COMMISSION STAFF WORKING DOCUMENT Annual overview with information on the results of the Hercule III Programme in 2018 Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLEMENT AND THE COUNCIL 30th Annual Report on the Protection of the European Union's financial interests - Fight against Fraud - 2018
Date: 2019-10-11
Institutions: European Anti-Fraud Office, European Commission
Subjects: EU programme, EU strategy, activity report, corruption, crime, fight against crime, financial control, fraud, fraud against the EU, illicit trade

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 11.10.2019  SWD(2019) 361 final  COMMISSION STAFF WORKING DOCUMENT Annual overview with information on the results of the Hercule III Programme in 2018 Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLEMENT AND THE COUNCIL 30th Annual Report on the Protection of the European Union's financial interests - Fight against Fraud - 2018 {COM(2019) 444 final} - {SWD(2019) 362 final} - {SWD(2019) 363 final} - {SWD(2019) 364 final} - {SWD(2019) 365 final}  
 
 
1. 

Introduction ................................................................................................................................................ 3 

1.1  Hercule III Programme........................................................................................................................ 3 

1.2  Hercule III: eligible actions, beneficiaries and budget ........................................................................ 4 

1.3 

Purpose and scope of this overview .................................................................................................... 4 

2.  Budget implementation in 2018 ................................................................................................................. 4 

2.1  Budget implementation by type of financial intervention ................................................................... 5 

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

2.2.1   Technical Assistance grants ......................................................................................................... 8 

2.2.2  

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

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

2.2.4 

Legal training and studies ......................................................................................................... 11 

3.  Achievements 2018 .................................................................................................................................. 11 

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

3.2  To  increase  the  protection  of  the  financial  interests  of  the  Union  against  fraud  by  facilitating  the 
exchange of information, experiences and best practices, including staff exchanges ................................. 14 

3.3 
Strengthening  the  fight  against  fraud  and  other  illegal  activities  by  providing  technical  and 
operational support to national investigation, and in particular customs and law enforcement, authorities15 

3.4  To limit the currently known exposure of the financial interests of the Union to fraud, corruption 
and  other  illegal  activities  with  a  view  to  reducing  the  development  of  an  illegal  economy  in  key  risk 
areas such as organised fraud, including cigarette smuggling and counterfeiting ....................................... 19 

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

4.  Communication ........................................................................................................................................ 21 

4.1 

Informing potential applicants .......................................................................................................... 21 

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

4.3  Visibility of EU funding .................................................................................................................... 22 

5.  Feedback from participants of the programme ........................................................................................ 22 

6.  Conclusions and way forward .................................................................................................................. 22 

2 

 
 
 
 
 
 
1. 

Introduction 

1.1  Hercule III Programme  

The  aim  of  the  Hercule  III  Programme  (hereinafter  referred  to  as  “the  Programme”)  is  to  protect  the 
financial interests of the European Union by fighting fraud, corruption and any other illegal activities. The 
Programme provides support to  national  and regional  administrations, as  well as research and  educational 
institutes and other non-profit making entities which “promote the strengthening of action at Union level to 
protect  the  financial  interests  of  the  Union”.  The  financial  support  mostly  consists  of  grants  awarded  to 
competent  authorities in  the Member States to  strengthen their operational and technical capacity to carry 
out investigations into activities detrimental to the financial interests of the Union. The financial support is 
used  for  the  purchase  of  technical  equipment,  such  as  x-rays  scanners,  soft-  and  hardware  for  securing 
evidence from computers or smartphones (digital forensics examinations) or the purchase and installation of 
integrated systems for number plate recognition (Automated Number Plate Recognition Systems-ANPRS). 
The  Programme  also  finances  trainings  and  conferences  as  well  as  comparative  studies  and  scientific 
publications. 
The legal  basis1 of the Programme requires the Commission  to adopt  an annual  work programme2 for the 
implementation of the Programme and to submit a report3 on the main results and achievements every year 
to  the European Parliament  and to  the Council. This  is the fifth  annual overview of the achievements and 
results.  

The  Programme  was  implemented  in  2018  in  accordance  with  Regulation  (EU,  Euratom)  No.  Regulation 
(EU, Euratom) No. 966/20124.  

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

The general objective of the Programme is “to protect the financial interests of the Union thus enhancing the 
competitiveness of the Union's economy and ensuring the protection of the taxpayers' money”5, whereas the 
Programme’s specific objective is “to prevent and combat fraud, corruption and any other illegal activities 
affecting  the  financial  interests  of  the  Union”6.  The  five  operational  objectives7  of  the  Programme  are 
described in section 3 of this report, together with an overview of the main results of the actions carried out 
under the Programme and their contribution to the operational objectives. 

1  
2  
3  

4  

5  
6  
7  

Regulation 250/2014 of the European Parliament and of the Council of 26 February 2014, OJ L 84 of 20 March 2014.  
The fifth annual work programme was adopted by Financing Decision  C(2018) 1763 final of 28 March 2018. 
Article  13  of  Regulation  250/2014  (Monitoring  and  Evaluation)  requires  the  Commission  “to  provide  the  European 
Parliament and the Council, on an annual basis, with information on the implementation of the Programme, including on 
the achievement of the objectives of the Programme and the results”.  
Regulation (EU, Euratom) 966/2012 of the European Parliament and of the Council of 25 October 2012 on the financial 
rules  applicable  to  the  general  budget  of  the  Union  (Financial  Regulation  –  FR),  OJ  L  298  of  26  October  2012,  as 
amended by Regulation (EU, Euratom) 2015/1929 of 28 October 2015, OJ L 286 of 30 October 2015 and Commission 
Delegated  Regulation  1268/2012  of  29 October 2012  on  the  rules  of  application  of  Regulation  (EU,  Euratom)  No. 
966/2012 of the European Parliament and of the Council on the  financial rules applicable to the general budget of the 
Union, OJ L 362 of 31 December 2012 (Rules of Application – RAP), as amended by Commission Delegated Regulation 
(EU) 2015/2462 of 30 October, L 342 of 29 December 2015. 
Article 3 of Regulation 250/2014. 
Article 4 of Regulation 250/2014. 
Article 5 of Regulation 250/2014. 

3 

 
 
 
                                                 
1.2  Hercule III: eligible actions, beneficiaries and budget   

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

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

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

the Union’s financial interests; 

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

objectives of the Programme.  

The beneficiaries10 of the Programme are eligible bodies that are:  

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

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

The  budget  for  the  implementation  of  the  Programme  in  2018  amounted  to  EUR 15.35 million  in 
commitment  appropriations  and  EUR 13.2  million  in  payment  appropriations  and  is  financed  under  item 
24.0201 of the European Union budget for 2018. 

1.3 

Purpose and scope of this overview 

The annual overview is intended to fulfil the requirement under Article 13(1) of Regulation (EU) 250/2014 
to  "provide  the  European  Parliament  and  the  Council,  on  an  annual  basis,  with  information  on  the 
implementation of the Programme, including on the achievement of the objectives of the Programme and the 
results".  To  this  end,  this  overview  covers  information  on  actions  (section  2)  for  which  financial 
commitments  were  made  under  the  2018  Annual  Work  Programme,  as  well  as  the  results  of  actions  that 
were finalised in 2018, but committed under the Programme in previous years (section 3).   

2. 

Budget implementation in 2018  

The  budget  for  the  implementation  of  the  Programme  amounted  to  EUR  15.35  million  in  commitment 
appropriations. Table 1 gives an overview of the available budget and the commitments made in 2018. 

8  

9  

10  

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

4 

 
 
 
 
 
 
 
 
                                                 
Table 1: Available budget and commitments made in 2018 

TYPES OF ELIGIBLE ACTIONS 2018 
TECHNICAL ASSISTANCE (min. 70%) 
Grants: Cigarettes and Investigation support  Grants 

IT Databases 

IT tools and tobacco analysis  

Purchase of technical equipment 

Procurement 

Procurement 

Procurement 

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

Grants 

Procured conferences  

Digital Forensics Training sessions 

Procurement 

Procurement 

Grants: Law Training and Studies 

Grants 

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

TOTAL 2018 

Procurement 

Procurement 

BUDGET11  COMMIT12 
11 595 609 
11 497 500  
10 397 500  
9 547 500 

1 350 000 

550 000 

50 000 

3 650 000  
1 000 000 

1 000 000 

1 000 000 

500 000 

150 000  
200 000 
200 000 

650 614 

547 495 

0 

3 014 084 
500 00013 
516 083 

1 518 001 

480 000 
014 
192 139 
192 139 

% 
101 
109 

48 

99 

0 

83 
54 

52 

152 

83 

0 
96 
96 

15 347 500 

14 801 832 

96.44 

The information in the table above relates only to commitments made in 2018.  The amount committed for 
technical  assistance  was  higher  than  the  earmarked  budget  in  the  annual  work  programme.  During  2018, 
appropriations that were not  committed for the procurement  of databases were transferred to  the technical 
assistance grants. The payments under the grant agreements and most of the contracts signed in 2018 cannot 
be reported as most of them will only be made in 2019 and beyond. 

2.1 

Budget implementation by type of financial intervention 

The  Programme  was  implemented  by  making  use  of  public  procurement  (for  contracts)  and  calls  for 
proposals (for grants)15. The Commission concluded contracts for the purchase of goods and services, such 
as access to databases, the development of IT systems or the organisation of training and conferences. The 
contracts  were  concluded  on  the  basis  of  existing  framework  contracts  (FWC)16,  establishing  the  terms 
governing  specific  contracts  to  be  awarded  during  a  given  period.  In  2018,  the  overall  amount  spent  on 
contracts was EUR 3 424 332  (as shown in graph 1).  

