COMMISSION STAFF WORKING DOCUMENT Hercule III programme 2020 implementation Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL 32nd Annual Report on the protection of the European Union's financial interests - Fight against fraud - 2020
Date: 2021-09-20
Institutions: European Anti-Fraud Office, European Commission
Subjects: EU Member State, EU budget, EU strategy, activity report, coronavirus disease, epidemic, fight against crime, financial control, fraud, fraud against the EU

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 20.9.2021  SWD(2021) 257 final  COMMISSION STAFF WORKING DOCUMENT Hercule III programme 2020 implementation Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL 32nd Annual Report on the protection of the European Union's financial interests - Fight against fraud - 2020 {COM(2021) 578 final} - {SWD(2021) 258 final} - {SWD(2021) 259 final} - {SWD(2021) 262 final} - {SWD(2021) 263 final} - {SWD(2021) 264 final}  
 
 
TABLE OF CONTENTS 

1. 

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

1.1.  Hercule III programme ...................................................................................... 2 

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

1.3.  Purpose and scope of this overview .................................................................. 3 

2.  BUDGET IMPLEMENTATION IN 2020 .................................................................. 4 

2.1.  Budget implementation by type of financial intervention ................................. 4 

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

2.2.1.  Technical assistance grants .................................................................. 7 

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 .................................................................. 12 

3.  ACHIEVEMENTS 2020 ........................................................................................... 12 

3.1  Operational objective 1 .................................................................................... 13 

3.2  Operational objective 2 .................................................................................... 15 

3.3  Operational objective 3 .................................................................................... 16 

3.4  Operational objective 4 .................................................................................... 23 

3.5  Operational objective 5 .................................................................................... 25 

4.  COMMUNICATION ................................................................................................ 28 

4.1. 

Informing potential applicants ......................................................................... 28 

4.2.  Dissemination of results .................................................................................. 29 

4.3.  Visibility of EU funding .................................................................................. 29 

5.  FEEDBACK FROM PARTICIPANTS OF THE PROGRAMME ........................... 29 

6.  CONCLUSIONS AND WAY FORWARD .............................................................. 30 

ANNEX  1:  GRANTS  AND  CONTRACTS  AWARDED  AND  FINALISED 

UNDER THE 2020 FINANCING DECISION ......................................................... 31 

 
 
 
 
 
 
1. 

INTRODUCTION 

1.1.  Hercule III programme 

The Hercule III programme (‘the Programme’) aims 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,  and  to  research 
and  educational  institutes  and  other  non-profit-making  entities,  that  ‘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  Member  State  competent 
authorities  to  strengthen  their  operational  and  technical  capacity  to  carry  out 
investigations  into  activities  detrimental  to  EU  financial  interests.  It  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  training  and  conferences,  and  comparative  research  and 
scientific publications. 

The  legal  basis1  of  the  Programme  requires  the  Commission  to  adopt  an  annual  work 
programme2 for its implementation and to submit an annual report3 on the main results 
and achievements to the European Parliament and to the Council. This is the final annual 
overview of the Programme’s achievements and results. 

The Programme was implemented in 2020 in accordance with Regulation (EU, Euratom) 
No. 2018/10464. 

The Programme is the only instrument specifically dedicated to protecting EU financial 
interests. It 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. 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   Regulation (EU No 250/2014 of the European Parliament and of the Council of 26 February 2014, OJ 

L 84, 20.3.2014, p. 6. 

2   The  seventh  annual  work  programme  was  adopted  by  Financing  Decision  C(2020)  28  final  of  16 

January 2020.  

3   Article 13 of Regulation (EU) No 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.’  

4   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). 

5   Article 3 of Regulation (EU) No 250/2014. 

6   Article 4 of Regulation (EU) No 250/2014. 

7   Article 5 of Regulation (EU) No 250/2014. 

2 

 
                                                 
1.2.  Hercule III: eligible actions, beneficiaries and budget 

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

1. 

