COMMISSION STAFF WORKING DOCUMENT Annual overview with information on the results of the Hercule III Programme in 2019 Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL 31st Annual Report on the protection of the European Union's financial interests - Fight against fraud - 2019
Date: 2020-09-03
Institutions: European Anti-Fraud Office, European Commission
Subjects: EU budget, EU programme, EU strategy, activity report, corruption, crime, fight against crime, financial control, fraud, fraud against the EU

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 3.9.2020  SWD(2020) 156 final  COMMISSION STAFF WORKING DOCUMENT Annual overview with information on the results of the Hercule III Programme in 2019 Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL 31st Annual Report on the protection of the European Union's financial interests - Fight against fraud - 2019 {COM(2020) 363 final} - {SWD(2020) 157 final} - {SWD(2020) 158 final} - {SWD(2020) 159 final} - {SWD(2020) 160 final}  
 
 
TABLE OF CONTENTS 

1. 

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

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

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

1.3 

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

2.  Budget implementation in 2019 .............................................................................................................. 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 .......................................... 11 

2.2.4 

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

3.  Achievements 2019 ................................................................................................................................. 12 

3.1  Operational  objective  1  -  To  improve  the  prevention  and  investigation  of  fraud  and  other  illegal 
activities beyond current levels by enhancing transnational and multi-disciplinary cooperation ............... 13 

3.2  Operational objective 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  Operational  objective  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 authorities ................................................................................................................................ 16 

3.4  Operational  objective  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 ............................................................................................................................................... 21 

3.5  Operational objective 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 ... 22 

4.  Communication ...................................................................................................................................... 23 

4.1 

Informing potential applicants .......................................................................................................... 23 

4.2  Dissemination of results .................................................................................................................... 24 

4.3  Visibility of EU funding .................................................................................................................... 24 

5.  Feedback from participants of the programme .................................................................................. 24 

6.  Conclusions and way forward .............................................................................................................. 25 

1 

 
 
 
 
 
 
 
 
1. 

Introduction 

1.1  Hercule III Programme  

The  aim  of  the  Hercule  III  Programme  (hereinafter  referred  to  as  “the  Programme”)  is  to  protect  the 
financial interests of the European Union by fighting fraud, corruption and any other illegal activities. The 
Programme provides support  to  national  and regional  administrations, as  well as research and  educational 
institutes and other non-profit making entities which “promote the strengthening of action at Union level to 
protect  the  financial  interests  of  the  Union”.  The  financial  support  mostly  consists  of  grants  awarded  to 
competent  authorities in  the Member States to  strengthen their operational and technical capacity to carry 
out investigations into activities detrimental to the financial interests of the Union. The financial support is 
used  for  the  purchase  of  technical  equipment,  such  as  detection,  investigation  and  forensic  tools,  or  the 
purchase and installation of integrated systems for number plate recognition. The Programme also finances 
trainings and conferences as well as comparative research 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 an annual report3 on the main results and achievements to 
the  European  Parliament  and  to  the  Council.  This  is  the  sixth  annual  overview  of  the  achievements  and 
results of the Programme.  
The Programme was implemented in 2019 in accordance with Regulation (EU, Euratom) No. 2018/10464.  

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  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; 

1  
2  
3  

4  

5  
6  
7  
8  

9  

Regulation 250/2014 of the European Parliament and of the Council of 26 February 2014, OJ L 84 of 20 March 2014.  
The sixth annual work programme was adopted by Financing Decision C(2018) 8568 final of 17 December 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) 2018/1046 of the  European Parliament and of the  Council of 18 July 2018 on the  financial 
rules applicable to the general budget of the Union (Financial Regulation – FR). 
Article 3 of Regulation 250/2014. 
Article 4 of Regulation 250/2014. 
Article 5 of Regulation 250/2014. 
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 

2 

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

the Union’s financial interests; 

3.  “Any other action”: other 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  the  participation  of  persons  from  third  countries  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  2019  amounted  to  EUR 15.89 million  in 
commitment  appropriations  and  EUR 16.06  million  in  payment  appropriations  and  is  financed  under  item 
24.0201 of the European Union budget for 2019. 

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  for  which  financial  commitments  were 
made  under  the  2019  Annual  Work  Programme  (section  2),  as  well  as  the  results  of  actions  that  were 
finalised in 2019, but committed under the Programme in previous years (section 3).   

2. 

Budget implementation in 2019  

The  budget  for  the  implementation  of  the  Programme  amounted  to  EUR  15.89  million  in  commitment 
appropriations. Table 1 gives an overview of the available budget and the commitments made in 2019. 

Table 1: Available budget and commitments made in 2019 

TYPES OF ELIGIBLE ACTIONS 2019 
TECHNICAL ASSISTANCE (min. 70%) 
Grants: Cigarettes and Investigation support  Grants 

IT Databases 

IT Tools and tobacco analysis  

Procurement 

Procurement 

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

Grants 

BUDGET11  COMMIT12 
12 062 616 
11 741 200 
10 901 200  
9 866 200 

1 350 000 

525 000 

4 150 000  
1 100 000 

666 442 

494 974 

3 719 865 
605 056 

% 
103 
110 

49 

94 

90 
55 

10  

11  

12  

“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.  
The  budget  corresponds  to  the  summary  table  in  the  Annual  Work  Programme  2019  as  adopted  by  the  Financing 
Decision 2019 C(2018)8568 final of 17 December 2018. 
Commitments cover the total costs in 2019 of legal obligations (contracts, grant agreements/decisions) entered into for 
operations extending over more than one year.  

3 

 
 
 
 
                                                                                                                                                                                
Procured conferences  

Digital Forensics Training sessions 

Procurement 

Procurement 

Grants: Legal Training and Studies 

Grants 

TOTAL 2019 

1 000 000 

1 550 000 

500 000 

952 460 

1 730 273 

432 076 

95 

112 

86 

15 891 200 

15 782 481 

99.32 

The information in the table above relates to commitments made on the 2019 available budget. The amount 
committed  for  technical  assistance  was  higher  than  the  earmarked  budget  in  the  annual  work  programme. 
During 2019, appropriations that were not  committed for the procurement  of databases and the “Training, 
Conference and Staff Exchange” call for proposals were transferred to the Technical Assistance grants. The 
payments under the grant agreements and most of the contracts signed in 2019 cannot be reported as most 
of them will only be made in 2020 and beyond. 

2.1 

Budget implementation by type of financial intervention 

The  Programme  was  implemented  by  making  use  of  public  procurement  (for  contracts)  and  calls  for 
proposals (for grants)13. The Commission concluded contracts for the purchase of goods and services, such 
as access to databases, the development of IT systems or the organisation of training and conferences. The 
contracts  were  concluded  on  the  basis  of  existing  framework  contracts  (FWC),  establishing  the  terms 
governing specific contracts to be awarded during a given period. In 2019, the overall amount committed for 
contracts was EUR 3 844 149 (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 11 938 332. Grants are awarded following a call for 
proposals,  inviting  applicants  to  submit  proposals  for  an  action  that  contributes  to  the  achievement  of  the 
Programme's objectives. The beneficiary of a grant becomes the legal and economic owner of the goods or 
services that are purchased with the help of the grant. Under the Programme, grants may cover up to 80% of 
the  eligible  costs14  of  the  action  and  up  to  90%  in  exceptional  and  duly  justified  cases.  In  2019,  the 
Commission awarded one 90% grant request for the “Legal Training and Studies” call for proposal (out of 
28 grants awarded).   

In March 2019, the Commission launched three calls for proposals: "Technical Assistance", "Legal Training 
and Studies" and "Training, Conferences and Staff Exchange". The deadline for submission of applications 
was set for 14 May 2019.  

The  calls  were  published  via  the  Commission's  Funding  &  Tenders  Portal,  an  IT  tool  developed  for  the 
electronic submission of applications for grants and for the management of grant contracts. Under the three 
calls,  the  Commission  received  68  applications15  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 applications were ranked on the scores obtained 
for the following award criteria: 

  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.  

13  
14  

15  

Article 10 of Regulation 250/2014.  
Article 10(4) of Regulation 250/2014. The annual work programme 2019 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: 43, Legal Training: 6 and Training and Conferences: 19. 

4 

 
 
 
                                                 
The examination of the applications led to the award of 28 grants16 at the end of 2019. Table 9 in the Annex 
provides  an  overview  of  the  successful  and  rejected  applications,  broken  down  by  call,  Member  State, 
amount requested and grant awarded. 

Graph  1  below  gives  a  breakdown  of  the  planned  budget  and  achieved  commitments  in  2019  by  type  of 
financial intervention (grants and procurement).   

Graph 1: Hercule III budget and commitments in 2019 by type of financial intervention 

Budget 2019 (planned) 

Commitments 2019 (achieved) 

4.425.000 
28% 

3.844.149 
24% 

Grants

Procurement

11.466.200 
72% 

Grants

Procurement

11.938.33
2 
76% 

2.2 

Budget implementation by type of eligible action 

Graph 2 below gives a breakdown of the planned budget and commitments made in 2019 by type of action. 
The  "Technical  Assistance"  actions  identified  in  Regulation  250/2014  encompass  "Technical  Assistance" 
grant activities, as well as "IT support" (databases and IT tools), whereas the "Training Actions" include the 
grant activities under "Training, Conferences and Staff exchanges" and "Legal Training and Studies" calls 
for  proposals,  as  well  as  the  procured  conferences  and  specialised  trainings.  The  planned  budget  for 
technical  assistance  support  represented  74%  of  the  total  and  the  commitments  represented  76%.  These 
percentages are well above the minimum percentage of 70% foreseen for Technical Assistance in the annex 
to Regulation 250/2014. 

16  

Technical Assistance: 13, Legal Training: 5 and Training and Conferences:10. 

