided support to strengthen border checks in and 
around the region, since firearms trafficking falls under the definition of "cross-border crime" 
the  area  for  which  it  is  responsible.  The  EBCGA  has  identified  the  Western  Balkans  as  an 
important operational area and supports the coordinated data collection on firearms trafficking 
thanks to the indicators agreed under the Western Balkan Risk Analysis Network set by up by 
the EBCGA. 

Cooperation  agreements  exist  between  Europol  and  Albania,  Bosnia  and  Herzegovina, 
Montenegro,  North  Macedonia  and  Serbia18.  These  agreements  provide  the  opportunity  to 
exchange information and intelligence and to cooperate on operations.  Five Western Balkan 
partners19 have  participated in 16 of 19 Operational Actions within the Firearms Platform. 

Under Goal 3, CEPOL developed working arrangements with all Western Balkan partners on 
training  and  capacity  building  (except  with  North  Macedonia,  for  which  negotiations  of  the 
working arrangements are ongoing). It provided between two and four training activities and 
webinars  per  year,  as  well  as  online  modules  and  an  exchange  programme.  In  addition,  the 
Clearinghouse developed specialised training modules on firearms focal points for operational 
analysts,  criminal  investigators,  criminal  intelligence  analysts,  and  forensic  investigators.  It 
also  helped  government  institutions  coordinate  the  small  arms  control  activities,  and  align 
their national legislation with EU standards and their respective national action plans.  

15   https://www.unodc.org/unodc/en/firearms-protocol/data-collection-and-analysis.html  
16   http://www.seesac.org/publication/p2.html  
17    Council  conclusions  on  the  creation  and  implementation  of  an  EU  policy  cycle  for  organised  and  serious 
international  crime  (doc.  15358/10  COSI  69  ENFOPOL  298  CRIMORG  185  ENFOCUSTOM  94, 
10.6.2011). 

18   Respectively of 9 December 2013, 31 August 2016, 29 September 2014, 22 December 2011 and 16 January 

2014. 

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

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3.  CONCLUSIONS OF THE EVALUATION 

3.1.  Relevance 

Firearms  trafficked  to,  within  and  from  the  Western  Balkan  remain  a  threat  for  the  whole 
European continent.  It  is  estimated that 2.3 million weapons in  the hands of civilians in the 
Western Balkans are registered, and 3.8 million are unregistered.20 

The diversion of illegally converted blank-firing or gas and alarm weapons into real firearms 
is an emerging trend and the region is a transit point for traffickers of these kinds of weapons. 

Chart 1.  Relevance of the action plan for current needs21 

In general, Western Balkan partners perceived the action plan and cooperation with the EU as 
more relevant and important than the EU Member States. 

The consulted stakeholders have given a positive evaluation of the action plan for its focus on 
structures; law-enforcement cooperation and technical assistance and training. However, they 
said  that  cooperation  with  other  countries  like  Moldova  and  Ukraine,  where  control  of 
firearms is less rigorous, should be developed. The Firearms Platform has also accepted the 
expansion of the current Operational  Action to  those countries.   The  consulted stakeholders 
said  that  the  action  plan  gave  insufficient  attention  to  criminal  policy,  the  reinforcement  of 
criminal sanctions and criminal procedures. Those topics appeared to be major issues because 
criminal  sanctions  in  the  Western  Balkans  often  do  not  adequately  address  firearms 
trafficking  as  a  separate  crime,  and  is  therefore  rarely  prosecuted  by  national  authorities. 
Stakeholders  also  stressed  the  insufficient  attention  given  to  awareness-raising  activities  for 
stockpile  management,  surplus  reduction  or  the  gender  dimension  (underrepresentation  of 
women, awareness of gender-based violence). 

Overall, stakeholders said although the action plan had played an important role in improving 
cooperation against firearms trafficking it still needed to be improved and updated. 

20   Strengthening Resilience in the Western Balkans, op. cit. 
21   Responses to the questionnaire sent to law enforcement Agencies in June 2018. 

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Key findings 

  The action plan focused on 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 coordinated collection of data for threat assessment 

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. 
It does not sufficiently tackle future possible threats linked to trafficking to or from 
Ukraine and Moldova.  

  Western Balkans partners are overall more involved than EU Member States  
  The action plan does  not  sufficiently take into consideration the issue of criminal 

sanctions and policies, and of stockpile reduction.  

