Preventing fraud and corruption in the European Structural and Investment Funds : compendium of anti-fraud practices for preventing and detecting fraud and corruption in ESI Funds.
Date: 2019-08-12
Institutions: Directorate-General for Regional and Urban Policy
Subjects: Cohesion Fund, EAFRD, EU Member State, European Regional Development Fund, European Social Fund, European Structural and Investment Funds, European fisheries fund, administrative check, conflict of interest, corruption, distribution of EU funding, fraud, fraud against the EU

Preventing fraud and 
corruption in the European 
Structural and Investment 
Funds – taking stock of 
practices in the EU Member 
States 

Compendium of anti-fraud practices for 
preventing and detecting fraud and 
corruption in ESI Funds 

Written by Léna Bonnemains, Melissa Campagno, 
Brian Kessler, Olga Mala, and Goya Razavi 
5 October 2018 

 
 
 
 
 
 
 
 
 
 
DISCLAIMER  
The authors of this document are Léna Bonnemains, Melissa Campagno, Brian Kessler, Olga Mala, and 
Goya Razavi. The information and views set out in it are those of the authors and do not necessarily reflect 
the official opinion of the Commission. The Commission does not guarantee the accuracy of the data 
included in it. Neither the Commission nor any person acting on the Commission’s behalf may be held 
responsible for the use which may be made of the information contained therein. 

EUROPEAN COMMISSION 

Directorate-General for Regional and Urban Policy 
Directorate E - Administrative Capacity Building and Programmes Implementation II 
Unit REGIO.DDG.E.1 

Contact: Inguna Kramina 

E-mail:  REGIO-E1-ADMINISTRATIVE-CAPACITY@ec.europa.e  

European Commission 
B-1049 Brussels 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 

Preventing fraud and 
corruption in the European 
Structural and Investment 
Funds – taking stock of 
practices in the EU Member 
States 

Compendium of anti-fraud practices for 
preventing and detecting fraud and 
corruption in ESI Funds 

Directorate-General for Regional and Urban Policy 

2019 

EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Europe Direct is a service to help you find answers  
to your questions about the European Union. 

Freephone number (*): 

00 800 6 7 8 9 10 11 

(*) 

The information given is free, as are most calls (though some operators, phone 

boxes or hotels may charge you). 

Manuscript completed in October 2018 

The European Commission is not liable for any consequence stemming from the reuse of this publication.  

Luxembourg: Publications Office of the European Union, 2019 

ISBN 978-92-76-08799-1 
doi: 10.2776/488340 

© European Union, 2019 
Reuse is authorised provided the source is acknowledged.  
The reuse policy of European Commission documents is regulated by Decision 2011/833/EU (OJ L 330, 
14.12.2011, p. 39). 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents 

1. 

Introduction ............................................................................................................................ 4 

2.  Objective of this Compendium ................................................................................................ 4 

3.  Glossary of key concepts .......................................................................................................... 5 

4.  Approach ..................................................................................................................................7 

5.  How to use this Compendium ................................................................................................. 8 

6.  Anti-fraud practice fiches ....................................................................................................... 12 

 
 
 
 
 
 
 
 
 
 
 
 
 
DG REGIO 
Compendium of anti-fraud practices for preventing and detecting fraud and corruption 
in ESI Funds 

1. 

Introduction 

With  approximately  EUR  460  billion  allocated  for  the  2014-2020  programming  period,  the  European 
Structural  and  Investment  (ESI)  Funds  (consisting  of  the  Cohesion  Fund  (CF),  the  European  Regional 
Development Fund (ERDF), the European Social Fund (ESF), the European Agricultural Fund for Rural 
Development (EAFRD), and the European Maritime and Fisheries Fund (EMFF)) represent almost a third 
of the EU budget.  

ESI Funds finance operational programmes (OPs) in Member States (MS), each aimed at achieving specific 
objectives within the areas defined as EU priorities. About 400 OPs are funded through ESI Funds for the 
2014-2020 programming period and managed by competent authorities within each EU Member States. 

The European Commission (EC) and MS share responsibilities for the implementation and management of 
ESI  Funds,  and  both  must  ensure  funds  are  spent  properly  and  achieve  the  greatest  possible  impact. 
Moreover, they must put in place the proper safeguards to limit the risks of fraud and corruption. Fraud is 
defined  by  the  Convention  on  the  protection  of  the  European  Communities’  financial  interests  as  the 
deliberate act of deception intended for personal gain or to cause a loss to another party. A definition of 
corruption  used  by  the  EC  is the  abuse  of  (public)  position  for  private  gain.  Example  of  fraudulent  and 
corrupt  practices  can  include  but  are  not  limited  to  conflict  of  interest,  double  funding,  bribery  or 
falsification of document.  

Authorities in the MS have the legal obligation to safeguard EU funds as per Article 325 of the Treaty on the 
Functioning  of  the  European  Union  and  Article  59(2)  of  the  Financial  Regulation.  This  obligation  was 
specified and reinforced in 2013 by Article 125(4)(c) of the Common Provisions Regulation (CPR). Article 
125(4)(c) requires the implementation of risk-based, effective and proportionate measures to prevent fraud 
in managing and controlling the OPs. 

2.  Objective of this Compendium 

The purpose of this Compendium is to present a sample of anti-fraud practices identified in the context of 
the  study  on  preventing  fraud  and  corruption  in  ESI  Funds.  This  study  aims  at  taking  stock  of  and 
disseminating  information  on  anti-fraud  measures  put  in  place  by  authorities  responsible  for  the 
management and control of ESI Funds in the 28 EU MS to prevent and detect fraud and corruption.  

Anti-fraud practices featured in this Compendium consist of relevant measures developed by ESI Funds 
practitioners at the regional, national and EU level, which represent strong potential candidates for good 
practices in the fight against fraud and corruption. This Compendium also informs about other measures 
developed  by  non-ESI  Funds  practitioners  that  bring  a  positive  a  positive  impact  to  the  MS’  anti-fraud 
system. 

The Compendium targets ESI Funds management practitioners and policy makers who are exploring ways 
to improve their national management and control system or elements of it. 

4 

 
 
 
 
 
 
 
 
DG REGIO 
Compendium of anti-fraud practices for preventing and detecting fraud and corruption 
in ESI Funds 

3.  Glossary of key concepts 

European Structural and Investment (ESI) Funds  

ESI  Funds  includes  the  Cohesion  Fund  (CF),  the  European  Regional  Development  Fund  (ERDF),  the 
European Social Fund (ESF), the European Agricultural Fund for Rural Development (EAFRD), and the 
European Maritime and Fisheries Fund (EMFF). 

European Anti-Fraud Office (OLAF) 

OLAF investigates fraud against the EU budget, corruption and serious misconduct within the European 
institutions, and develops anti-fraud policy for the EC. 

Fraud 

Fraud is defined by the Convention on the protection of the European Communities’ financial interests as 
the deliberate act of deception intended for personal gain or to cause a loss to another party. 

Corruption 

A  definition  of  corruption  used  by  the  European  Commission  (EC)  is  the  abuse  of  (public)  position  for 
private gain.  

Practice 

For the purposes of this compendium, we considered as “practice” a solution or approach implemented by 
one or several authorities within the EU Member States (MS) that deserves special attention because of its 
potential to improve anti-fraud and anti-corruption systems.  

Operational Programmes (OPs) 

ESI Funds are used to finance several Operational Programmes (OPs), each aiming at achieving specific 
objectives within the areas defined as EU priorities. ESI Funds’ competent authorities within the EU MS 
are responsible for the sound management and control of OPs.  

Managing Authorities (MAs) 

MAs are responsible for managing one or several OPs in accordance with the principle of sound financial 
management.  The  MA  is  also  the  end-responsible  for  putting  effective  and  proportionate  anti-fraud 
measures in place on risk-based approach. 

Common Provision Regulation (CPR) 

Regulation (EU) N1303/2013 of the European Parliament and of the Council of 17 December 2013 laying 
down  common  provisions  on  the  ERDF,  the  CF,  the  EARDF  and  the  EMFF,  and  laying  down  general 
provisions on the ERDF, the ESF, the CF and the EMFF funds and repealing Council Regulation (EC) No 
1083/2006. 

Audit Authorities (AAs) 

5 

 
 
 
 
 
DG REGIO 
Compendium of anti-fraud practices for preventing and detecting fraud and corruption 
in ESI Funds 

AAs ensure that audits are carried out on the proper functioning of the Management and Control System 
(MCS) of the OP. As a part of the assurance that the AAs give, they have the obligation to verify and monitor 
how the MA complies with Art. 125(4)(c) of the CPR. Auditors have a key role (both an audit and an advisory 
role) in providing an opinion on the functioning of management and internal control systems for OP that 
are part of the  ESI Funds.  They have an obligation in the fight against fraud and  must assist the  MS in 
preventing, detecting and correcting irregularities and fraud.  

Certifying Authorities (CAs) 

CAs  are  responsible  for,  amongst  others,  drawing  up  and  submitting  payment  applications  to  the 
Commission,  and  certifying  that  they  result  from  reliable  accounting  systems,  are  based  on  verifiable 
supporting documents, and have been subject to verifications by the MA. Additionally, they are responsible 
for certifying the completeness, accuracy and veracity of the accounts and that the expenditure entered in 
the accounts complies with applicable law.  

Anti-Fraud Coordination Service (AFCOS) 

The  OLAF  Regulation  has  created  the  requirement  for  MS  to  designate  a  service  (‘the  anti-fraud 
coordination service’) to facilitate effective cooperation and exchange of information, including information 
of an operational nature, with OLAF  (Article 3 (4) of the OLAF Regulation). Following this requirement to 
establish an AFCOS, the Commission has issued a Guidance Note on the main tasks and responsibilities of 
an AFCOS. It has to be kept in mind that in each country, AFCOS set-up, role and functions differ in many 
ways. 

Intermediate Bodies (IBs) 

MAs and CAs may also delegate some of their duties to Intermediate Bodies (IBs). An IB is any public or 
private body, which acts under the responsibility or carries out duties on behalf of an MA (or sometimes a 
CA). 

Beneficiaries 

Beneficiaries  are  the  (public  or  private)  bodies  that  receive  financing  from  the  MA  or  IBs.  They  are 
responsible for executing the projects for which the financing has been received. 

Red flags 

Red flags can be defined as a set of indicators that may signal possible fraud. Red flags do not indicate fraud 
by themselves but provide possible warning signs of fraud.  

6 

 
 
 
 
 
 
 
DG REGIO 
Compendium of anti-fraud practices for preventing and detecting fraud and corruption 
in ESI Funds 

4.  Approach 

A good practice is commonly understood as a solution or approach that can be assessed as having a positive 
verified  impact  on  a  specific  issue.  However,  when  it  comes  to  the  fight  against  fraud  and  corruption, 
establishing  a  clear  link  between  the  effects  of  a  practice  implemented  and  the  reduction  of  fraud  and 
corruption  is  not  straightforward  as  evidence  of  the  impact  on  fraud  and  corruption  of  any  measure  is 
particularly difficult to gather. For instance, a reduction of fraud cases detected does not necessarily mean 
that fraud has decreased, but can also mean that the system is less efficient in detecting fraud.  

Furthermore,  as  a  large  part  of  the  anti-fraud  practices  featured  in  this  Compendium  have  been 
implemented in response to the new requirements brought by the 2014-2020 programming period, it is too 
soon at this stage to call those practices good practices. Indeed, authorities who have implemented them 
have  not  yet  collected  sufficient  insights  to  assess  the  results  of  the  practice  on  their  anti-fraud  system. 
Therefore, this Compendium focus on examples of identified anti-fraud practices, which display a strong 
potential to be considered good practices at a time when, and if, their impact on fraud and corruption can 
be assessed. 

Anti-fraud practices presented in this Compendium were primarily identified when discussing with MAs, 
AAs,  AFCOS,  and  CAs  where  relevant,  during  more  than  140  interviews  conducted.  Interviews  were 
complemented by desk research work and insights collected from speakers who presented their anti-fraud 
practice on this occasion of the 13 September workshop on preventing fraud and corruption in ESI Funds. 

An initial list of 104 practices examples were identified and further refined to obtain a sample of 65 practice 
examples. In order to select the best examples from this sample and to feature them in this Compendium, 
we relied on opinions of stakeholders interviewed, and on PwC experts’ qualitative assessment based on the 
following two criteria:  

1.  Potential  impact:  whether  the  practice  has  the  potential  to  positively  impact  the  anti-fraud 

system of the MS; 

2.  Transferability  and  applicability:  whether  the  practice  is  seen  as  easily  transferable  and 
applicable to other contexts (e.g. other OPs or MS). This criterion ensures that the selected anti-
fraud practices are relevant for a maximum of OPs and MS. 

In very few cases, and for the reasons abovementioned, the  innovative and unique character of the 
anti-fraud  practice  was  considered  i.e.  whether  the  practice  display  innovative  characteristics  that 
differentiate it from what is usually done.  

As a result, this Compendium encompasses two types of anti-fraud practices. For the main part, practice 
examples presented consist of good implementations of suggestions, guidelines, and requirements of the 
EC (e.g. designation criteria). For a small part, practice examples highlight unique and innovative features 
of certain examples. These were usually put in place on the sole initiative of practitioners or authorities, or 
as part of other initiatives.  

Following  this  assessment,  we  grouped  the  shortlisted  practice  examples  into  8  categories  of  practices 
featuring 25 examples and case studies. Hence, a fiche in the Compendium corresponds to a category of 
anti-fraud  practices,  e.g.  “Practical  anti-fraud  trainings”.  The  anti-fraud  practice  fiches  further  include 
descriptions of some of the identified examples in order to illustrate the various practical ways to implement 
the anti-fraud practice.  

7 

 
 
 
 
 
 
DG REGIO 
Compendium of anti-fraud practices for preventing and detecting fraud and corruption 
in ESI Funds 

5.  How to use this Compendium 

Each anti-fraud practice is described in a “fiche”. Each fiche is composed of 3 to 8 pages. The content of 
the first page of the fiches is described below.  

8 

 
 
 
 
 
 
DG REGIO 
Compendium of anti-fraud practices for preventing and detecting fraud and corruption 
in ESI Funds 

Title of the anti-fraud practice 

Summary:  
brief description of the 
category. 

Practice spotted in: 
a few examples of MS 
that have adopted, or 
are in the process of 
adopting, the practices. 

Expected impact: 
brief description of the 
positive impact the 
anti-fraud practice may 
bring. 

9 

 
 
 
 
 
 
 
 
DG REGIO 
Compendium of anti-fraud practices for preventing and detecting fraud and corruption 
in ESI Funds 

Examples:  
Short descriptions of 
the implementation of 
the anti-practice in 
different MS.  

This box indicates the 
type of measure 
and the type of risks 
mitigated when 
implementing this 
anti-fraud practice 

10 

 
 
 
 
 
 
 
 
 
DG REGIO 
Compendium of anti-fraud practices for preventing and detecting fraud and corruption 
in ESI Funds 

Case studies: 
2-4 page description of 
an implementation of 
the anti-practice. For 
each case study, the 
contact details of the 
person, body, or 
authority, which has 
put in place the anti-
fraud practice are 
provided. 

11 

 
 
 
 
 
  
 
 
 
DG REGIO 
Compendium of anti-fraud practices for preventing and detecting fraud and corruption 
in ESI Funds 

6.  Anti-fraud practice fiches 

12 

 
 
 
 
 
Practice 1 – MA’s monitoring system shared 
with other entities 

Summary of the practice 

Practice spotted in… 

 BE 
 CY 
 DE 
 DK 

 FI 
 LT 
 LU 
 PT 

One  designation  criteria  for  MAs  in  the  2014-2020 
programming  period  is  ensuring  that  all  exchanges  of 
information  between beneficiaries and the MA,  IBs,  CA 
and  AA  can  be  carried  out  by  means  of  electronic  data 
exchange (As per Article 122(3) of CPR). 

MAs  have  thus  introduced  electronic  management  and 
monitoring systems to carry out all projects’ operations 
and sometimes, public procurement procedures.  

These  systems  vary  and  can  consist  of  completely  new 
systems  or  existing  information  systems  to  which  new 
modules  and  functionalities  have  been  added  to  meet 
designation criteria.  Such systems allow for the sharing 
of  information  between  ESI  Funds  authorities  and 
beneficiaries, as well as ensure an audit trail and a strong 
traceability of operations.  