2. 

3. 

technical  assistance:  support  aimed  at  providing  specific  knowledge,  equipment 
and  information  technology  (IT)  tools  to  national  authorities,  and  providing 
specific databases and IT tools facilitating data access and analysis; 

training:  support  for  training  activities,  conferences,  research  studies  and 
dissemination  activities,  focused  on  the  protection  of  the  Union’s  financial 
interests; and 

any other action: other actions necessary for attaining the general, the specific and 
the operational objectives of the Programme. 

The beneficiaries9 of the Programme are eligible bodies that are: 

national or regional administrations of a Member State; or 

research and educational institutes and non-profit-making entities in Member States. 

Both types of beneficiaries are to ‘promote the strengthening of action at Union level to 
protect the financial interests of the Union’. Costs incurred for the participation of people 
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 Programme implementation in 2020 amounted to EUR 16.44 million 
in  commitment  appropriations  and  EUR 13.65 million  in  payment  appropriations.  It  is 
financed under item 24.0201 of the EU budget for 2020. 

1.3. 

Purpose and scope of this overview 

The  annual  overview  is  intended  to  fulfil  the  requirement  under  Article  13(1)  of 
Regulation (EU) No 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 2020 annual work programme (Section 2), and the results of actions that were 
finalised  in  2020,  but  for  which  commitments  were  made  under  the  Programme  in 
previous years (Section 3). 

8   Article  8  of  Regulation  (EU)  No  250/2014.  Article  8(a)  lists  seven  types  of  actions  for  technical 

assistance and Article 8(b) lists seven types of actions for training. 

9   Article 6 of Regulation (EU) No 250/2014. Article 7 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  EU  on  the  former’s  participation  in  EU 
programmes. For the duration of the Programme, no such agreement came into force.  

3 

 
                                                 
2.  BUDGET IMPLEMENTATION IN 2020 

The  budget  for  the  Programme  implementation  amounted  to  EUR 16.44 million  in 
commitment appropriations. Figure 1 gives an overview of the available budget and the 
commitments made in 2020. 

Figure 1: Available budget and commitments made in 2020 

TYPES OF ELIGIBLE ACTIONS 2020 
TECHNICAL ASSISTANCE (min. 70%) 
Grants 
Grants: Technical Assistance 

BUDGET10  COMMIT11 
11 909 290 
12 150 000 
11 200 000 
10 000 000 

IT Databases 

Procurement 

1 280 000 

419 290 

IT Tools and tobacco analysis  
ANTI-FRAUD TRAINING (max. 25%) 
Grants: Anti-fraud training 

Grants 

Procurement 

Procured conferences  

Digital Forensics and Analyst Training  

Grants: Legal Training and Studies 
OTHER ACTIONS  
TOTAL 2020 

Procurement 

Procurement 

Grants 

870 000 
4 200 000 
750 000 

1 050 000 

1 900 000 

290 000 
2 114 899 
1 120 000 

44 899 

0 

500 000 
93 100 
16 443 100 

950 000 
0 
14 024 189 

% 
98.02 
112.00 

32.76 

33.33 
50.35 
149.33 

4.28 

0 

190.00 
0 
85.29 

The information in Figure 1 relates to commitments made on the 2020 available budget. 

The exceptional pandemic circumstances of 2020 had a significant impact on the general 
implementation  of  the  Programme.  Many  procured  training  activities  and  conferences 
were  postponed  or  cancelled.  Following  a  successful  publication  and  evaluation  of  the 
2020 calls for proposals, unused amounts earmarked for procured activities in the 2020 
budget (the activities envisaged under ‘Procured conferences’ and ‘Digital Forensics and 
Analyst  Training’ were  especially  affected) were transferred to  grants,  divided between 
the three calls. This transfer of approximately 12% of the total annual budget ensured an 
efficient  implementation  of  operational  funds  and  selection  of  the  best-ranked 
applications across the three calls. 