Grants  are  direct  financial  contributions  to  finance  an  action  intended  to  help  achieve  a  Union  policy 
objective. The overall budget spent on grants was EUR 11 377 500. Grants are awarded following a call for 
proposals,  inviting  applicants  to  submit  proposals  for  an  action  that  contributes  to  the  achievement  of  the 
Programme's objectives. The beneficiary of a grant becomes the legal and economic owner of the goods or 
services that are purchased with the help of the grant. Under the Programme, grants may cover up to 80% of 

11  

12  

13  

14  

15  

16  

The  budget  corresponds  to  the  Summary  Table  in  the  Annual  Work  Programme  2018  as  adopted  by  the  Financing 
Decision 2018 C(2018)1763 final of 28 March 2018. 
Commitments cover the total costs in 2018 of legal obligations (contracts, grant agreements/decisions) entered into for 
operations extending over more than one year.  
A  grant  agreement  signed  in  February  2019  was  partially  financed  (EUR  36  236)  by  the  budget  appropriation 
corresponding to the Hercule budget 2019 for "Training, Conference and Staff Exchange". 
The contract for the illicit tobacco trade study was awarded in 2018 following a call for tender and the  amount of EUR 
150 000 was committed from the 2017 budget. 
Article  10  of  Regulation  250/2014.  Titles  V  and  VI  of  Regulation  966/2012,  as  amended.  Title  V  (Articles  101-120) 
determines  the  rules  on  public  procurement,  whereas  Title  VI  (Articles  121-137)  contains  the  rules  in  relation  to  the 
award of grants. 
Article 101(2) of Regulation 966/2012. 

5 

 
 
 
 
                                                 
the  eligible  costs17  of  the  action  and  up  to  90%  in  exceptional  and  duly  justified  cases.  In  2018,  the 
Commission awarded five 90% grant requests (out of 33 grants awarded).   

In April 2018, the Commission launched three calls for proposals: "Technical Assistance", "Legal Training 
and Studies" and  "Training  and Conferences". The deadline for submission  of  applications was set  for 14 
June 2018.  

2018 was the second year that OLAF has used the Commission's Funding & Tenders Portal, developed for 
the electronic submission of applications for grants and for the management of grants. Under the three calls, 
the  Commission  received  72  applications18  that  were  subsequently  examined  by  Evaluation  Committees. 
Each application was examined on the basis of four criteria: eligibility, exclusion, selection and award that 
were listed in the specifications of the call. The award criteria were ranked on the scores obtained for: 

  Added value of the application for the protection of the financial interests of the Union; 
  Conformity with the operational objectives of the Programme; 
  Quality; 
  Value for money.  

The examination of the applications led to the award of 33 grants19 at the end of 2018. Tables 9, 10 and 11 
provide  an  overview  of  the  successful  and  rejected  applications,  broken  down  by  call,  Member  State, 
amount requested and awarded grant. 

Graph  1  below  gives  a  breakdown  of  the  planned  budget  and  achieved  commitments  in  2018  by  type  of 
financial intervention (grants and procurement).   

Graph 1: Hercule III budget and commitments in 2018 by type of financial intervention 

Budget 2018 (planned) 

Commitments 2018 (achieved) 

4.300.000 
28% 

3.424.332 
23% 

Grants

Procurement

Grants

Procurement

11.047.500 
72% 

11.377.500 
77% 

2.2 

Budget implementation by type of eligible action 

Graph 2 below gives a breakdown of the planned budget and commitments made in 2018 by type of action. 
The  "Technical  Assistance"  actions  identified  in  Regulation  250/2014  encompass  "Technical  Assistance" 
activities, as well as "IT support", whereas the "Training Actions" include "Training and Conferences" and 
"Legal  Training  and  Studies".  The  planned  budget  for  technical  assistance  support  represented  74.91%  of 

17  

18  
19  

Article 10 (4) of Regulation 250/2014. The annual work programme 2018 contained the criteria as required under Article 
11  of  Regulation  250/2014  for  the  definition  of  these  exceptional  cases.  Applicants  for  "Technical  Assistance"  and 
"Legal Training and Studies" grants were given the possibility to request the maximum co-financing percentage of 90%.   
Technical Assistance: 42, Legal Training: 13 and Training and Conferences: 17. 
Technical Assistance: 20, Legal Training: 5 and Training and Conferences: 8. 

6 

 
 
 
 
 
 
                                                 
the  total  and  the  commitments  represented  78.34%.  These  percentages  are  well  above  the  minimum 
percentage of 70% foreseen for Technical Assistance in the annex to Regulation 250/2014. 

Graph 2: Hercule III budget and commitments in 2018 by type of eligible action 

Budget 2018 (planned)  

Commitments 2018 (achieved) 

650.000 
4% 

200.000 
1% 

3.000.000 
20% 

2.534.084 
17% 

480.000 
3% 

192.139 
2% 

1.900.000 
12% 

9.597.500 
63% 

1.198.109 
8% 

Technical assistance
IT Support
Anti-fraud Training
Law Training
Other actions

10.397.500 
70% 

Technical assistance
IT Support
Anti-fraud Training
Law Training
Other actions

Graph  3  gives  an  overview  of  the  2018  budget  commitments  showing  the  total  amounts  and  number  of 
grants awarded by Member State for technical assistance, anti-fraud training and legal training. The graph 
shows that grants were awarded to applicants from 13 Member States.  

Graph 3: Hercule III commitments (in EUR) and number of grants in 2018 by Member State and by 
sector of activity 

4 

1 

2 

3 

1 

5 

1.800.000,00

1.600.000,00

1.400.000,00

1.200.000,00

1.000.000,00

800.000,00

600.000,00

400.000,00

200.000,00

0,00

LEGAL

TRAIN

TA

2 

2 

3 

3 

2 

3 

2 

RO SI

HR MT

ES

PL

EL

SK

BG LT

LV DE

IT

7 

 
 
 
 
2.2.1   Technical Assistance grants   

The budget for technical assistance grants was EUR 9 547 500. It was available for funding actions proposed 
by national and regional authorities for: 

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

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

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

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

and tobacco. 

The  Commission  received  42  applications  from  17  Member  States  by  the  deadline  of  14  June  2018.  The 
total budget of the proposed actions was EUR 33.5 million and the requested financial support amounted to 
EUR 27.3 million. This amount exceeded the available budget of EUR 9.5 million more than threefold. The 
Evaluation Committee adopted its recommendations in November 2018 and the decision to award grants for 
20 actions was also adopted in November 2018.  

All applicants were informed of the outcome of the evaluation procedure. The overall amount approved for 
technical  assistance  grants  was  EUR 10.4 million.  The  average  co-financing  percentage  for  the  awarded 
grants was 81.5% of the eligible costs20 of the action. Grants were awarded for the purchase of investigation 
equipment  (including  forensics  equipment),  the  purchase  of  x-rays  scanners,  the  purchase  and  training  of 
sniffer dogs and the purchase and installation of Automated Number Plate Recognition Systems. Table 1 of 
Annex  1  gives  an  overview  of  the  beneficiaries,    project  title  and  brief  description  as  well  as  the  grant 
amount and the co-financing rate.  

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

Databases 

The  Programme  provides  funds  for  the  procurement  of  subscriptions  to  databases,  on  behalf  of  law 
enforcement  authorities  in  Member  States  to  support  operations  and  investigations.  The  Commission 
procures  and  manages  the  access  to  these  databases  enabling  substantial  economies  of  scale.  Within  the 
framework  of  investigations  that  are  jointly  undertaken  with  its  Member  State  partners  and  for  its  own 
investigations, OLAF staff also makes a limited use of these databases21.  

Access to databases for trade and company data as well as for vessel movements were purchased in 2018 by 
concluding specific contracts under existing framework contracts22. Table 3 in Annex 1 gives an overview of 
the contracts awarded in 2018.  

Development of specific IT tools for data analyses  

20  

21  
22  

The maximum co-financing percentage is 80%, but the Commission may award in exceptional and duly justified cases a 
grant covering up to 90% of the eligible costs. Four applicants were awarded 90% co-financing.   
The use of the databases made by OLAF staff is paid from the administrative budget of the Commission (OLAF).    
 Two  framework  contracts  concluded  by  Eurostat  for  trade  and  company  data  in  2015  and  2016  and  a  framework          
contract concluded by OLAF for vessel movements information in 2016. 

8 

 
 
                                                 
The  Automated  Monitoring  Tool  (AMT)  project  for  the  analysis  of  “big  data”  carried  out  by  the  Joint 
Research Centre (JRC) of the European Commission in Ispra (Italy), was continued in 2018 for an amount 
of EUR 744 211.  

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

The existing administrative arrangement for this project was extended until January 2021 to further develop 
and implement statistical methods for analysis of trade data and additional tools for the detection of patterns 
of fraud to support Member States, especially in view of Regulation (EC) No 515/9723.  

OLAF and the JRC also concluded an administrative arrangement (for an amount of EUR 578 492) for the 
project  “Scientific  and  technical  support  in  advancing  the  anti-fraud  EU  customs  data  analytics  capacity” 
(INTEL4CUSTAF). This  project  looks at  activities falling under the scope of Regulation  (EC) No 515/97 
and  aims  to  support  Member  States  to  better  target  customs  controls  and  perform  investigations  by 
identifying  and sharing  good data  analysis practices.  It  is  part of a long-term  effort  to  provide knowledge 
and facilitate the work of customs in Member States by increasing awareness and ultimately use of (new) 
data analytical techniques to improve the effective and efficient  use of the wide range of available data to 
identify potential customs fraud. During 2018, the project established a community of practice in the domain 
of  customs  data  analysis  and  improved  collaboration  among  Member  States'  customs  authorities  and  with 
the  Commission,  thus  bringing  genuine  European  added-value.  The  administrative  arrangement  was 
extended for the second phase of the project in 2019, to research and develop some promising analysis tools 
and methods intended to help detect fraud in key areas of interest to Member States, including e-commerce. 
This work will continue to support and strengthen the customs analytical community, including through the 
strengthening of networks and sharing of good practices. Section 3 provides examples of the results obtained 
in 2018 using the AMT tool and the data analysis project. 

Tobacco analyses  

The illicit trade of tobacco products in large volumes is almost exclusively the domain of organised criminal 
groups  operating  across  borders.  These  products  are  for  the  most  part  not  produced  in  accordance  with 
requirements  of  the  EU  tobacco  products  legislation.  The  European  Agenda  on  Security  adopted  by  the 
Commission in 201524 recognised the need to cut off criminal groups from this revenue source. Fighting the 
illicit tobacco trade is therefore essential to protecting the financial interests of the EU and Member States as 
well as to protecting public health and security. 