This anti-fraud practice presents examples of MAs which 
have  met  the  designation  criteria,  ensuring  an  equal 
sharing of information, a fast coordination of activities, 
and  a  strong  audit  trail,  facilitating  the  review  by  audit 
authorities.   

Expected impact on anti-fraud systems 

Transparency 

Information related to the applicant selection process is 
encoded  and  available  on  the  platform  to  all  relevant 
stakeholders  depending  on  their  access  rights,  thereby 
ensuring  transparency  and  integrity.  This  information 
can include documents such as project appraisal analyses 
and reports resulting from evaluation committees and/or 
the project implementation phase, such as declarations of 
payment and other supporting documents. 

Increase 
document forgery 

traceability 

and 

avoid 

The  archiving  of  documents  at  each  stage  of  the  co-
financed  project’s  lifecycle  ensures  an  auditable  paper 
trail. In some cases, documents published in the system 
locked  and  cannot  be  changed  after  official 
are 
submission  to  prevent  possible  document  forgery  and 
ensure that all users have access to the same version of the 
document.  

Coordination between stakeholders 

Such  information  systems  ensure  that  the  most  recent 
information  is  shared  between  all  relevant  stakeholders 
concerned  and  that  anyone  can  consult  the  status  of  an 
activity. In some cases, after a modification to a document 
or an operation is done, an automatic notification is sent 
through the platform to inform all relevant stakeholders. 

13 

 
 
 
 
 
 
Practice 1 – MA’s monitoring system shared 
with other entities 

This anti-fraud practice is considered a hard prevention measure designed to mitigate:  
• 
• 
Member State, when consistently applied by several authorities. 

The risks of manipulation of projects’ costs and quality; and 
The  lack  of  an  anti-fraud  culture  within  an  authority  and,  on  a  larger  scale,  within  a 

Examples of the practice 

Belgium – EUROGES database as a unique platform 
connecting all relevant stakeholders 

How it works 

It  uses 

‘Wallonia-2020.EU’. 

The  Walloon  government  is  the  MA  responsible  for  OP 
ERDF 
the  so-called 
EUROGES  database  as  a  platform  for  the  coordination, 
management,  monitoring,  control  and  evaluation  of 
projects  co-financed  by  ERDF.  Among  other  goals, 
EUROGES has a number of modules designed to facilitate 
the  recording  and  sharing  of  information  between 
stakeholders.  It  also  keeps  a  record  of  all  user  activities 
and documents submitted, creating a clear audit trail for 
all operations.  
EUROGES is composed of an award and a management 
module.  The  award  module  serves  to  carry  out  the 
evaluation  and  award  of  projects  and  allows  sharing 
useful  information  between  beneficiaries  and  the  MA, 
IBs, and members of a special Task Force, which provides 
advice during project appraisal.  

Unique features 

The management module, allows users to manage the 
data collected in the selection of applicants, and collects 
new  data  specific  to  the  monitoring  of  projects  such  as 
annual  updates  of  indicators,  biannual  updates  of 
projects’  physical  progress,  and  quarterly  updates  of 
projects’ financial data. This information can be accessed 
by the services of the EC, beneficiaries, the AA, external 
auditors,  the  CA,  the  various  actors  within  the MA,  and 
the IBs, so they can monitor the progress of projects co-
financed by ERDF. 

The  EUROGES  platform  also  allows  beneficiaries  to 
submit standard documents to the IBs or the MA, such as 
receipts, project fiches, project listings, eligibility analyses 
etc.  Users  can  access  predefined  electronic  formats  to 
create their declaration of payments, and upload scans of 
supporting  documents  such  as  invoices,  proofs  or 
payments, timesheets, etc.).  Moreover, the system keeps 
a log of users’ actions, and alerts the relevant authorities 
when a submission is made. 
There  is  also  an  interface  between  EUROGES  and  the 
system  used  by  the  CA,  allowing  for  the  transfer  of 
payment  requests  made  by  beneficiaries  and  other 
supporting documents.  

A  public procurement  module  has  been  created  for 
the  new  programming  period,  enabling  beneficiaries  to 
enter  a  series  of  new,  predefined  data  relating  to  their 
procurements  as  well  as  attach  supporting  documents. 
Once the encoding of the predefined data and supporting 
documents has been completed, beneficiaries can submit 
these  to  the  IB  or  MA,  which  proceeds  to  the  first  level 
controls  of  the  project.  Opinions  issued  are  directly 
encoded  in  the  management  section  of  EUROGES  and 
before issuing a final opinion of its control, the MA or IB 
can request additional information to the beneficiary.  
Finally,  the  platform  can  also  be  used  to  exchange 
messages between users via a chat function.  

Expected impact 

14 

 
 
 
 
 
 
 
 
 
 
 
 
Practice 1 – MA’s monitoring system shared 
with other entities 

In March 2016, the EC verified and confirmed that all the 
relevant  requirements  regarding  Article  122(3)  of  CPR 
had  been  met  at  ERDF  level  in  Wallonia.  EUROGES 

increases the transparency of the project data, as well as 
improves the traceability of the operations and reinforces 
coordination between key stakeholders involved in order 
to prevent fraudulent activities and irregularities. 

Denmark – Subsidy Administration Control System (TAS) 
linked to the MA administration system for ERDF and ESF 

How it works  

The Danish Business Authority is the MA for ERDF and 
ESF  OPs  in  Denmark  for  the  2014-2020  programming 
joint  Monitoring  Committee  has  been 
period.  A 
established between the MA and the six Regional Growth 
Forums  (IBs)  to  monitor  both  funds,  and  the  MA  holds 
the  presidency  of  the  Committee.  Most  of  the  funds  are 
implemented in line with the recommendations made by 
the  Regional  Growth  Forums  established  in  all  five 
Danish regions and the island of Bornholm. The Regional 
Growth  Forums  develop  and  prioritise  actions  meant  to 
translate the regional business development strategy into 
specific improvements of the regional growth conditions. 

The  existing  system  for  processing  the  ERDF  and  ESF 
enables  applicants  to  search  for  all  the  relevant 
information about the funds on the managing authority’s 
website (www.regionalt.dk). The website is continuously 
updated  and  contains  general  information  about  the 
funds, 
information  about  the  application  process, 
reporting requirements, requirements for settlement, etc.  
A project database (CVR) is also integrated in this system 
and  contains,  among  other  things,  descriptions  of  all 
supported  projects,  a  regional  statistics  bank,  research 
articles and descriptions of the annual events. 

Unique features 

Information  and  data  from  project  applicants  are 
automatically  fed  into  the  MA’s  Subsidy  Administration 
Control  System  (TAS).  The  regional  growth  forum 
secretariats  have  access  to  the  TAS  and  carry  out  their 
initial  case  processing  recommendations  through  this 
system. The MA continues its case processing in the same 
system.  The  central  auditor  who  endorses  financial 
statements work in the system, and the CA has access to 
the  system  to  check  payments  requests  and  supporting 
documents.  TAS  contains  project  master  data,  financial 

(accounts 

record-keeping, 
data 
categorisation/impact  data  and  built-in  management  of 
the case flow.  

budgets), 

and 

When funding is awarded to an applicant, a project case 
is opened in the Project Reporting Application (PRV. In 
PRV, the project is given access to the commitment details 
and  the  project’s  budget,  including  information  about  a 
new  budget  every  time  the  MA  approves  a  change.  The 
information is automatically transferred from TAS. From 
here,  budgetary  changes  can  be 
requested  and 
automatically  submitted  to  the  MA  for  approval.  In 
addition,  information  about  the  project’s  participating 
partners and network participants using this application 
is also provided.  

Beneficiaries  can  thus  submit  their  interim  financial 
statements,  progress  reports,  milestones  and  results, 
provide  information  about  modified  contact  details, 
register  participants’/employees’ 
time  use,  provide 
information  about  impact,  and  contact  the  MA  if  they 
have  questions  via  a  messaging  system.  Recently,  it  has 
been made possible to use modules such as an accounting 
form/presentation 
statements, 
participant/employee 
to  start-up  and 
termination  forms  and  result  follow-up  forms  through 
PRV.  In  addition,  it  is  possible  to  submit  financial 
statements  for  projects  through  PRV.    Efforts  have  also 
been made to develop and test a flexible reporting system 
based on a standard software, which will make it possible 
to collate all data from the various databases used in the 
administration of the ERDF and ESF. 

financial 
links 

of 
files, 

Expected impact 

TAS improves the traceability and audit trail of the project 
operations, and allows easy and transparent data sharing, 
and  timely  identification  of  inconsistencies  in  the  data.  
Creation of one management tool can provide benefits of 
data centralisation and more efficient data management.  

15 

 
 
 
 
Practice 2 – Use of data collected through the MA’s 
monitoring system to detect fraud risks 

Summary of the practice 

Practice spotted in… 

 HR 
 EE 
 FI 
 LT 
 LU 
 PT 

A number of MAs who use their electronic management 
and  monitoring  system  to  carry  out  and  record  all 
operations  related  to  ESI  Funds  co-financed  projects 
(see  practice  1),  have  gone  a  step  further  in  using  this 
system.  Indeed,  some  MAs  are  using  data  collected  to 
detect fraudulent activities. 

Data collected can come from:  

 

  Operations  encoded  in  the  system  by  its  different 
users including (IBs, MA, CA, Funds’ applicants and 
beneficiaries)  such  as  on-the-spot  visit  report, 
requests for payments and supporting documents; 
Information collected through other databases and 
registers  publicly  available  (e.g.  tax  register, 
criminal  register,  etc.),  or  interoperable  with  the 
system  (e.g.  e-procurement  platform,  certified 
bidders  register)  needed  to  verify  applicants’ 
eligibility in the applicant selection stage. 

The  most  common  fraud  risks  that  MAs  and  IBs  can 
detect  via  this  system  by  using  the  data  collected 
through  it,  include  double  funding  applications  and 
manipulations of project and labour costs.  

Expected impact on anti-fraud system 

Strengthened checks in the selection of 
applicants 

When verifying the eligibility of fund applicants, MAs and 
IBs  need  to  have  access  to  a  variety  of  data  on  the 
applicant.  Interoperability  between  the  MA  monitoring 
system and other national databases provides a rapid and 
efficient  way  to  collect  this  information  in  a  short 
timeframe  as  well  as  reinforce  the  checks  performed  on 
fund applicants.  

Reinforced management verifications 
during project implementation 

During  project  implementation,  a  significant  amount  of 
data  is  required  and  exchanged  between  beneficiaries, 

IBs,  MAs,  and  CAs.  For  instance,  payment  requests 
submitted  by  beneficiaries  and  accompanied  by 
supporting  documents  such  as  timesheets,  enables 
verification  of  possible  manipulations  of  project  and 
labour costs.  

Increase administrative compliance 
and fraud detection  

The  once-only  principle,  enabled  by  interoperability, 
contributes  to  reducing  errors  and  irregularities  and 
consequently  strengthening  administrative  compliance. 
Hence, when a malpractice is detected, MAs and IBs are 
more attentive to red flags and fraud risks. 

16 

 
 
 
 
 
 
 
 
 
 
 
 
Practice 2 – Use of data collected through the MA’s 
monitoring system to detect fraud risks 

This  anti-fraud  practice  is  considered  a  hard  detection  measure  designed  to  mitigate  both 
external risks of fraud, mainly occurring during the selection of applicants, but also  during the 
project implementation and payments. The anti-fraud practice can effectively detect the following 
fraud risks : 
  Double funding; 
  Manipulation of project costs and quality. 

Examples of the practice 

Finland – EURA 2014 to detect double funding and 
manipulation of project and labour costs 

How it works 

is 

the  electronic  management  and 
EURA  2014 
monitoring  system  for  projects  co-financed  by  the  ESF 
and  ERDF  for  the  programming  period  2014-2020  in 
Finland.  The  Finnish  Ministry  of  Employment  and  the 
Economy  manages  EURA  2014.  MA,  IBs,  CA,  AA, 
applicants  and  beneficiaries,  which  have  access  to  this 
system (see Practice 1).  

The system primarily serves to ensure traceability of all 
projects’  operations  i.e.  selection  of  applicants,  project 
implementation  and  verifications,  and  payments  and 
certifications.  The  system  records  and  archives  all  data 
input by its users during these phases, such as follow-up 
and  final  reports,  preparation  and  receipt  of  project 
management  decisions,  etc.  The  system  also  stores  all 
documentation from management verifications (e.g. on-
the-spot  visit’s  reports)  and  documentation  for  EC 
reporting. 

The  EURA  2014  system  follows  the  so-called  once-only 
principle,  which means  that  once  information  has  been 
provided by a user once, there should be no need to input 
it  again.  The  once-only  principle  also  enables  users  to 
pre-fill  documents  on  the  basis  of  the  information 
previously  provided  by  s  project’s  applicant  and 
beneficiary. All documents produced by EURA 2014 are 
solely archived in electronic form.  

Unique features 

The  system  includes  direct  access  to  the  tax  authority 
website (vero.fi) and links  to other relevant authorities. 

The company registration numbers for all new applicants 
are sent on a daily basis from the EURA 2014 database to 
the  tax  authority’s  database  in  order  to  get  extensive 
information  on  the  tax  debts  of  the  applicant.  The  tax 
debt  information  is  checked  from  the  EURA  2014 
database before funding decisions are made. 

In addition, EURA uses data from projects’ operations to 
perform  the  following  countermeasures  related  to  the 
detection of fraud:  

  The same invoice cannot be entered twice in the MIS, 

which avoids double funding applications; 

  Concerning labour costs, the MA can use the system 
to check whether the same staff member was working 
less  than  the  required  number  of  hours  per  day, 
across all projects; 

  The system automatically prevents the same person 
being declared as staff for more than one project; 
  The timesheet completed by staff working on projects 
must  include  all  projects  in  which  the  person  is 
involved. 

Expected impact 

EURA  2014 management and monitoring system offers 
various  functionalities  including  greater  efficiency  in 
procedures and reduction of administrative burden and 
traceability of project’s operations. In addition, thanks to 
data  stored  in  EURA  2014,  MAs  and  IBs  can  perform 
fraud detection activities, including checking for double 
funding 
possible 
detecting 
manipulations of project and labour costs.   

applications 

and 

17 

 
 
 
 
 
 
Practice 2 – Use of data collected through the MA’s 
monitoring system to detect fraud risks 

Portugal – Balcão 2020 to detect double funding  

The result of this process establishes the classification of 
the  entities  in  two  dimensions.  One  related  to  the 
suitability and reliability code of the applicant (inhibited, 
conditioned, indicted or suitable), and the other related to 
the debt (in terms of ESIF recovery procedures) code of 
the  applicant  (entity  not  eligible  or  eligible  entity).  This 
information is only available in detail for the MA, ADC, CA 
and AA.  

However, the set of tools and modules used within Balcão 
2020  do  not  perform  any  checks  for  adverse  media 
searches about applicants or other referred entities. 

Expected impact 

The  interoperability  of  Balcão  2020  with  other  national 
systems  and  databases  enables  IBs  and  MAs  to  perform 
checks  for  double  funding  applications,  and  ensure  that 
the applicant is eligible for funding and complies with the 
principle of sound financial management.   

How it works  

The  “Balcão  2020”  is  system  is  the  point  of  access  and 
monitoring system for all OPs co-financed by ESI Funds 
for all entities wishing to apply for project financing. The 
system  also  performs  the  selection  of  applicants  and 
project  implementation.  Balcão  2020  was  developed  by 
the Agency for Development and Cohesion to be used as a 
communication platform between ESI Funds authorities 
and applicants that participate in the OPs Portugal 2020. 
This system is used to manage all applications and entities 
under the ESIF programmes and its development started 
in  previous  programmes  (2007/2013).  This  tool  has 
several  integrated  modules  used  in  the  application 
process.  

Unique features 

The  main  module  that  manages  eligibility  factors  for 
applications  is  the  business  register  (“Base  única  de 
Promotores”).  This  module  aims  to  identify  double 
funding  applications  by  project  applicants,  which 
is  against  the  principle  of  sound  financial  management, 
one of the key requirements for ESIF applicants. In case a 
double  funding  application  is  detected,  the  applicant  is 
forbidden to submit a new application for a defined period 
of time.   

This  module  also  uses  information  associated  with  the 
applicant, 
in  several  public  administration 
located 
databases, namely:  

  The Tax Authority; 
  The Social Security; 
  The Judicial Authority;  
  The  National  Register  of  Certified  Beneficiaries, 

IAPMEI).  