A portion of the remaining funds available under the 2020 budget for procured activities 
will be used during the first half of 2021 by organising virtual procured activities. 

Payments  associated  with  the  grant  agreements  and  most  of  the  procurement  contracts 
signed in 2020 will be reported at a later stage, since they will be made during the course 
of 2021 and the following years. 

2.1.  Budget implementation by type of financial intervention 

The  Programme  implementation  relies  on  contracts  (for  public  procurement)  and  calls 
for  proposals  (for  grants)12.  The  Commission  concluded  contracts  for  the  purchase  of 

10   The budget corresponds to the summary table in the annual work programme 2020 as adopted by the 

Financing Decision C (2020)28 final of 16 January 2020. 

11   Commitments cover the total costs in 2020 of legal obligations (contracts, grant agreements/decisions) 

entered into for operations extending over more than one year.  

12   Article 10 of Regulation (EU) No 250/2014.  

4 

 
                                                 
specialised  services  for  the  benefit  of  Member  States,  such  as  access  to  commercial 
databases  and  the  development  of  IT  systems.  The  contracts  were  concluded  using 
existing  framework  contracts  establishing  the  terms  governing  specific  contracts  to  be 
awarded  during  a  given  period.  In  2020,  the  overall  amount  committed  for  procured 
contracts was EUR 754 189 (as shown in Figure 2). 

Grants are direct financial contributions to finance an action intended to help achieve an 
EU  policy  objective.  The  overall  budget  allocated 
in  2020  was 
EUR 13 270 000.  Following  calls  for  proposals  inviting  applicants  to  submit  proposals 
for  actions  contributing  to  the  achievement  of  the  Programme's  objectives,  grants  are 
evaluated  and  awarded.  The  beneficiary  of  a  grant  becomes  the  legal  and  economic 
owner  of  the  goods  or  services  purchased  with  grant  financing.  Under  the  Programme, 
grants  may  cover  up  to  80%  of  the  eligible  costs13  of  the  action  and  up  to  90%  in 
exceptional and duly justified cases. Due to the high number of applications received and 
the  limited  available  budget,  the  Commission  chose  not  to  award  any  90%  exceptional 
co-financing rate. All grant beneficiaries received the 80% financing for their projects. 

to  grants 

In  February  2020,  the  Commission  launched  three  calls  for  proposals:  technical 
assistance; training, conferences and staff exchange; and legal training and studies. The 
deadlines  for  submission  of  applications  were  initially  set  for  23  April,  30  April  and  7 
May,  respectively.  Following  many  requests  from  applicants,  in  view  of  their 
organisational challenges during the health crisis, the Commission extended the deadline 
for all three calls to 27 May 2020. 

The  calls  were  published  via  the  Commission's  funding  &  tenders  portal14,  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  105 
applications15. An evaluation committee assessed each application against four criteria as 
detailed  in  the  call  specifications:  eligibility;  exclusion;  selection;  and  award.  The 
applications were scored and ranked on the 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; and 

  value for money. 

The  examination  of  applications  led  to  the  award  of  53  grants16.  Table  9  of  the  Annex 
provides an overview of the successful and rejected applications, broken down by 2020 
call, Member State, grant requested and awarded. 

13   Article  10(4)  of  Regulation  (EU)  No  250/2014.  The  annual  work  programme  2020  contained  the 
criteria  as  required  under  Article  11  of  the  Regulation  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 rate of 90%.  

14  https://ec.europa.eu/info/funding-tenders/opportunities/portal/screen/home 

15   Technical assistance - 47; legal training - 21; and training, conferences and staff exchange - 37. 

16   Technical assistance - 29; legal training – 11; and training, conferences and staff exchange - 13. 

5 

 
                                                 
Figure 2 features a breakdown of the planned budget and achieved commitments in 2020 
by type of financial intervention (grants and procurement). 