TOBLAB,  a  laboratory  for  the  analysis  of  tobacco  products,  was  set  up  in  2016  to  provide  independent 
testing  facilities  to  analyse  whether  seized  cigarettes  were  genuine  or  counterfeit  and,  also,  to  support 

23  

24  

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

9 

 
 
 
 
 
 
                                                 
investigations, based on the needs signalled by Member States' investigative authorities.25 An administrative 
arrangement with the JRC's Institute for Reference Materials and Measurements in Geel (Belgium), updated 
on a yearly basis, allows for its operation through Programme funding. In 2018, an amount of EUR 163 596 
was  provided.  The  analyses  carried  out  confirmed  that  the  composition  of  the  illicit  tobacco  market  has 
significantly  changed  over  the  years.  Significantly,  cheap  whites  represent  approximately  80%  of  the 
samples analysed by the JRC.  

In the 2018 Action Plan the Commission has identified a lack of knowledge of the scale of illicit trade of 
raw tobacco in the EU. Such illicit trade can create negative impacts in terms of tax revenues and tobacco 
control policy. To remedy the situation, and in line with the 2017 Progress Report and the Action Plan, the 
2018  Administrative  Arrangement  between  JRC  and  OLAF  foresees  the  preparation  of  a  mapping  of  raw 
tobacco in Europe. Section 3 describes some concrete results.  

2.2.3  Conferences, seminars and digital forensics and analysts training   

Training, conferences and staff exchanges organised under grants 

Training activities financed under the Programme aim to provide grants to beneficiaries for the organisation 
of targeted specialised trainings, conferences and staff exchanges. These activities aim to strengthen cross-
border cooperation and networking activities between experts and law enforcement staff and to facilitate the 
exchange of information on best practices in relation to the protection of the financial interests of the Union. 
The topics addressed in the call for proposals 2018 emphasised the further development, improvement and 
update of staff's skills and competences through specialised trainings and risk-analysis workshops. 

The  Commission  received  17  applications  from  11  Member  States  by  the  deadline  of  14 June 2018.  The 
total  amount  of  requested  grants  was  EUR  1.1  million  whereas  only  EUR 1 million  was  available.  The 
Commission selected eight projects for the amount of EUR 536 236. Table 4 in Annex 1 gives an overview 
of the awarded grants and co-financing rate. 

Conferences organised under procurement  

The Programme also finances high-level conferences and ad-hoc training activities focused on the protection 
of the Union’s financial interests organised by the Commission. Using the services of a framework service 
contract26 the Commission funded six events in 2018. The overall budget available for procured conferences 
was EUR 1 million. Table 5 in Annex 1 provides an overview of the six events that were procured in 2018.  

Training organised under procurement: digital forensics and analysts training  

The  "Digital  forensics  and  analysts  training"  (DFAT),  aims  to  reinforce  the  capacity  of  law  enforcement 
agencies to combat fraud including cigarette smuggling and counterfeiting. This training provides improved 
detection skills to extract and use data from digital devices. A network of certified digital forensic specialists 
was created in 2007 as a result of this annual training.    

The complexity of EU funds-related investigations has increased, creating larger volumes of data to process 
as well as a growing need to train analysts. To address this need, analysts training courses have been added 
in  2018  to  the  original  "Digital  forensics  training"  (DFT)  of  2007-2017,  complementing  digital  forensics 
investigations  by  ensuring  that  data  will  be  processed  with  a  view  to  enhancing  the  quality,  accuracy  and 
efficiency of investigations related to EU funds. 

25 The setting up of an independent tobacco testing facility was an objective of the Action Plan accompanying the Commission 
communication  of  6  June  2013  "Stepping  up  the  fight  against  cigarette  smuggling  and  other  forms  of  illicit  trade  in  tobacco 
products". 
26 MCI Benelux S.A located in Brussels. 

10 

 
 
 
                                                 
The  typical  progression  of  those  trained  is  attendance  at  a  two-week  basic  course  providing  methods  to 
secure evidence from digital information carriers and networks in a lawful manner. This basic course may 
then be followed by specialised 'topic' trainings (intermediate, advanced and specialised). From 2007-2018, 
16  digital  forensics  training  sessions,  offering  113  individual  classes,  have  been  financed.  Third  countries 
having agreements on mutual assistance in customs matters may also apply. The network of professionals 
having attended DFT/DFAT courses reinforces transnational cooperation and increases coordination at EU 
level.  

In 2018, a total of 230 officials attended two training sessions financed by Hercule III in Tallinn (Estonia). 
This includes the participation of 11 EU officials financed by the administrative budget. These sessions were 
managed  under  the  collaboration  of  a  professional  conference  organiser  and  a  training  provider.  The  first 
session was attended by 110 national officials. The second session was attended by 109 national  officials. 
The trainees came from 27 Members States and 11 third countries. 

2.2.4  Legal training and studies   

The legal training and studies grants aim at enhancing the development of the legal and judicial protection of 
the financial interests of the Union. In 2018, the Commission awarded grants to applications that proposed 
actions covering three types of specific topics: 

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

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

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

knowledge. 

The Commission received 13 applications from 8 Member States by the deadline of the call for proposals on 
14 June 2018.  The  aggregate  budget  of  the  13  actions  totalled  EUR 1.5 million  and  the  Commission  was 
requested to contribute an amount of EUR 1.3 million (84% co-funding), where only EUR 0.5 million was 
available.  The  Commission  decided  to  award  a  grant  to  five  applications  for  an  overall  amount  of  about 
EUR 413  948  with  an  average  co-financing  rate  of  82%.  The  grants  were  awarded,  amongst  others,  for 
conducting  studies  on  EU  anti-fraud  laws,  the  integration  of  the  EPPO  in  the  national  criminal  justice 
systems,  digital  forensic  evidence,  as  well  as  for  the  publication  of  a  periodical  on  the  protection  of  the 
Union’s financial interests. Table 7 in Annex 1 gives an overview of the awarded grants in 2018. 

3. 

Achievements 2018    

This  section  provides  an  overview  of  the  main  results  achieved  by  beneficiaries  implementing  awarded 
grants.  It  presents  the  results  of  actions  that  were  initiated  before  2018  and  came  to  an  end  in  2018.  As 
condition  for  final  payment,  grant  beneficiaries  must  submit  a  final  technical  report  outlining  the  main 
achievements and results of their actions. These results are examined in the light of the contribution made to 
the achievement of the operational objectives of the Programme. 

All  beneficiaries  (grants  and  procured  contracts)  also  report  any  problems  encountered  during  the 
implementation  of the action, such as delays in  procurement  procedures  or staff changes. The final  report 
indicates how these problems were addressed and whether or not the problems eventually had an impact on 
the outcome and results.  

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

11 

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

3.1 

To improve the prevention and investigation of fraud and other illegal activities beyond 

current levels by enhancing transnational and multi-disciplinary cooperation27     

The  training  activies  finalised  in  2018  consisted  mainly  of  conferences,  trainings  and  workshops.  A  wide 
range  of  disciplines  including  combating  irregularitities  in  the  use  of  EU  funds,  corruption,  conflicts  of 
interests, cross border tobacco-related crimes,  combatting illegal trade, EU agricultural funds-related fraud, 
smuggling, and digital forensics training courses were covered. They contributed to improve the analyses of 
specific fraud patterns, to identify indicators of fraud, to share experience and to disseminate best practices 
while fostering cooperation between authorities to  fight  fraud detrimental  to  the EU budget.  Significantly, 
nearly one third of the payments concerned projects aimed to enhance the fight against corruption. 

While most of projects addressed representatives of law enforcement agencies (police, customs, prosecution 
office), the participation of professionals, NGO's and educational institutions was also noteworthy. A total of 
1 338 persons attended anti-fraud trainings and conferences and 1 038 post-event evaluations were received. 
The  feedback  received  was  overwhelmingly  positive,  showing  that  95%  of  the  participants  assessed  the 
events as 'excellent' or 'good'28. Participants particularly appreciated the events having a pratical impact on 
their daily work. The evaluations of the projects finalised in 2018 indicated an improvement regarding the 
international dimension of the conferences and training. In order to more fully assess the mid-term impact of 
training actions, a "post-event" survey of participants is now requested six months after the implementation 
of the project. The result of the 2018 "post-event" surveys will be detailed in the 2019 annual overview of 
the Hercule III programme. 

The main results of these actions were: 

 

 
 

Improved  investigation  abilities  of  law  enforcement  officials  involved  in  the  protection  of  the 
financial  interests  of  the  European  Union  through  the  acquisition  of  new  skills,  knowledge  and 
competences; 
Increased awareness on fraud risk indicators and EU anti-fraud policy; 
More  widespread  use  of  specialised  methodologies,  tools  and  techniques  to  fight  against  fraud 
affecting the Union’s financial interests.  

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

The  Ministry  of  Finance  of  the  Republic  of  Latvia  implemented  an  action  aimed  at  strengthening  the 
capacity of the anti-fraud coordination service network (AFCOS) members to set up and identify strategic 
tools for the fight against fraud and corruption affecting the EU’s financial interests.  

27  
28  

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

12 

 
 
 
 
                                                 
Between January 2017 and March 2018, it organised three two-day seminars in the Latvian School of Public 
administration  of  Riga  (Latvia),  a  five-day  study  visit  in  Brussels  (Belgium)  and  a  five-day  internship  in 
Zagreb (Croatia). These events gathered a total of 222 participants from Bulgaria, Croatia, Estonia, Latvia 
and Malta plus representatives of OLAF, the European Court of Auditors (ECA) and the Organised Crime 
and  Corruption  Reporting  Project  (OCCRP).  Member  State  participants  were  customs  or  police  officers, 
magistrates,  representatives  of  national  and  regional  ministries,  local  administrations  and  non-profit 
organisations.The project contributed to strengthening the AFCOS network and cooperation both at  national 
level and between Member States.  