18 

 
 
 
 
 
 
 
 
 
 
 
 
  
Practice 3 - Cooperation between ESI Funds 
authorities and other national authorities 

Summary of the practice 

Practice spotted in… 

Cooperation  between  ESI  Funds  authorities  and  other 
key  national  anti-fraud  stakeholders  brings  several 
benefits to the fight against fraud and corruption. In its 
guidelines for preparing national anti-fraud strategies for 
ESI  Funds,  the  European  Commission  emphasises  the 
value  of  strengthening  prevention  measures 
for 
competent authorities in MS.  

To  make  prevention  more  effective,  closer  and  faster, 
cooperation  between  all  relevant  stakeholders  and  an 
overall  enhanced  coordination  of  action  are  highly 
encouraged. 

 BG 
 DK 
 EL 
 FI 
 IT 
 HR 

 LT 
 LU 
 LV 
 NL 
 PL 

can  be 

Cooperation 
various 
mechanisms,  such  as  the  creation  of  working  groups, 
informal  networks  of  authorities,  and  formal  and 
informal cooperation agreements.  

achieved 

through 

Examples  presented  in  this  practice  cover  some  of  the 
cooperation mechanisms put in place under the initiative 
of MS competent authorities.  

Expected impact on anti-fraud system 

Synergies 

An important benefit from such cooperation mechanisms 
is  the  synergy  arising  from  the  regular  exchanges  of 
information  and  discussions  on  risks  and  potential 
controls  to  be  implemented.  The  collaboration  also 
enables  the  devising  of  tools  and  procedures  that  better 
target  identified  areas  of  risks.  It  also  reduces  the 
duplication of work and allows an alignment of strategies 
for fighting fraud and corruption.  

Knowledge sharing 

Establishing  close  links  through  common  workshops, 
presentations  or  trainings  with  other  relevant  bodies 
enables the sharing of knowledge and the development of 
a common understanding with counterparts. Such events 

are important in ensuring all bodies are informed about 
new  risk  areas,  are  trained  or  made  aware  of  potential 
fraud  schemes  and  ways  to  identify  these.  Knowledge 
sharing  also  fosters  peer  learning  and  leads  to  an 
increased capacity of all parties involved. 

 Coordination between stakeholders 

Greater cooperation among bodies often leads to greater 
coordination,  which  is  crucial  in  fighting  fraud  and 
corruption.  Indeed,  practices 
identified  show  that 
coordination  with  authorities  such  as  law-enforcement 
authorities  can  lead  to  a  better  identification  and 
reporting of fraud cases by combining efforts and building 
on various stakeholders’ expertise. In essence, improved 
coordination  leads  to  more  efficient  and  more  effective 
common operations. 

19 

 
 
 
 
 
 
 
 
Practice 3 - Cooperation between ESI Funds 
authorities and other national authorities 

This  practice  is  considered  as  a  soft  prevention  anti-fraud  measure,  primarily  helping  to 
mitigate a lack of skills and reinforce an anti-fraud culture within an authority and at the national 
level,  as  well  as  support  the  capacity  building  of  anti-fraud  practitioners  within  competent 
authorities.  In  addition,  cooperation  mechanisms  are  considered  to  have  an  indirect,  positive 
impact on the detection of all fraud risks. This is due to the sharing of knowledge and information, 
which  contributes  to  awareness  raising  on  fraud  indicators  amongst  participating  authorities, 
allowing them to take timely take relevant actions.   

Examples of the practice 

Croatia – Network for the Management of 
Irregularities 

How it works 

Croatia  has  a  decentralised  management  system  of  ESI 
Funds  involving  several  IBs.  The  Ministry  of  Regional 
Development  and  EU  Funds  of  Croatia  is  the  MA 
responsible for the OP Competitiveness and Cohesion. It 
has  delegated  responsibilities  to  nine  first  and  second 
level  IBs,  to  which  duties  and  obligations  significantly 
vary as they relate to different priority axes, and thereby 
requires  the  monitoring  and  control  of  very  different 
projects.  

In  order  to  prevent  the  occurrence  of  irregularities  and 
fraud cases and to exchange good and bad practices in the 
handling,  reporting  and  follow-up  on  irregularities,  the 
Ministry  of  Finance  has  established  a  Network  for  the 
Management of Irregularities. 

Unique features 

The initial Network meeting took place in February 2017, 
and in general, the meetings are to be held regularly every 
three  to  four  months  or  earlier  if  needed.  The  Network 
includes  staff  for  irregularities  in  second  level  IBs, 
irregularity  coordinators  in  first  level  IBs,  and  where 
appropriate, other representatives of IBs, representatives 
from  the  Agency  for  the  Audit  of  European  Union 
Programmes  Implementation  System  and  experts  from 
the Ministry of Economy, Entrepreneurship and Crafts, as 
well as the Directorate for Public Procurement Policy.  

Network for the Management of Irregularities is a forum 
that  gathers  practitioners  and  sets  up  an  arena  for 
discussion.  The  Network  allows  stakeholders  to  share 
practices and experiences, discuss cases of irregularities, 
reflect  on  common  trends  and  changes,  and  focus  of 
irregularities.  

Involvement  of  the  stakeholders  from  different  levels  
(central authorities and IBs) creates the opportunity for 
them to  raise the questions, request additional guidance 
and  have  a  better  visibility  on  the  overall  process  of 
irregularities management and roles and responsibilities 
of  each  stakeholder.  The  organisation  of  the  regular 
meetings of the Network is the key to its success, as timely 
and  coordinated  knowledge  sharing  allows  for  more 
efficient  detection  of  irregularities  and  their  effective 
management. 

Expected impact 

Croatia’s 
for  the 
implementation  of  the  Network 
Management  of  Irregularities  is  expected  to  benefit  all 
stakeholders involved. Potential benefits may include the 
enhancement of competences related to fraud detection, 
better  coordination  between  stakeholders  of  different 
levels,  shorter  feedback  loops,  faster  and  more  efficient 
decision making, and improved peer learning between the 
IBs. 

20 

 
 
 
 
 
 
 
 
 
 
 
Practice 3 - Cooperation between ESI Funds 
authorities and other national authorities 

Lithuania – Cooperation with the Financial Crime 
Investigation Service 

How it works  

To  ensure  a  sufficient  flow  of  information  between  the 
MA, the AA and the CA, a cooperation agreement between 
these  authorities  and  the  Financial  Crime  Investigation 
Service  (FCIS)  has  been  established.  Trainings  and 
workshops  are  organised,  particularly  between  those 
three authorities  but also  with the Special Investigation 
Service (SIS). 

Unique features 

The  Board  of  the  Illegal  Support  Prevention  and 
Investigation  is  the  main  unit  of  FCIS,  involved  in  the 
coordination with the ESI Funds authorities. The Board 
of the Illegal Support Prevention and Investigation seeks 
to  strengthen  the  competences  of  the  management  and 
control system institutions. In addition, it actively shares 
information about the trends in criminal acts and newly 
emerging fraudulent mechanisms, and offers preventive 
measures. 

The  Board  of  the  Illegal  Support  Prevention  and 
Investigation  organizes  meetings  of  the Working  Group 
of  Irregularity  Officers  for  the  ESI  Funds  authorities. 

These  meetings  provide  the  possibility  to  exchange  on 
best  practices,  deal  with  current  issues  and  solve 
emerging problems. 

The meetings with the Irregularity officers are attended 
by representatives of IBs, ministries and the SIS, among 
others. These meetings take place on a quarterly basis as 
a  means  to  exchange  information  on  fraud  prevention 
measures, planning processes and developing anti-fraud 
tools.  The  number  of  institutions  having  Irregularity 
Officers  has  constantly  increased  since  the  2004-2006 
programming  period  from  15  to  22  for  the  2014-2020 
programming period. 

Expected impact 

The practical cooperation with the investigation services 
and law enforcement institutions in Lithuania is expected 
to  reinforce  the  practical  skills  of  fraud  detection  and 
thereby improve the Irregularity Officers’ understanding 
of  the  fraud  implementation  mechanisms  as  well  as 
detection and investigation. Moreover, such cooperation 
influences the assessment of fraud risks and fosters better 
targeting of measures in light of evolving fraud practices. 

21 

 
 
 
 
 
 
 
Practice 3 - Cooperation between ESI Funds 
authorities and other national authorities 

Italy – Memorandum of understanding between the Ministry 
of Economic Development and the Financial Police 

How it works  

Expected impact 

On  21  January  2014,  the  Ministry  of  Economic 
development  and  the  Financial  police  of  Italy  signed  a 
memorandum  of  understanding  in  order  to  formalise 
their  cooperation.  It  focused,  among  other  areas  of 
collaboration, on the “investments projects and programs 
of  administrations,  entities  and  individuals  that  avail  of 
both  public  and  European  funds  as  well  as  the  national 
subsidies,  also  cofounded  by  the  European  Union,  in 
relation  to  incentives  being  benefited  from  firms  in 
disparate sectors".  

In  this  light,  the  collaboration  between  the  Ministry  of 
Economic Development and the Special Unit of Financial 
Police on  public  expenditure and repression of  European 
frauds  strengthened  the  prevention  aimed  at  curbing 
fraudulent  activities  and  smoothened  the  exchange  of 
information.  In  addition,  the  Ministry  of  Economic 
Development,  when  needed,  may  also  call  on  the  above-
conduction  of 
the 
mentioned  Special  Unit 
investigations, checks and monitoring. 

for 

Lithuania – Knowledge transfer with the Financial Police of 
FYR Macedonia 

How it works  

Building  the  capacity  in  fraud  detection  can  benefit  not 
only from national exchange, but also from international 
collaboration.  An 
successful 
collaboration  is  a  twinning  project  between  Lithuanian 
authorities,  led  by  the  Financial  Crime  Investigation 
Service,  and  the  Financial  Police  within  the  Ministry  of 
Finance of FYR Macedonia. 

example 

such 

of 

The project was executed in November 2015- May 2016 as  
part of the European Union IPA 2011 Programme, with a 
budget or EUR 250,000. It gathered five authorities from 
Lithuania  (the  Ministry  of  Finance,  the  Central  Project 
Management  Agency,  Financial  Crime  Investigation 
Service, Special Investigation Service and the Prosecutor 
General's  Office) 
the  detection  and 
investigation of financial crimes. 

involved 

in 

administrative capacities of the national institutions and 
strengthen cooperation within the system for fight against 
fraud and irregularities of ESI Funds. 

Unique features 

In the scope of the twin project, the representatives from 
the  public  administrations  of  Lithuania  and  FYR 
Macedonia  worked  together  in  order  to  transfer  the 
expertise and good practices developed within the EU. 

from  Lithuanian 

institutions  shared  their 
Experts 
experience and, in cooperation with the colleagues from 
Macedonia,  developed  recommendations  on  how  to 
improve  the  practices  of  the  Financial  Police  on 
Macedonia when dealing with fraud and corruption in ESI 
Funds, 
relevant  procedures, 
conducted trainings targeted trainings for the staff of the 
Financial Police and organised study visits in Lithuania.  

supported  drafting 

The objective of the project was to improve the national 
capacities of the Finance Police for protection of the EU 
financial  interests  and  cooperation  with  the  European 
Anti-Fraud Office (OLAF). In addition, this project aimed 
at  improving  the  national  legal  framework,  reinforce 

Expected impact 

The  bilateral  project  between  public  authorities  from 
Lithuania  and  FYR  Macedonia  contributed  to  the 
development  of  an  effective  and  efficient  system  of 

22 

 
 
 
 
Practice 3 - Cooperation between ESI Funds 
authorities and other national authorities 

protection  of  EU  financial  interests  in  FYR  Macedonia 
and  reinforced  its  cooperation  with  the  European  Anti-
Fraud Office (OLAF). 

This  project  represents  a  successful  practice  of  sharing 
knowledge and experience between several countries and 
thereby increasing the capacity of local authorities in the 
field of fraud detection for ESI Funds operations. 

Case study: Danish AFCOS network 

Context 

Under the new Regulation No 883/2013 (OLAF Regulation), which came into force in October 2013, all Member States 
were required to designate an Anti-Fraud Coordination Service (AFCOS). In May 2014, the Danish Ministry of Finance 
was appointed AFCOS, and at the same time, an AFCOS network was established at the national level ensuring adequate 
and close coordination between Danish authorities relevant to the fight against fraud and corruption.   

Objective 

The Danish AFCOS network ensures fast and sound cooperation in the fight against fraud and corruption in Denmark, and 
provides a valuable input to the functioning of the Danish AFCOS.  

Structure 

In addition to transferring fraud cases of an administrative nature from the Danish competent authorities to OLAF, the 
Danish AFCOS also chairs the network, which is composed of the following authorities:  

  Danish Agricultural Agency under the Ministry of Environment and Food.  
  Danish Fisheries Agency  under the Ministry of Foreign Affairs 
  Danish Business Authority , regional unit under the Ministry of Business and Growth 
  Danish Tax Authority (SKAT)  
  Danish State Prosecutor for Serious Economic and International Crime (SOIK) under the Ministry of Justice. 

These authorities consist of the Danish authorities in charge of managing the EU spending programmes, collecting the 
Danish contribution to EU own resources (customs), as well as investigating and prosecuting criminal cases of fraud in EU 
funds.  

How it works  

Members of the Danish AFCOS network usually meet three times a year - in January, May and October - or as needed, 
and the goal of these meetings serves various purposes related to the fight against fraud.  

First, these meetings help ensure a regular top-down and bottom-up communication between the Commission 
and  national  ESI  Funds  authorities  on  anti-fraud  issues.  For  instance,  the  network  meets  to  prepare  and  agree  on  the 
content and information to report to the Commission, which constitutes an input to the PIF report.  

23 

 
 
 
 
 
 
 
Practice 3 - Cooperation between ESI Funds 
authorities and other national authorities 

Case study: Danish AFCOS network 

Such meetings also serve to disseminate knowledge and information stemming from the Commission to all 
members  of  the  network.  Following  a  meeting  of  the  Advisory  Committee  for  the  Coordination  of  Fraud  Prevention 
(COCOLAF) for instance, members of the network meet to discuss information and updates from the EC level, and agree 
on the best approach to disseminate this information to staff members of all relevant authorities e.g. discussing follow up 
measures to PIF report recommendations.  

Similarly, these meetings also present an opportunity to share fraud related knowledge obtained or produced by 
members of the network. For instance, sharing a presentation from the Ministry of Justice on data protection law and 
its impact on the work of competent authorities in combating fraud and corruption, or disseminating the annual report 
from the European Court of Auditors on their major audit findings.  

Finally, members of the AFCOS network meet to share and benefit from the feedback, experience and practices 
implemented,  which  have led to a successful anti-fraud outcome such as the detection of a fraudulent case. Successful 
approaches and processes used by managing authorities which have led to the identification of certain patterns of fraud, 
or  the  detection  of  real  fraud  cases,  are  regularly  shared  within  the  network  and  widely  disseminated  to  benefit  other 
managing authorities or other authorities.  

In  addition  to  regular  and  ad  hoc  meetings,  members  of  the  AFCOS  network  have  concluded  several  informal 
cooperation agreements, and in some cases with external parties. These cooperation agreements primarily serve to:  

  Reinforce the detection of double funding. A cooperation agreement has been concluded between the Danish 
Business Authority and the Danish Agriculture Agency under the Ministry for Food, Agriculture and Fisheries on the 
issue of double funding. Twice a year, the Danish Business Authority supplies data to the Ministry on companies, 
which have received funding. The Ministry for Food, Agriculture and Fisheries further checks for double applications. 
Should  a  suspicion  remain  after  the  check  is  completed,  the  case  manager  from  the  Danish  Business  Authority  is 
informed and can request additional verifications.  

  Support specific sectors of economy. A similar cooperation agreement has been concluded in June 2014 between 
the Danish Agriculture Agency and the Danish Tax Authority (SKAT) on agricultural support and EU market 
organisations. The goal of this agreement is to create a framework for ongoing cooperation and dialogue in relation 
to agricultural support and EU Common Market Organisations.  

  Provide  harmonised  and  comprehensive  anti-fraud  responses.  A  third  cooperation  agreement  has  been 
concluded  between  SKAT,  the  national  police,  and  the  Attorney  General.  The  goal  of  this  agreement  is to  create  a 
framework for constructive cooperation between the three parties, where authorities jointly ensure an effective, correct 
and  uniform  task  solution  and  continuously  strive  to  facilitate  cooperation.  Notably,  close  cooperation  between 
relevant managers and employees of the three authorities is fostered to ensure  effective and comprehensive action 
against  economic,  organised  and  cross-border  crime,  border  control,  customs,  investigation  and  enforcement  of 
criminal matters. The cooperation takes the form of coordinated efforts, discussion and planning of priorities, common 
focus on specific actions, and information exchange and assistance.  