Figure 2: Hercule III budget and commitments in 2020 by type of financial intervention 

2.2.  Budget implementation by type of eligible action 

Figure 3 below provides a breakdown of the planned 2020 budget and commitments by 
type  of  action.  The  technical  assistance  actions  as  provided  for  in  Regulation  (EU)  No 
250/2014  encompass technical  assistance  grant  activities and  IT support (databases and 
IT  tools).  Training  actions  include  the  grant  activities  under  the  ‘training,  conferences 
and  staff  exchanges’  and  ‘legal  training  and  studies’  calls  for  proposals,  and  procured 
conferences and specialised training. In 2020, the planned budget for technical assistance 
support  represented  74.3%  of  the  total  and  commitments  represented  84.9%.  These 
percentages exceed the minimum percentage of 70% for technical assistance stipulated in 
the Annex to the Regulation. 

Figure 3: Hercule III budget and commitments in 2020 by type of eligible action 

Figure 4 gives an overview of the 2020 budget commitments showing the total amounts 
and  number  of  grants  awarded  by  Member  State  for  technical  assistance,  anti-fraud 
training and legal training. Grants were awarded to applicants from 17 Member States. 

6 

 
 
 
Figure 4: Hercule III commitments (in EUR) and number of grants in 2020 by Member State and 
by sector of activity 

2.2.1.  Technical assistance grants 

The  budget  for  technical  assistance  grants  was  EUR 10 million.  It  was  available  for 
funding actions proposed by national and regional authorities for the following. 

1. 

2. 

3. 

4. 

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

The  purchase  and  maintenance  of  detection  devices  to  carry  out  inspections  of 
containers, trucks, railway wagons and vehicles - at the EU's external borders and 
within the Union - to detect smuggled and counterfeited goods imported into the 
EU  with  the  aim  or  consequence  to  evade  customs  and  excise  duties.  Also 
covered  was  the  purchase  and  maintenance  of  technical  equipment  for  the 
identification  of  beneficiaries  of  cash  assistance  programmes,  including  by 
biometric means, to prevent fraud and irregularities related to the use of EU funds 
in the field of migration and refugee management. 

The purchase, maintenance and interconnection of systems for the recognition of 
vehicle  number  plates  (automatic  number  plate  recognition  systems)  or 
container  codes  for  purposes  related  to  the  protection  of  EU  financial  interests, 
including specialised training needed to operate these systems. 

The  purchase  of  services  for  the  analysis,  storage  and  destruction  of  seized 
genuine  or  counterfeit  cigarettes  and  other  counterfeit  goods  detrimental  to  EU 
financial interests. 

The Commission received 47 applications from 16 Member States by the deadline of 27 
May  2020.  The  total  budget  of  the  proposed  actions  was  EUR 29.8 million  and  the 
requested  financial  support  amounted  to  EUR 24.4 million.  This  amount  exceeded  the 

7 

 
 
available budget by EUR 13.2 million. Both the Evaluation Committee recommendations 
and the decision to award grants for 29 actions were adopted in October 2020. 

for 

All  applicants  were informed of the outcome of  the evaluation procedure in  November 
2020.  The  overall  amount  approved 
technical  assistance  grants  was 
EUR 11.2 million. The exceptional health crisis led to a postponement of several planned 
procured events and offered the opportunity of additional funding for technical assistance 
grants: EUR 1.2 million was added to the budget available. Grants were awarded for the 
purchase  of  investigation  equipment  (including  forensics  equipment),  data  analysis 
systems  and  large  X-ray  scanners,  and  detection  equipment  for  customs.  The  co-
financing  percentage  for  the  awarded  grants  was  80%  of  eligible  costs17  of  the  action. 
Table 1 in Annex 1 provides an overview of the beneficiaries, project title, grant awarded 
and 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,  on  behalf  of  law 
enforcement authorities in Member States, to commercial databases 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 make a limited use of these databases18. 