5 

 
 
 
 
                                                 
Graph 2: Hercule III budget and commitments in 2019 by type of eligible action 

Budget 2019 (planned)  

Commitments 2019 (achieved) 

500.000 
3% 

3.650.000 
23% 

3.287.790 
21% 

432.076 
3% 

1.875.000 
12% 

1.161.416 
7% 

9.866.200 
62% 

10.901.20
0 
69% 

Technical assistance

IT Support

Anti-fraud Training

Legal Training

Technical assistance

IT Support

Anti-fraud Training

Legal Training

Graph  3  gives  an  overview  of  the  2019  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 14 Member States.  

Graph 3: Hercule III commitments (in EUR) and number of grants in 2019 by Member State and by 
sector of activity 

2 

1 

3 

6 

2.500.000

2 

2.000.000

1.500.000

1.000.000

500.000

0

LEGAL TRAINING

ANTIFRAUD TRAINING

TECHNICAL ASSISTANCE

1 

1 

3 

1 

2 

3 

1 

1 

1 

LV

SK

IE

PL

IT

BE HR RO CZ DE

LT UK

ES HU

6 

 
 
 
 
2.2.1   Technical Assistance grants   

The budget for technical assistance grants was EUR 9 866 200. 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  detection  devices  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;  the  purchase  and  maintenance  of  technical  equipment  for  the 
identification of beneficiaries of cash assistance programmes, including by biometric means, in order 
to prevent fraud and irregularities related to the use of the Union's funds in the migration and refugees 
management field; 

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.  Beneficiaries’  purchase  of  services  for  the  analysis,  storage  and  destruction  of  seized  genuine  or 
counterfeited cigarettes and other counterfeited goods detrimental to the Union’s financial interests. 

The  Commission  received  43  applications  from  16  Member  States  by  the  deadline  of  14  May  2019.  The 
total budget of the proposed actions was EUR 36.5 million and the requested financial support amounted to 
EUR 30.9 million. This amount exceeded the available budget of EUR 9.87 million more than threefold. The 
Evaluation Committee adopted its recommendations in October 2019 and the decision to award grants for 
13 actions was also adopted in October 2019.  

All applicants were informed of the outcome of the evaluation procedure. The overall amount approved for 
technical  assistance  grants  was  EUR 10.9 million.  The  average  co-financing  percentage  for  the  awarded 
grants was 78.5% of the eligible costs17 of the action. Grants were awarded for the purchase of investigation 
equipment  (including  forensics  equipment),  data  analysis  systems  and  large  x-rays  scanners  as  well  as  a 
plant laboratory and Automated Number Plate Recognition Systems. Table 1 in Annex 1 gives an overview 
of the beneficiaries,  project title as well as the grant amount and awarded 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 databases18.  

17  

18  

The maximum co-financing rate is 80% for Technical Assistance grants but the Commission may award in exceptional 
and  duly  justified  cases  a  grant  up  to  90%  of  eligible  costs.  In  order  to  finance  more  projects  in  2019,  the  evaluation 
committee recommended that only 80% co-financing should be awarded. The two projects financed from the reserve list 
were co-financed at a rate of 70%.   
The use of the databases made by OLAF staff is paid from the administrative budget of the Commission (OLAF).    

7 

 
 
                                                 
Access to databases for trade and company data as well as for vessel movements were purchased in 2019 by 
concluding specific contracts under existing framework contracts19. Table 3 in Annex 1 gives an overview of 
the contracts awarded in 2019.  

Development of specific IT tools for data analyses  

The Automated Monitoring Tool (AMT) project for the analysis of “big data” on external trade, carried 
out by the Joint Research Centre (JRC) of the European Commission in Ispra (Italy), was continued in 2019 
under an existing administrative arrangement funded from previous years and lasting until January 2021. It 
aims to enhance and implement specific statistical methods and tools for the analysis of data from customs 
declarations  to  detect  anomalies  in  trade  patterns.  In  this  way,  it  supports  risk  management  activities 
undertaken by Member States’ customs authorities to fight evasion and fraud.  

The  AMT  generates  automated  alerts  for  outliers  in  trade  data.  It  generates  estimates  for  average  import 
prices,  at  EU  and  national  level,  by  applying  statistical  methods  for  each  combination  of  product,  third 
country  of  origin  and  Member  State  of  destination.  It  is  a  risk  analysis  tool  for  Member  States’  customs 
authorities to monitor trade flows for intelligence analyses, target their controls and produce risk profiles to 
identify cases of potential customs fraud. It also provides realistic scenarios for joint customs operations and 
is a tool for estimation of  the customs duties that should be collected and the related potential total losses 
due to undervaluation in the EU in such cases. The use of AMT has improved authorities’ ability to detect 
the  undervaluation  of  imported  goods  and  thereby  helped  to  reduce  the  level  of  losses  to  the  EU  and 
Member States' budgets in customs duties and taxes. In 2019, several Member States broadened the use of 
the  AMT  during  a  pilot  project  where  Member  States’  customs  shared  best  practices  and  data  for  the 
development  of new data analysis techniques  to detect  undervaluation and to  improve estimates of import 
prices. This pilot took place under the INTEL4CUSTAF project, which is also a Hercule funded project to 
improve and strengthen cooperation between customs authorities in the area of data analysis for anti-fraud 
activities, described below. 

OLAF and the JRC extended the administrative arrangement (for an amount of EUR 322 763) for the “Data 
Analysis for Customs Anti-Fraud” project (INTEL4CUSTAF). Work on this project started in 2018, at 
the request  of Member  States,  to  provide “scientific and technical  support in  advancing the  anti-fraud EU 
customs data analytics capacity”. It covers activities falling within the scope of Regulation (EC) No 515/97 
on  mutual  administrative  assistance  in  the  areas  of  customs  and  agriculture  matters  to  ensure  the  correct 
application  of  customs  legislation.  The  longer  term  goal  of  the  project  is  to  provide  knowledge  and  to 
facilitate and support the work of customs authorities in the Member States for the effective and efficient use 
of data and analytical approaches in the area of customs anti-fraud.  

During 2019, as in 2018, networking activities were conducted. In two years, the project has established and 
strengthened a community of practitioners in the domain of customs data analysis, bringing together around 
150 experts drawn from all Member States and the Commission. The 3rd workshop, organised in Prague with 
the assistance of the Czech Customs Administration, attracted 58 participants from 27 Member States, who 
discussed  new  work,  good  practices  and  progress  with  the  pilot  research  projects.  Visits  were  also 
undertaken  by  the  Commission  to  two  Member  State  customs  authorities.  Such  activities  have  improved 
collaboration  among  Member  States'  customs  authorities  and  with  the  Commission.  Also  in  2019,  five 
concrete  data  analysis  (pilot)  exercises  started,  to  research  and  develop  new  data  analytical  tools  and 
methods  intended  to  help  detect  customs  fraud  in  key  areas  of  interest  to  Member  States.  The  projects 
looked at issues related to: undervaluation, misdescription of goods, automatic identification of possible e-
Traders  (linked  to  e-commerce),  the  potential  of  comparing  the  results  from  different  ways  of  measuring 
container  weight  to  identify possible fraud, using text  mining and media monitoring to  identify reports of 

19  

 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 

 
 
                                                 
illicit tobacco. In addition to this analysis, the pilot projects facilitated data and knowledge sharing between 
participants in the Member States and the Commission and work on joint analysis. 

The results of the project contributed to improve fraud detection and investigation, through the strengthening 
of the customs analytical community and the work performed in the pilots. Thus, the project improved the 
transnational cooperation and collaboration with the Commission, the sharing of good data analysis practices 
among  Member  States  and  supported  the  strengthening  of  Member  States  capacity  to  combat  fraud,  and, 
overall, of the protection of the financial interests of the EU. 

Following positive feedback from the Member States customs experts, the administrative arrangement was 
extended  for  a  third  phase  in  2020.  It  was  decided  to  continue  four  of  the  2019  pilot  projects  and  to 
implement  two  new  pilots:  i)  using  text  mining  for  the  validation  of  commodity  descriptions  in  customs 
declarations;  and  ii)  a  study  to  understand  the  potential  use  of  the  new  tobacco  track  and  trace  data  in 
tackling tobacco fraud.  

Section  3  provides  examples  of  the  results  obtained  in  2019  using  the  AMT  tool  and  the  data  analysis 
project. 

Tobacco analyses  

The  illicit  tobacco  trade  causes  losses  of  taxes  to  the  EU  and  Member  States,  is  a  revenue  source  for 
organised crime groups, and undermines health policies. Fighting the illicit tobacco trade is therefore key to 
protecting  the  financial  interests  of  the  EU  and  Member  States,  as  well  as  protecting  public  health  and 
security. To help tackle this phenomenon TOBLAB, a laboratory for the analysis of tobacco products, 
was  set  up  in  2016  by  the  JRC's  Institute  for  Reference  Materials  and  Measurements  in  Geel  (Belgium). 
TOBLAB  provides  and  develops  independent  testing  facilities,  IT  infrastructure  and  analysis  methods  to 
determine whether tobacco products are genuine or counterfeit and to support investigations, in response to 
needs  expressed  by  the  Member  States.20  The  annual  administrative  arrangement  with  the  JRC's  Geel 
Institute  was  renewed  in  2019  with  Programme  funding  for  an  amount  of  EUR  171  771.  The  analyses 
carried  out  confirmed  an  increase  in  seizures  of  cheap  whites.  In  this  context,  providing  chemical  and 
technical  analysis  on  selected  samples  of  seized  tobacco  products  and  promoting  the  capacities  of  the 
laboratory facility is an action to strengthen analytical tools in the 2nd Action Plan to fight the illicit tobacco 
trade adopted by the Commission in 201821.  