Expected results 
The Danish AFCOS network brings about several benefits: 

 

Increased  and  faster  cooperation  and  reaction  of  member  Authorities,  leading  to  an  increased  awareness  and 
exchange of knowledge and good practices related to fraud and corruption risks, patterns, cases identified, etc.; 

24 

 
 
 
 
 
Practice 3 - Cooperation between ESI Funds 
authorities and other national authorities 

Case study: Danish AFCOS network 

  Fast and informal communication between member Authorities who are more comfortable and prone to engage 

with colleagues from a different Authority and informal discussions; 

  Due to its informal nature, the network is very agile and can thus be adjusted dependt on the need, and can involve 

additional non-member Authorities if need be.  

The creation of the AFCOS network did not entail the signing of any formal or written cooperation agreements from the 
participating  Authorities.  Rather,  the  network  was  created  upon  a  government  decision,  following  the  2013  OLAF 
Regulation and the requirement to designate an AFCOS.  

Contact details 

Name of the entity: 5th Division - International Cooperation 
and Defence, Ministry of Finance of Denmark 

Website:  

www.fm.dk  

Email address: fm@fm.dk 

25 

 
 
 
 
 
 
 
 
 
 
 
Practice 4 – Use of red flags 

Summary of the practice 

Practice spotted in… 

 BG 
 CZ 
 DK 
 ES 
 HR 
 HU 

Red flags are defined by the Commission and OLAF as a 
set of circumstances that are unusual or vary from normal 
activity  and  may  indicate  warning  signs,  hints,  and 
indicators  of  possible  fraud  or  irregularities. 
OLAF  is  in  charge  of  elaborating  an  overview  of  fraud 
risks and associated red flags.  

In several MS, MAs have either integrated OLAF’s red flag 
list  into  their  verification  checklists,  or  they  have  
expanded  it  to  create  their  own  list.  While  relying  on 
OLAF guidance increases the capacity of MAs and IBs to 
recognise red flags, the examples described in this anti-
fraud practice go a step further. They focus on authorities 
that  have  implemented  a  more  systematic  and  efficient 
use of red flags.   

Measures  developed  by  MAs  and  IBs  in  using  red  flags 
range from integrating a predefined list of red flags 
into their management verification checklists, to 
creating more advanced IT tools such as, data analytics 
tools  capable  of  detecting  red  flags  early  enough  to 
foresee relevant mitigating actions. 

Expected impact on anti-fraud system 

More harmonised and targeted 
management verification procedures  

More consistent approach in 
performing management verifications  

targeted  red 

When red flags are integrated into checklists or systems, 
verifications performed by IBs and MAs are improved and 
procedures  are  more  standardised  and  evenly 
applied.  In  addition,  the  staff  of  the  IBs  and  MA  can 
apply 
to  specific  projects  or 
beneficiaries.  Therefore,  MAs  and  IBs  staff  are  more 
cautious  and  thorough 
in  conducting  checks,  and 
verifications become more project or beneficiary-specific, 
thereby increasing the likelihood of detecting any possible 
deviations  from  normal  activity  and  practice.  In  some 
MAs, specific additional checks are foreseen when some 
red flags are detected.  

flags 

When red flags are documented in a checklist or a system, 
and  do  not  only  rely  on  staff’s  experience,  changes  of 
personnel have less impact on the quality of the controls. 
Similarly,  several  staff  members  working  on  the  same 
project or with the same beneficiary can obtain the same 
level of knowledge about fraud risks related to a project or 
a beneficiary by simply looking at the checklist or in the 
system.  

Reinforced detection of fraud 

Systematic  use  of  red  flags  and  their  integration  in 
processes  allows 
for  more  efficient  detection  of 
irregularities and fraudulent cases. Indeed, the use of red 
flags  in  itself  highlight  fraud-attractive  processes  and 
point  on  those  areas  that  need  additional  anti-fraud 
measures to be introduced to reduce the risk of red flags. 

26 

 
 
 
 
  
 
 
 
 
 
 
 
Practice 4 – Use of red flags 

This  anti-fraud  practice  is  considered  a  hard  detection  measure  designed  to  mitigate  both 
internal and external risks of fraud mainly occurring during the public procurement process, but 
also  during  the  project  implementation  and  payment.  The  following  fraud  risks  are  effectively  
detected by red flags:    
  Rigged specification, collusive bidding, manipulation of bids; 
  Conflict of interest; 
  Manipulation of project costs and quality. 

Examples of the practice 

Czech Republic – Risk cards 

How it works 

Unique features 

In  Czech  Republic,  the  Ministries  of  Transports,  of 
Agriculture, and of Industry and Trade - respectively the 
MAs  for  OP  Transport,  OP  Maritime  and  Fisheries,  and 
OP Enterprise and Innovation for Competitiveness - have 
adopted  a  common  approach  to  integrating  red  flags  to 
monitor  and  follow  up  on  projects’  management  risks, 
including fraud risks. To do so, the three MAs are using 
so-called  risk  cards,  which  are  used  to  follow-up  on 
fraud  risk  indicators  along  the  project  cycle 
from  approval  to  termination.  Hence,  for  each 
project co-financed under a certain OP, the MA creates a 
risk card.  

flags.  The  responsibility 

Where  MAs  have  delegated  responsibilities  to  IBs,  the 
MAs and their IBs conduct an initial common assessment 
for 
of  the  project’s  red 
monitoring the project’s risk card is then given to IBs who 
regularly update it during the project cycle. MAs regularly 
follow  up  on  the  work  of  IBs  on  risks  cards.  At  crucial 
stages of the project, MAs and IBs discuss the status of the 
project’s  risk  card.  This  allows  sharing  information  on 
new red flags identified, discussing the status of the risk 
management  approach,  and  commonly  agreeing  on 
additional  verifications  to  be  carried  out.  Hence,  during 
every stage of the project, IBs and MAs who perform first 
and second level controls on the project consult, monitor, 
and update the project’s risk card.  

Similar to the methodology of the FRA recommended by 
the  EC,  the  probability  of  the  risk  occurrence  and  the 
importance of the risk impact are assessed and quantified 
in the risks card by the person who identified the red flag. 
The probability of the risk occurring can range from very 
rare  to  almost  certain,  while  the  importance  of  the  risk 
impact  goes  from  imperceptible  to  unacceptable.  Based 
on the assessment of each risk, the total risk of the project 
is quantified and reported in an overview table listing 
the  total  risks  for  each  ongoing  project.  In 
addition, a description of the risk management approach 
or  any  additional  verification  planned  are  provided, 
together with an indication of their status. For instance, a 
risk of conflict of interest within the MA during the award 
procedure is identified as a red flag for a specific project. 
The  risk  management  approach  or  mitigating  measure 
proposed would result in systematically sending results of 
all award evaluation to all unsuccessful applicants. 

Expected impact 

Since  there  are  usually  multiple  project  and  financial 
managers responsible for checking the implementation of 
each  project,  risk  cards  serve  as  communication  tools 
referencing  all  past  red  flags  identified  for  a  specific 
project,  and  indications  of  next  steps  to  undertake  in 
order to pay closer attention to certain areas seen as risky. 
Risk cards therefore allow the manager who conducts the 
verifications to know where to focus efforts.  

27 

 
 
 
 
 
 
 
 
 
Practice 4 – Use of red flags 

Croatia – EC-recommended red flags integrated into management 
verifications  

How it works  

Croatian  regulation  sets  the  requirement  for  all  MAs  of 
ESI Funds and their IBs to use red flags for carrying out 
their  management  verification  procedures.  More 
the  EC’s  Information  Note  of  Fraud 
specifically, 
Indicators for ERDF, ESF, and CF (COCOF 09/0003/00-
EN)  has  been  transposed  into  the  Common  National 
Rules (CNR) for Management and control system of MAs 
in  Croatia.  Implementation  of  the  CNR  is  expected  to 
reinforce the use of red flags and identification of fraud 
risks for OPs under ESI Funds.  

fraud 

Application of CNR in the part of red flags is done through 
risks 
implementation  of  EC-recommended 
indicators, tailored fraud risks indicators or by using  IT 
tools.  The case of latter, the MA responsible for the OP 
Competitiveness and Cohesion reinforces the project risk 
assessment and red flag identification using Arachne risk 
scoring  tool.    For  this  OP,  The  MA  has  introduced 
procedures for the use of Arachne in the  CNR No.6  and 
No.10. However, all the functionalities offered by Arachne 
are  not  yet  fully  used  by  Croatian  authorities.  Those 
mostly used by the MA include identification of relations 
between legal entities and/or persons in order to identify 
possible conflict of interest.  

Unique features 

The  MA  for  the  OP  Competitiveness  and  Cohesion 
integrated  a  list  of  16  fraud  schemes  and  their 
associated  red  flags  into  management  verification 
checklists during desk-based and on-the-spot checks. The 
type, degree and frequency of the verifications using those 
red  flags  depend  on  the  assessed  level  of  risk  for  the 
project. Hence, the higher the perception of fraud risks for 
a specific project, the stricter the verifications will be. For 
instance, a project assessed with a high degree of riskiness 
could  be  subject  to  more  frequent  on-the-spot  checks, 
involving more targeted verifications. 

To  follow  up  on  the  implementation  and  monitoring  of 
fraud risks, the MA has designated risk coordinators 
in charge of coordinating with project managers of IBs on 
the use of red flags in their management verifications 

Therefore,  IBs  are  required  to  use  the  red  flags  in 
monitoring the following websites:  

  The 

e-procurement  website  on 

the  Public 

Procurement Office website; 

  The  State  Commission 
Procurements’ website. 

for  Control  of  Public 

In  addition,  IBs  carry  out  ex-ante  and  ex-post 
verifications of public procurement documentation, in 
which  they  also  pay  close  attention  to  red  flags. 
Methodology 
for  conducting  ex-ante  and  ex-post 
verifications  also  foresees  the  use  of  Arachne,  based  on 
the  risk  analysis  related  to  individual  procurements, 
ensuring that all procurement with estimated value equal 
to or higher than EU thresholds are selected for ex-ante 
verifications.  

Moreover, IBs also integrate red flags when verifying and 
approving applications for  reimbursement submitted by 
beneficiaries. During this process, IBs verify all submitted 
applications  for  reimbursement  and  choose  a  sample  of 
claimed costs for additional verifications.   

Expected impact 

integration  of  red  flags 

into  the 
Requirement  of 
management  and  control  system  in  Croatia  ensured  a 
high  standard  for  risk  control  and  verification  for  ESI 
Funds  operation.  The  list  of  red  flags  covering  16  fraud 
schemes ensure that all the risky areas of the project cycle 
are  regularly  monitored  and  investigated.  Moreover, 
implementation of IT tools for identification of red flags 
for  key  risk  areas  suggest  more  efficient  and  effective 
identification  of  irregularities  and  potential  fraudulent 
cases. 

28 

 
 
 
 
 
 
 
 
Practice 4 – Use of red flags 

Denmark – Red flags to assess and categorise companies  

How it works  

4.  Companies willing to comply with the rules and have 

The  Danish  Business  Authority,  the  MA  responsible  for 
ERDF and ESF OPs during the 2014-2020 programming 
period,  and  its  six  regional  IBs,  integrate  red  flags  into 
their  management  verification  checklists.  In  addition, 
authorities  have  tailored  specific  red  flags  for  assessing 
and  classifying  companies  during  the  selection  of 
applicants and the implementation phase of the project. 
The  assessment  of  companies  is  performed  using  the  
MA’s  monitoring  system  and  external  databases.  
Identification of the risky areas is based not only on the 
knowledge  and  experience  of  MA  staff  but  is  also 
reinforced  through  the  knowledge  exchange  with  other 
MAs through Danish AFCOS network of national bodies 
(see Case study in anti-fraud practice 5).  

Unique features 

information  on 

Red  flags  are  used  during  the  company  assessment  to 
indication  of  business, 
collect 
geographical, legislative, and economic nature, and cover 
the  organisation  structure,  history  and  business 
relationships  of  companies  at  stake.  Once  sufficient 
information on a company has been collected, the MA and 
IBs categorise companies into one of the four groups:   

1.  Companies unwilling to comply with the rules; 
2.  Companies  unwilling  to  comply  with  the  rules  but 

may be affected;  

3.  Companies willing to comply with the rules but do not 

have the ability to do so; and 

the ability to do so. 

These  categories  were  developed  on  the  basis  of  the 
following indicators:  

  Track records on irregularities; 
  Filing of complaints; 
  Knowledge and skills to comply with the rules; 
  Organisational structure;  
  Level of confidence in the authority. 

This structure is dynamic and flexible, allowing company 
to be moved into a different group if a change of behaviour 
occurs. This system allows the Danish Business Authority 
and its six IBs, to use a similar approach in assessing fund 
applicants and bidders. 

Expected impact 

to 

Danish  Business  Authority  believes  that  the  red  flag 
system  fosters  a  strong  ethical  culture  and  a  zero 
tolerance  approach 
fraud.  The  system  allows 
authorities regularly exchange  information on suspicion 
of  fraud,  identified  potential  fraud  patterns  and  good 
practices in fighting fraud and corruption. In addition, the 
flexible nature of the system creates the need for periodic 
fora  and  workshops  where  authorities  discuss  the 
developments  and  behavioural  changes  of  selected 
companies, thus reinforcing the cooperation and capacity 
building among authorities. 

Hungary – The Red Flags early warning system 

How it works 

The  Red  Flags  www.redflags.eu  tool  is  the  result  of  an 
initiative  started 
in  2013  between  Transparency 
the  K-Monitor  Watchdog 
International  Hungary, 
Organisation  for  Public  Funds  and  the  PetaByte  IT 
Research Company. The tool was launched in 2015 with 
the  purpose  of  bringing  more  transparency  to  the 
Hungarian public procurement system by creating an IT 
system capable of generating automatic alerts whenever a 
contract notice or contract award notice seems suspicious 
or may contain corruption  or fraud risks. It is funded by 
the  HERCULE 
the  European  Commission  under 

programme,  as  part  of  a  larger  effort  to  address 
procurement risks in several MS.  

Unique features 

Tender notices and contract award notices are the main 
source  of  structured 
information  on  procurement. 
Therefore, the Red Flag tool relies on tender notices and 
contract  award  notices  published  in  Tenders  Electronic 
Daily  (TED)  to  automatically  monitor  and  control 
procurement  expenditure  in  Hungary.  This  is  made 
possible thanks to an algorithm that allows to filter areas 
where procurements are at risk.  The algorithm has been 

29 

 
 
 
 
Practice 4 – Use of red flags 

developed  around  a  set  of  40  indicators  that  are 
considered as risk factors  by Transparency International 
Hungary,  from  which  32  are  used  to  check  contract 
notices and 9 are used to check award notices.  

When  looking  at  contract  notices,  indicators  such  as 
technical  capacity  and  economic  and  financial  ability 
requirements  as  well  as  the  use  of  specific  procedures 
considered favourable ground for corruption are assessed 
to  determine  whether  the  notice  contains  risk  factor(s). 
For  contract  award  notices,  indicators  can  include 
procedures without prior publication, the ratio of the total 
final  value  and  estimated  value,  or  unsuccessful 
procedures  for  risky  reasons  or  without  statement  of 
reason.  

For the risk analysis, the tool makes a distinction between 
‘red  flags’  and  ‘pink  flags’.  The  ‘red  flag’  indicators  are 
directly linked to contract or award notice data related to 
a  specific  procurement  procedure.  These  red  flags  may 
indicate an actual infringement or a simple risk. On  the 
other  hand,  ‘pink  flags’  are  not  linked  the  specific 
procurement  procedure  but  refer  to  previous  instances, 
which  increase  the  risk  profile  of  either  the  contracting 
authority  or  the  economic  operator.  They  are  based  on 
information  collected  in  previous  research  or  from 
information  (e.g.  government 
external  sources  of 

databases)  and  serve  to  complement  the  red  flags.  For 
instance,  they  can  inform  on  whether  the  contracting 
authority  has  been  convicted  by  a  final  judgement  or 
provide  information  on  the  conduct  of  the  winning 
bidder.  