Access  to  databases  for  trade  and  company  data  and  for  vessel  movements  were 
purchased in  2020 by  concluding specific contracts  under existing framework contracts 
or concluding new framework contracts as previous ones had become outdated19. Table 3 
in Annex 1 gives an overview of the contracts awarded in 2020. 

Development of specific IT tools for data analysis 

The automated monitoring tool (AMT) project for the analysis of external trade data, 
carried  out  by  the  Joint  Research  Centre  (JRC)  of  the  European  Commission  in  Ispra 
(Italy),  continued  in  2020  under  an  existing  administrative  arrangement  funded  from 
previous  years  and  lasting  until  January  2021.  AMT  is  an  algorithm  that  retrieves  and 
processes  subsets  from  Eurostat’s  COMEXT  database  and  links  this  selection  with 
information  from  customs  declarations  and  the  Commission’s  database  of  tariff 
information  (TARIC)  in  order  to  identify  patterns  and  long-term  trends  of  imports  into 
the EU. The long-term trends are expressed as average aggregated prices of imports from 
one exporting country into the EU and are further broken down by Member State. AMT 
identifies  any  import  that  deviates  substantially  from  these  long-term  trends  and  flags 
them as anomalous. The AMT results are shown with the help of dashboards (interactive, 
read-only displays with the results of pre-defined queries), and include, for example, the 

17   The  maximum  co-financing  rate  is  80%  for  technical  assistance  grants  but,  in  exceptional  and  duly 
justified  cases,  the  Commission  may  award  a  grant  up  to  90%  of  eligible  costs.  In  order  to  finance 
more projects in 2020, the evaluation committee recommended only 80% co-financing awards. 

18   The  use  of  the  databases  made  by  OLAF  staff  is  paid  from  the  administrative  budget  of  the 

Commission (OLAF). 

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 movement information in 2016. 

8 

 
                                                 
average monthly prices over 48 months of imported goods broken down by product code, 
exporting  country  and  importing  Member  State.  In  2020,  the  JRC  continued  the 
development  of  new  queries  for  the  analysis  of  imports  related  to  the  COVID-19 
pandemic, such as facemasks or vaccines. The AMT generates results in support of risk 
management  activities  undertaken  by  Member  State  customs  authorities  to  fight  tax 
evasion and fraud. 

The  AMT  also  provides  realistic  scenarios  for  joint  customs  operations,  and  estimates 
that customs authorities may use for customs valuation purposes. The latter are the basis 
for assessing the amount of duties that should be collected and the related potential total 
losses  due  to  undervaluation  in  the  EU. The  AMT  has  improved  authorities’  ability  to 
detect  the  undervaluation  of  imported  goods  and  thereby  helped  to  reduce  the  level  of 
losses  to  EU  and  Member  State  budgets  in  customs  duties  and  taxes.  In  2020,  several 
Member States continued using the AMT during a pilot project where national customs 
authorities  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 
project  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. 

In 2020, OLAF and the JRC continued with the administrative arrangement for the Data 
analysis  for  customs  anti-fraud  project  (INTEL4CUSTAF).  Funded  by  the  Hercule 
III programme, the administrative arrangement was initially set up at the end of 201720 
between OLAF and the JRC to provide ‘scientific and technical support in advancing the 
EU’s customs anti-fraud data analytics capacity’21. 

initiated 

following 

the  project 

OLAF 
from  Member  State  customs 
representatives, who recognised the potential  of  working together  through new datasets 
and analytical methods to address the ever-changing world of customs fraud. The scope 
of  the  project  is  defined  by  activities  under  Council  Regulation  (EC)  No  515/97  on 
mutual administrative assistance to ensure the correct application of customs legislation. 

requests 

The  project  is  part  of  a  wider  effort  to  provide  knowledge  and  facilitate  the  work  of 
customs  authorities  in  Member  States  for  the  effective  and  efficient  use  of  data  and 
analytical approaches in the area of customs anti-fraud. In line with the objectives of the 
Hercule III programme, the main beneficiaries of this project are Member State customs 
authorities. Since this project aims to improve the overall effectiveness and efficiency of 
customs anti-fraud data analysis across the EU, OLAF will also benefit from the results. 