In its 2018 Action Plan, the Commission  acknowledges a need to  focus on input materials,  including raw 
tobacco, also in the context of increased detection of illicit production sites within the EU. The number of 
requests from Member States for JRC analysis of seized raw tobacco and fine cut tobacco samples increased 
significantly  in  2018-2019.  Such  illicit  trade  has  negative  consequences  in  terms  of  revenues  and  broader 
tobacco control policy. To address the situation, and in line with the objectives of the Action Plan, the JRC 
strives  to  populate  its  databases  on  raw  tobacco  while  continuing  to  increase  the  samples  of  cigarettes 
analysed  under  the  project.  The  creation  of  a  mapping  of  raw  tobacco  in  Europe  would  help  to  monitor 
cross-border movements of raw and fine cut tobacco.  Section 3 describes some concrete results. 

20  

21  

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". 
COM(2018)846 final of 7 December 2018.  

9 

 
 
                                                 
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 to facilitate the exchange of information 
on best practice in relation to the protection of the financial interests of the Union. The topics addressed by 
the  2019  applicants  emphasised  transnational  cooperation  and  the  further  development,  improvement  and 
update  of  staff's  skills  and  competences  through  risk-analysis  workshops  and  conferences  (50%  of 
applications received), specialised trainings (33%) and staff exchange (17%). 

The  Commission  received  19  applications  from  10  Member  States  by  the  deadline  of  14  May  2019.  The 
total  amount  of  requested  grants  was  EUR  1.5  million  whereas  a  maximum  of  EUR  1.1  million  was 
available.  The  Commission  selected  for  award  ten  projects  for  the  amount  of  EUR  605  056.  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 training activities focused on the protection of the 
Union’s financial interests organised by the Commission. Nine events were funded in 2019 through the use 
of an existing framework service contract. The overall budget available for procured conferences was EUR 1 
million. Table 5 in Annex 1 provides an overview of the nine events that were procured in 2019.  

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 
since 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. 

In 2019, a total of 233 officials attended two training sessions financed by Hercule III in Spain, in Seville 
(September 2019) and  Malaga (November 2019). These sessions were managed under the collaboration of a 
professional  conference  organiser  and  a  training  provider.  The  first  session  was  attended  by  106  national 
officials. The second session  was  attended by 107 national  officials. The trainees came from 28 Members 
States  and  9  third  countries.  In  addition,  20  EU  officials  participated,  financed  by  the  EU  administrative 
budget. 

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 2019, 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; 

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

knowledge. 

10 

 
 
The Commission received six applications from five Member States by the deadline of the call for proposals 
on  14 May 2019.  The  aggregate  budget  of  the  six  projects  totalled  EUR 0.68 million  and  the  Commission 
was  requested  to  contribute  an  amount  of  EUR 0.54  million,  where  EUR  0.5  million  was  available.  The 
Commission decided to award a grant to five applications for an overall amount of about EUR 0.43 with an 
average co-financing rate of 81%. The grants were awarded, amongst others, for conducting studies on EU 
VAT fraud, fraud prevention, national transposition of the Directive on the fight against fraud to the Union's 
financial interests by means of criminal law, 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 2019. 

3. 

Achievements 2019    

This  section  provides  an  overview  of  the  main  results  achieved  by  beneficiaries  implementing  awarded 
grants  coming  to  an  end  in  2019.  The  outcomes  of  projects  are  reported  in  the  final  technical  report 
submitted  by  beneficiaries  with  their  payment  requests.  Final  technical  reports  also  describe  issues 
encountered during the implementation  of the action, such as delays or staff changes.  It records how they 
were resolved and eventual impacts on the project’s outcome.  

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. 

Training  activities  finalised  in  2019  consisted  of  conferences  (83%)  and  staff  exchanges  (17%)  and 
concerned a wide range of disciplines and topics such as: combating irregularities in the use of EU funds, 
corruption and conflicts of interests, fighting intra-community VAT fraud and cross border tobacco-related 
crimes,  enhancing  the  legal  protection  for  the  Union’s  financial  interests,  enhancing  cooperation  for  the 
establishment  of  the  European  Public  Prosecutor’s  Office  (EPPO),  preventing  frauds  and  irregularities  in 
international  cooperation  and  development  projects,  and  strengthening  actions  to  fight  frauds  in  public 
procurement.  

While  most  of  the  training  projects  addressed  representatives  of  administrations  responsible  for  managing 
EU  funds  and  law  enforcement  agencies  (police,  customs),  the  participation  of  students,  professionals, 
NGO's  and  educational  institutions  was  also  noteworthy.  A  total  of  1  551  persons  attended  anti-fraud 
trainings  and  conferences  and  1  095  event  evaluation  forms  were  received.  The  feedback  received  was 
overwhelmingly positive, with 99% of the participants giving the events “excellent” or “good” assessments. 
The evaluations of the projects finalised in 2019 confirmed a growing international dimension. Participants 
came from the 28 EU Member States, 5 candidate countries and 9 third countries. 

Technical assistance grants are awarded for the  purchase and installation of technical equipment which, at 
the  time  of  final  reporting,  has  only  been  operational  for  a  short  period.  The  first  tangible  results  of  the 
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. For this reason, beneficiaries are also required to submit a final implementation report one year after 
the closing date of their actions to report on the results from the use of equipment. 

The reported results are examined in the light of the operational objectives of the Programme. Sections 3.1 
to 3.5 below describe the Programme’s achievements in the framework of these objectives. 

11 

 
 
3.1  Operational  objective  1  -  To  improve  the  prevention  and  investigation  of  fraud  and  other 
levels  by  enhancing  transnational  and  multi-disciplinary 
illegal  activities  beyond  current 
cooperation22     

This  operational  objective  is  fulfilled  mainly  through  the  projects  that  are  funded  under  the  training 
component  of  the  Programme.  A  vast  array  of  anti-fraud  related  topics  were  covered  during  the  training 
actions finalised in 2019. The projects had the following main results: 

a)  Widespread dissemination of strategies, experiences and good practices to fight corruption and other 

criminal activities affecting EU-funded projects in various countries; 

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

c)  Enhanced use of specialised methodologies, tools and techniques to fight against fraud affecting the 

Union’s financial interests. 

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

The  Romanian  Centre  of  Legal  Resources  implemented  an  action  aimed  to  review  corruption  schemes, 
prevention mechanisms and investigation strategies.  

Between  January  2018  and  March  2019,  it  organised  the  following  three  international  conferences  in 
Bucharest (Romania): 

-  Two-day  conference  “Mapping  corruption  schemes  involving  EU  funds”  gathering  78  participants  from 
Romania, Croatia, Serbia, Albania, Bulgaria, Hungary and Macedonia.  

-  One-day  conference  “Corruption  prevention  mechanisms  related  to  EU  funded  projects”  with  60 
participants from Romania, Italy, Albania, France, Netherlands and United Kingdom.  

-  One-day  conference  “New  investigation  strategies  to  uncover  corruption  in  the  EU  financed  projects” 
gathering  45  participants  from  Romania,  Hungary,  Bulgaria,  United  Kingdom,  Greece,  Serbia,  and 
Netherlands.  

The participants were customs and police officers, magistrates, representatives of administrations and non-
profit organisations. The project had a strong transnational dimension, bringing together 183 attendees from 
12  countries  and  contributed  to  disseminate  strategies,  experiences  and  best  practice  to  fight  corruption 
affecting EU-funded projects throughout the EU and abroad. 

The Italian Ministry of Economy and Finance carried-out an action aimed to strengthen the cooperation 
between anti-fraud coordination services (AFCOS) in the Member States and similar services in candidate 
and neighbouring countries.  

Between January and December 2018, it organised the following events: 

- Two-day international conference in Rome gathering authorities of the 28 countries involved.  

-  Several  round  tables  on  anti-fraud  issues  gathering  representatives  of  the  AFCOS  in  Tallinn  (Estonia), 
Helsinki (Finland), Kiev (Ukraine) and Prague (Czech Republic).  

- One-day international conference at the European Parliament in Brussels gathering representatives of EU 
institutions and of the 28 participating countries.  

This  action  gathered  a  total  of  155  participants  (21  Members  States,  4  candidate  countries  and  3  third 

22  

Article 5(a) of Regulation 250/2014. 

12 

 
 
                                                 
countries)  mainly  from  the  AFCOS  and  law  enforcement  authorities.  It  contributed  to  a  reflection  on  the 
needs for further developments aiming to improve the fight against fraud, such as: 

-  Increased  cooperation  between  European  and  national  authorities  and  real-time  information  sharing 
between AFCOS (improvement of communication systems);  

- Improvement of the structure, powers and tasks of the AFCOS; 

- More effective methodologies and guidelines for risk assessment in the management of irregularities and 

fraud within the national anti-fraud strategy; 

-  Implementation  of  an  “early  warning”  system  to  improve  information  exchange  and  risk  assessment 

procedures;  

- Development of tools for effective collaboration between European and national authorities. 

Two sessions of the Digital Forensic and Analyst Training were organised by OLAF in 2019, improving 
the  detection,  collection  and  analysis  skills  of  staff  in  charge  of  extracting  and  using  data  from  digital 
devices. The first session took place in September 2019 in Seville (Spain) and was attended by 116 trainees. 
Courses such as “advanced Windows forensic examiner” and “access data forensics” were held. The second 
session  was  organised  in  November  2019  in  Malaga  (Spain)  with  117  participants  and  included,  among 
others, an “advanced forensic” course and an “operational  analysis” training. The trainees originated from 
all 28 Member States, 3 candidate countries and 5 third countries, coming from various public organisations 
such as Police, Customs, Ministries, etc. 