The Financial Directorate of the Slovak Republic  organised a seminar focused on customs controls and 
risk analysis to fight the smuggling and counterfeiting of tobacco products at the Ukrainian border. 
The four-day event gathered for 40 persons from 5 countries (SK, PL, HU, RO and EE). National practices 
were presented, followed by practical demonstrations of customs checks. Focusing on the area of passenger 
and  freight  transport  (including  the  inspection  of  vehicles  with  dogs).  Time  was  dedicated  as  well  to  risk 
analyses of checks. Finally, participants discussed potential improvements to the exchange of information at 
the international  level.  Specific attention was made to  the use of  risk analysis tools to  fight  illicit tobacco 
trade. 

The action contributed to: 

-  exchanging  information, experience and knowledge between the five participating Member States in the 
field of risk analysis and risk management; 

-  improving of the fight against smuggled and counterfeited cigarettes, tobacco and tobacco products in the 
area of passengers, freight and rail freight transport; 

 -  increasing  efficiency  in  the  detection  of  smuggled  cigarettes,  tobacco  and  tobacco  products  thanks  to 
customs checks by mobile control units based on the results of risk analyses and risk management; 

 -  increasing  the  number  of  detected  illegal  imports  of  tobacco  products  at  the  Slovakian  border  with 
Ukraine.  

The Agency for Agricultural Payments from the Region of Venice, Italy (AVEPA) organised a three day 
event  in  Padua,  gathering  55  representatives  of  12  EU  Member  States  plus  European  Commission 
representatives. The event consisted in round-tables and working groups where participants  analysed various 
fraud prevention systems used in European Paying Agencies. This work led to the comparaison of national 
methods to identify best practices, significant cases as well as useful tools and to promote staff exchange and 
training.  

The action contributed to: 

- enhancing networking; 

-  comparing  fraud  risk  management  issues,  tools,  best  practices  in  the  area  of  fraud  prevention  in  the 
agricultural sector; 

- elaborating common proposals on critical issues identified during the action; 

- exchanging knowledge and tools between European Paying Agencies in the agricultural sector. 

13 

 
 
 
3.2 
the exchange of information, experiences and best practices, including staff exchanges29    

To increase the protection of the financial interests of the Union against fraud by facilitating 

The anti-fraud training activities and staff exchanges contributed to the achievement of this objective. Each 
of the  co-financed projects  involved several  Member States  and created  opportunities  for the exchange of 
information and experience among participants. Manuals and "best practice" guidelines were produced and 
disseminated throughout the Union. The staff exchanges impoved participants' knowledge and expertise and 
established cooperation channels.  

The  Hungarian  Univeristy  of  Miskolc  organised  a  research  study,  a  conference  and  several  training 
sessions on the "Criminal law protection of the financial interests of the EU" with six participating Member 
States (Hungary, Germany, Austria, Romania, Greece and Italy). The project emphasised recent procedural 
developments,  the future European Public Prosecutor’s Office (EPPO), the relationship  between the EPPO 
and other EU organisations, the connection between EPPO and non-EPPO-countries, cross-border evidence 
gathering and e-evidence, especially in connection with the EPPO.  

The  training  sessions  and  workshops  targeted  the  exchange  of  good  legal  practices  in  the  involved  six 
Member States in relation to corruption, tax offences, money laundering, and criminal compliance.  

The recommendations from the study will be used in several ways: 

- in the preparation of course curriculum on EU criminal law and the protection of the financial interests of 
the EU; 

- the organisation of special courses for practitioners. 

The  Anticorruption  General  Directorate  of  Romania  implemented  an  action  that  intended  to  improve 
cross-border  cooperation  for  preventing  and  combating  fraud,  corruption  and  illegal  activities  in  South 
Eastern  Europe  by  developing  best  practices  and  sharing  them  between  anti-corruption  agencies  from 
Romania, Bulgaria, Hungary and Ukraine.  

A  series  of  staff  exchanges  and  bilateral  meetings  were  organised  together  with  a    two-day  workshop  in 
Bucharest  (Romania).  The  143  participants  were  mainly  police  officers  and  representatives  of  anti-
corruption offices. 

The project contributed to:  

- enhancing cooperation and exchange of information and best practices between anti-corruption agencies at 

the international and European level; 

- improving cooperation channels for investigative purposes; 

- training law enforcement officers at using new methods of risks assessment applicable to investigation of 

crimes affecting the financial interests of the EU; 

- enhancing the expertise of law  enforcement officers in  the prevention  and detection of fraud, corruption   
and other illegal activities; 

- creating networking between Romanian, Bulgarian, Hungarian and Ukrainian law enforcement agencies to 
exchange best practices and information with a special focus on cigarettes and other goods smuggling, tax 
evasion, active and passive corruption affecting the financial interest of EU. 

29  

Article 5 (b) of Regulation 250/2014. 

14 

 
 
 
                                                 
A "best practice manual" was published and disseminated through the European Partners Against Corruption 
network (EPAC). 

3.3  Strengthening the fight against fraud and other illegal activities by providing technical 
and  operational  support  to  national  investigation,  and  in  particular  customs  and  law 
enforcement, authorities30     

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

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

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

the new equipment; 

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

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

The  Commission  received  reports  on  the  implementation  of  grants  that  were  funded  by  the  Programme 
budgets of previous years. Though it is challenging to establish a direct relationship between a grant for an 
equipment  purchase,  and  the  results  achieved  using  the  equipment,  it  can  nevertheless  be  concluded  that 
financial  support  for  equipment  and  technical  assistance  contributes  substantially  to  a  higher  number  of 
arrests, seizures and convictions. The seizures made with the help of x-rays scanners, for example, allow for 
a  clear  demonstration  of  this  relationship,  whereas  this  relationship  is  more  difficult  to  demonstrate  for 
support  given  for  the  purchase  of  digital  forensics  software  or  devices  to  monitor  vehicles  or  persons 
suspected  of  involvement  in  illicit  activities.  The  equipment,  nevertheless,  enables  the  beneficiaries  to 
improve the overall efficiency and effectiveness of the operations they carry out in support of investigations 
to protect the Union's financial interests, as shown in the examples below. 

Examples of technical assistance grants finalised (final reports received) in 2018 include the following: 

A  grant  was  used  to  design  and  furnish  a  computer  forensics  lab  in  the  Department  of  Criminal 
Investigation  of  the  Prosecutor  General's  Office  (DCIAP)  of  Portugal.  The  digital  forensics  lab  has 
recently  been  equipped  with  state  of  the  art  hardware  and  software,  facilitating  the  handling  of  digital 
evidence. The equipment purchased allows for the extraction, analysis, exportation and storage of mass data 
in a systematic, fast and secure way, substantially reducing the length of investigations. 

Improvements to the functioning of the DCIAP include:  

- the purchase of additional NUIX licenses; 

- technical capacity to copy magnetic media; 

30  

Article 5 (c) of Regulation 250/2014. 

15 

 
 
 
                                                 
- train staff in the use of NUIX tools. 

At the time of its final report at the end of 2018, the beneficiary reported that the lab had already been used 
in  four  ongoing  investigations  into  smuggling  and  counterfeit  cigarettes  as  well  as  in  support  of  eleven 
criminal inquiries for fraud related to the financial interests of the Union.  

The National Anticorruption Directorate of the Romanian National Prosecutor's Office was awarded a 
grant  to  improve  the  investigative  capacity  of  the  National  Anticorruption  Directorate.  The  beneficiary 
purchased several devices for its technical service (audio video recorders, radio transmitters, etc.), computer 
forensics devices and also obtained specialised training for its staff to use the equipment. This equipment is 
now  being  used  to  enhance  Romanian  efforts  in  fighting  fraud  and  corruption  detrimental  to  the  financial 
interests  of  the  EU  by  consolidating  support  to  the  operational  and  technical  units.  The  beneficiary  has 
reported already having used the equipment in several cases of corruption and of fraud against the financial 
interests of the EU. 

The  Ministry  of  Finance,  Treasury  Intelligence  Department  -  Technical  and  Observation  Unit  of 
Poland  received  a  grant  for  the  purchase  of  IMSI-Catcher  system  to  help  identify  communications  by 
criminal  groups  specializing  in  cross-border  crimes  and  VAT  fraud,  detrimental  to  the  EU  and  domestic 
budgets.  The  IMSI-Catcher  purchased  enables  much  faster  analysis  and  identification  of  requested  data. 
Furthermore,  its  compactness  allows  it  to  be  readily  used  during  various  types  of  operations  in  various 
situations  and  is  very  useful  for  searching  small,  confined  spaces.  The  equipment  has  been  used  in  cases 
involving illicit trade and smuggling of tobacco products.  

Technical  assistance  implementation  reports  submitted  during  2018  describe  the  results  obtained  after  12 
months  of  using  purchased  equipment.  Thirteen  implementation  reports  were  received  in  2018.  These 
reports reflect the results of grants  awarded under the annual budgets of 2014, 2015 and 2016.  

The  specialised  technical  hardware  purchased  by  the  Guardia  Civil  (DIGEGUCI)  (Spain)  in  2016  has 
improved the skills and technical capacity of Guardia Civil  investigators, while enhancing the quality and 
results of investigations. The estimated damage to  EU budget  avoided has been estimated to  be EUR 103 
million, resulting in the arrest or the investigation of more than 200 people. 

The  General  Inspectorate  of  Romanian  Police  (Special  Operations  Directorate)  reported  that  the 
integrated  surveillance  and  intelligence  systems  purchased  have  greatly  enhanced  their  investigative 
capacity  and  has  already  been  used  in  545  operations.  Significantly,  a  reported  25  persons  have  been 
detained and nearly 7 million cigarettes seized. 

The  State  Police  of  Latvia  Central  Criminal  Police  Department  Investigation  Support  Department 
reported  that  the  tools  purchased  in  2016  have  improved  cross-border  cooperation.  Using  the  updated 
equipment has led to better evidence-gathering, contributing to the discovery of criminal networks involved 
in  financial  fraud,  counterfeiting,  manufacture,  transport  and  smuggling  of  illicit  goods.  As  a  result,  the 
estimated prevented damage has been reported as more than EUR 320 000 in a 12-month period. 