From  inception,  the  project  has  aimed  to  establish  and  strengthen  a  community  of 
practice in the domain of customs anti-fraud data analytics, to facilitate the sharing of the 
results produced. 

In  2020,  the  project  continued  to  provide  technical  support  to  Member  State  customs 
authorities through the implementation of the five pilot projects identified at the end of 
2019.  From  a  technical  perspective,  the  pilot  projects  applied  a  wide  range  of  analysis 

20   The first administrative arrangement was signed in late December 2017, covering work undertaken in 
2018, meaning there is a one-year lag between the  year of the annual Hercule III financing decision 
and the associated INTEL4CUSTAF work (e.g. the 2017 Hercule III decision covered the funding for 
INTEL4CUSTAF work in 2018). 

21   This work falls under the activity defined in Article 8(a)(v) of Regulation (EU) No 250/2014. 

9 

 
                                                 
techniques, ranging from the use of statistical methods (as applied in the Undervaluation 
and  Estimated  Container  Weight  projects)  to  deterministic  approaches  and  text  mining. 
Artificial intelligence techniques, and in particular machine learning, were experimented 
with in the e-Commerce (e-Trader) pilot project, while visual analytics tools and network 
analysis  were  used  to  test  ideas  for  tobacco  track  and  trace  data  analysis  and 
visualisations. 

Unfortunately, due to the exceptional health crisis, there were no work visits to Member 
State customs administrations in  2020. A series of virtual  events  replaced the proposed 
physical workshop. 

Tobacco analyses (TOBLAB) 

It is estimated that cigarette smuggling costs the EU and Member State national budgets 
at  least  EUR 10 billion22  per  year  in  lost  customs  and  tax  revenue.  It  also  undermines 
health  policy.  OLAF  takes  the  view  that  investigative  purposes  and  the  proper 
implementation of cooperation agreements with tobacco manufacturers require Member 
State  national  authorities  to  have  access  to  state-of-the-art  specialised  testing  facilities. 
This  is  also  in  line  with  the  European  Commission's  Communication  Stepping  up  the 
fight against cigarette smuggling and other forms of illicit trade in tobacco products - a 
comprehensive EU strategy of 6 June 2013, the Progress Report on the implementation 
of this Communication23 and the new Action Plan for the period 2018-202224. The new 
Action Plan includes both policy and operational law enforcement measures designed to 
curtail either the supply of, or the demand for, illicit tobacco products. 

To  help  tackle  this  phenomenon,  a  laboratory  for  the  analysis  of  tobacco  products, 
TOBLAB,  was  set  up  in  2016  by  the  JRC's  Institute  for  Reference  Materials  and 
Measurements  in  Geel  (Belgium).  The  JRC  in  Geel  specialises  in  producing  tools 
(certified  reference  materials,  proficiency  testing  schemes,  harmonised  and  validated 
testing  methods)  to  ensure  the  quality  of  chemical  measurements  in  health,  food  and 
environmental  applications.  It  operates  three  EU  reference  laboratories  for  food  safety 
and runs the European Reference Centre for Control in the Wine Sector. It has networks 
with  Member  State  laboratories  (also  customs  laboratories)  and  maintains  related 
databases. 

A  close  cooperation  between  TOBLAB  and  Member  State  customs  laboratories  is 
considered  the  best  option  leading  to  the  most  efficient  and  cost-effective  use  of  the 
required testing facilities. 

Member States and OLAF can submit requests for analysis of tobacco products using the 
dedicated  IT  Tobacco  Seizure  Management  Application  (ToSMA),  administered  by 
OLAF on the Anti-Fraud Information System (AFIS) platform. 

The  annual  administrative  arrangement  with  the  JRC's  Geel  Institute  was  renewed  in 
2020 with programme funding of EUR 183 801. 