3.2  Operational  objective  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 exchanges23    

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 Agency for Agricultural Payments from the Region of Venice, Italy (AVEPA) organised four staff 
exchanges  gathering  a  total  of  79  participants  representing  AVEPA  (Veneto  Region,  Italy),  the  National 
Paying  Agency  (NPA)  under  the  Ministry  of  Agriculture  of  Lithuania,  the  Agricultural  Registers  and 
Information  Board  (ARIB)  of  Estonia,  and  the  Agrarmarkt  Austria  (AMA)  of  Austria  -  as  well  as  other 
related institutions (e.g. relevant ministries). 

The  four  staff  exchanges  took  place  in  Vilnius  (Lithuania),  Tartu  (Estonia),  Vienna  (Austria)  and  Padua 
(Italy). 

Competent  authorities  in  the  participating  countries/regions  exchanged  experiences  and  best  practices  and 
shared knowledge to better identify risks of irregularities and fraud in private and public procurement. 

Partners collaborated to produce a collection of contributions entitled “Strengthening Actions to Fight Fraud 
in Procurement - Private and public procurement procedures: some practical solutions for Paying Agencies 

23  

Article 5 (b) of Regulation 250/2014. 

13 

 
 
 
 
                                                 
to  get  more  value  for  money  and  reduce  irregularity  and  fraud  risks”.  The  volume  provides  a  targeted 
summary of  effective measures taken by the participating agencies. It contributes to: 

- Increasing the awareness of the paying agencies’ staff on specific issues related to the fight against fraud 
and irregularities in public and private procurement; 

- Developing the theme of public and private procurement from a "value for money" perspective;  

- Sharing tested solutions to common problems. 

The activities and results of the project were published on the institutional website of the beneficiary. The 
beneficiary reported that all conference materials, a description of the project and results were sent to the EU 
paying agencies and were also disseminated via its social media channels. The project was presented to the 
directors of the European Paying Agencies during an annual meeting in Bucharest where representatives of 
the European Commission and the European Court of Auditors participated as speakers. 

The  Hungarian  National  Tax  and  Customs  Administration  (NTCA)  implemented  a  staff  exchange 
program  with  the  participation  of  six  Member  States’  counterpart  administrations  (Slovakia,  Bulgaria, 
Estonia, Lithuania, Poland, Romania).  

After a kick-off meeting where representatives discussed technical aspects and expectations, and created a 
staff-exchange coordination group, the NTCA organised six one-month staff exchanges between May 2018 
and  January  2019.  With  each  staff  exchange,  two  officers  from  another  EU  Member  State  came  to  a 
sensitive external EU border crossing point of Hungary.  

Officers  from  the  Financial  Administration  of  the  Slovak  Republic,  the  National  Customs  Agency  of 
Bulgaria, the Estonian Tax and Customs Board, the Customs Department under the Ministry of Finance of 
Republic  of  Lithuania,  the  National  Revenue  Administration  of  the  Republic  of  Poland  and  the  National 
Agency for Fiscal Administration of Romania attended. The focus of the event was the control tasks of the 
NTCA Tax and Customs Directorate with special attention paid to searches of cargo and passenger traffic. 
Participants reviewed methods and techniques, expanded their knowledge and shared experience. During the 
closing  meeting,  34  participants  evaluated  the  results  of  the  action  and  selected  the  most  successful  and 
effective control techniques to formulate a set of new best practices. 

The  action  contributed  to  the  following  improvements  in  the  fight  against  fraud  cigarettes  smuggling  and 
counterfeiting: 

-  The  customs  officers  developed  working  relationships,  exchanged  their  experience  on  risk  analysis, 
selection for control, and searching techniques applied to cargo and passenger traffic; 

- The participants became familiar with Hungarian control procedures and best practice; 

-  All  participants  had  the  opportunity  to  implement  the  newly  acquired  skills  in  their  own  country.  In 
particular, the search experts working at external EU borders of the six participating Member States defined 
new risk profiles in order to filter cigarette smuggling; 

- The exchange of information between the participants developed more effective detection procedures; 

-  During  the  action,  the  participants  controlled  877  vehicles  and  detected  and  seized  19  466  packets  of 
cigarettes for a value of more than EUR 65 000. Together with the cigarettes, the participants seized other 
illegal goods for a similar value (cash, amber stones, alcoholic beverages, pesticide). 

14 

 
 
 
3.3  Operational  objective  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 authorities24     

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  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. 

The  Commission  receives,  during  a  given  year,  final  technical  reports  on  the  implementation  of  grants 
funded in previous years. The duration of technical assistance grants is generally 18 months and, under very 
exceptional circumstances, may be extended to 24 months. Therefore, final reports received correspond to 
actions  financed  under  several  budget  years.  Financial  support  for  equipment  and  technical  assistance 
contributes substantially to a higher number of arrests, seizures and convictions. Seizures made with the help 
of  x-rays  scanners,  for  example,  clearly  demonstrate  a  direct  relationship.  Digital  forensics  software  or 
devices to monitor vehicles or persons suspected of involvement in illicit activities enables beneficiaries to 
improve the overall efficiency and effectiveness of the operations carried out in support of investigations to 
protect  the  Union's  financial  interests,  as  shown  in  the  examples  below  for  technical  assistance  grants 
finalised  (final  technical  reports  received)  in  2019.  The  complete  list  of  finalised  Technical  Assistance 
grants is found in  Annex 1, Table 2. 

The  National  Fiscal  Administration  Agency  of  Romania  (N.A.F.A)  reported  on  its  grant  for  detection 
equipment  aimed  at  curtailing  cigarette  smuggling  and  illicit  cross-border  trafficking  of  goods.  The 
equipment purchased includes two detection kits with density scanners and digital cameras, portable x-ray 
systems and portable endoscopes. Training for the mobile team customs officials from various locations in 
Romania  took  place.  The  use  of  the  equipment  leads  to  increased  efficacy  combatting  the  trafficking  of 
illegal  goods  and  diminishing  the  black  market  of  cigarettes  while  improving  the  security  of  the  EU’s 
external border. The equipment reduces the control time of minibuses, coaches and railway carriages where 
the dismantling of large panels is required. 

The  Regional  Police  Headquarter  in  Olsztyn,  Poland,  purchased  a  mobile  intelligence  centre.  The 
equipment,  designed  to  detect  criminal  networks  involved  in  illicit  cigarette  and  tobacco  smuggling, 
increases the investigative capabilities of the beneficiary. Ensuring data collection from the mobile network 
supports  operations  and  permits  the  gathering  of  data  for  criminal  proceedings  and  the  identification  of 
smuggling routes across Poland and the external border of the EU. The identification of suspects and their 
locations  in  remote  areas  is  greatly  enhanced  using  this  unit.  At  the  time  of  the  first  reporting  period,  the 
mobile unit had been used in 27 operations and also in cooperation with other law enforcement agencies in 

24  

Article 5 (c) of Regulation 250/2014. 

15 

 
 
 
                                                 
the region of Olsztyn. 

The State Forensic Examination Office of Latvia purchased spectrometry tools and an ultra performance 
chromatography  system  designed  to  facilitate  forensic  examinations  of  documents  and  inks.  Thirty-seven 
experts  from  Latvia,  Lithuania  and  Estonia  attended  trainings  carried  out  by  experts  from  France  and 
Germany.  Cooperation  with  experts  from  France  and  Poland  has  also  been  established  to  reinforce  skills. 
The  beneficiary  reports  that  its  analytical  capacity  has  been  enhanced  and  that  its  ability  to  provide  high 
quality forensic evidence for financial and economic crime investigations has been significantly reinforced. 
It is able to provide better services to various law enforcement institutions including the police, prosecutor’s 
office, border guard offices and the state revenue service. The equipment is instrumental in cases involving 
illicit trade and smuggling of tobacco products. 

A  mobile  X-Ray  unit  was  purchased  by  the  Customs  Administration  of  the  Czech  Republic.  This  unit 
allows for non-intrusive  inspection of road and train  transported  goods. Twenty  customs officers  attended 
the expert training  course to  learn how to  operate the scanner  and how to  interpret images. This  unit will 
assist in the detection of illicit and smuggled goods and will facilitate fast and effective inspections. The aim 
is  to  detect  smuggled  tobacco  and  cigarettes  in  small  shipments  transported  by  cars,  lorries,  buses  and 
planes. The mobile unit can be deployed throughout the country supporting enforcement units. Crossborder 
cooperation will be enhanced mainly with  Germany and Poland. Results and best  practices will be shared 
with the Customs Detection Technology Project Group to enhance international cooperation. 

Technical  assistance  implementation  reports  submitted  describe  the  results  obtained  after  12  months  of 
using purchased equipment. These provide a better overview and understanding of the long 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. In 2019, 
fourteen  implementation  reports  were  received  for  grants  awarded  under  the  annual  budgets  of  2015  and 
2016. 

The Customs Administration of the Republic of Croatia reported on the outcomes from the purchase of a 
mobile x-ray scanner mainly used in the port of Rijeka and the surrounding motorway and border crossing. 
The  equipment  aims  to  strengthen  its  operational  and  technical  capacity  to  detect  smuggled  and 
counterfeited goods, in particular cigarettes and tobacco, imported into the European Union resulting in the 
evasion  of  VAT,  customs  duties  and  excise  taxes.  The  scanner  has  improved  the  efficiency  of  customs 
controls resulting in significant seizures including more than 3 million cigarettes.  The beneficiary reported 
overall in the 12-month period, a collection of EUR 590 000 in import duties, evaded VAT and excise taxes 
and penalties. 

The Maritime Unit of Border Guard in Gdansk, Poland reported on the results of its purchase of mobile 
x-ray  scanners  type  ‘Mini-Z’.  These  devices  improved  detection  ability  during  checks  on  cargo  ships, 
fishing vessels  and other watercraft. The portable size of the scanners permits  effective  controls  in  closed 
and inaccessible spaces. The gathering of evidence for criminal proceedings has also improved. The report 
outlines  various  controls  carried  out  on  passenger  cars,  merchant  vessels  and  recreational  vehicles.  33 
maritime  border  guard  officers  were  trained  and  certified  and  a  further  24  officers  from  Szinoujscie  and 

16 

 
 
 
 
 
Elblag were trained. Cigarette seizures amount to 7 420 pieces and 768 packs during the reporting period; 
other seized items including ammunition were also reported.   