Every  signal  sent  by  the  Red  Flags  tool  cannot  be 
considered  as  an  evidence  for  corruption.  These  signals 
should be considered as a gauging mechanism that advise 
on  areas  of  a  tender  or  award  notice  where  special 
attention  should  be paid.  In  cases  where  several  signals 
are received for the same notice of award notice, then this 
may suggest a greater likelihood that  corruption exist.     

Expected impacts 

The Red Flags tool is considered very promising, as it is 
the  first  of  its  kind.  Despite  its  limited  coverage  of 
procurement  expenditure, 
it 
represents an effective tool for detection of fraud risks for 
the  stake  of  project  procurement  and  increase  of  its 
transparency. The tool currently has over 700 registered 
users in Hungary and its application is being considered 
by civil society organisations in several other MS. 

i.e.  above  thresholds, 

Italy – National Anti-fraud Database (future implementation) 

In  order  to  introduce  an  IT  system  for  risk  analysis, 
complementary  to  those  of  the  Commission  (Arachne, 
IMS,  etc.),  the  Italian  Central  Anti-Fraud  Coordination 
Office (AFCOS) has planned the development of a special 
electronic  application,  known  as  DNA  (National  Anti-
Fraud Database), whose purpose is to strengthen the fight 
against fraud in Italy. 

In  order  to  design  and  develop  an  efficient  tool,  a 
preliminary  benchmarking  of  all  existing  databases 
used for the monitoring and control of EU funding in Italy 
was  carried  out,  both  at  central  and  local  level  by  the 
competent authorities. In addition, the feasibility of the 
creation  and  use  of  the  DNA  by  all  ESI  Funds 

authorities has been assessed, with the specific purpose 
of detecting irregularities and fraud.   

The  national  anti-fraud  IT  application  will  consist  of  a 
single platform compiling data from different sources. In 
particular,  the  data  included  in  the  application  should 
come from two types of sources: (i) information on the use 
and  destination  of  EU  financing  streams  held  by  the 
Authorities  (or  Bodies)  responsible  for  managing  them 
and (ii) information that is cross-checked and combined 
with  the  data  in  the  information  databases,  in  order  to 
carry out risk analysis. 

The  full  scale  implementation  of  the  tool  is  expected  in 
2020 

30 

 
 
 
 
 
 
 
 
 
 
 
 
Practice 4 – Use of red flags 

Case study: Spain – The Rapid Alert System  

Context 

The Rapid Alert System (Sistema d’ALErta Rapida or SALER) is an IT system jointly created by Generalitat Valencian 
and the Technical University of Valencia, which analyse the data generated by the administration, and detects possible 
irregularities and risks of fraud and corruption in public procurement procedures.  

Generalitat Valenciana is the self-government institution under which the Spanish autonomous community of Valencia 
is politically organised. The General Inspection of Services of the Valencian administration is the highest internal control 
and  inspection  body,  responsible  for  monitoring  of  administration’s  compliance  with  the  law,  and  its  observance  of 
general principles of the public administration (i.e. objectivity, impartiality, and efficiency). 

Objective 

The Rapid Alert System was created in 2016 with the purpose to have a fast, practical and effective system to analyse the 
data generated by the Valencian administration, and to detect any possible malpractice or fraud and corruption risk. Such 
tool was largely deemed necessary by the administration as the usual ways of detecting malpractices (e.g. complaints, 
audits  and  inspections,  etc.)  were  not  sufficient  to  detect  fraud  and  corruption  cases.  Complaints,  for  instance,  were 
usually  filed  when  corruption  cases  are  already  advanced,  while  audit  systems  and  inspections  only  help  detect 
irregularities a posteriori.  

The Rapid Alert System therefore represents an early detection measure to identify risky areas in a preventive way. The 
system aims to prevent those risks from becoming real fraud or corruption cases.  

1st Semester of 2016 

Step 1. Making the 
information available 

Step 2. Requesting reports on 
legality, opportunity and 
authorisation

2017

Step 5. Testing the IT system

Structure 

Approach   

2nd Semester of 2016

Step 3. Defining 
components of the IT system

Step 4. Establishing logical 
and physical elements of the 
IT system 

The  Valencian  administration  and  the  Technical  University  of 
Valencia  adopted  a  seven-step  approach  over  a  three-year  time 
horizon to develop the Rapid Alert System.  

During the first year of development, the focus was put on preparing 
the ground for the tool’s development, while the last two years focused 
on obtaining the general buy-in from the administration’s hierarchy, 
and raising the tool’s awareness.  

2018

Step 6. Activation of the IT 
system

Step 7. Evaluation of 
the IT system 

Steps  

It was first important to meet the main prerequisites for such a tool to 
exist,  i.e. data availability  and data accessibility, in order to identify 
the right sources of information available. Based on these, the relevant 
risk indicators for fraud or corruption were defined.  

The next steps were to gather and compute relevant  data, clean and 
parse  it,  where  necessary,  so  that  it  is  readable  and  usable  by  the  algorithm  that  will  analyse  it.  Designing  the  tool’s 
software, that is the tool’s algorithm, consisted of building the code that extrapolates, analyses and presents the data.  

31 

 
 
 
Practice 4 – Use of red flags 

Case study: Spain – The Rapid Alert System  

Once the tool’s software was built, the pilot results had to be tested to ensure the system worked as intended, and if not 
case, to refine the process or the indicators, or possibly add more data. The final step served to present the data in a user-
friendly and intuitive way.  

The  last  two  years  of  development  were  dedicated  to  the  official  launch  of  the  tool  and  to  obtain  a  buy-in  from  key 
stakeholders. These include relevant ministries, the legal Council and the main Valencian Council. A prior consultation 
with relevant ministries and a public consultation were organised to promote and facilitate a wide acceptance of the tool.  

Once the buy-in was obtained, the final step was to create a legal basis for the Rapid Alert System, and for the General 
Inspection of Services of the Valencian administration that will be responsible for the use and management of the tool. 
The  legal  basis  will  also  indicate  sanctions  related  to  cases  detected  by  the  Rapid  Alert  System.  The  draft  law  was 
submitted and is currently in parliamentary procedure. It is expected to be approved this year upon which, the use of the 
Rapid Alert System will be activated.  

How it works 

The  Rapid  Alert  System  interconnects  information 
from files containing administrative data, allowing 
the system to identify areas of risk.  

Risk indicators 

Indicators  are  established  on  the  selected  data  and 
parametrised  using  algorithms.  This  further  allows 
revealing  correlations  by  cross-referencing  the  data. 
Indicators  include  both  quantitative  and  qualitative 
elements.  Quantitative  indicators are converted  into 
numerical  parameters  that  make  it  possible  to  set 
automatic alerts (e.g. unjustified period payments to the 
same  company,  or  double  application  for  subsidies). 
Qualitative indicators identify the modus operandi of 
possible  bad  practices  based  on  the  study  of  past  cases 
(e.g. organisational deficiencies related to responsibilities 
and functions). 

When  an  alert  is  triggered,  the  action  protocol  of  the 
General Intervention Services is activated. In addition to 

signalling alerts, the system enables proactive searches and the evaluation of results. 

Information sources  

Information  feeding  the  Rapid  Alert  System  come  from  both  internal  and  external  databases  to  which  the 
administration  has  access.  Internal  information  sources  include  files  such  as  records  of  contracts  (data  relating  to  all 
phases of the  bidding process, implementation of the contract and complaints where relevant), direct payments (data 
related to the types of  products or services acquired  and suppliers), subsidies  (data relating to the  holder  of the body 
granting  the  subsidy,  conflicts  of  interest,  beneficiary,  justification,  and  invoices).  External  databases  consists  of  the 
register  of  declarations  of  activities  and  goods  held  by  high  officials,  notarial  information  from  the  Valencian  tax 
administration, the register of the controlling bureau for conflict of interest, and databases with personnel and payroll 
data. Monitoring these records and databases does not imply any legal obstacle as the information stored is public. 

Defining accurate and specific risk indicators serving as red flags is key to identify irregularities and fraud cases. 
Some of them are easy to identify such as, VAT numbers, contract references, payment date, and references in records 

32 

 
 
 
Practice 4 – Use of red flags 

Case study: Spain – The Rapid Alert System  
regarding gifts, trips etc., while some others are more complex and require knowledge of apparently unrelated processes 
taking place at the same time. Each department of the Valencian administration has developed its own set of indicators 
and identified risk factors associated with their procedures. All data provided by individuals or companies applying for 
public  calls  for  tender,  and  interacting  with  the  public  administration  will  be  digitalised  to  further  reinforce  these 
indicators. 

An  alert  is  triggered  when  an  objective  risk  is  detected.  All  alerts  are  registered,  and  when  an  investigation  is 
launched, it results in monitoring activities or a case being filed. Investigations consist of identifying weaknesses in the 
system, coding ongoing situations, and improving existing and adding new indicators. This continuous process is key to 
the success of the Rapid Alert System.  

Expected results 

The  Rapid  Alert  System  brings  about  several  benefits.  First,  it  acts  as  a  firebreak  to  counteract  inertia  and 
malpractices within the Valencian administration by enabling a consistent and systematic way of monitoring of past 
and present irregularities and fraud cases. Based on real detected cases, the tool allows  identifying some patterns, 
which give indications of where follow-up is most needed. Second, the Rapid Alert System and more specifically the legal 
basis around it which provides for sanctions, fosters an ethical culture amongst public employees, bidder and beneficiaries 
of the Valencian administration.  

During its pilot, the tool has already demonstrated its capacity and efficiency in detecting fraudulent cases. The type of 
irregularities and fraud risks the Rapid Alert System has been able to identify include among others, split purchases and 
more specifically unjustified separation of purchases, conflict of interest, and collusive bidding.   

Some lessons learnt  

The  development  and  implementation  of  the  Rapid  Alert  System  has  been  facilitated  by  several  key  success  factors 
including:   

  Data availability - which is a binding prerequisite to develop such system; 
  Access to the right information sources - without them key indicators cannot be computed; 
  Early buy-in of stakeholders - as it is key to obtain all necessary data; 
  Creating a legal basis needed to provide legal coverage to the inspection staff when they request data.  

.

Contact details 

Name of the entity: Generalitat Valenciana 

Website: www.gva.es/ 

Email address: generalitat_en_red@gva.es 

Name of the entity: Technical University of Valencia 

Website: www.upv.es/ 

Email address: informacion@upv.es 

33 

 
 
 
Practice 5 –  Whistleblowing mechanisms 

Summary of the practice 

Practice spotted in… 

 BG 
 CZ 
 EL 
 FR 
 NL 

Whistleblowing  policies  are  a  means  to  encourage 
individuals  to  reporting  unethical,  criminal  or  unlawful 
activity  to  authorities  by  offering  them  protection  from 
reprisals.  

A  clear  and  well-enforced  policy  of  whistleblower 
protection policy is an essential part of a comprehensive 
anti-fraud approach.  Whistleblowing  mechanisms differ 
between  MS  and  OPs  and  can  take  a  form  of  an  email 
channel,  a  dedicated    web-page  at  the  MA  or 
centralised  level,  or,  in  some,  cases,  a  regional  or  a 
coordinates 
web-platform 
national 
whistleblowing channels of several authorities. 

that 

A  comprehensive  whistleblowing  policy  should  be  built 
on  a  strong  national  whistleblowing  legislation,  and 
provide  authorities  with  clear  internal  structures  and 
procedures  on  how  to  stimulate  and  protect  whistle-
blowers, as well as how to follow up and investigate the 
whistleblowing alert. 

examples  below 

effective 
The  policy 
implementation of several forms of whistleblowing policy 
at  the  national  and  fund  level.  However,  some forms  of 
whistleblowing policies were spotted in all MS. 

represent 

Expected impact on anti-fraud system 

Enhanced fraud detection  

Effective whistleblowing mechanisms allow authorities to 
identify cases of potential fraud or irregularities as well as 
evidence  for  their  further  investigation.  In  combination 
with  internal  anti-fraud  measures  implemented  by  the 
MA or IB, the whistleblowing reinforces the detection of 
fraud and provides important data on the misconduct that   
at the early stage, allowing for effective control. 

Reinforcement of anti-fraud culture and 
ethical behaviour 

An  effective  and  well-developed  whistle  blowing  system 
creates  the  pre-conditions  for  the  more  responsible  and 

transparent  management  of  the  funds.  It  reinforces  the 
anti-fraud culture at the level of the beneficiaries and at 
the  level  of  responsible  authorities.  Moreover,  it  is  an 
important driver of ethical behaviour in the workplace. 

Strengthening internal controls 

The  potential  for  a  whistleblowers’  accusation  to  lead 
significant  financial  and  reputational  damage.  As  such, 
the  mere  presence  of  a  whistleblower  policy,  and  of  a 
culture that rewards and protects whistleblowers can also 
act as an incentive for beneficiaries to reinforce internal 
anti-fraud controls.  

34 

 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
Practice 5 –  Whistleblowing mechanisms 

This  anti-fraud  practice  is  considered  a  hard  detection  measure  designed  to  reinforce  the 
detection  of  fraud  and  to  strengthen  the  anti-fraud  environment  and  ethical  culture.   
Implementation  of  the  whistleblowing  mechanisms  has  transversal  impact  and  covers  all  risk 
categories across all the stages of the project cycle. 

Examples of the practice 

France – ELIOS platform  

How it works 

In the context of the Art 125(4)(c) of the CPR and Art. 59 
of  the  EU  Financial  Regulation  (Regulation  (EU) 
No 966/2012) the managing authority for the Operational 
Programmes 
in 
for  Employment  and 
Metropolitan  France  (FSE)  and  Youth  Employment 
Initiative  (YEI),  has  developed  the  so-called  ELIOS 
whistle-blowing platform. 

Inclusion 

The ELIOS platform is a website composed of a homepage 
and two main sections allowing to make a whistleblowing 
alerts: 

  Whistleblowing alert on fraud, 
  Whistleblowing alert on conflict of interest. 

Unique features 

The  homepage  of  the  platform  provides  users  with 
information  on  the 
legal  basis  of  whistleblowing 
protection.  It  also  contains  links  for  the  whistleblowing 
form and for two possible topics for whistleblowing: fraud 
and conflict of interest. For each of the topics, explanation 
and  definition  of  fraud,  conflict  of  interest  and  related 
misconduct is provided. 

The  platform’s  homepage  contains  a  link  to  access  the 
whistleblowing form. However, before the user can access 
the  actual 
form,  the  platform  requires  a  3-step 
confirmation procedure, includes warnings on: 

  During the first step, the ELIOS  platform states 
that  the  user  can  report  a  suspicion  regarding 
projects of ESF or YEI only. The platform is not is 
not  competent  for  reporting  other  European 
funds  (EAFRD  /  EMFF)  nor  for  programs 
managed  by  regional  management  authorities 
(Regional  Council  ERDF  /  ESF  programs).  The 
whistleblowing  platform  provides  users  with 

guidance  on  where  to  address  the  inquiries 
related to topics not related to ESI Funds (e.g. tax 
evasion,  contribution  fraud  and  social  benefits, 
customs fraud or fraud in the labour code) 

  The  second  step  contains  a  warning  on  the 
consequences  and  legal  responsibility  for  false 
reporting; 

  The third step includes detailed description of the 

legal basis for whistle-blower protection. 

The user has to confirm the understanding of all warnings 
before accessing the whistleblowing form. 

Finally,  the  platform  requires  the  whistleblower  to 
provide his personal information.  Therefore, anonymous 
whistleblowing  is  not  possible  on  the  ELIOS  platform. 
Users can file a claim up to six months after the date of 
the incident. 

Expected impact 

The  development  and  implementation  of  the  ELIOS 
platform allows to : 

  Centralize all complaints, regardless of the 
management department concerned; 

  Trace the filing of the complaints (registration 

and acknowledgment of receipt); 

  Transfer claims to relevant manager services for 

processing; 

  Allows  to  follow-up  with  the  whistle-blower  on 

the case. 

Thus, the ELIOS platform supports the detection and the 
reporting  of  the  risks  of  fraud  on  the  site  of  the  MA  to 
allow  whistle-blowers  to  have  a  single  entry  to  signal 
anonymous and secure signalling of fraud and conflict of 
interest. 

35 

 
 
 
 
 
 
Practice 5 –  Whistleblowing mechanisms 

As a result, the availability of a centralized whistleblowing 
platforms for ESF and YEI funds creates additional tool 
for  fraud  detection,  improves  the  trust  to  the  MA  and 

created  a  feedback  loop  with  the  beneficiaries  and  the 
general public. 