16 

 
 
 
 
 
 
Examples of procured access to external databases   

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

The Member States  and OLAF use a commercial database of  worldwide trade statistics to  analyse  trade 
flows  (imports  and  exports),  identify  potentially  suspicious  trade  and  cross-check  allegations  of  customs 
fraud.  The  database  is  an  essential  part  of  a  risk  analysis  system  and  is  in  regular  use  by  Member  State 
customs services in connection with anti-dumping cases to confirm suspicion of a suspected misdeclaration 
of the country of origin of goods imported into the EU and circumvention of anti-dumping duties. It is used 
for  comparing  declared  exports  from  a  non-EU country  to  declared  imports  into  a  Member  State  to  detect 
irregularities. 

This  database  is  also  used  for  identification  of  possible  undervaluation  of  goods.  For  example,  a  Member 
State  customs  service  mainly  uses  trade  statistics  data  to  estimate  reference  prices  within  the  frame  of  a 
system of reference prices which is widely used to fight undervaluation of textile products. It is also used to 
estimate  average  prices  of  goods  imported  in  Member  States  used  for  comparison  purposes.  The  database 
allows identification of goods imported to a Member State at significantly lower prices than other Member 
States,  indicating  possible  undervaluation.  In  addition,  the  tool  is  used  as  a  basic  element  of  risk  analysis, 
especially to identify sudden changes in trade flows. 

Member States' customs authorities use a database with information on vessel movements in supporting risk 
analysis of commercial vessel traffic. The information contained in the database contributes to combatting 
fraud  affecting  the  financial  interests  of  the  EU,  including  cigarette  smuggling.  The  database  is  used  in 
vessel tracking analyses and finding data on vessels in combination with other databases. Furthermore, it is 
used to check the actual routes of vessels in order to verify the origin of goods, for instance, when fraud is 
detected in anti-dumping duty evasion in risky and potentially suspicious cases of import transactions. It is 
also used for checking goods in containers, when the claim in administrative procedures for recognition of 
export is submitted. This database was used, for instance, in an administrative procedure, when a  company 
requested a repayment of customs duties for a product imported from a third country for which additional 
customs duties were paid, on the basis that the export from that country was made before the introduction of 
these duties. A check on the database showed that the vessel had not left the third country port before the 
date of introduction of customs duties and the claim for refund for a significant amount was rejected. 

A  database  with  information  on  companies  is  also  a  very  useful  tool  to  support  investigations  led  by 
Member States' customs authorities related to fraud affecting the financial interests of the EU, for instance, 
dumping  fraud.  For  example,  a  Member  State  customs  service  has  investigated  infringements  of  EU  anti-
dumping measures on imports of solar panels from a third country. In 2018, the searches carried out in the 
database  in  two  cases  led  to  the  detection  of  a  network  of  companies  which  circumvented  anti-dumping 
duties.  The  companies  engaged  in  practices  of  transhipment  of  products  via  third  countries  to  the  EU  by 
undercutting the prices of the imports through kick-back payments. The fraud scheme involved a network of 
companies in the Member State and third countries. The duty losses identified were of a significant amount.       

17 

 
 
 
 
 
 
Examples  of  operational  results  obtained  from  the  use  of  the  AMT  tool,  the  data  analysis  project  and  the 
tobacco analyses laboratory (developed with the JRC). 

The  Automated  Monitoring  Tool  (AMT)  is  used  as  part  of  a  set  of  risk  analysis  tools  by  the  Member 
States' customs authorities to identify cases of potential fraud, such as undervaluation (tax evasion), which 
affect the national and EU budgets. It provides objective statistical values for imports of goods, also known 
as  cleaned  average  prices,  providing  reference  EU  prices  for  the  determination  of  the  customs  value  of 
imported  goods.  Customs  authorities  use  these  AMT  values,  for  example,  when  they  have  doubts 
concerning the declared customs value of goods or to challenge understated values declared by importers. 
The  scale  of  undervaluation  has  decreased  in  those  Member  States  using  the  AMT,  thereby  reducing  the 
level of losses to the EU and Member States' budgets in customs duties and taxes. The AMT tool receives 
more than 15 000 data requests per year from more than 120 customs officers. Below are direct results of 
the use of the tool in support of operations, for example:  

A joint customs operation was conducted by nine Member States' customs authorities and OLAF targeting 
criminal  networks  importing  textiles  and  footwear  from  a  third  country  into  one  Member  State.  The 
operation  found  that  out  of  more  than  1  000  trucks  controlled  277  participated  in  fraud  circuits,  five 
criminal  networks  were  identified  and  several  shell  companies  were  closed  in  several  countries,  several 
dozens of investigations were opened in several countries based on the information gathered until December 
2017  and  enhanced  with  other  data  in  the  following  months.  The  operation  determined  that  the  value  of 
imported goods from this third country was significantly understated, leading to substantial losses to the EU 
and  Member  States'  budgets  in  customs  duties  and  taxes.  During  the  operation,  large  quantities  of 
counterfeit products were also seized. This also revealed that these large-scale frauds were the result of very 
organized circuits on European scale, extremely reactive and having an excellent knowledge of the faults of 
controls, logistic circuits, false invoice systems and clandestine financial flows.  

Some Member States customs are assessing the benefit of integrating the AMT tool in their audit plans. For 
example,  a  Member  State  customs  service  uses  the  AMT  tool  for  the  calculation  of  a  minimum  trustful 
value for imports of goods and the related potential customs duty gap. The case selection for the customs 
audit plan is done either by selecting companies with a potential duty gap, or using internal methods based 
on  predictive  models  for  undervaluation  combined  with  other  information  about  the  results  of  different 
types of audits and controls, such as suspicious companies involved in the import. Another Member State 
customs  service  uses  the  AMT  tool  in  a  methodology  that  aims  to  identify,  analyse  and  control  customs 
declarations with statistical anomalies in terms of values declared for imported goods. The customs service 
uses the AMT tool firstly to analyse and select the most suspicious imports of goods for controls and then to 
create risk profiles with high level of efficiency in identifying cases of undervaluation. The statistical values 
collected from  AMT and other internal  methods are then combined with  results of controls.  Each type of 
good is analysed with specific risk thresholds, which are updated with reliable results of controls.  

As an indirect result of the operations, the AMT tool has generated a new scientific approach to the fraud 
detection which highlights the continuing value of the tool and is an example of a long term effect of using 
this tool on a constant basis. This has led to cutting edge research into new statistical tools that rely on the 
application of the Newcomb-Benford law which uses the observation of the distribution of the first digits of 
numbers in large databases with customs declarations to tackle fraud in international trade31. 

31   An article on the application of  Benford's law and the detection of fraud in international trade was published by the JRC in the 
Proceedings of the National Academy of Sciences (PNAS - USA) on 2 January 2019 and a reference to EU funding under the 
Hercule budget is made at the end of the text. https://www.pnas.org/content/pnas/116/1/106.full.pdf  

18 

 
 
 
 
                                                 
By  establishing  a  community  of  practice  and  bringing  together  Member  States  experts  in  the  field  of 
customs anti-fraud data analysis, the INTEL4CUSTAF project facilitated transnational cooperation and 
collaboration,  promoting  the  sharing  of  good  practices  and  experience  among  Member  States  to  tackle 
customs fraud. 

In 2018, OLAF, working closely with the JRC, implemented a series of actions to understand the data and 
the analytical approaches already being used by Member States and the Commission, as well as the needs 
and limitations of Member States. These actions included a survey to identify existing practices and issues; 
the  study  of  data  sources;  organisation  of  two  workshops;  five  targeted  visits  to  Member  States customs; 
numerous presentations and two prototype systems providing information to customs domain experts: i) the 
on-line  data  catalogue  and  ii)  a  new  24/7  search  of  media  to  identify  reports  related  to  illicit  tobacco 
(utilising an existing tool). Based on the positive feedback from the community of Member State experts, 
these actions are having a positive impact in strengthening the know-how and collaboration among Member 
State customs experts and also with the Commission. Through these actions, OLAF and the JRC have also 
provided technical support to customs authorities in various Member States, thus helping to strengthen their 
capacity to combat fraud. These actions generated concrete proposals for further collaboration and research 
into  new  tools  and  methods  for  anti-fraud  data  analysis.  The  results  of  the  project  contribute  to  a  more 
homogeneous EU capacity to detect customs fraud, and, overall, to the protection of the financial interests 
of the EU.   

The laboratory for testing tobacco at the JRC-Geel facility became operational in April 2016 and is being 
used by Member States' customs services and OLAF investigators. The JRC carries out analyses on samples 
of seized cigarettes and tobacco to identify the geographical origin of tobacco, link seizures from a common 
source  and  compare  the  chemical  composition  of  seized  tobacco  products  against  reference  samples  to 
determine  whether  they  are  genuine,  counterfeit  or  cheap  whites.  The  JRC  maintaines  and  updates  a 
database  with  information  on  the  chemical  composition  and  origin  of  seized  smuggled  and  counterfeit 
tobacco  products.  In  2018,  103  analyses  of  tobacco  and  tobacco  products  were  carried  out  at  JRC.  The 
information  obtained from  the analyses allowed tobacco investigators to  share information, establish links 
between tobacco products seized within the EU and draw useful conclusions from on-going investigations 
carried out in Member States. 

3.4  To limit the currently known exposure of the financial interests of the Union to fraud, 
corruption  and  other  illegal  activities  with  a  view  to  reducing  the  development  of  an  illegal 
economy  in  key  risk  areas  such  as  organised  fraud,  including  cigarette  smuggling  and 
counterfeiting32    

Several actions contributed to achieving this objective in 2018. The widespread availability of illicit tobacco 
within the EU has led to the loss of considerable tax and duty revenues (losses to the EU and Member States' 
budgets as a result of cigarette smuggling are estimated to be at least EUR 10 billion per year33). One feature 
of the illicit market for cigarettes in the EU is the significant quantity of counterfeit products available at a 
lower cost than the genuine products.  