The purchase of technical updates for an Automated Number Plate Recognition System (ANPRS) for nine 
patrol cars for the Customs Department of the Ministry of Finance of Lithuania has led to 60 pre-trial 
investigations  involving  the  smuggling  of  cigarettes.  The  replacement  of  computers  for  the  system  has 
improved  its  funtioning  and  data  flow,  and  is  now  linked  to  a  system  used  by  the  Polish  customs.  The 
system is also integrated with those of the Baltic countries. 19 stationary ANPRS check points operate at the 
borders with Lithuania, 7 internal and 12 external. 16 workplaces were were upgraded and 1 400 users have 
been trained to analyse the data stored. This integrated  system enables data exchange among the 75 regional 
check points installed at the external borders with Russia, Belorussia and Ukraine. The reporting period of 
2018 – first quarter of 2019 indicates that 170 million cigarettes were seized for a value of EUR 26 million, 
or EUR 19.5 million in losses to the national budget.  

Examples of procured access to external databases   

The  Commission  procured  access  to  external  databases  for  use  by  law  enforcement  authorities  of  the 
Member  States.  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 controls. 

The  Member  State  customs  services  use  a  commercial  database  of  worldwide  trade  statistics  to  analyse 
trade  flows  (imports  and  exports)  as  part  of  a  risk  analysis  system.  In  general,  Member  States  use  the 
database for strategic and/or initial analysis to gain an overview of the movement of goods at a world level 
and focus on specific goods or countries of interest. This enables them to decide what action to take in cases 
of suspicion of potential customs fraud. 

Specifically, it has been used primarily to assist identification of traffic diversions or transhipment of goods, 
which are being moved via an intermediate third country to disguise the real origin of goods imported into 
the EU, usually to avoid anti-dumping duty or to evade a prohibition/restriction. In addition, it provides the 
basis to cross-check information on exports from third countries with information on imports into a Member 
State from other sources.  

These statistics are used to compare values leading to the identification of possible undervaluation of goods 
to avoid or diminish import duties. Customs services consult the database to create risk profiles for specific 
countries/products.  Preparatory  analyses  for  a  recent  joint  customs  operation  were  conducted  using  this 
database.  

Member States' customs authorities use a database on vessel information and movements, in combination 
with other databases, to support risk analysis and targeting of commercial vessel traffic. It is regularly used 
to  check  the  actual  routes  of  vessels  in  order  to  cross-verify  the  origin  of  the  goods  in  containers,  for 
instance, when fraud is detected in anti-dumping and/or countervailing duties evasion. The database is also 
used in  the customs clearance phase in  order to  detect  potentially suspicious cases of import transactions. 
Moreover,  the  database  was  used  for  monitoring  vessels  transporting  cargo  containers  directed  to  the  EU 
customs territory for risky shipments, including smuggling of tobacco products. 

17 

 
 
 
 
 
A  database  with  information  on  companies  has  also  contributed  to  investigations  led  by  Member  States' 
customs authorities related to  fraud affecting the financial interests of the EU.  In one instance, a Member 
State customs service was able to perform a mapping of companies and their managers within the country 
and  abroad,  by  querying  the  database  to  obtain  information  to  expand  fraud  risk  analysis  capabilities, 
formulating  new  profiles  to  target  controls.  In  another  instance,  searches  were  run  on  a  company's 
shareholders to determine whether company's imports were the result of an intra-group sale and to analyse 
risks of undervaluation.  This  database was also  used to  investigate a case of international  tax evasion  and 
unlawful  capital  transfers  to  tax  havens.  Furthermore,  with  the  help  of  the  database,  it  was  possible  to 
establish  potential  customs  debt  for  suspected  import  consignments  using  customs  procedure  42  (which 
allows  importers  to  obtain  a  VAT  import  exemption,  when  goods  imported  from  outside  the  EU into  one 
Member State are subsequently transported to another Member State) to evade customs duties and VAT. 

Examples of operational results obtained from the use of the Automated Monitoring Tool, the Data Analysis 
project and the Tobacco analyses laboratory (developed with the Joint Research Centre). 

The  Automated  Monitoring  Tool  (AMT)  is  an  IT  tool  developed  by  the  JRC  and  available  to  Member 
States’ customs services. The AMT can be used to determine the risk thresholds for customs value. Several 
Member States use these estimates and the related price anomalies of specific products or origins, for their 
integration in the national risk profile systems, in some cases by combining estimates of EU average product 
prices  with  the  results  of  their  customs  controls.  It  is  used  in  the  detection  of  undervaluation  of  imported 
goods, especially textiles and footwear. 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,  excises  and  VAT.  The  use  of  the  AMT  tool  has  considerably  increased  in  2019:  the  tool  received 
more than 80 000 data queries from almost 600 customs officers. 

The  AMT  tool  is  also  used  in  support  of  joint  customs  operations:  for  example,  a  recent  operation  was 
conducted  by  customs  authorities  of  25  Member  States  and  OLAF  covering  a  wide  range  of  textiles  and 
footwear goods and other goods imported from one third country in the EU. The operation is on-going and 
results will be reported later this year. 

Two Member States are carrying out pilot activities with the JRC, as an extension of the AMT tool, using 
the Newcomb-Benford’s law analysis on traders in annual audit plans, to improve the quality of results and 
the definition of the risk profiles. The research relies on the application of the Benford law which uses the 
observation of the distribution of the first digits of numbers in large databases with customs declarations to 
detect  suspicious  traders.  The  approach  mainly  aims  at  the  detection  of  serial  fraudsters,  for  which 
information  accumulates  in  the  corresponding  transaction  records.  The  findings  from  the  application  of 
Benford’s  methodology  can  be  the  basis  for  further  investigative  work  if  coupled  with  additional 
information from the AMT tool or the national risk profiles. 

The INTEL4CUSTAF project  aims to provide knowledge, facilitate and support the work of customs in 
Member States for the effective and efficient use of data and analytical approaches in the area of customs 
anti-fraud.  The  project  has  created  an  EU  community  in  the  field  of  customs  anti-fraud  data  analysis 
(totalling 150 members from Member States and the Commission).  

In 2019, five pilots of INTEL4CUSTAF brought together 44 experts from 18 Member States and colleagues 
from  JRC  and  OLAF.    The  objective  of  the  pilot  project  on  undervaluation  aimed  to  investigate  the 
potential for signal  generation, bringing together the results generated by the Automated Monitoring Tool 
(AMT) with those from customs controls performed by the Member States. It revealed variations among the 
approaches  followed  by  Member  States  to  estimate  the  risk  thresholds  for  customs  value.  These  findings 

18 

 
 
 
generated strong interest during the 3rd INTEL4CUSTAF workshop, culminating in a proposal to continue 
this work in 2020. 

During  2019,  the  e-commerce  pilot  project  focused  on  the  detection  of  customs  sensitive  e-traders.  E-
commerce is a new priority in the fight against fraud affecting the Union budget, and this pilot is a first step 
aimed at automatically detecting importers of goods destined to be sold to individual customers through e-
commerce  platforms  and  fulfilment  centres,  with  a  high  risk  of  customs  and  tax  fraud.  Experts  from 
participating Member States discussed the definition of a customs sensitive e-trader and shared knowledge 
and experience of typical e-commerce fraud modus operandi as well as associated customs data.  

The pilot project on misdescription of goods fraud aimed at developing a tool for the automated detection 
of  misdescribed  commodity  codes  as  declared  when  goods  are  imported  into  the  EU.  The  tool,  based  on 
national methods, provides the flexibility to perform analysis at country and EU level, thus helping to fight 
transnational customs fraud.  A proto-type open-source analytical software was developed and is available 
for further testing. The project analysed about 130 000 declarations and generated 2 000 signals of potential 
fraud.  

The  aim  of  the  container  weight  pilot  was  to  study  the  feasibility  of  using  a  statistics  model  for  the 
prediction of an estimated container weight. Comparing differences between this estimated weight, the real 
weight (as measured before loading) and the declared weight could potentially identify fraud such as under 
or  over-valuation  and  wrong  description  of  goods.  Testing  of  this  innovative  idea  during  2019  was 
hampered  by  problems  in  obtaining  good  quality  data.  However,  several  Member  States  stated  that  they 
should  be  able  to  provide  the  required  information  and  many  supported  the  continuation  of  this  novel 
analysis in 2020. 

A  further  pilot  project  built  on  the  work  started  in  2018,  to  develop  a  search  case  for  the  automated 
monitoring and sharing of international on-line media for reporting illicit tobacco cases, using the existing 
Europe  Media  Monitor  (EMM)  tool.  Drawing  on  the  wider  INTEL4CUSTAF  community,  350  new, 
customs-relevant,  sources  of  information  and  many  new  key  words/phrases  were  added  to  cover  the 
emerging fraud area of water-pipe tobacco. This pilot generated a new proposal: to test the application of 
text mining for the validation of commodity descriptions in customs declarations.  

The laboratory for testing tobacco (TOBLAB) at the JRC-Geel facility has been operational since April 
2016  and  is  regularly  used  by  Member  States'  customs  services  and  OLAF.  The  laboratory  carries  out 
analyses on samples of seized cigarettes and tobacco to identify the geographical origin of tobacco. On the 
basis of the results obtained it is possible to identify the origin, the producer and commercial brands. The 
analytical  methods  applied  allow  the  identification  of  counterfeit  tobacco  products  and  can  contribute  to 
forensic  investigations  aiming  to,  for  example,  dismantle  criminal  networks.  TOBLAB  aims  to  develop 
intelligence on cheap whites as well as onraw and cut tobacco. In order to provide information about the 
geographical origin of seized raw tobacco, TOBLAB aims to construct a repository of raw tobacco grown 
in Europe including different production regions and varieties in a region.  