3.2.  EU Added value and sustainability 

No direct causal link can be drawn between the activities mentioned in the action plan and the 
current trends in firearms trafficking, which are influenced by a variety of other factors and 
individual  or  bilateral  initiatives.  The  lack  of  performance  indicators  in  the  action  plan,  as 
well as an uneven level of details in the reporting, have also had an impact on the difficulty to 
quantify the EU added value of the action plan. 

However, the majority of stakeholders involved recognised the action plan’s added value. The 
importance  of  the  European  Commission’s  role  as  coordinator  was  positively  considered  as 
the Commission helps by providing a forum for law enforcement agencies to meet, develop 
connections  and  improve  cooperation,  with  Western  Balkan  partners.  The  stakeholders 
commented that, in itself, this can be considered a major achievement in a region where there 
are significant political tensions. 

Chart 2.  Main areas of added value of the action plan22 

On  operational  cooperation,  the  organisation  of  joint  coordinated  targeted  checks  has  been 
mostly  praised  as  it  facilitates  intelligence  collection,  information  sharing  and  identifies 
bottlenecks.  

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

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Most  Western  Balkans  partners  acknowledged  Europol’s  support  to  the  operational 
cooperation through the involvement of its operation centre and its 24/7 intelligence reporting. 
At the same time, some Western Balkans partners expressed the view that Europol’s support 
did not provide timely feedback and useful intelligence analysis. Europol has only been able 
to  produce  a  low  number  of  intelligence  cases  related  to  the  Western  Balkans  (5.4%  of  all 
cases  in  2017,  7.6%  in  2018).23  Western  Balkans  partners  considered  that  other  Agencies, 
such  as  Eurojust  and  EBCGA  had  only  provided  a  marginal  contribution.  No  Joint 
Investigation Team on firearms trafficking was supported by Eurojust in the Western Balkans, 
and  the  involvement  of  the  EBCGA  and  the  use  of  the  Eurosur24  Fusion  Services  did  not 
provide for sufficiently useful information to allow major seizures of firearms.25  

All EU and Western Balkans stakeholders positively assessed the meetings of Western Balkan 
Experts, which facilitated the establishment of firearms focal points in the Western Balkans. 
In addition, these meetings facilitated the involvement of Western Balkans law-enforcement 
agencies in the Firearms Platform’s 2019 operational action plan.  

The  sustainability  of  the  outcomes  achieved  under  the  action  plan  very  much  depends  on 
whether and how the action plan will continue in the future. Its mere extension without taking 
into  account  the  new  realities  and  needs  identified  would  probably  not  have  any  noticeable 
effect.   

However, the action plan has been a dynamic document that provided general objectives and 
targets  but  also  enabled  the  Joint  Committee  between  EU  Firearms  Experts  and  south-east  
Europe  partners’  experts  to  build  on  it  conclusions  and  set  out  specific  objectives  and 
activities to implement it. 

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.   

3.3.  Effectiveness 

As explained also under section 3.2, two factors made it difficult to assess the effectiveness of 
the plan: the action plan’s lack of performance indicators and an uneven level of details in the 
reporting.  When  conducting  its  evaluation,  the  Commission  had  only  limited  access  to 
operational  information  from  Europol,  EU  member  states  and  south-east  Europe  partners. 
Cases  of  seizures  and  joint  operations  very  rarely  provided  detailed  information  that  would 
allow  an  assessment  of  the  trafficking  routes  and  traffickers’  operational  methods.  The 
Commission  also  received  contradicting  figures  that  made  the  evaluation  of  the  countries’ 

23   Source: Europol. 
24   European Border Surveillance System. 
25   Albania, Bosnia Herzegovina, North Macedonia , Montenegro and Serbia. 

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involvement difficult. Statistics on seizures, voluntary surrenders and destructions of weapons 
were  not  sufficiently  detailed  to  allow  for  trend  analyses  and  comparisons  between 
jurisdictions. 

Consulted  stakeholders  expressed  mixed  feelings  about  the  action  plan’s  effectiveness. 
Activities related to the modernisation of law-enforcement agencies (Goal 1) were generally 
considered more effective than those related to  building mutual  trust  and actual cooperation 
(Goal 2). Similarly, mixed feelings were also expressed on the activities on enhancing training 
and capacity building (Goal 3). 