 Bulgaria - Whistle Blowing of Irregularities under EU Projects 

How it works 

The Ministry of Finance (MoF) is the body responsible for 
implementing the whistleblowing policy in relation to the 
EU projects in Bulgaria. The EU projects whistleblowing 
mechanism webpage (http://www.minfin.bg/en/375) is a 
go-to information source for whistleblowers.  It contains 
the  contact  information  on  the  relevant  bodies  for  the 
whistleblowing  for  different  Funds  and  programmes,  as 
well  as  procedures  and  requirements  for  successful 
whistleblowing.  

The  MoF’s  webpage  on  irregularities  contains  guidance 
for a person that wants to blow the whistle in relation to 
EU  funded  projects.  The  webpage  is  structured  around 
several key topics: 

  Definitions of irregularities, suspected fraud and 

fraud; 

  Key responsible authorities and their functions; 
  How to blow the whistle; 
  Procedures  to  follow  up  the  submitted  whistle 

blowing alert; 

  Specific 

features 

regarding 

alerting 

the 

irregularities. 

Unique features 

The  MoF  lists  the  distribution  of  the  tasks  and  scope  of 
activities  of 
the  National  Funds  Directorate  and 
Centralised  Contracting  and  Public  Procurement 
Directorate  in relation  to  the management  of  funds  and 
dealing with the irregularities and fraud. 

 The webpage suggest several ways to blow the whistle: 

  Directly contact the relevant MA; 
  Fill in the form and submit it though the website 

of  the MoF; 

  Send  a  free-form  email  at  the  email  address 

provided. 

In  addition,  any  oral  or  written  alerts  may  also  be 
submitted. 

The  MoF  guarantees  the  anonymous  submission  of  the 
whistleblowing  alert  though  all  the  channels,  including 
oral and written channels.  Similarly, the  web-form does 
not  require  submission  of  personal  data  by  the 
whistleblower. 

information 

The webpage provides clear indications on the minimum 
amount  of 
the 
whistleblowing  alert.  It  should  include  at  least  clear 
financing 
the  specific  project, 
reference 
programme, the administrative unit and a description of 
the irregularity. 

included 

to  be 

the 

to 

in 

Next,  the  guidance  to  the  whistle-blowers  provide  the 
legal  basis  for  the  whistle-blower  protection  and  the 
procedure how the alert will be followed up.  It gives the 
whistle-blower an opportunity to be informed personally 
on  the  status  of  his/her  request,  if  contact  details  were 
provided during the submission of the request. 

Upon  submission  of  the  alert  on  irregularities  to  the 
National  Fund  Directorate,  the  system  generates  a 
reference number and an access code.  The whistle blower 
can  use  this  information  to  follow  up  on  the  alert. 
Moreover, one can check the status of the whistleblowing 
alert  directly  on  the  website  of  the  OF  by  entering  the 
specific reference number and an access code of the alert. 

Expected impact 

The  centralization  of  the  information  of  the  possible 
whistleblowing channels at the website of the MoF allows 
systematising the approach for different authorities and 
funds.  Moreover,  it  suggests  to  the  user  single  point  of 
contact and single information source of different aspects 
of the whistle blowing policy.  Such approach will increase 
the  chances  of  the  user  to  find  a  reliable  channel  for 
whistleblowing.  

In  addition,  the  whistleblowing 
is  encouraged  by 
providing  numerous  ways  to  blow  the  whistle  and 
anonymous nature of posting an alert.  MoF improves the 
transparency of the follow up on the alert by providing the 
user the access to the status of the case investigation by 
entering the alert details on the website.  

36 

 
 
 
 
 
Practice 6 – Practical anti-fraud training 

Summary of the practice 

Practice spotted in… 

Enhancing 
the  skills  and  anti-fraud  capacity  of 
authorities  dealing  with  ESI  Funds  is  seen as  a  general 
need throughout Europe.  

Training courses are the most common form of capacity-
building exercise as they can be implemented in several 
ways  and  produce  rapid  tangible  results  when  they  are 
designed in a practical manner and based on real-life case 
studies. A wide range of involved parties including public 
bodies, NGOs and highly experienced anti-fraud auditors 
have designed such anti-fraud training courses.  

 NL 
 PL 
 SI 

training,  e-learning  modules, 

Existing anti-fraud training courses have been designed 
in different formats that are more or less interactive, i.e. 
immersion 
on-site 
seminars 
and 
investigation games. The scope of these training courses 
varies from basic introductory sessions to more targeted 
anti-fraud courses.  

fostering  peer-to-peer 

exchange, 

Examples  of  anti-fraud  training  courses  under  this 
those  designed  with  anti-fraud 
practice 
investigation services of the police and experienced anti-
fraud investigators from audit authorities. 

include 

Expected impact on anti-fraud system 

Enhanced anti-fraud capacities and 
skills 

Practical  training  courses  based  on  real-life  fraud  cases 
help  participants  to  enhance  specific  fraud-detection 
capacities  and  skills.  In  addition  to  teaching  techniques 
and procedures to identify  red flags and fraud  schemes, 
training also helps participants to develop an affinity for 
detecting  cases  of  fraud  and  corruption,  which  usually 
only experience can bring. 

Earlier detection of fraud and 
corruption cases  

Increased  anti-fraud  capacities  and  skills  results  in  the 
ESI Funds authorities being more proactive and cautious. 
This means that they can detect fraud indicators in a more 
timely  fashion,  thus  allowing  them  to  take  relevant 
measures  to  avoid  potential  fraud  and  corruption  from 
becoming a reality. 

Sharing of anti-fraud good practices 

Training  that  encourage  the 
interactivity  and  the 
participation of attendees usually allow time for informal 
peer-to-peer  exchanges.  These  interactions  mean  that 
experience  and  good  practices  can  be  shared  and  the 
experience of other authorities can be enhanced. 

This  anti-fraud  practice  is  considered  a  horizontal  soft  prevention  measure  that  has  an 
impact on all types of fraud risk, primarily by increasing the anti-fraud capacity of authorities’ 
staff members. 

37 

 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
Practice 6 – Practical anti-fraud training 

Examples of the practice 

Poland – Training delivered by the Central Anti-Corruption 
Bureau  

How it works 

Poland’s  Central  Anti-Corruption  Bureau  (CBA)  is  a 
special  government  body  with  police  and  monitoring 
powers.  The  CBA’s  objective  is  to  combat  corruption  in 
in 
the  public  and  private 
governmental  institutions  and  local  governments  and, 
more  generally,  in  every  activity  that  endangers  the 
State’s  economic  interest.  The  CBA  has  850  fraud 
investigators and 150 civil servants.  

sectors,  particularly 

Based  on  the  pressing  need  for  anti-fraud  training 
identified  while  investigating  fraud  cases,  and  on  the 
extensive  experience  gained,  the  CBA  has  decided  to 
invest in the creation of anti-fraud training. 

Initially, 
the  CBA  created  an  on-site  anti-fraud 
introductory  training  course  based  on  its  previous  anti-
corruption guide for public officials. The training course 
aimed  to  raise  awareness  among  public  officials,  clerks, 
public administrations and businesses of corruption.  To 
do  so,  the  content  of  the  training  course  was  based  on 
real-life case studies. As part of the training, participants 
learn  about  possible  behaviours  to  adopt  when  dealing 
with corruption. Participants are also provided with more 
topic-specific training material prepared by the CBA, such 
as  recommendations  on  anti-corruption  proceedings  by 
using public procurement procedures.  

Unique features 

In  addition  to  on-site  training,  the  CBA  has  created  an 
anti-corruption  e-learning  platform.  First  launched  in 
May  2014,  this  platform  is  the  first  free  e-learning 
platform in Poland, accessible only using a username and 
password. The platform was developed with the financial 
support of the European Commission (EC) as part of the 
Prevention  of  and  Fight  against  Crime  Programme.  The 
goal  of  this  e-learning  platform  is  to  raise  participants’ 

awareness  of  corruption  within  public  administrations 
and businesses, as  well as  raising society’s awareness of 
anti-corruption efforts in Poland. The platform consists of 
three  theme-based  blocks  covering  corruption  in  public 
administration,  corruption  in  business,  and  the  social 
impact  of  corruption.  Those  with  access  to  the  platform 
may take any of the three training courses corresponding 
to these blocks. Online training consists of no more than 
10 chapters, each of  which contains an  informative part 
and a test. The test must be passed in order to move on to 
the next chapter. The trainings is available in Polish and 
English. 

Expected impact 

Only  three  months  after  the  e-learning  platform  was 
launched,  4,500  persons  were  already  registered  on  the 
platform; and after 12 months, this figure rose to 22,000. 
Between  May  2014  and  November  2017,  46,626  people 
in  public 
took  the  training  course  on  corruption 
administration.  In  November  2017,  the  CBA  decided  to 
modernise  the  platform,  and  10  months  after  the  new 
platform was launched, there were 61,272 members. The 
platform  currently  has  126,757  members  who  have 
enrolled on one of the training courses, 25,017 of whom 
have  completed  the  course  on  corruption  in  public 
administration  since  the  new  platform  was  launched. 
These  statistics  demonstrate  the  interest  and  need  for 
more anti-corruption training in Poland and elsewhere.  

The  CBA  has  plans  for  the  future:  a  train-the-trainer 
programme will be developed to scale up on-site training 
courses,  the  content  of  the  e-learning  platform  will  be 
modernised,  and  a  new  technical  solution  will  be 
international  universal  e-learning 
implemented.  An 
platform  with  national  plug-ins 
is  also  under 
development.  

38 

 
 
 
 
 
 
 
 
Practice 6 – Practical anti-fraud training 

Slovenia – Training for fraud investigators and criminalists to 
improve fraud detection and investigation 

How it works  

In 2013, the Ministry of the Interior of the Republic of 
Slovenia coordinated and benefited from the THEMIS 
project funded  by the  EC as part of the Prevention of 
and  Fight  against  Crime  (ISEC)  programme.  The 
objective  of  this  two-year  project  was  to  improve  the 
overall knowledge and increase the skills and capacities 
of fraud investigators and criminalists working for the 
Slovenian  police,  as  well  as  judges  dealing  with 
financial crime and suspicions of fraud and corruption 
in  the  detection  and  investigation  of  EU  co-financed 
projects.  

To do so, targeted parties were provided with valuable 
and  necessary  insight  into  the  complex  system  of  EU 
funding,  thus  allowing  them  to  perform  their  work 
more  efficiently  and  effectively.  More  specifically, 
relevant  and 
participants  were  provided  with 
comprehensive information on:  
  The  EU  funding  in  the  2007-2013  programming 

period; 

  Respective national implementing structures of the 
the  MCS,  key  parties 

programming  period, 
involved and their roles and functions; 

  Different programmes and funding from different 

agencies; 

  The  new  set-up  of  national 

implementing 
structures for the 2014-2020 programming period. 

In addition, training participants received a structured 
compendium  with  a  systematic  overview  on  funding 
and implementing structures for each target group.  

Unique features 

The method used to train the target groups consisted of 
a  series  of  interactive  and  participative  workshops 
covering the following themes:  
  Fraud detection by MAs, IBs, AAs and Corruption 
the  context  of 

Prevention  Commissions, 
Structural and Cohesion funds management; 

in 

  Crime intelligence and detection and investigation 

 

of fraud cases; and 
International  cooperation  of  police  authorities  to 
protect the EU’s financial interests.  

Those  attending  the  workshops  signed  up  for  an 
immersive experience as the workshops were held over 
a short period. Therefore, participants were invited to 
stay on site so that they could attend all the workshops. 
Those  that  did  so  were  able  to  enjoy  informal 
conversations,  ask  questions  and 
their 
experiences 
good  practices  with  others 
participants. These interactions were seen as a positive 
and valuable outcome of the THEMIS project.  

share 

and 

In  addition,  participants  were  invited  to  take  part  in 
panel  discussions  and  presentations  on  management 
verifications  and  relevant  funds.  Sharing  of  real-life 
examples  as  well  as  active  participation  during  Q&A 
sessions was encouraged. 

Expected impact 

The Ministry of the Interior participated as a Slovenian 
MA in the series of workshops covering fraud detection 
in  the  context  of  Structural  and  Cohesion  funds 
management.  Following  these  training  sessions,  the 
MA  was  able  to  identify  tangible  benefits  of  the 
THEMIS project.  

A general increase  in and  closer cooperation between 
ESI  Funds  authorities  and  the  police was  noted.  This 
led  to  additional  capacity-building  initiatives  and 
training  provided  to  authorities  by  the  police  on  the 
fraud  prevention  and  detection.  This  then  resulted  in 
an earlier detection of fraud by ESI Funds authorities’ 
staff members, and more structured risk management 
and control procedures.  

39 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Practice 6 – Practical anti-fraud training 

Case study: The Netherlands –Anti-fraud game  

Context 

The anti-fraud game is a highly interactive and engaging anti-fraud training course developed to build the capacity of all 
ESI  Funds’  authorities  to  prevent,  detect  and  combat  fraud  and  corruption.  The  anti-fraud  game  was  created  by  Jo 
Kremers, a Senior Audit Manager working in the Dutch Ministry of Finance, using his extensive experience gained from 
working as a fraud investigator for the private and public sectors, and then as an auditor.  

Rationale  

During  the  previous  and  current  programming  period,  Jo  Kremers  detected  several  cases  of  fraud  and  misuse of  ESI 
Funds, which were never detected by the Dutch MAs. The lack of general knowledge on the anti-fraud cycle and the need 
for increased knowledge and capacity in setting up a robust anti-fraud system were the first elements indicating the strong 
need for anti-fraud training in preventing, detecting and combatting fraud.  

This led to a realisation in the importance of raising ESI Funds authorities’ awareness of the reputational damages fraud 
and  corruption  cases  can  cause,  and  the  need  to  enhance  their  anti-fraud  capacity  by  providing  them  with  the  right 
instruments, methods and tools to combat fraud.  

Objective 

While developing the anti-fraud game, the aim was to create a highly interactive game relying on several multimedia tools 
such as videos, music, pictures and animations, and attributes in order to:  

  Draw and retain the attention of participants during the entire session;  
  Foster a rapid and lasting learning process by associating a concept or information taught with a sound, image, 

video or object. 

Therefore, the aim is neither to provide a classical training course covering EU laws and regulations, nor to provide them 
with a set of ready-to-use anti-fraud measures that they can directly integrate into their management and control system 
procedures. Instead, the anti-fraud game training was invented with the aim of motivating and encouraging participants 
and developing their ability to identify red flags of fraud and corruption by being more aware, attentive and responsive to 
hints  and  cues  of  fraud,  thereby  allowing  them  to  put  in  place  the  most  appropriate  and  effective  anti-fraud  control 
measures. 

Target group  

The anti-fraud game focuses on the wide group of ESI Funds stakeholders, including MAs, IBs, the CA, the AA from all 
EU  Member  States,  EU  candidate  countries,  and  more  generally  practitioners  working  with  EU  and  national  funds. 
However, it can easily be adapted to a single stakeholder group or a mix thereof. A game session includes a maximum of 
35 to 40 participants. 

Format 

The anti-fraud game is divided into two parts:  

1.  Part I – Game for sub-groups; 
2.  Part II – Individual game. 

40 

 
 
 
 
 
Practice 6 – Practical anti-fraud training 

Case study: The Netherlands –Anti-fraud game  

The training course generally starts with a plenary session, during which the trainer breaks the ice among participants by 
raising participants’ awareness of their lack of knowledge of the anti-fraud cycle. After the plenary session, participants 
are put into mixed sub-groups and the first part of the game can start. Placing participants into sub-groups early on in 
the session encourages the start of discussions and the sharing of experience. Moreover, mixing different authorities into 
a sub-group helps them understand each other’s obligations and challenges. 

To encourage the start of discussions, the trainer uses real-life cases of fraud and corruption in ESI Funds that have been 
anonymised and used as test cases. The second part of the game is a plenary session involving all participants. Participants 
work individually on 12 test cases based on real (realistic) cases of fraud and corruption in ESI Funds. The test cases are 
designed  to  improve  the  group’s  skills  and  use  of  instruments,  and  raise  awareness  of  the  importance  of  ethics  and 
integrity.  

Unique features 

An  important  aspect  of  fraud  detection,  yet  one  that  is  more  difficult  to  understand,  is  successfully  developing  an 
affinity  for  detecting  cases  of  fraud  and  corruption.  In  addition  to  using  checklists  and  making  on-the-spot 
verifications, participants need to learn how to better observe and understand the environment in which they operate and 
where fraud could possibly occur. Hence, participants need to learn how to rely on and trust their common sense, and 
build on their experience by being exposed to different settings and a range of fraud schemes.  