The  JRC  maintains  and  updates  a  database  with  information  on  the  chemical  composition  and  origin  of 
seized smuggled and counterfeit tobacco and tobacco products submitted by the customs services. In 2019, 
115  samples  of  seized  cigarettes,  raw  and  fine  cut  tobacco  were  analysed.  It  was  possible  to  identify 
cigarettes  that  had  been  smuggled  into  the  European  market  and  to  establish  connections  between  raw 
tobacco,  fine  cut  tobacco  and  cheap  white  cigarettes  seized  in  different  places  and  at  different  moments 
within the EU, by connecting seizures to each other. The information obtained from the analyses allowed 
tobacco investigators to share intelligence on on-going investigations. 

A repository of commercially available cigarettes purchased at licensed tobacconists across the world and 

19 

 
 
 
of cheap whites is maintained by JRC for building statistical discrimination models.  

The 5th annual workshop with representatives of national customs laboratories and enforcement staff from 
14  Member  States,  held  in  JRC-Geel  in  2019,  facilitated  knowledge  sharing  and  cooperation  between 
Member State experts and the Commission.   

3.4  Operational  objective  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 counterfeiting25    

Several actions contributed to achieving this objective in 2019. 

The Foundation Lelio and Lisli Basso (Italy) organised a two-day international conference on the EPPO in 
Rome  (Italy)  attended  by  73  EU  legal  practitioners  coming  from  14  EU  Member  States.  The  participants 
were  judges,  public  prosecutors,  lawyers,  law  students  and  other  relevant  stakeholders  at  EU  and  Italian 
level and representatives of the Network of Associations for European Criminal Law and for the Protection 
of the EU’s Financial Interests. 

The  project  aimed  to  improve  knowledge  of  the  EPPO  Regulation  in  conjuction  with  national  law  and 
identify  and  discuss  possible  solutions  and  working  methods  to  overcome  aspects  that  may  hinder  the 
operational set up of the EPPO.  

The action contributed to: 

-  Improving the knowledge of the interaction between the EPPO Regulation and national law; 

- Better understanding the conditions for a smooth operational set up of the EPPO; 

- Acquiring qualifications and skills by strengthening awareness of the EU and national policy makers on the 
problems that may hinder the operational set up of the EPPO;  

-  Improving  the  understanding  of  the  practical  implications  that  the  governance  system  of  the  EPPO,  in 
particular, the establishment of European Delegated Prosecutors, may entail in national contexts. 

In  close  cooperation  with  the  Commission  Directorates-General  for  Taxation  and  Customs  Union  and  for 
Climate Action, OLAF organised a Conference on the fight against illegal imports of refrigerant gases 
into the EU for 64 participants from the EU industry, experts from the national customs administrations and 
from the Ministries of Environment in Brussels (Belgium). The participants came from 27 Member States,  

This conference was in the context of one of the key priorities of the new Commission - making Europe the 
first climate neutral continent by 2050, the “European Green Deal”. It addressed the cross-border fraud and 
raised  the  need  of  customs  and  environmental  authorities,  as  well  as  industry,  to  work  together,  with  the 
support of the European Commission. 

The main attained objectives of the conference were:  

-  To  share  experience  and  strengthen  the  exchange  of  information  among  customs  authorities  and  the 
competent environmental authorities; 

- To gather information from industry and other stakeholders that could help fighting against illegal imports 
of refrigerant gases into the EU. 

The  representatives  from  the  private  sector  provided  a  threat  assessment  in  their  respective  domains.  In 
addition, the participants discussed the following three topics during the break-out sessions:  

25  

Article 5(d) of Regulation 250/2014. 

20 

 
 
 
 
                                                 
- The significant increase of illegal traffic of water pipe tobacco; 

- The implementation of the traceability system of tobacco deriving from the Tobacco Products Directive, at 
national level; 

- The added-value of OLAF. 

The  conference  contributed  to  the  development  of  activities  at  both  Union  and  Member  States’  level  to 
counter counterfeit and banned refrigerant gas, and should lead to increasing transnational cooperation and 
coordination.  

The  24th  Task  Group  Cigarettes  Conference  organised  by  OLAF  brought  together  99  participants  from 
Member States, candidate and third countries in Zagreb (Croatia) in September 2019.  

Its main achievements were to:  

- 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; 

-  Illustrate best  practices and results obtained by OLAF in  the fight  against smuggling and other tobacco-
related offences, as a result of its investigative and coordination work; 

- Deepen the analysis of the most salient investigative issues in the field of the fight against illicit trafficking 
and production of cigarettes and tobacco; 

- Provide Member States with an updated situation of the cigarette smuggling phenomenon in the EU. 

3.5  Operational objective 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 
analysis26     

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

University  of  Luxembourg  received  a  grant  under  the  “Legal  training  and  studies”  call  for  proposals  to 
conduct  a  comparative  research  titled  “Admissibility  of  OLAF  final  reports  as  evidence  in  criminal 
proceedings”.  The  project  compared  the  national  approaches  to  the  admissibility  as  evidence  of 
administrative reports, in particular OLAF's, in criminal cases. It also looked at the topic from a wider EU 
perspective - by discussing relevant European standards and principles.  

The  project  produced  a  set  of  policy  recommendations,  as  well  as  seven  national  reports  of  participant 
Member  States  (Germany,  France,  Hungary,  Italy,  Luxembourg,  Netherlands,  and  United  Kingdom),  two 
transversal  reports  ("EU  administrative  investigations  and  the  use  of  their  results  as  evidence  in  national 
punitive proceedings" and "Lawful and fair use of evidence from a European Human Rights perspective"), 
and one comparative report.  

The impact of the project can be summarised as follows: 

-  Increasing  knowledge  and  awareness  of  rules,  procedures,  and  problems  related  to  the  admissibility  of 
OLAF reports in national proceedings; 

-  Encouraging  both  national  authorities  and  OLAF  to  develop  virtuous  practices  to  ensure  that  OLAF 
investigations  and  their  outcomes  are  duly  valued  and  taken  into  account  by  domestic  law  enforcement 
authorities and courts; 

26  

Article 5(e) of Regulation 250/2014. 

21 

 
 
 
 
                                                 
- Considering the OLAF-EPPO relationship and its impact on the admissibility of OLAF collected evidence. 

included 

the  project's  outputs  are 

free-access  version  made  available: 
All 
(https://orbilu.uni.lu/bitstream/10993/40141/1/ADCRIM_final_report.pdf).  The 
results  were  widely 
disseminated  through  the  online  platform  of  the  University  of  Luxembourg  (Open  Repository  and 
Bibliography  Platform:  http://orbilu.uni.lu/),  the  website  and  the  social  media  accounts  of  the  Faculty  of 
Law,  Economics  and  Finance  (https://wwwen.uni.lu/fdef),  as  well  as  presented  in  various  conferences  and 
events. 

in  an  online 

The  Programme  continued  funding  the  publication  of  “eucrim  –  The  European  Criminal  Law 
Associations’ Forum", which was published in four issues during 2019 by the German Max Planck Institute 
in  Germany.  The  periodical  addressed  current  developments  in  the  European  criminal  law,  such  as  the 
implementation of the European Public Prosecutor Office, the Commission’s new anti-fraud strategy, or the 
EU judicial cooperation with third countries. Each issue was printed in two thousands copies and distributed 
to  universities,  libraries,  courts,  law  enforcement  authorities  and  individual  subscribers.  The  articles  were 
also published on the internet, free of charge27.  

The  Romanian  National  Anticorruption  Directorate  received  funding  for  the  project  “Promoting  the 
protection  of  the  financial  interests  of  the  EU  by  supporting  the  actions  of  the  Member  States  and  the 
European institutions in the transition towards the EPPO”, aimed to support to Romania and other Member 
States in the process of preparing the transition to a functional EPPO. The project included a study analysing 
the impact of the future EPPO on the Romanian judicial system, a national workshop (Bucharest, November 
2018)  and  a  European  conference  (Bucharest,  December  2018)  on  the  relation  between  the  national 
prosecutorial  systems  and  the  EPPO  and  between  the  national  authorities  and  OLAF,  EUROJUST  and 
EPPO. A hundred professionals from EU national prosecution offices, judges and academics, members of the 
Network  of  Associations  for  European  Criminal  Law  and  the  Protection  of  the  Financial  Interests  of  the 
European Union, as well as representatives of OLAF and EUROJUST, participated in the final event, sharing 
experiences,  challenges  and  solutions  on  how  the  national  systems  should  prepare  themselves  for  the 
establishment  of  the  EPPO.  The  study  and  conference  results  were  disseminated  among  the  professionals 
from 23 Member States participating in the closing event. 

4. 

Communication  

The  successful  implementation  of  the  programme  required  a  structured  approach  to  inform  potential 
beneficiaries on funding opportunities. The Commission also disseminates information on the achievements 
and the results of the actions that received funding.28 

4.1 

Informing potential applicants 

The full texts of the calls' documents were made available on the Commission's Funding & Tenders portal 
and notices concerning the launch of calls for proposals were published in the Official Journal29 as well as 
on  the  Commission's  website30.  Professional  networks  were  actively  informed.  Potential  applicants  were 

27  
28  

29  
30  

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”.   
OJ C 111 of 25.3.2019. 
http://ec.europa.eu/anti-fraud/policy/hercule_en  

22 

 
 
 
 
 
                                                 
also  informed  via  emails  sent  to  the  members  of  the  Advisory  Committee  for  the  Coordination  of  Fraud 
Prevention  (COCOLAF),  to  the  Anti-fraud  coordination  services  (AFCOS)  and  to  the  Network  of 
Asociations  for  European  Criminal  Law  Associations  and  the  Protection  of  the  Financial  Interests  of  the 
European Union.   