32  
33  

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

19 

 
 
 
 
 
 
                                                 
The Observatory on criminal activities in agriculture and in the agri-food sector (IT) organised a two-
day conference in January 2018 in Rome.  

The conference was attended by 109 participants from Montenegro and 14 Member States.   The participants 
were  representatives  of  law  enforcement  agencies,  ministries,  legal  practitioners,  local  and  regional 
authorities,  customs,  revenues  agencies,  tobacco  companies  and  a  national  agency  for  the  protection  of 
consumers.  

The action contributed to: 

- increasing awareness of the tobacco sector about the prevention and the fight against fraud; 

- collecting input for developing and improving a track and tracing system; 

- collecting and linking information on different ways of transposing the Directive 2014/40/EU concerning 
the manufacture, presentation and sale of tobacco and related prodicsts,  as regards of developing a track 
and tracing system, in order to identify strengths and weaknesses; 

- discussing  the  development  of  possible  solutions  and  proposals  for  implementing  tracking  and  tracing 

systems and security features at the European level. 

The 23rd Task Group Cigarettes Conference organised by OLAF gathered 88 participants from Member 
States, candidate and third countries in Pravets (Bulgaria) in September 2018. Its main objectives were to:  

- illustrate  best  practices  and  results  obtained  by  OLAF  in  the  fight  against  smuggling  and  any  other 

tobacco-related offence, as a result of its investigative and coordination function in the specific sector; 

- provide Member States with an updated situation of the cigarette smuggling phenomenon in the EU; 

- exchange information about recent developments, strategies and trends in the area of cigarettes smuggling, 
along  with  discussing  enforcement  measures  in  order  to  improve  effectiveness  and  cooperation  in  this 
field; 

- deepen, through specific group work, the most salient investigative issues in the field of the fight against 

illicit trafficking and production in cigarettes and tobacco. 

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

- enhancing transnational cooperation; 

- facilitating the exchange of information, experiences and best practices; 

- providing  technical  and  operational  support  to  national  investigation,  in  particular  customs  and  law 

enforcement authorities; 

- reducing the development of an illegal economy in the area of cigarette smuggling and counterfeiting.   

3.5  To enhance the degree of development of the specific legal and judicial protection of the 
financial interests of the Union against fraud by promoting comparative law analysis34     

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

34  

Article 5(e) of Regulation 250/2014. 

20 

 
 
 
 
 
 
                                                 
The University of Luxembourg conducted a comparative law study on the "Liability of Company Directors 
in a Comparative EU Criminal Justice Context", aimed at analysing and systemising the aspect of punitive 
liability of heads of business in the selected Member States (FI, FR, DE, NL and PL).  

The  study's  outcome  highlighted  the  existence  of  rather  different  approaches  that  may  lead  to  significant 
disparities from  one Member State to  another and to  a potential “deterrence  gap”. Recommendations  were 
developed taking into account three possible policy options, each one of them entailing different legislative 
ambitions and a different potential impact on the national systems.  

The report together with the policy recommendations have been largely disseminated as well as uploaded on 
the University's online repository.  

The  Programme  continued  funding  the  publication  of  “eucrim  –  The  European  Criminal  Law 
Associations’ Forum", which was published in four issues during 2018 by the German Max Planck Institute 
in  Germany.  The  periodical  addressed  current  developments  in  the  European  criminal  law,  such  as 
fundamental  rights,  the  implementation  of  the  European  Public  Prosecutor  Office,  the  protection  of 
whisleblowers or the exchange of information and data protection. Each issue was printed in 2000 copies and 
distributed  to  universities,  libraries,  courts,  law  enforcement  authorities  and  individual  subscribers.  The 
articles were also published on the internet35.  

The Expert Forum (Romania) conducted a research on "Money and politics – linking EU funds to political 
parties".  The  project  generated  a  report  (published  in  RO  and  EN)  analysing  the  connection  between  the 
political  parties and the illegal  use of public funds through public procurement in  Romania and Croatia as 
well as a list of red flags related to public procurement.  

The  results  were  disseminated  thorugh  an  international  conference  and  a  public  campaign  addressed  to 
experts, stakeholders, the general public in Romania and countries from the region.  

4. 

Communication  

The successful implementation of the programme required a structured way to inform potential beneficiaries 
on  funding  opportunities.  The  Commission  also  disseminates  information  on  the  achievements  and  the 
results of the actions that received funding. 36 

4.1 

Informing potential applicants 

The full texts of the Calls' documents were made available on the Commission's Funding & Tenders portal 
and an announcement of the Calls was posted on the Commission's website37. Professional networks were 
actively informed. Potential applicants were also informed via emails sent to the members of the Advisory 
Committee for the Coordination of Fraud Prevention (COCOLAF), the OLAF Anti-Fraud Communicators 
Network (OAFCN) and the European Judicial Training Network (EJTN).  

35  
36  

37  

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

21 

 
 
 
 
 
                                                 
4.2 

Dissemination of results 

The dissemination on training activities was made through the distribution of electronic and/or paper reports 
summarising  the  event.  Some  beneficiaries  posted  the  projects'  outputs  on  their  websites  or  created 
dedicated  websites  in  order  to  disseminate  results  and  conclusions.    The  dissemination  of  the  results  of 
actions  related  to  technical  assistance  is  not  always  possible  since  most  of  the  achievements  relate  to 
investigations for which information often cannot be disclosed.  

4.3 

Visibility of EU funding 

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

 

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

 
  At information events (conferences, seminars); 
  By inserting a link from their website to the Hercule III programme's site.  

Beneficiaries of technical  assistance grants  were  requested to  mention  the Hercule support in  their reports 
and any other document or press release that reported on the results: press releases issued following seizures 
of counterfeited or smuggled cigarettes made with Hercule funded equipment, for example, should refer to 
the Union's funding.  

5. 

Feedback from participants of the programme    

As indicated in section 3.1, beneficiaries of grants for trainings, conferences and seminars carry out surveys 
among  the  participants  to  collect  information  on  the  perceived  quality  and  relevance  of  the  event.  A  total 
number  of  1  338  participants  attended  Hercule  training  events  in  2018.   The  Commission  received  1  038 
completed questionnaires (78% response rate), most of which indicated a high level of satisfaction. Nearly 
95%  of  the  participants  considered  the  event  'good'  or  'excellent'.  Written  feedback  confirmed  the  target 
audience,  the  event’s  relevance  for  the  participants'  professional  activities,  the  quality  of  the  organisation, 
the speakers, venue and other relevant aspects. 

6. 

Conclusions and way forward    

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

The  relevance  of  the  Programme's  aims  and  objectives  is  supported  by  the  findings  of  the  mid-term 
evaluation  carried  out  in  2017.  The  evaluation  demonstrated  that  the  Programme,  in  its  current  form  and 
stage of implementation, has largely fulfilled its mission. The stakeholders reported that the Programme has 
been efficiently implemented while effectively addressing the Member States' needs. 

The  introduction  of  the  electronic  submission  and  processing  of  grant  applications  is  an  important 
development  which has  considerably shortened the time for notifying applicants  about  the outcome of the 
evaluation  procedure.  As  its  full  implementation  continues,  this  electronic  system  is  expected  to  further 
reduce the administrative burden for applicants, grant beneficiaries and the Commission.  

The Hercule III programme will come to an end on 31 December 2020. Acknowledging its contribution, the 
Commission adopted on 30 May 2018 a proposal for a new EU Anti-Fraud Programme38 under the financial 
framework  2021-2027.  The  proposal  combines  two  types  of  spending  activities:  a  classic  spending 

38 COM(2018) 386 final of 30 May 2018. 

22 

 
 
 
 
                                                 
programme  following  up  on  the  Hercule  III  programme  and  the  financing  of  two  operational    activities 
which are tasked to  the  Commission  by secondary legislation (the Anti-Fraud  Information  System  (AFIS) 
which  supports,  essentially,  operational  activities  in  the  area  of  mutual  administrative  assistance  between 
Member States’ customs authorities, and the Irregularity Management System (IMS), an IT established for 
the reporting by Member States of fraudulent and non-fraudulent irregularities to the EU budget in shared 
management and pre-accession funds). This combination will permit the creation of synergies and allow for 
flexibility between the three components of the new programme as well as with other relevant programmes.  

23 

 
 
 
 
Annex 1: Grants and contracts awarded and finalised under the 2018 Financing Decision 

Table 1 – TECHNICAL ASSISTANCE grants AWARDED under the 2018 Financing Decision  

MS 

Beneficiary 

Title and description 

Awarded grant 
(EUR) 

Co-fin 
% 

1 

PL 

Izba Administracji Skarbowej w Rzeszowie 

2 

LT 

Finansiniu Nusikaltimu Tyrimo Tarnyba Prie 
Vidaus Reikalu Ministerijos 

3  MT  Department of Customs 

4 

BG  National Revenue Agency 

Hand-held X-ray scan - 
purchase of hand-held 
X-ray 
scanner 
detectors 

FNTT TA – purchase of 
digital 
investigation 
tools 

Herculepara2018 
– 
purchase of x-ray vans  

– 
BG-NRA-ITF-2018 
purchase  of  digital 
forensic tools 

237 251 

80 

103 570 

80 

207 000 

90 

117 945 

80 

5 

PL 

Revenue  Administration  Regional  Office  in 
Lublin 

PURCHASE-SCANNERS  

229 783 

80 

6 

ES  Ministerio del Interior 

7 

LV 

Valsts Ienemumu Dienests 

8 

PL 

Komenda Wojewodzka Policji W Lublinie 

9 

SK 

Financial Directorate of the Slovak Republic 

GRADIUNTUR 
purchase 
surveillance 
equipment 

– 
of 

SCCS  -  purchase  of 
surveillance 
equipment 

Operational  control  – 
purchase  of    a  vehicle 
and ANPRS system 

SK  ANPRS  -  purchase 
of 
and 
ANPRS system 

vehicle 

a 

10 

RO 

Directia Nationala Anticoruptie 

11 

BG 

Agencija Mitnici 

TADNA  –  purchase  of 
IT forensic equipment 

FAST  DETECTION  – 
purchase  of  detection 
tools 

24 

1 010 914 

80 

270 000 

80 

98 274 

80 

660 000 

80 

370 924 

80 

381 312 

80 

 
 