The anti-fraud game is a multimedia training course that uses pictures, videos, music and animation associated to the 
variety of topics covered in the course. Indeed, linking a visual or sound to a topic makes it more attractive to participants 
who grasp the shared knowledge and information more quickly and thus remember it more easily. The use of tokens and 
attributes is also encouraged as it also improves their learning process and memory retention.  

In order to spark participants’ interest and motivation, awards and prizes are offered to participants at the end of the 
training course. 

Delivery mode 

The  anti-fraud  game  is  played  in  various  educational  institutions  throughout  Europe,  e.g.  the  European  Academy  for 
Taxes, Economics & Law in Berlin or the International Anti-Corruption Academy in Vienna. The training course has also 
been  given  during  some  EU-level  events  such  as  the  Annual  Symposium  EU  Funds  in  Berlin,  and  following  ad-hoc 
requests  made  by  EU  Member  States  and  candidate  countries,  including  Belgium,  Germany,  Latvia  and  Macedonia. 
Finally, Jo Kremers also gives the training to the Dutch Ministry of Finance’s audit department. 

Expected results 

As new technology  is changing, fraud techniques and corruption methods are becoming more advanced, thus making 
them more difficult to detect. Players of the anti-fraud game will therefore learn how to move away from the traditional 
formal ways of detecting cases of fraud and corruption, and will develop a unique ability that allows them to pay more 
attention to the least obvious signs of fraud. The anti-fraud game has shown promising results in promptly increasing the 
capacity of authorities to detect fraud and irregularities at different stages of the project cycle. 

Contact details 

Name of the trainer: Jo Kremers 

E-mail address: jmwkremers@home.nl 

41 

 
 
 
 
Practice 7 – Cooperative approaches to conducting the FRA 

Summary of the practice 
Several managing authorities (MAs) across the EU  have 
adopted  a  cooperative  approach  when  organising 
their  Fraud  Risk  Assessment  (FRA)  process.  It 
consist  of  working  together  to  develop  an  FRA 
and support the intermediary bodies (IBs) with the 
performance  thereof.  This  resulted  in  a  consistent  and 
coordinated approach to analysing fraud and corruption 
risks,  and  to  setting  up  effective  and  proportionate 
identified,  thereby 
measures  to  mitigate  the  risks 
increasing  the  potential  of  those  measures  in  the  fight 
against fraud and corruption. 

Practice spotted in… 

 CY 
 ES 
 NL 
 DK 

have 

delegated 

This practice particularly concerns Member States where 
MAs) 
and 
responsibilities  to  their  IBs,  which  therefore  must 
also carry out  an FRA. It also specifically concerns  MAs 
and  IBs  that  have  chosen  to  use  the  template 
prepared  by  the  European  Commission  (EC)  to 
conduct the FRA. 

functions 

This  anti-fraud  practice  provides  examples  of  such  set-
ups,  which  have  facilitated  the  uptake  and  conduct  of 
FRAs  by  several  bodies,  and  adopted  a  team-based 
approach to discussing fraud risks and related mitigating 
measures.  

Expected impact on the anti-fraud system 

Common and better understanding of 
fraud risks and anti-fraud measures 

When  processes  that  clearly  define  management  and 
controls procedures and put in place anti-fraud measures 
are run in parallel, the learning process is accelerated. In 
addition,  the  parties  involved  tend  to  better  and  more 
rapidly understand the importance of the FRA process by 
linking it to the well-organised management and control 
system.  

Increased transparency  

A comprehensive manual of procedures, such as the Blue 
Book,  helps  increase  transparency  of  management  and 

control  procedures  (including  anti-fraud  procedures) 
among  all  the  parties  involved.  In  addition,  since  all  of 
these  parties  have  a  clear  vision  of  their  functions  and 
responsibilities, this increases their accountability in day-
to-day tasks. 

Improved compliance and mitigated 
reputational risks 

the 

transparency  of  procedures  and 

Since 
the 
accountability  of  the  authorities’  staff  members  who 
implement them are improved, there are fewer errors and 
irregularities, thereby minimising the reputational risk of 
authorities.  

This anti-fraud practice is considered a horizontal soft prevention measure that has an impact on all 
types of fraud risk, primarily by increasing the anti-fraud capacity of authorities’ staff members. 

42 

 
 
 
 
 
  
 
 
 
 
 
 
 
Practice 7 – Cooperative approaches to conducting the FRA 

Examples of the practice 

Cyprus – Cooperation between MAs and IBs 

How it works 

The  Directorate-General  for  European  Programmes, 
Coordination and Development of the Republic of Cyprus 
is the MA responsible for most of the country’s OPs. It has 
delegated some of its functions to four categories of IBs in 
the country. To conduct the FRA, the MA has chosen to 
use the template proposed by the EC and to transpose it 
for use by the IBs. 

for 

from 

the  MA  responsible 

Before conducting the assessment, the MA set up a single 
self-assessment  team  for  all  OPs,  including  staff 
financial 
members 
management  and  control,  staff  members  from  IBs 
responsible 
for  project  selection  and  on-the-spot 
verifications  specifically,  the  control  authority  (CA),  the 
Anti-Fraud Coordination Service (AFCOS), and the Public 
Procurement Directorate of the Treasury of the Republic 
of  Cyprus.  Members  of  the  self-assessment  team  were 
selected to include those who have relevant experience in 
all  basic  functions  covered  by  the  management  and 
control system (MCS) of the OPs. In addition, a member 
of the audit authority (AA) was selected to be an observer 
of the entire FRA process.  

The  self-assessment  team  based  its  FRA  on  the  list  of 
fraud risks identified by the EC and followed the five-step 
methodology  proposed  by  the  EC.  However,  the  self-
assessment team customised all fraud risks to its context, 
together  with  the  mitigating  control  measures  that  it 
tailored according to the MCS. 

Unique features 

The self-assessment team was divided into subgroups to 
cover the risks and measures pertaining to a specific FRA 
process.  For 
involving  IBs 
instance,  a  subgroup 
responsible  for  project  selection  focussed  on  risk  and 

to 

mitigating  measures  related 
the  “Selection  of 
Applicants” section in the  FRA,  while another subgroup 
was  in  charge  of  the  “Implementation  and  Verification” 
section. The CA was responsible for addressing risks and 
mitigating  measures  related  to  the  “Certification  and 
Payment” section.  

The MA organised a meeting gathering all members of the 
self-assessment  team  to  explain  the  overall  structure, 
purpose  and  benefits  of  the  FRA.  Several  meetings  and 
sub-group meetings were subsequently held to explain in 
more  detail  how  the  assessment  should  be  completed. 
These on-request meetings between the MA and the self-
assessment team or between the MA and the sub-groups 
were beneficial, as some members found the terminology 
used in the FRA not always straightforward or mitigating 
measures not always applicable to the specific context of 
IBs. 

Expected impact 

Cooperation  between  authorities  when  conducting  the 
FRA  provided  a  comprehensive  overview  of  the  ESI 
Funds’ MCS for OPs, as well as a better understanding of 
existing  procedures and  mitigating measures applied  by 
all the parties involved, at all levels and for all OPs. The 
MA  was  able  to  obtain  a  full  overview  of  the  checks 
implemented by the IBs in the country, while IBs had the 
opportunity to discuss their specific set-up in detail with 
the  MA  and  other  IBs.  The  resulting  FRA  confirms  this 
cooperation,  as  it  includes  an  additional  “Comments” 
column used by all members of the self-assessment team 
to explain when a mitigating measure proposed by the EC 
was not relevant to the IB context, or simply to describe 
the status of the mitigating measure. This is seen as very 
proactive and useful for conducting future FRAs as it will 
be easier to make corrective changes and re-evaluate the 
risks.  

43 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Practice 7 – Cooperative approaches to conducting the FRA 

The Netherlands – Cooperation between MAs of European Structural 
and Investment Funds (ERDF) 

How it works  

The  four  ERDF  MAs  in  the  Netherlands  adopted  a 
coordinated and cooperative approach when conducting 
their FRA.  When setting up their anti-fraud system, the 
four  ERDF  MAs  had  already  organised  joint  meetings 
with the CA, AA and the Ministry of Economic Affairs and 
Climate  and  Ministry  of  Finance,  where  relevant,  to 
discuss and agree on an anti-fraud system and ensure that 
all MAs act in the same way in similar circumstances. For 
instance, the MAs have set up common checklists for all 
ERDF MAs and IBs. Discussions only take place when all 
the authorities involved are present. It is in the context of 
these regular meetings that the FRA was conducted.  

Unique features 

The  self-assessment  team  was  composed  of  the  four 
ERDF MAs and the CA. The AA was not part of the self-
assessment  team,  instead  acting  as  an  observer  of  the 
overall process. The meeting regarding the FRA became a 
one-day workshop. The workshop was initially intended 
to set up the common approach for completing the FRA 
and screen the mitigating measures recommended by the 
EC, in order to identify those that needed to be tailored to 
the  context  of  the  OPs.  The  self-assessment  team 
therefore  used  a  mix  of  EC-recommended  mitigating 
measures and customised measures. This workshop also 
allowed  the  four  MAs  to  share  their  experience  on  the 

most important fraud risks in their environment as well 
as  express  their  views  on  the  most  relevant  mitigating 
measures,  in  order  to  address  them  in  their  context.  As 
the four MAs used the FRA template proposed by the EC, 
some  parts  were  filled  in  as  a  team,  while  others  were 
filled  in  individually  during  the  one-day  workshop.  The 
four  ERDF  MAs  jointly  filled  in  the  “Selection  of 
Applicants”  and  “Implementation  and  Verifications” 
sections,  while  the  CA  filled  in  the  “Payments  and 
Certification” one. With regard to the direct procurement 
process, the four ERDF MAs completed it individually in 
separate  documents  and 
the  dedicated 
workshop.  However,  the  MAs  did  not  work  in  silos  to 
complete  this  last  process,  as  each  one  shared  its 
completed  process  with  the  others  in  order  to  obtain 
feedback and suggestions for improvements.  

following 

Expected impact 

This type of cooperation is not only valuable to the FRA 
by the Dutch authorities, but also to the country’s general 
anti-fraud  system.  Sharing  experiences  and  practices 
between  the  MAs  of  one  fund  is  expected  to  lead  to  a 
better  coverage  of  risks,  improved  communication  from 
the  authorities  and  a  more  coordinated  implementation 
of anti-fraud measures. As a result, it should enhance the 
overall anti-fraud system for ERDF fund management in 
the country. 

44 

 
 
 
 
 
 
Practice 7 – Cooperative approaches to conducting the FRA 

Case study: Spain – Coordinated approach to create a compendium of 
anti-fraud procedures of the MA, CA and IBs 

Context 

The  Blue  Book  is  the  comprehensive  manual  of  procedures  of  the  MA  for  ERDF  to  describe  all  the  functions  and 
procedures  related  to  the  management  and  control  system  of  the  21  OPs  under  its  responsibility.  The  Blue  Book  is 
developed by the MA together with the CA, in order to support the designation requirements (as per Article 124 of the 
Common Provisions Regulation (Regulation (EU) No 1303/2013). 

ERDF management is highly decentralised in Spain, with the MA only managing 5% of ERDF funding. A large 
part  of  the  MA’s  functions  is  therefore  delegated  to  IBs.  The  main  tasks  of  IBs  include,  among  others,  the 
selection  of  operations,  ex  ante  verification  of  expenditure,  submission  of  applications  for  payment  to  the  MA,  and 
communication  with  beneficiaries.  IBs  also  support  the  MA  in  all  its  remaining  functions.  They  are  composed  of  13 
central  government  bodies  (e.g.  ministries  and  public  specialised  agencies),  25  regional  authorities  (e.g.  the 
Government of Valencia) and more than 100 ‘light IBs’ that consist of local administrations implementing integrated 
projects  for  urban  development  and  are  only  responsible  for  selecting  operations.  As  a  result,  IBs  perform  different 
operations  involving  very  distinctive  management  and  control  system  procedures,  and  are  thereby  prone  to  different 
fraud and corruption risks.  

Approach 

Since the MA must ensure the quality of all IBs’ control and management systems 
and supervise the tasks delegated to them, it adopted a two-fold approach to 
do so. First, it requested that each IB prepare its own Blue Book describing the 
procedures for the control and management system specific to its context. Second, 
the MA required all IBs to align the methodology in conducting their FRA, 
to  tailor  the  mitigating  measures  proposed  by  the  EC  to  their  specific 
aspects, and document the methodology and anti-fraud measures put in place in 
the annex to their Blue Books.  

Objective  

The objective of this approach was to cope with the decentralised management and 
control of ERDF OPs in Spain and to ensure that all IBs follow the same procedures 
under similar circumstances. To do so, the MA put together a compendium of 
all  the  monitoring  and  control  procedures  and  anti-fraud  measures 
implemented by the MA, CA and IBs in order to obtain an overview at 
ERDF  level,  thereby  ensuring  transparency  and  the  compliance  of 
procedures. Increasing transparency, awareness and compliance of such procedures also encourages the MA, CA and 
IBs’ staff members to pay closer attention to irregularities and red flags that could possibly indicate fraudulent activity. 

The individual IBs’ Blue Books supplement the one produced by the MA and CA. Together, they provide an overview at 
OP  level  of  all  the  management  and  control  system  procedures  for  the  21  ERDF  OPs.  They  also  summarise  the  legal 
framework for MA and IBs referring to the obligation to put in place anti-fraud measures that are based on the common 
tools and proposed set of mitigating measures defined in the EC guidelines and adapted to the Spanish context. The MA 
considered this as particularly important and relevant, especially given the lack of national fraud-prevention legislation. 
The fact that IBs function with a high degree of autonomy and are thus difficult to monitor and control is another reason 
for creating this overview of function and procedures. 

45 

 
 
 
 
 
 
 
 
 
Practice 7 – Cooperative approaches to conducting the FRA 

Case study: Spain – Coordinated approach to create a compendium of 
anti-fraud procedures of the MA, CA and IBs 

Process 

The entire process for developing the MA and CA Blue Book and the individual IBs’ Blue Books took one year.  

Structure  

Ten high-level and experienced MA staff members were responsible for supervising the work of IBs and ensuring that it 
was in line with the Blue Book prepared by the MA. An experienced staff member of the AA and the Spanish AFCOS were 
also involved in the process, mainly reviewing and verifying the compliance of the procedures proposed by IBs, and of the 
tailored anti-fraud measures proposed. The AA and AFCOS also regularly provided advice and suggestions.  

Steps 

The MA and CA started with creating their own Blue Book and devising the methodology for conducting the FRA. Since 
this was the basis for the IBs’ work, the MA had to ensure that it correctly understood the concept and methodology of 
the FRA devised by the EC, and that the topics to be covered in the Blue Books included all those suggested by the EC.  

Once this preparatory work was completed, the MA provided IBs with a copy of its Blue Book, a template thereof, the 
EC’s FRA template and its guidance note. The MA then put in place an assistance and communication plan for 
IBs, including training sessions and workshops, in order to provide IBs with a place to share their feedback and concerns 
and ask questions related to the tasks assigned to them. IBs have attended more than 25 training sessions to show 
them the structure and methodology used by the MA to create its Blue Book, which should be the basis of their work.  

As part of the training sessions, the MA gave presentations to IBs, providing an overview of the legal framework for 
the 2014-2020 programming period, and specifically the legal basis for drafting MCS and for conducting an FRA. These 
training sessions were very practical as they also aimed to explain in more detail the structure of the FRA template and 
the  steps  to  fill  it  in,  using  screenshots  of  the  tool.  A  detailed  explanation  was  also  provided  of  the  methodology  for 
assessing the impact and likelihood of risks before and after putting in place the control measures. The list of mitigating 
measures prepared by the EC was also discussed, and practical exercises to tailor those measures to the specific context 
of IBs were explored.  

Following  these  training  sessions,  six  experimental  trials  were  conducted  with  six  IBs  over  a  period  of  3 
months. The rationale of the MA for conducting experimental trials was to make sure the assistance and communication 
campaign was successful, and that IBs had sufficient knowledge and confidence to start work on both the individual Blue 
Books  and  the  FRA.  The  trial  was  an  iterative  process,  during  which  the  MA,  CA,  AA  and  AFCOS  were  regularly 
reviewing the work of IBs and providing comments and suggestions for improvement. The first versions of the Blue Books 
and FRA received by the MA were very poor and the majority of the IBs had to edit them at least twice or more before 
they were deemed satisfactory.  