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  recorded  event(s)  and  the  projects'  outputs  on  their 
websites or created dedicated websites in order to disseminate results and conclusions. The dissemination of 
the results of projects 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, 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  551  participants  attended  Hercule  training  events  in  2019.  The  Commission  received  1  095 
completed  questionnaires  (71%  response  rate),  most  of  which  indicated  a  high  level  of  satisfaction.  The 
feedback received was overwhelmingly positive, with nearly 99% of the participants assessing the events as 
“excellent”  or  “good”  .  Participants  particularly  appreciated  the  events  having  a  practical  impact  on  their 
daily  work.  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. 

A "post-event" survey of participants is requested six months after the implementation of a project in order 
to assess its mid-term impact. In 2019, the Commission has received seven ‘post-event’ surveys for training, 
conferences or staff exchange projects. In general, the number of participants who participate in post-event 
surveys six months after an event is lower than the number of those completing event evaluation forms.  

From  the  2019  surveys,  92%  of  participants  consider  that  the  actions  had  a  practical  impact  (increased 
knowledge,  skills,  practice  and  efficiency)  on  their  professional  activities.  90%  of  the  participants 
considered that the actions contributed to the objectives of the Hercule Programme. It must noted that 86% 
of the participants shared the information received during the event with their colleagues. However, in the 
six months following an event only half the participants have reported, treated, investigated or sentenced an 
illegal activity affecting the financial interests of the EU. Finally, the majority of participants are interested 
in their organisation’s submission of a proposal for one of the future Hercule Programme calls for proposals. 

23 

 
 
 
 
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  projects  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 Programme's relevance is supported also by the findings of the mid-term evaluation that was carried out 
in  2017.  The  stakeholders  reported  that  the  Programme  has  been  efficiently  implemented  and  that  it 
effectively  addresses  Member  States'  needs.  The  Commision  is  launching  the  final  evaluation  of  the 
programme in 2020, for completion at the end of 2021. The programme’s effectiveneness, efficiency, added 
value and sustainability will be assessed, now on the basis of results of the programme’s whole duration. 

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 Programme under the Mukti-
Annual  Financial  Framework  2021-2027  (MFF).  The  legislative  procedure  is  on-going.  The  proposal 
combines two types of spending activities: 

- 

- 

a classic spending 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  operational  activities  in  the 
area  of  mutual  administrative  assistance  between  Member  States’  customs  authorities,  and  the 
Irregularity Management System (IMS), an IT tool 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  merger  will  allow  the  achievement  of  operational,  budgetary  and  administrative  synergies  as  well  as 
increased resources’ flexibility, in view of specific needs that may arise during the period of application of 
the new MFF. The strand of the new programme that will continue Hercule III will build on the successes of 
the  current  programme,  and  the  learnings  from  the  completed  mid-term  evaluation  and  the  future  final 
evaluation. 

24 

 
 
 
 
Annex 1: Grants and contracts awarded and finalised under the 2019 Financing Decision 

Table 1 – TECHNICAL ASSISTANCE grants AWARDED under the 2019 Financing Decision  

  MS 

Beneficiary 

Title and description 

Awarded grant 
(EUR) 

Co-fin 
% 

1  BE 

Service 
Finances 

Public 

Federal 

Purchase,  installation  and  maintenance  of  one 
mobile backscatter vehicle 

2  HR  Ministry of Finance 

Mobile  backscatter  cargo  and  vehicle  screening 
system  

3  CZ 

Customs  Administration  of 
the Czech Republic  

A  mobile  X-ray  unit  for  detection  of  smuggled 
and/or  counterfeited  goods 
in 
luggage and parcels through aerodromes 

transported 

930 441 

80 

873 600 

70 

252 000 

80 

4 

IE  The Revenue Commissioner  Procurement of mobile x-ray container scanner 

1 734 720 

80 

5 

IT 

Ministry  of  Economy  and 
Finance/Guardia di Finanza 

Purchase  of  1  MINI-Class  Aircraft  System  for 
the  fight  against  counterfeiting  and  smuggling 
tobacco products 

635 383 

70 

6 

IT 

Ministry  of  Economy  and 
Finance/Italian AFCOS 

Anti-fraud Integrated Platform 

501 672 

80 

7  LV  State Revenue Service 

Development  of  Automated  Number  Plate 
Recognition System (ANPRS) 

1 793 039 

80 

8  LV  National Forensic Bureau 

forensic 
Operational  capacity  building  of 
examination  of  tobacco  and  other  plant-based 
substances 

407 821 

80 

Purchase of investigation tools 

102 818 

80 

9 

LT 

Crime 
Financial 
Investigation  Service  under 
the Ministry of the Interior 

10  PL  National Tax Administration 

a 

for 
technical 
Purchase  of 
Department  for  Combating  Economic  Crime  of 
National Revenue Administration 

equipment 

11  PL 

Tax 
Chamber in Lublin 

Administration 

the  operational  capacity  of 
Strengthening 
Mobile  Control  Units  in  combating  cigarettes 
smuggling  and  financial  fraud  at  EU  Eastern 
border – Purchase of a mobile scanner 

305 215 

80 

1 090 379 

80 

12  RO 

The  National  Anticorruption 
Directorate 

Supporting 
National  Anticorruption  Directorate 
investigating frauds against the EU funds 

the  operational  capacity  of  the 
in 

474 109 

80 

13  SK 

Financial  Directorate  of  the 
Slovak Republic 

Improving  customs  surveillance  and 
facilitation at the border crossing points  

trade 

1 800 000 

80 

TOTAL 

10 901 199 

78.5 

25 

 
 
 
 
 
 
Table 2 – TECHNICAL ASSISTANCE grants FINALISED in 2019 

MS 

Beneficiary 

Title 

Amount paid 
(EUR) 

Amount 
paid as 
% to 
initial 
commit-
ment31 

1 

LT 

Border 

State 
Service 
Ministry of the Interior 

under 

Guard 
the 

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

79 016 

100 

2 

SI  Ministry of the Interior 

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

324 899 

71 

3 

LT 

Customs Criminal Service 

Development of Criminal Intelligence Technical 
Tools 

483 347 

100 

4 

RO 

for 

Directorate 
Investigation 
Organized  Crime 
Terrorism  

the 
of 
and 

Improved  special 
in 
tackling  high-profile OCG smuggling at the EU 
Eastern border  

investigation  methods 

398 893 

95 

5 

RO 

Brasov  County  Police 
Inspectorate 

Fraud  investigation  in  Brasov  County  with 
digital forensic hard and software 

103 484 

98 

6 

LT 

Crime 
Financial 
Investigation 
Service 
under  the  Ministry  of  the 
Interior 

Procurement of intelligence equipment 

80 393 

78 

7 

CZ 

Customs  Administration 
of the Czech Republic 

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

246 278 

100 

8 

RO 

The 
Anticorruption 
Directorate 

National 

the  Capacity  of 

Improving 
the  National 
Anticorruption Directorate in investigating fraud 
and  corruption  detrimental  to  the  financial 
interests of the EU 

9 

PL 

Provincial 
Headquarters in Olsztyn 

Police 

Improving  the  effectiveness  of  detection  and 
combating 
tobacco  crime,  corruption  and 
financial  fraud  to  the  detriment  of  the  EU  by 
equipping  the  Warmian-Masurian  Police  with  a 

252 604 

97 

458 956 

99 

31  

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

26 

 
 
 
 
 
 
 
 
                                                 
mobile intelligence centre 

10 

RO 

National  Agency 
Fiscal Administration 

for 

the 

Increasing 
in 
preventing  and  combating  smuggling  and 
customs fraud  

role  of  mobile 

teams 

220 067 

69 

11 

IE 

The 
Commissioners 

Revenue 

Procurement  of  mobile  back  scatter  X-Ray 
scanning van 

515 057 

100 

12 

RO 

Anticorruption  General 
Directorate 

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

101 939 

88 

13 

LV  National Forensic Bureau 

Operational  capacity  building  of  the  forensic 
document examination 

557 078 

99 

14 

NL 

The  National  Police  Of 
The Netherlands 

Innovative  Self  Healing  Operational 

TSO 
Network 

445 912 

97 

TOTAL 

4 267 928 

Table 3 – DATABASES that were CONTRACTED under the Hercule III budget in 2019 

1 

2 

3 

Name 

Content 

IHS Maritime Portal 

Information on ship movements 

GTA 

ORBIS 

Trade statistics data 

Basic company information and financial details of companies all 
over the world 

Total committed under the 2019 budget  

Commitment in 
Euro 

227 554  

188 888 

250 000 

666 442 

Table 4 – ANTI-FRAUD TRAINING & CONFERENCES grants AWARDED under the 2019 Financing Decision 

MS 

Beneficiary 

Title 

1 

LT 

Special  Investigation  Service 
of the Republic of Lithuania  

Strengthening 
law  enforcement  analytical 
capacities in Big Data Analysis to prevent and 
detect  fraud  and  corruption  affecting  EU 
financial interests 

Awarded 
grant (EUR) 

Co-fin 
% 

38 140 

80 

2 

IT 

Court  of  Auditors/ 
AFCOS 

Italian 

Cooperation  Agreements  and  Training  on 
Objectives and New Experiences 

63 314 

80 

27 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
3 

IT 

European  Institute  for  Socio-
Development 
Economic 
Association 

European  Neighbourhood  Policy  &  EU 
enlargement training & cooperation 

56 737 

80 

4 

RO 

the 
Directorate 
Investigation  of  Organized 
Crime and Terrorism  

for 

Developing the working procedures and skills 
regarding 
of  prosecutors  and  specialists 
special 
techniques  and  data 
extraction  and  analysis  through  exchange  of 
staff  and  training  with  other  EU  border 
countries. 