 
 
12 

PL 

Komenda Glowna Policji 

13 

RO 

Inspectoratul General al Politiei Romane 

14 

EL 

Ministry  of 
Development Programmes Agency 

Interior 

/  European  & 

CIIB-LargeVolDatAn  – 
IT  data 
purchase  of 
analysis tools 

CARGOSCAN  2018  – 
purchase  of  technical 
scanning equipment 

– 
HE.F.E.ST.O.S. 
purchase  of  detection 
equipment 

355 680 

90 

1 243 200 

80 

461 760 

80 

15 

SI 

Ministrstvo  za  finance,  Financna  uprava 
Republike Slovenije 

X-ray FURS – purchase 
of a cargo scanner 

1 656 020 

80 

16 

EL 

Ministry  of 
Development Programmes Agency 

Interior 

/  European  & 

17  MT  Malta Police Force 

EX.E.C.U.T.I.V.E. 
– 
purchase of IT forensic 
tools 

ANPRS-4-MPF 
– 
purchase  of  ANPRS 
systems 

272 909 

80 

115 763 

90 

18 

LT 

Lietuvos  Respublikos  Specjaliuju  Tyrimu 
Tarnyba 

ACIPC  –  purchase  of 
data analysis tools 

365 612 

80 

19  MT  Malta Police Force 

20 

HR  Ministarstvo Financija Carisnka Uprava 

12  MPF 
purchase 
analysis tools 

2018 
of 

– 
data 

859 845 

90 

X-RAY  FOR  EASTERN 
EU  –  purchase  of  a 
cargo scan 

1 370 000 

68.5 

TOTAL 

10 387 762 

81.4 

Table 2 – TECHNICAL ASSISTANCE grants FINALISED in 2018 

MS 

Beneficiary 

Title 

Amount paid 
(EUR) 

Amount 
paid as 
% to 
initial 
commit-
ment39 

39  

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

25 

 
 
 
 
 
 
 
                                                 
1 

GR 

2 

LT 

General  Directorate  of 
Customs  and  Excise 
Division  of  Strategy  of 
Customs  Controls  and 
Offences 

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

Purchase of Services to destroy seized 
tobacco products 

71 866 

40 

X-SAFT:  purchase  of  advanced  x-ray 
scanner  

352 173 

64 

3 

LT 

Customs 
Service - CCS 

Criminal 

Improvement 
Customs 
investigations  through  deployment  of 
IT forensic equipment 

of 

288 110 

100 

4 

EE 

Estonian 
Customs 

Tax 

and 

The purchase of a portable X-Ray 

100 198 

100 

5 

RO 

Anti-Corruption 
General Directorate 

Increasing efficiency of the Ministry of 
Internal  Affairs  action  system 
in 
combating 
investigating 
corruption phenomenon 

and 

6 

PL 

Border  Guard  Maritime 
Division 

Purchase  of  Mobile  X-Ray  scanners  to 
guarantee  the  effectiveness  of  checks 
for illegal excise goods 

124 807 

90 

113 465 

97 

7 

PT 

General  Prosecutor  of 
the 
of 
Republic 
Portugal 

Puchase  of  IT  equipment  to  furnish  a 
forensic computer anaysis lab 

418 326 

76 

8 

ES 

AEAT-Customs 

distributed 

Two 
surveillance vehicles 

remote 

video 

Increase 
possibilities of the Polish Police 

the 

of 

investigation 

212 320 

56 

458 907 

84 

9 

PL 

National 
Headquarters 

Police 

10 

PL 

Ministry  of  Finance, 
Treasury 
Intelligence 
Department  -  Technical 
and Observation Unit 

Purchase  of  operational 
equipment 

technical 

273 670 

96 

11 

RO 

National  Anticorruption 
Directorate DNA 

for  consolidating  of 

the 
Support 
investigative  capacity  of  the  National 
Anticorruption Directorate 

816 064 

94 

12 

LT 

Investigation 
 Special 
Service  of  the  Republic 
of Lithuania 

Purchase  of  specialised  operational 
technical equipment 

228 416 

89 

13 

ES 

Guardia Civil 

Project 

Viriato 

– 

operational 

509 728 

83 

26 

 
 
253 437 

73 

236 856 

72 

218 947 

66 

308 548 

43 

equipment 

14 

EE 

 Estonian  Police  and 
Border Guard Board 

Creation  of 
analysis platform 

criminal 

intelligence 

153 610 

80 

Purchase of a mobile x-ray scanner  

967 677 

81 

15 

HR 

Croatian  Customs  The 
Republic  of  Croatia, 
Ministry  of  Finance, 
Customs Administration 
- Sector for Control 

16 

BG 

Bulgarian  Border  Police 
Interior  - 
Ministry  of 
CDBP 

17 

SL 

Financial  Directorate  of 
the Slovak Republic 

Enhancing  the  capacity  of  CDBP  for 
effective  detection  of  smuggled  and 
counterfeited  goods  imported  into  EU 
with the aim or consequence to evade 
custom duties and excises 

intensification  of 
Streamlining  and 
processes  within 
the  operational 
detection  and  prevention  -  control 
Financial 
activities 
Administration  in  combating  customs 
and tax fraud 

Slovak 

of 

18  MT 

Malta 
Department 

Customs 

Investment  in  combating  fraud  and 
contraband of illicit goods, particularly 
cigarettes and tobacco 

19 

HU 

Tax 

and 
 National 
Customs Administration 
of Hungary 

Technical capacity development of the 
NTCA  in  the  fight  against  cigarette 
smuggling 

TOTAL 

6 107 125 

Table 3 – DATABASES that were CONTRACTED under the Hercule III budget in 2018 

27 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Name 

Content 

Commitment in 
Euro 

1 

IHS Maritime Portal 

Information on ship movements 

2  GTA 

3  ORBIS 

Trade statistics data 

Basic  company 
details of companies all over the world 

information  and 

financial 

Total committed under the 2018 budget  

227 554  

206 060 

217 000 

650 614 

Table 4 – ANTI-FRAUD TRAINING & CONFERENCES grants AWARDED under the 2018 Financing Decision 

MS 

Beneficiary 

Title 

Awarded 
grant (EUR) 

Co-fin 
% 

1 

LV 

Valts Ienemumu Dienests  

Advanced  X-ray 
training 

image 

interpretation 

50 842 

80 

2 

SK 

Financial Directorate of the 
Slovak Republic 

Training focused on X-ray scanner image 
control 
interpretation  and 
process 

customs 

3 

PL 

Komenda 
Policji W Lublinie  

Wojewodzka 

4 

BG  National Revenue Agency 

of 

Methodology 
and 
investigating  crimes  detrimental  to  the 
financial interests of the European Union 

detecting 

Enhancing  the  cooperation  and  the 
control models in the field of prevention 
of  fraud,  related  to  customs  regimes 
4200  and  4000,  affecting  the  EU  system 
of own resources 

53 542 

80 

76 074 

80 

66 690 

80 

5 

LT 

Lietuvos 
Kriminalistiniu 
Centras  

Policijos 
Tyrimu 

"Improving  Baltic  States  and  Croatia 
Police  Computer  Forensics  Specialists' 
Skills in IT Investigations by 

67 186 

80 

6 

RO 

Directia 
Anticoruptie  

Nationala 

Organizing 
Operating 
Scripting" 

Training  of  UNIX-based 
and 
Systems 

Forensics 

73 610 

80 

7 

RO 

,,Mihai Bravul" Dolj County 
Inspectorate 
of 
Gendarmerie 

Trends 
in 
corruption 
interests of the European Union 

investigating 
affecting 

the 

frauds  and 
financial 

48 072 

80 

28 

 
 
 
 
 
 
 
 
8 

IT 

Regione Abruzzo 40 

Good  practices  in  the  fight  against  the 
illicit  trade  of  cigarettes  which  help 
protect  the  financial  interests  of  the 
European Union 

100 220 

80 

TOTAL 

536 236 

80 

Table 5 – Anti-Fraud procured confereces organised by the Commission under the 2018 Financing Decision 

Dates 

Conference title 

Location 

N° of 
participants 

Amount 
paid EUR 

1 

10 – 13 Sept 2018 

23rd 
Conference 

Task 

Group 

Cigarettes 

Sofia 

2 

5 - 8 March 2019 

JCO  ASEM  Conference  –  briefing 
meeting and training 41 

Chi 

Ho 
Minh City 

3 

25 Oct 2018 

Expert  workshop on  the  transposition 
of the PIF directive 42 

Brussels 

4 

20-22 June 2018 

AFCOS Seminar 2018 

Sarajevo 

5 

27 June 2018 

Project  Group  on  implementation  of 
FCTC Protocol  

Brussels 

6 

31  Jan 2019 

Project Group on implementation N° 2 
of FCTC Protocol 43 

Brussels 

88 

80 

36 

73 

29 

30 

92 121  

250 974  

28 000  

51 835  

16 721  

44 664  

TOTAL 

336 

484 315  

Table 6 – ANTI-FRAUD TRAINING & CONFERENCES grants FINALISED in 2018 

MS 

Beneficiary 

Title 

Amount paid 
(EUR) 

Amount 
paid as 
% to 
initial 
commit-
ment44 

40 The amount of EUR 36 236.40 is financed by the budget appropriation corresponding to the Hercule budget 2019 for "Training, 

Conference and Staff Exchange". 

41 The event had not yet taken place on the preparation date of this document 
42 The final payment was not made yet on the preparation date of this document 
3 The final payment was not made yet on the preparation date of this document 
44  

Final payment as percentage of the awarded grant. A percentage lower than 100% means that the action was not fully 

implemented or that the beneficiary managed to achieve considerable cost savings.  