Chart 3.  Effectiveness of Actions under Goal 126 

Under  Goal  1,  harmonised  data  collection  on  firearms  seizures  remains  one  of  the  main 
stumbling blocks both in the EU and in the Western Balkans. Only  16 EU Member States27 
and  4  Western  Balkan  partners28  participate  in  the  EU-funded  UNODC's  Global  Firearms 
Study, which limits the study’s effectiveness . The reason for this low level of participation is 
that  only  a  few  focal  points  are  sufficiently  operational  to  provide  the  required  data.  A 
template  with  minimum  standard  intelligence  requirements  was  not  developed  and 
enforcement  agencies  often  considered  that  a  template  limited  the  usefulness  of  the 
information exchanged.  

Western  Balkans  partners’  national  legislation  has  generally  been  brought  in  line  with  EU 
law29  but  the  revision  of  the  Firearms  Directive30  and  its  implementing  measures  requires 
partners  to  make  legislative  amendments,  especially  on  the  standards  for  deactivation  and 
marking firearms. 

26   Responses to the questionnaire sent to law enforcement Agencies in June 2018. 
27   AT, BE, CZ, DK, EL, ES, FI, HR, LT, NL, PT, RO, SE, SI, SK, UK. 
28   AL, BiH, MD, ME. 
29   Notably Council Directive 91/477/EEC on control of the acquisition and possession of weapons, OJ L 256 
13.9.1991, p. 51); 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. 

30   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. 

9 

 
  
 
                                                 
Chart 4.  Effectiveness of Actions under Goal 231 

Under Goal 2, stakeholders were generally satisfied with the effectiveness of joint meetings, 
but noted that their effectiveness was sometimes hampered by participants being mid-ranking 
investigators  who  required  authorisations  and  instructions  to  address  international  meetings, 
and were not always aware of broader developments in their respective institutions.  

Chart 5.  Effectiveness of joint EU-WB meetings32 

A high turnover of staff in the national law-enforcement agencies of Western Balkans partners 
made  daily  cooperation  and  exchanges  of  information  difficult.  Nevertheless,  available  data 
demonstrated the ability of participants to learn from the difficulties encountered during joint 
coordinated  targeted  checks.  This  is  demonstrated  by  the  increased  number  of  messages 
exchanged  through  the  Secure  Information  Exchange  Network  Application  (SIENA)  within 
the joint targeted operations (as shown in Chart 6). The number of seized firearms (during the 
action days and in the follow-up investigations) has also been steadily increasing (as shown in 
Chart 7). 

Chart 6. 

33 

Chart 7. 

34 

31   Responses to the questionnaire sent to law enforcement Agencies in June 2018. 
32   Responses to the questionnaire sent to law enforcement Agencies in June 2018. 
33   Sources: Europol, EMPACT. Figures for 2018 are not final. 
34  

Ibid. 

10 

 
  
 
   
 
 
 
                                                 
On  the  ground,  border  checks  between  Western  Balkan  partners  have  demonstrated  their 
inadequacy. Although there is evidence that firearms travel across the Western Balkans, from 
and  to  the  European  Union,  as  recognised  by  all  stakeholders  and  intelligence  assessments, 
seizures rarely take place at border, but mostly inland. Several stakeholders also pointed out 
to shortcomings: border guards and customs officers do not sufficiently rely on risk profiling 
and prior intelligence; they are not specifically trained to detect firearms and not adequately 
equipped, and focus on border crossing points with no clear strategy to control the rest of the 
land borders used by smugglers. 

The  operational  cooperation  between  EU  and  Western  Balkans  allowed  identifying  several 
weaknesses  in  criminal  procedures  of  each  country  in  both  regions:  special  investigative 
techniques  differ  widely  across  countries  and  controlled  deliveries  are  limited  by  a  general 
reluctance to authorise those operations in the transit countries. They also considered that an 
enabling common legislative framework at national level could be conducive to more efficient 
exchanges of information for intelligence purposes outside of specific investigations. 

In the field of forensics (notably ballistics), technologies vary widely across the region, which 
impedes exchanges and cross-comparison across borders. Ballistic analysis and international 
comparisons  are  carried  out  on  a  case-by-case  basis,  and  are  neither  systematic  nor  fully 
automatised.  

Under  Goal  3,  it  is  worth  noting  that  participation  of  Western  Balkan  partners  to  trainings 
provided  by  CEPOL  substantially  increased.  Figures  show  an  uneven  participation  by  EU 
Member States, with no specific identifiable trend, and a stable and low rate of participation.35 
Two  countries  stand  out  in  participation:  Greece  and  Portugal,  with  a  substantially  higher 
number of trainees effectively attending webinars (respectively 66 and 15 webinar trainees on 
average). 

However,  several  stakeholders  regretted  the  lack  of  sufficiently  practical  training;  they  also  
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.  

35   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. 