investigation 

36 709 

80 

5 

IT 

Customs agency 

E-commerce  tools  and    potential  risks  for 
customs fraud 

101 952 

80 

6 

LT 

Financial  Crime  Investigation 
Service  under  the  Ministry  of 
the Interior 

Training course towards more effective cross-
border cooperation against fraud affecting the 
financial interests 

39 292 

80 

7 

8 

PL 

National Tax Administration 

Mutual  actions  to  fight  frauds  in  order  to 
protect EU financial interests 

54 017 

80 

HU 

Transparency 
Hungary 

International 

New  European 
in 
Hungary: challenges and missed opportunities 

landscape 

antifraud 

9 

RO 

Dolj 
Inspectorate 

County 

Police 

Raising  awareness  and  improving  working 
methods  of  the  actors  involved  in  the  fight 
intra-Community 
trough 
against 
acquisitions affecting the EU budget 

fraud 

57 306 

80 

81 683 

80 

10 

SK 

Financial  Directorate  of  the 
Slovak Republic 

Training  focused  on  fight  against  VAT  fraud 
for goods imported into the EU 

75 899 

80 

TOTAL 

605 056 

80 

Table 5 – Anti-Fraud procured confereces organised by the Commission under the 2019 Financing Decision 

Dates 

Conference title 

Location 

N° of 
participa
nts 

Amount 
paid EUR 

19-21 June 2019 

PIF  :  Cooperation  between  OLAF,  law  enforcement 
and prosecution services 

La Hulpe  

158 

147 141 

9-12 September 2019 

24th Task Group Cigarettes (TGC) 

Zagreb 

16 September 2019 

Workshop  on  the  Future  of  the  Network  of  PIF 
Associations 

Brussels 

18-20 September 2019 

AFCOS Seminar 2019 

26-27 September 2019 

JCO HYGIEA-Debriefing Meeting 

Skopje 

Rome 

99 

31 

85 

43 

40 914 

33 361*  

33 434 

41 588 

28 

 
 
 
 
 
 
 
10-11 October 2019 

Briefing and training - JCO SNAKE II  

Brussels 

14-15 November 2019 

High Level Conference on Customs Challenges in the 
Antifraud Area 

Helsinki 

45 

87 

88 067* 

94 805 

19 November 2019 

Pilot  project  related  to  Transhipment  fraud  on 
dangerous goods 

Bangkok 

15 

23 548 

23-24 January 2020 

Fight  against  the  smuggling  of  Refrigerant  Gas, 
including counterfeit & banned products, in the EU 

Brussels 

81 

67 298 

*  Amount  committed,  as  no  final  invoices  were  received  at  the 
date of publication of this document 

TOTAL 

644 

448 731 

Table 6 – ANTI-FRAUD TRAINING & CONFERENCES grants FINALISED in 2019 

1. 

 MS 

Beneficiary 

Title 

Amount paid 
(EUR) 

Amount 
paid as 
% to 
initial 
commit-
ment32 

1 

CZ 

Transparency 
International 
Republic 

-  Czech 

Clean contraction in the European Funds 

32 129  

72 

strengthening 

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

of 

in 

47 201  

71 

Cooperation Project 2 

80 943 

84 

2 

HR  Ministry of Finance 

3 

IT 

Ministry  of  Economy 
and  Finance/Guardia  di 
Finanza/Italian AFCOS 

4 

IT 

Foundation  Lelio  E  Lisli 
Basso 

Conference 
International 
Cooperation for the Establishment of the EPPO. 

Enhanced 

on 

5 

IT 

European  Institute  For 
Socio-Economic 
Development 
Association 

EU  Funded  actions:  detecting,  handling,  and 
learning  how  to  prevent  frauds  and  irregularities 
in  international  cooperation  and  development 
projects (IPA and ENI) 

56 607 

87 

78 778 

86 

6 

IT 

Veneto  Agency 
Agricultural Payments 

For 

Strengthening 
procurement 

actions 

to 

fight 

fraud 

in 

67 994 

99 

7 

HU 

National 
Customs 

Tax 

and 

Anti-cigarette smuggling staff exchange program 

45 237 

53 

32  

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

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

29 

 
 
 
                                                 
8 

HU 

Transparency 
International - Hungary 

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

38 055 

94 

9 

RO 

National  Agency 
Fiscal Administration 

for 

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

10  RO 

Legal  Resources  Centre 
Foundation 

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

11  RO 

Alexandru 
Police Academy 

Ioan  Cuza 

12  RO 

The Romanian Branch of 
the  Freedom  House  Inc. 
Foundation 

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

fraud 

and 

Enhancing  the  legal  protection  for  EU  financial 
interests in Romania 

44 327  

59 

TOTAL 

593 538 

73 

40 605 

68 

48 368 

60 

13 289 

38 

Table 7 – LEGAL TRAINING & STUDIES grants AWARDED under the 2019 Financing Decision 

MS 

Beneficiary 

Title 

Awarded Grant 
(EUR) 

Co-fin 
% 

1 

DE  Max-Planck Institute 

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

157 161 

80 

2 

DE 

European  Academy  of 
Law 
Public 
Trier 
Foundation 

Transposition 
consequences on the effectiveness of the EPPO 

of  PIF  Directive 

and 

its 

39 892 

80 

3 

ES 

University of Burgos 

Toolkit  for  the  prevention  of  frauds  in  European 
funds with special attention to ERDF and CF 

79 033 

90 

4 

IT 

University of Perugia 

Administrative  prevention  through  targeted  anti-
corruption models for candidate countries 

72 491 

80 

5 

UK 

Coventry University 

VAT  fraud:  interdisciplinary  research  on  tax 
crimes in the European Union 

83 498 

80 

TOTAL 

432 075 

82 

Table 8 – LEGAL TRAINING & STUDIES grants FINALISED in 2019 

30 

 
 
 
 
 
 
 
 
 
 
 
MS 

Beneficiary 

Title 

1 

NL  University of Utrecht 

2 

DE 

European Law Academy  

OLAF and the EPPO in the new institutional 
setting  for  the  protection  of  the  financial 
interests of the EU 

Understanding  each  step  of  the  “anti-fraud 
cycle”:  prevention,  detection,  investigation, 
sanctioning  and  recovery  to  combat  the 
irregularities affecting the financial interests 
of the European Union 

Amount paid 
(EUR) 

Amount 
paid as 
% to 
initial 
commit-
ment33 

23 806 

59 

25 184 

60 

3 

IT 

University of Modena  

Europe Against Cyber VAT Frauds 

66 323  

100 

4 

HU  University of Miskolc 

5 

RO 

The  National  Anticorruption 
Directorate 

Criminal  law  protection  of  the  financial 
interests  of  the  EU  –  Focusing  on  money 
laundering,  tax  fraud,  corruption  and  on 
criminal  compliance  in  the  national  legal 
systems with reference to cybercrime 

Promoting  the  protection  of  the  financial 
interests of the EU by supporting the actions 
of  the  member  states  and  the  European 
institutions  in  the  transition  towards  the 
EPPO 

56 985 

77 

35 785 

55 

6 

LU  University of Luxembourg 

Admissibility  of  OLAF  final  reports  as 
evidence in criminal proceedings 

58 496 

75 

7 

RO 

“Alexandru Ioan Cuza” Police 
Academy 

Developing  the  capacity  to  prevent  and 
investigate  situations  of  incompatibility  and 
conflict  of  interest  affecting  the  financial 
interests of the European Union 

22 799 

54 

TOTAL 

289 378 

71 

33  

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

31 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Table 9 – GLOBAL OVERVIEW per country of awarded grants and rejected applications in 2019 

Number of 
applications 
received 

Number of 
awarded 
grants 

Grants requested 
(EUR) 

Grants awarded 

(EUR) 

TECHNICAL ASSISTANCE 2019 

43 

13 

36 003 542  

10 901 200 

Belgium 

Bulgaria 

Croatia 

Czech Republic 

Finland 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Malta 

Poland 

Romania 

Slovakia 

Spain 

2 

2 

2 

1 

1 

3 

2 

1 

2 

7 

3 

1 

6 

6 

1 

3 

1 

0 

1 

1 

0 

0 

0 

1 

2 

2 

1 

0 

2 

1 

1 

0 

1 183 440 

930 441  

873 600  

252 000  

1 055 579  

2 200 758  

269 640  

416 272  

1 780 276  

4 123 522  

1 734 720  

1 734 720  

1 353 418  

1 137 055  

3 791 837  

2 200 861  

1 319 818  

102 818  

93 600  

3 384 202  

1 395 595  

5 415 071  

474 109  

2 100 000 

1 800 000  

2 281 385  

TRAINING  &  CONFERENCES 
2019 

19 

10 

1 486 009   

605 056  

Bulgaria 

Cyprus 

Greece 

Hungary 

Italy 

Lithuania 

1 

1 

1 

2 

4 

2 

0 

0 

0 

1 

3 

2 

32 

43 266  

81 417  

203 728  

190 870  

305 201  

84 959  

57 306  

222 004  

77 433  

 
 
 
 
 
 
 
 
 
 
 
 
Malta 

Poland 

Romania 

Slovakia 

LEGAL TRAINING 2019 

Germany 

Italy 

Spain 

United Kingdom 

1 

2 

3 

2 

6 

2 

2 

1 

1 

0 

1 

2 

1 

5 

2 

1 

1 

1 

59 506  

73 387  

211 592  

232 078 

542 104  

197 096  

191 259  

70 251  

83 498  

54 017 

118 392  

75 899 

432 075  

197 053  

72 491  

79 033  

83 498  

TOTAL  

68 

28 

38 031 655 

13 814 230  

33