The last part of the experimental trial involved the six IBs actually implementing the procedures described in their 
individual Blue Books, as well as the customised anti-fraud measure they had devised. 

Once  the  six  experimental  trials  were  deemed  satisfactory  by  the  MA,  the  same  approach  was  rolled  out  with  all  the 
remaining IBs under the supervision of the MA controlling department. By Q4 2018, IBs were still in the process of testing 
these procedures and anti-fraud measures, following which they will create a new appendix to the Blue Book in case of 
any amendments.  

46 

 
 
 
 
 
 
 
Practice 7 – Cooperative approaches to conducting the FRA 

Case study: Spain – Coordinated approach to create a compendium of 
anti-fraud procedures of the MA, CA and IBs 

Expected results 

The  process  of  creating  a  Blue Book  and  having  a  FRA  conducted  by  each IB  was  a  success.  Indeed,  100%  of  the  IBs 
followed the Blue Book template and successfully prepared their FRA. Feedback provided by IBs during this process was 
positive as the majority of them found that having all the procedures clearly explained was key to the sound financial 
management of the OPs. Another tangible benefit was that staff members responsible for conducting the procedures now 
tend to be more accountable for their work and have a clear vision of their role and responsibilities, which is crucial to the 
fight against fraud and corruption.  

Although it is still early to draw conclusions on specific benefits gained from this cooperation process, the authorities are 
already  noticing  increased  efficiency  in  the  procedures  implemented,  thus  allowing  staff  members  performing 
administrative and on-the-spot verifications to be more cautious and attentive to fraud and corruption risks. 
Furthermore, this cooperation seems to result in positive benefits to the reputation of the MA and the IBs, there appears 
to be fewer errors and irregularities and fewer complaints from beneficiaries or applicants.  

Finally, this process was a win-win for the MA and IBs as they both stated that they had learnt a lot about their work and 
each other, and had improved their knowledge and capacity on preventing and detecting fraud and corruption.  

Lessons learned 

In  addition  to  drawing  some  preliminary  benefits  from  this  exercise,  the  MA  also  learns  some  lessons  from  it.  One 
takeaway is that although the process for conducting the work was very time-consuming and challenging, especially the 
part regarding the FRA, it is the only way that all the parties involved are able to learn about fraud prevention and improve 
their capacities therein. 

Another takeaway  is that,  when using EC templates,  it is crucial to adapt them  to the MA’s or  IB’s specific aspects to 
ensure that staff members take them on board and use them properly. With regard to the FRA, it was deemed useful but 
it appears that extensive explanations need to be provided before fully understanding the concept and methodology. The 
involvement  of  all  parties  participating  in  programming,  managing  and  controlling  the  OPs,  and  especially  the 
involvement  of  top  management,  is  key  to  ensure  consensus  when defining  and  implementing  the  most  effective  and 
proportionate anti-fraud measures used. 

Finally,  when  conducting  educative  training  and  workshops,  promoting  best  practices  and  practical  examples  is 
important because it is also during these activities that new good practices are unveiled.  

Contact details 

Name of the entity: Ministry of Finance, Directorate-General for 
European Funds 

Website: http://www.sepg.pap.hacienda.gob.es/  

E-mail: fondoscomunitarios@sepg.minhafp.es 

47 

 
 
 
 
 
 
 
 
 
 
Practice 8 – Fostering an anti-fraud culture 

Summary of the practice 

Practice spotted in… 

 LT 
 LV 
 HU 

An  anti-fraud  culture  is  a  fundamental  part  of  a 
comprehensive  anti-fraud  system.  Anti-fraud  culture 
includes a number of elements that form intolerance and 
unacceptance of fraud in the organisation and in society. 

The anti-fraud  practices that focus on building a strong 
anti-fraud  culture  may 
include  organisation-related 
activities  and  awareness-raising  campaigns  for  the 
general public. The first group of practices includes tone 
from the top and the availability of a code of ethics, while 
also  featuring  the  elements  of  fraud  awareness  in 
employees’ job descriptions. When applying practices to 
the  general  public,  they  take  the  role  of  regional  or 
national  initiatives  on  fraud  intolerance  or  increased 
transparency. 

Fostering an anti-fraud culture aims at increasing public 
awareness of fraud risk and mitigating tools, uniting them 
in  the  fight  against  corruption  and  fraud,  and  making 
society more involved in anti-fraud activities. 

the  elements  of  anti-fraud  culture 

Most of the MAs in the sample have implemented some 
of 
their 
organisations,  albeit  within  the  limits  of  necessary 
procedures. The practices featured below are recognised 
initiatives  at  national  level  aiming  at  improving  general 
anti-fraud awareness. 

in 

Expected impact on the anti-fraud system 

Awareness-raising 

Preventing fraudulent activities 

improving  anti-fraud  culture 
Activities  aiming  at 
generally  increase  awareness  of  fraud  issues  among  the 
target  audience.  When 
implemented  within  an 
organisation,  these  measures  reinforce  the  message  of 
fraud  and 
management’s  commitment 
employees’ responsibility to behave ethically. When used 
as a part of wider regional or national initiatives, they are 
used  to  create  the  mass  movement  of  fraud  and 
corruption intolerance using common logos or branding. 
Overall,  such  practices  reinforce  the  understanding  of 
fraud  risks  and  create  a  culture  of  unacceptance  and 
resistance in society. 

fighting 

to 

The  systematic  implementation  of  measures  focusing  at 
an  anti-fraud  culture  has  a  positive  effect  on  fraud 
prevention.  Thus,  creating  an  environment  that  is 
sensitive  to  corruption  and  fraud  suggests  that  more 
attention  will  be  paid  to  the  risk  of  fraud  and  its 
prevention  in  organisations  and  among  the  public.  The 
long-term impact of the growing anti-fraud culture lies in 
the  strong  commitment  to  prevent  and  report  any 
suspicious  or  fraudulent  activities,  as  well  as  improving 
the transparency of processes and budget management at 
all stages of the project cycle. 

This anti-fraud practice is considered a soft prevention measure designed to reinforce fraud 
prevention and strengthen the anti-fraud environment and ethical culture. Implementing activities 
related to the anti-fraud culture have a horizontal impact and touch upon all fraud risks. 

48 

 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
Practice 8 – Fostering an anti-fraud culture 

Examples of the practice 

Latvia – #FraudOff awareness-raising campaign 

How it works 

To  combine  efforts  in  the  fight  against  the  shadow 
economy,  corruption  and  other  fraudulent  activities 
affecting the state budget and overall social welfare, the 
Latvian  Government  has 
social 
the  anti-fraud 
information 
movement  –  #FraudOff!  The  long-term  goal  of  the 
movement is for Latvian society to have zero tolerance of 
fraud. 

campaign  known  as 

implemented  a 

The idea of the campaign is based on the combined efforts 
of public institutions, businesspeople, social partners and 
everyone  in  society  in  the  fight  against  fraud.  The 
campaign  focuses  on  preventive  measures,  including 
promoting public awareness of the shadow economy and 
fraud,  and 
for  each 
individual  and  the  country’s  general  prosperity.  In 
addition,  the  campaign  explains  how  to  report  fraud  to 
the  relevant  law  enforcement  authorities  if  someone 
suspects  or  knows  about  a  specific  case  of  fraudulent 
activity. 

their  negative  consequences 

Unique features 

#FraudOff!  is  the  first  initiative  of  its  kind  in  Latvia, 
bringing  together  more  than  20  public  institutions  and 
partners in a joint anti-fraud campaign. 

The  main  partners  in  the  initiative  are  ministries  and 
State  authorities,  e.g.  the  Ministry  of  Finance,  the 
Ministry  of  the  Interior,  the  Ministry  of  Economics,  the 
State  Revenue  Service,  the  State  Police,  the  Corruption 
Prevention  and  Combating  Bureau,  the  Competition 
Council, the Procurement Monitoring Bureau and others, 
as well as Transparency International Latvia. 

The  anti-fraud  movement  brings  together  private 
organisations that are ready to join hands to fight against 
fraud  and  involve  all  of  Latvian  society  in  this  fight.  In 
2018,  #FraudOff 
initiative  has  additionally  been 
supported  by  Latvian  law  enforcement  authorities, 
combining  efforts  in  the  fight  against  fraud  with 
promoting education among society. 

goals  of  the  initiative,  information  on  the  level  of  fraud 
and  corruption  in  Latvia,  and  practical  advice  to  the 
public on the areas sensitive to fraud in day-to-day life: 

  What  you  should  know  when  entering  into  an 
employment contract with a potential employer; 
  How  to  check  whether  your  employer  is  paying 

tax; 

  What occupational safety regulations you should 

consider; 

  How to recognise a fake branded product; 
  How to recognise fake money; 
  What you should know about food labelling. 

In  2018,  the  #FraudOff!  movement 
is  specifically 
addressing people aged 16 to 24, informing them of fraud 
risks and what they should  consider when entering into 
an employment relationship with a potential employer. 

invited 

Latvian 

to  use 

citizens, 
All 
businesses and organisations 
are  invited  to  participate  in 
the  anti-fraud  movement. 
#FraudOff!’s main tool is the 
use  of  its  logo  by  public  and 
private 
institutions. 
Supporters  of  the  movement 
are 
the 
campaign  brand  in  everyday 
the 
communication.  On 
movement’s website, it is possible to download campaign 
posters, visual materials for websites and social networks, 
as well as to apply for a special sticker that can be placed 
on doors at a company, institution or shop. Citizens are 
also  encouraged  to  use  the  hashtags  #atkrāpies!  and 
#fraudoff!, as well as #viltotaiszaķis, which translates as 
#fakechick.  The  organisers  emphasise 
the 
movement’s  brand  will  not  serve  as  a  quality  mark,  but 
rather  will  demonstrate  an  organisation  or  person’s 
negative  attitude  towards  fraudulent  activities.  For 
traders,  it  is  also  an  opportunity  to  show  that  they  sell 
original products and not counterfeit ones. 

that 

#FraudOff! 
website 
(http://atkrapies.lv/),  which  contains  a  message  on  the 

dedicated 

has 

a 

49 

 
 
 
 
 
 
 
 
Practice 8 – Fostering an anti-fraud culture 

Expected impact 

The #FraudOff! movement has been considered a success 
in Latvia and abroad. It was honoured at the IPRA Golden 
World  Awards  2018 
the  best  concept  and 
campaign.  #FraudOff!  has  been 
communication 

for 

successful  in  uniting  public  authorities,  entrepreneurs, 
social  partners  and  everyone  in  society  in  combating 
fraud. It has also successfully raised public awareness of 
the  shadow  economy  and  fraud,  and  their  negative 
consequences  for  each  individual  and  the  economy  in 
general. 

Lithuania – “Jonvabaliai” transparency initiative 

How it works 

“Jonvabaliai” (“Fireflies”)  is the first voluntary initiative 
in the EU to encourage project promoters to be more open 
to  the  public  and  to  seek  greater  transparency  for 
themselves. EU project promoters from this initiative now 
report  not  only  to  various  institutions,  but  also  to  the 
general public, and each resident of Lithuania can 
invested  and  managed 
that 
be  sure 
transparently. 

funds  are 

Jonvabaliai  was  created  by  eight  Lithuanian  public 
organisations  (including  the  Ministry  of  Finance  and 
Transparency  International  Lithuania)  with  the  support 
of  the  European  Social  Fund.  Total  investment  for  the 
“Transparency 
is 
EUR 58,873, with the European Social Fund contributing 
EUR 50,042 
“Technical  Assistance” 
the 
Operational Programme for the 2007-2013 programming 
period. 

Jonvabaliai”  project 

Initiative 

through 

The  goal  of  the  initiative  is  to  encourage  enterprises, 
institutions and organisations to share information on the 
use  of  EU  funds  and  to  improve  transparency-budget 
spending for EU-funded projects. The initiative also aims 
to  provide  the  public  with  more  information  on  EU 
investments from the project promoters and to encourage 
joint  efforts  to  achieve  positive  systemic  changes  in  the 
area of transparency. 

The main objectives of the initiative are: 

 

 

in 

seek 

greater 

transparency 

to 
the 
implementation  and  payment  of  EU-funded 
projects; 
to encourage project promoters to operate on the 
principles of integrity and openness and to make 
changes in the field of transparency; 

 

 
 

to  rate  project  promoters  according  to  the 
transparency  of  the  use  and  settlement  of 
investments, giving them a bonus (from 1 to 3); 
to present good examples of EU investment; and 
to  increase  public  awareness  of  the  use  of  EU 
funds in Lithuania. 

Jonvabaliai  is  implemented  in  the  form  of  an  online 
platform that collects information on the projects funded 
by the EU and shares this information with the public. 

Unique features 

The  Jonvabaliai  online  platform  (www.jonvabaliai.lt) 
provides information on projects funded by the EU. More 
specifically, the platform and maps specify the location of 
each project and explain what the project does, how much 
money it has received, and how this money is managed. 
Via  a  website,  project  managers  can  voluntarily  submit 
information  about  project 
results,  prices,  public 
procurements, stakeholders, risk-management practices, 
etc. 

The  more  information  a  project  shares,  the  more 
“fireflies” it earns. One firefly given to a project means 
that the  project is dedicated  to improving transparency, 
while  three  fireflies represent  the  highest  level  of 
transparency and openness to the public. 

When  a  user  visits  the  website,  they  see  a  map 
highlighting all EU-financed projects, with each project’s 
number of fireflies being fully visible – giving them a clear 
visual understanding of how transparent a project is. 

50 

 
 
 
 
Practice 8 – Fostering an anti-fraud culture 

Members  of  the  Jonvabaliai 
Initiative have the right to use 
the  logo  of  the  initiative to 
demonstrate  that  their  EU-
funded 
provides 
project 
detailed 
information 
contributing  to  the  use  of 
responsible EU funds. 

Expected impact 

Since  the  start  of  the  project  in  September 2014,  more 
than  630  project  managers  have  joined  the  initiative 
following a series of awareness-raising campaigns. These 
for 
included  an  advertising  campaign,  a  contest 
municipalities, the possibility to use the initiative’s logo, 
invitations  to  attend  open  days  for  projects,  the 

production  of  road  signs  inviting  people  to  visit  the 
projects, and a TV show dedicated to the Fireflies project. 

During  the  two-year  implementation  of  the  project,  the 
Jonvabaliai  platform  was  visited  by  35,500  unique 
visitors, accounting for 140,000 page views. Following the 
project’s  implementation,  62%  of  Lithuanian  citizens 
think they have enough information on EU funding and 
51% think the money is managed transparently – nearly 
twice as many people as before the Fireflies initiative. 

The success of the initiative is recognised at EU level. In 
2016,  the  Jonvabaliai  initiative  was  honoured  at  the 
prestigious  RegioStars  Awards  in  Category 5  (“Effective 
transparency 
Management”)  as 
initiative. 

the  best  regional 

51 

 
 
 
 
 
 
© 2018 PricewaterhouseCoopers S.à r.l.  

 
 
Getting in touch with the EU 

In person 

All over the European Union there are hundreds of Europe Direct information centres. You can find the address 
of the centre nearest you at: https://europa.eu/european-union/contact_en 

On the phone or by email 

Europe Direct is a service that answers your questions about the European Union. You can contact this service: 

– by freephone: 00 800 6 7 8 9 10 11 (certain operators may charge for these calls), 

– at the following standard number: +32 22999696 or  

– by email via: https://europa.eu/european-union/contact_en 

Finding information about the EU 

Online 

Information about the European Union in all the official languages of the EU is available on the Europa website 
at: https://europa.eu/european-union/index_en 

EU publications 

You  can  download  or  order  free  and  priced  EU  publications  at:  https://publications.europa.eu/en/publications. 
Multiple  copies  of  free  publications  may  be  obtained  by  contacting  Europe  Direct  or  your  local  information 
centre (see https://europa.eu/european-union/contact_en). 

EU law and related documents 

For  access  to  legal  information  from  the  EU,  including  all  EU  law  since  1952  in  all  the  official  language 
versions, go to EUR-Lex at: http://eur-lex.europa.eu 

Open data from the EU 

The EU Open Data Portal (http://data.europa.eu/euodp/en) provides access to datasets from the EU. Data can be 
downloaded and reused for free, for both commercial and non-commercial purposes. 

 
 
 
 
 
 
 
K
N
-
0
1
-
1
9
-
6
7
3
-
E
N
-
N

  doi: 10.2776/488340