11 

 
                                                 
Key findings 

  Activities carried out under the action plan to modernise law enforcement agencies. 
  Approximation of legislation in the Western Balkans towards EU standards. 
  The  organisation  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 not operational, and as a 

consequence: 

iArms database not systematically populated 

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

  Border  checks  across  the  Western  Balkans  have  proven  inadequate  to  detect  firearms 
trafficking,  mainly  due  to  uninformed,  untrained  and  unequipped  border  guards  and 
customs officers. 
Inadequacy of investigative tools during cross-border operations due to diverging legal 
frameworks. 

 

3.4.  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. 

In principle, the Firearms  Platform  can provide substantial  financial support to  EU Member 
States  and  Western  Balkan  partners.  This  financial  support  can  cover  expenses  such  as  the 
costs  of  participation  in  joint  action  days,  rewards  for  the  public  to  provide  information, 
funding  for  special  equipment;  and  rental  of  premises  for  covert  operations.  This  financial 
support  is  available  through  different  funds  such  as  DG  HOME's  Internal  Security  Fund; 
Instrument for Pre Accession Assistance 2015-2020; Instrument contributing to stability and 
peace (2014-2020); Common Foreign and Security Policy (2017-2019). However, it appeared 
that  EU  Member  States’  liaison  officers  in  Western  Balkans  partners  and  national 
investigators are not fully aware of this facility and rely mostly on national funding and purely 
bilateral cooperation. 

Over the years operational cooperation between the European Union and the Western Balkans 
partners  did  not  improve  or  even  had  a  negative  trend.  This  is  shown  by  the  decreasing 
number of SIENA messages (outside joint control operations) from Western Balkan partners 
that  moved  down  from  67%  in  2017  to  29%  in  2018.  The  same  trend  can  be  observed  for 
cases  shared  with  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).36  

36   Source: Europol. 

12 

 
 
                                                 
 
 
On trainings, CEPOL decided to cover the expenses of participants of each Western Balkan 
partner  to  its  activities  (6  in  2016  and  2017  and  4  in  2018),  and  they  sent  twice  as  many 
participants  than  they  received  funding  for  (while  at  the  same  time,  EU  member  states  sent 
1.62 to 1.69 times more trainees than the number of participants funded by CEPOL).37 This 
indicates  a  proportionally  higher  commitment  and  interest  of  Western  Balkan  partners  than 
EU Member States in transnational training opportunities, and hence a high value for money. 
The Clearinghouse also provided useful practical training for law enforcement officers across 
the  region.  For  example,  it  developed  a  weapon  identification  platform  to  help  law-
enforcement authorities to: (i) identify seized weapons, ammunition  and explosives, and (ii) 
generate  reports  for  further  criminal  investigations.  The  efficiency  of  trainings  is  however 
difficult  to  assess,  since  no  analysis  of  cascading  trainings  (i.e.  further  trainings  at  national 
level provided by participants to regional trainings) was provided by the organisers. Most of 
the  training  audience  consulted  did  not  express  any  opinion  about  trainings  they  received. 
Those who did express an opinion stressed the lack of a practical advice on the setting up of 
joint investigations teams and on specific issues such as convertible firearms. 

Key findings 

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

by CEPOL and SEESAC. 

  Not enough data on concrete outcomes Lack of awareness of the 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. 

3.5.  Consistency 

The  European  Commission  has  endeavoured  to  ensure  that  all  stakeholders'  actions  are 
complementary.  This  will  reduce  the  risk  of  overlaps  and  improve  cooperation  in 
investigations  of  trans-border  crimes,  in  line  with  the  Council  conclusions  of  13  December 
2016.38 Firearms trafficking was also included in the joint action plan on counter terrorism for 
the  Western  Balkans  of  5  October  2018.39  The  Firearms  Platform  and  the  activities  of  the 
Clearinghouse were also enshrined within the Integrative Internal Security Governance (IISG) 
approach  for  the  Western  Balkans  that  has  three  pillars:  counter-terrorism,  fight  against 
serious and organised crime and border security.40  

The Clearinghouse was acknowledged by the coordinating body of the IISG as a facilitator of 
coordination of activities on arms control and the fight against illicit trafficking of firearms. 
This will ensure consistency with other streams of work and expert groups.  