29 

 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
1 

PL 

Komenda  Wojewódzka 
Policji w Olsztynie  

2 

RO 

Anticorruption  General 
Directorate (DGA) 

3 

LT 

Lithuanian 
Police 
Forensic Science Centre 

the 

Protecting 
European  Union’s 
financial  interests  through  cooperation 
between  services,  and  acquisition  and 
exchange of skills in combating tobacco 
crimes  and  crimes  to  the  detriment  of 
the European Union 

Improving the cross-border cooperation 
for  preventing  and  combating  fraud, 
corruption and other illegal activities in 
South Eastern Europe  

Improving Baltic States Police Computer 
Forensics 
IT 
Investigations  by Organizing  Training  of 
Specialized IT Forensics Software 

Specialists' 

Skills 

in 

46 172  

51 

28 012 

49 

40 791  

87 

4 

CZ 

Transparency 
International CZ 

Conflict of Interests as a Risk of Fraud 

30 206  

75 

5 

IT 

University  of  Perugia  – 
Department  of  Political 
Sciences 

corruption 

through 
Fighting 
administrative 
measures.  
Supporting  development  of  new  anti-
corruption policies. 

6 

PL 

Szkoła 
Katowicach 

Policji 

w 

Protection  of  the  financial  interests  of 
the  EU  –  common  obligations  and 
challenges 

7 

RO 

Călăraşi  County  Police 
Inspectorate 

Transnational cooperation between law 
enforcement 
for 
strengthening the activity of preventing 
and fighting against fraud with EU funds 
in the agricultural field 

authorities 

8 

PL 

Regional 
Headquarters in Lublin 

Police 

Enhancing  the  effectiveness  of  fighting 
corruption  crimes  detrimental  to  the 
European Union’s financial interests 

Seminar  focused  on  customs  controls 
and  risk  analysis  of  vehicles  on  the 
border with Ukraine in the fight against 
customs  fraud  targeting  the  smuggling 
and counterfeiting of tobacco products 

9 

SK 

Financial  Directorate  of 
the Slovak Republic 

10 

IT 

sulla 

Osservatorio 
criminalità 
nell’agricoltura  e 
sul 
sistema agroalimentare 

89 107  

61 

44 662  

60 

82 501  

85 

22 882  

52 

22 118 

54 

Tobacco road 

23 630  

49 

30 

 
 
11 

LV 

Ministry  of  Finance  of 
the Republic of Latvia 

involved 

Strengthening  the  capacity 
for  the 
in  the  AFCOS 
institutions 
network  to  set  up  and  identify  the 
strategic  and  control  tools  for  the  fight 
against fraud and corruption. 

41 079  

77 

TOTAL 

471 160 

Table 7 – LEGAL TRAINING & STUDIES grants AWARDED under the 2018 Financing Decision 

MS 

Beneficiary 

Title 

Awarded Grant 
(EUR) 

Co-fin 
% 

1 

DE 

European Law Academy 

approach 

Towards a more proactive, intelligence-
led 
and 
preventing  fraud  affecting  the  financial 
interests of the EU 

to  detecting 

2 

DE 

Max Planck Institute  for 
and 
Foreign 
International 
Criminal 
Law 

EUCRIM:  The  European  Criminal  Law 
Associations'  Forum  -  publication  of  a 
periodical on the protection of the EU's 
financial interests 

3 

IT 

Alma  Mater  Studiorum 
Universita Di Bologna 

forensic  Evidence: 

towards 
Digital 
Common 
in 
antifraud  administrative  and  criminal 
investigations. 

Standards 

European 

4 

HR 

HUKZP 
Hrvatsko 
- 
udruzenje  za  kaznene 
znanosti i praksu 

Integration  of  the  EPPO  in  the  national 
criminal  justice  systems:  institutional, 
procedural and cooperative challenges 

45 385 

80 

78 302 

80 

68 670 

80 

122 724 

90 

5 

DE 

Justus-Liebig-
Universitaet Giessen  

EU  anti-fraud 
Article by article. 

laws.  A  commentary. 

98 866 

80 

TOTAL 

413 947 

83 

Table 8 – LEGAL TRAINING & STUDIES grants FINALISED in 2018 

31 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MS 

Beneficiary 

Title 

Amount paid 
(EUR) 

Amount 
paid as 
% to 
initial 
commit-
ment45 

1 

NL 

Utrecht University 

2 

CZ 

Transparency  International 
Czech Republic 

3 

LU 

University of Luxembourg 

4 

BG 

for 

the 
Program 
Development 
the 
Judicial System Association 

of 

5 

ES 

Antifraud 
Catalonia 

Office 

of 

6 

RO 

Transparency  International 
Romania 

7 

DE 

Institute  for 
Max  Planck 
Foreign  and  International 
Criminal Law 

8 

PL 

European  Law  Research 
Association 

Exchange  of  information  with  EU  and 
- 
national  enforcement  authorities 
Improving  OLAF  legislative  framework 
through  a  comparison  with  other  EU 
authorities 

Transparency  of  corporate  ownership 
structures  of  public  money  recipients, 
including their tax transparency 

Comparative 
of 
Study: 
Company Directors in a Comparative EU 
Criminal Justice Context 

Liability 

Liability  of  Legal  Persons  for  Abuse  of 
EU  Funds:  Comparing  Bulgaria’s  New 
Legislation with EU Member States’ Law 
and Practice 

Management of conflicts of interest for 
the  prevention  of  fraud  and  corruption 
in the European Union 

The  preventive  role  of 
in 
protecting  the  financial  interest  of  the 
European Union: a comparative analysis 
for improved performance 

judiciary 

64 632 

85 

45 616 

99 

39 373 

79 

24 719 

78 

16 350 

51 

41 074 

84 

eucrim:  The  European  Criminal  Law 
Associations’ Forum  

59 679 

84 

The Cost of Non-Europe 

28 709 

63 

9 

RO 

Expert Forum Association 

Money and politics – linking EU funds to 
political parties 

47 939 

86 

10  DE 

Academy of European Law 

Conference on combating corruption in 
the EU 

19 130 

53 

45  

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

32 

 
 
 
                                                 
Table 9 – TECHNICAL ASSISTANCE – overview per country of awarded grants and rejected applications in 2018 

TOTAL 

387 221 

MS 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

Number of 
applications 
received 

Number of 
awarded 
grants 

Grants 
requested 
(EUR) 

Grants 
awarded 

 (EUR) 

- 

- 

2 

- 

- 

1 

- 

- 

5 

1 

- 

1 

2 

- 

- 

3 

2 

- 

2 

3 

2 

- 

- 

2 

- 

- 

0 

- 

- 

2 

1 

- 

0 

1 

- 

- 

0 

2 

- 

1 

3 

0 

- 

- 

- 

- 

624 070 

499 256 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

918 337 

734 669 

1 263 643 

1 010 914 

- 

- 

- 

- 

1 800 000 

1 370 000 

- 

- 

- 

- 

- 

- 

586 478 

469 182 

- 

- 

337 500 

270 000 

1 314 008 

1 182 608 

- 

- 

33 

 
 
 
 
 
 
 
  
22 

23 

24 

25 

26 

27 

28 

PL 

PT 

RO 

SE 

SI 

SK 

UK 

13 

- 

3 

- 

1 

1 

- 

4 

- 

2 

- 

1 

1 

- 

1 168 121 

920 988  

- 

- 

2 017 655 

1 614 124 

- 

- 

2 070 026 

1 656 020 

825 000 

660 000 

- 

- 

TOTAL 

42 

20 

12 924 838 

10 387 762 

Table  10  –  ANTI-FRAUD  TRAINING  &  CONFERENCES  overview  per  country  of  awarded  grants  and  rejected 
applications in 2018 

MS 

BE 

BG 

CZ 

DK 

DE 

EE 

IE 

EL 

ES 

FR 

HR 

IT 

CY 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

Number of 
applications 
received 

Number of 
awarded 
grants 

Grants 
requested  

(EUR)  

Grants 
awarded 

(EUR) 

- 

2 

1 

- 

1 

- 

- 

- 

2 

- 

- 

3 

1 

- 

1 

0 

- 

0 

- 

- 

- 

0 

- 

- 

1 

0 

- 

- 

189 362 

66 690  

57 182  

- 

0  

- 

- 

- 

146 136  

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

260 570  

100 220  

77 489  

- 

34 

 
 
 
 
14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

LV 

LT 

LU 

HU 

MT 

NL 

AT 

PL 

PT 

RO 

SI 

SK 

FI 

SE 

UK 

1 

1 

- 

- 

- 

- 

- 

1 

- 

3 

- 

1 

- 

- 

- 

TOTAL 

17 

1 

1 

- 

- 

- 

- 

- 

1 

- 

2 

- 

1 

- 

- 

- 

8 

50 842  

50 842  

67 187  

67 186  

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

76 074  

76 074  

- 

- 

158 784  

121 682  

- 

- 

55 999  

53 542  

- 

- 

- 

- 

- 

- 

1 139 625 

536 236 

Table 11 – LEGAL TRAINING & STUDIES – overview per country of  awarded grants and rejected applications in 2018 

MS 

BE 

BG 

CZ 

DK 

DE 

1 

2 

3 

4 

5 

Number of 
applications 
received 

Number of 
awarded 
grants 

Grants 
requested 
(EUR) 

Grants 
awarded  

(EUR) 

- 

- 

- 

- 

3 

- 

- 

- 

- 

3 

- 

- 

- 

- 

- 

- 

- 

- 

222 554 

222 554 

35 

 
 
 
 
 
6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

EE 

IE 

EL 

ES 

FR 

HR 

IT 

CY 

LV 

LT 

LU 

HU 

MT 

NL 

AT 

PL 

PT 

RO 

SI 

SK 

FI 

SE 

UK 

- 

- 

- 

1 

- 

1 

4 

1 

- 

- 

- 

1 

- 

- 

- 

- 

- 

1 

- 

1 

- 

- 

- 

TOTAL 

13 

- 

- 

- 

0 

- 

1 

1 

0 

- 

- 

- 

0 

- 

- 

- 

- 

- 

0 

- 

0 

- 

- 

- 

5 

- 

- 

- 

93 675 

- 

- 

- 

- 

- 

- 

122 724 

122 724 

342 921 

68 670 

81 202 

- 

- 

- 

59 911 

- 

- 

- 

- 

- 

65 527 

- 

235 135 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

1 223 649 

413 948 

36