Cooperation  between  the  EU  and  the  south-east  Europe  region  remains  difficult  due  to  the 
existence  of  a  multitude  of  stakeholders,  which  are  not  always  coordinated.  Different 
countries  and  international  organisations  such  as  the  Small  Arms  Survey,  the  Southeast 
European  Law  Enforcement  Centre,  the  North  Atlantic  Treaty  Organisation  (NATO), 
UNODC  or  the  Organisation  for  the  Security  and  Cooperation  in  Europe  (OSCE)  are  also 

37   Source: CEPOL. 
38   Council Document 15536/16. 
39   https://ec.europa.eu/home-affairs/sites/homeaffairs/files/news/docs/20181005_joint-action-plan-counter-

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

40   https://wb-iisg.com/  

13 

 
 
                                                 
active in the region. However, there is an unclear coordination of these groups’ activities with 
the Clearinghouse, the Firearms Platform, and the Internal Integrated Security Governance.  

Many  stakeholders  have  spoken  of  an  unnecessary  duplication  of  meetings,  with  similar 
participants  having the same discussions. Conversely, due to a lack of internal  coordination 
and information sharing, country representatives often attend different meetings with no prior 
knowledge  of  similar  discussions  or  presentations  having  already  taken  place  in  similar 
formats.  

Various funding channels (such as the Instrument for Pre-accession Assistance, including the 
Technical  Assistance  and  Information  Exchange  Instrument  (TAIEX)  modality,  the  Internal 
Security  Fund)  initially  created  inconsistencies  and  lack  of  coordination.  However,  these 
issues  have  been  addressed  and  overcome  with  the  help  of  the  Commission.  One  of  the 
remaining  challenges  is  that  common  foreign  and  security  policy  funding  is  sometimes 
granted without a global overview of other similar activities in the region. 

Finally,  consistency  was  ensured  between  the  action  plan  and  the  regional  roadmap.  The 
Commission,  the  Firearms  Platform,  Europol  and  the  Clearinghouse  were  all  closely 
associated with the formulation of the regional roadmap’s needs assessment and drawing up 
of objectives.  

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 coherence between activities of different stakeholders; many overlaps; lack of 

integrated steering structure in the organisation of different activities. 
lack of integrated and comprehensive budgetary approach at EU level. 

 

4.  CONCLUSIONS 

The EU and Western Balkan partners are facing common challenges.  

The  action  plan’s  added  value  was  most  visible  in  improving  networking,  exchange  of 
information and putting in place the building blocks of future cooperation.  

However,  the  action  plan  evaluation  shows  that  several  planned  actions  have  not  yet  been 
fully implemented, which reduced the action plan’s effectiveness. This is notably the case for 
the  establishment  of  firearms  focal  points,  which  are  necessary  for  proper  enforcement 
strategies,  coordination,  intelligence  and  exchanges  of  information,  both  nationally  and  at 
European level. There is also still no harmonised data collection for firearms seizures which 
would  enable  an  evidence-based  policy  and  proper  and  reliable  assessment  of  trafficking 
trends. Similarly, stakeholders did not develop a standard reporting format for the exchange of 
information as planned by the action Plan.  

The evaluation also demonstrates that the action plan’s effectiveness could be improved. For 
example, to allow the joint meetings to deliver concrete results they could benefit from clear 
instructions  to  participants,  which  should  be  authorised  to  deliver  a  position  or  an  input  on 
possible  deliverables.  Many  stakeholders  considered  that  trainings  would  be  made  more 

14 

 
 
 
efficient  by  focusing  on  practical  cases,  the  establishment  of  joint  investigations  and  on 
specific issues such as convertible firearms.  

With respect to the geographical scope, activities have been focusing on the Western Balkan, 
but future challenges may justify covering effectively the whole south-east Europe, including 
the Republic of Moldova and Ukraine, in order to develop future-proof solutions in the EU's 
Eastern neighbourhood.  

Member States and Western Balkan partners should now turn their political commitments into 
operational priorities and deliverables. Closer co-ordination between Member States, Western 
Balkans  partners,  EU  agencies  and  international  organisations  is  needed  in  order  to  ensure 
better and concrete results in the joint fight against firearms trafficking.  In that context, the 
regional roadmap presents a comprehensive assessment of the needs for a future policy in the 
region.  It  could  be  complemented  by  country-specific  operational  objectives,  more  detailed 
performance  indicators  and  a  clear  steering  and  budgetary  structure.  The  Commission  is 
prepared to support Member States, Western Balkan partners, EU agencies and international 
organisations  in  delivering  on  these  challenges.  The  different  stakeholders  consulted  have 
expressed the need for an action plan. Overall, the evaluation of this Action Plan will need to 
be taken into account to ensure continuous cooperation in this area in the future. 

15