22   This  estimate  is  based  on  the  assumption  that  the  seizures  made  in  Member  States  represent 

approximately 10% of the overall amount of counterfeit and smuggled cigarettes in the EU.  

23   COM(2017) 235 final.  

24   COM(2018) 846 final. 

10 

 
                                                 
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  training,  conferences  and  staff  exchanges. 
These  activities  aim  to  strengthen  cross-border  cooperation  and  networking  activities 
between  experts  and  to  facilitate  the  exchange  of  best  practices  in  relation  to  the 
protection  of  EU  financial  interests.  The  topics  addressed  by  the  2020  applicants 
emphasised  transnational  cooperation  and  the  further  development,  improvement  and 
update  of  staff  skills  and  competences  through  workshops  and  conferences,  specialised 
training and a staff exchange. 

The Commission received 36 applications from 13 Member States by the deadline of 27 
May  2020.  The  requested  grants  totalled  EUR 3.7 million  whereas  a  maximum  of 
EUR 0.75 million  was  initially  available.  The  exceptional  health  crisis  led  to  a 
postponement  of  several  planned  procured  events  and  offered  the  opportunity  of 
the 
additional  funding  for  grants 
EUR 0.75 budget  available  under  the  ‘training,  conferences  and  staff  exchanges’  call. 
Therefore,  the  Commission  selected  for  award  13  projects  for  a  total  grant  of 
approximately  EUR 1  million.  Table  4  in  Annex  1  gives  an  overview  of  the  awarded 
grants and co-financing rate. 

in  2020.  EUR 0.37 million  was  added 

to 

Conferences organised under procurement 

The  Programme  also  finances  high-level  conferences  and  training  activities  focused  on 
the  protection  of  EU  financial  interests,  to  be  organised  by  the  Commission.  Eleven 
events were planned for 2020, using an existing framework service contract. The overall 
budget  available  for  procured  conferences  was  EUR 1.05 million.  This  part  of  the 
Programme,  along  with  the  procured  digital  forensics  and  analysts  training  below,  was 
significantly affected by the exceptional pandemic circumstances of 2020. The procured 
conferences were initially postponed to the second half of 2020, and, as the situation did 
not improve, were eventually postponed to 2021. A virtual format of these events was not 
considered feasible due to the nature of planned topics and the professional backgrounds 
of participants. Two of the eleven events were organised in an online format. Table 5 in 
Annex 1 provides an overview of the events that took place under the 2020 budget. 

Training organised under procurement: digital forensics and analysts training 

The  digital  forensics  and  analysts  training  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. This annual training contributed to the creation of a network of certified digital 
forensics specialists, starting in 2007. The complexity of EU funds-related investigations 
has  increased,  creating  larger  volumes  of  data  to  process  and  a  growing  need  to  train 
digital  analysts.  To  address  this  need,  since  2018,  analysts  training  courses  have  been 
added  to  the  original  digital  forensics  training.  This  complements  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. 

Two  training  events  were  scheduled  for  2020,  with  a  total  indicative  budget  of 
EUR 1.8 million.  The  health  situation  led  to  postponement  of  the  training,  first  to  the 
second half of 2020, and then to 2021. Since the pandemic conditions  did not improve, 
the 2020 sessions were transformed to a virtual mode and took place between May and 

11 

 
June  2021.  Sixteen  sessions  were  held  online  for  about  250  participants  (15 
participants/session), covering the topics most requested by Member State authorities. 

2.2.4.  Legal training and studies 

The grants for legal training and studies aim at enhancing development of the legal and 
judicial protection of EU financial interests. In 2020, the Commission awarded grants to 
applications that proposed actions covering three types of specific topics: 

a) 

b) 

c) 

developing high-profile research activities, including studies in comparative law; 

increasing cooperation and awareness among practitioners and academics through 
conferences; and 

developing periodical scientific publications and other tools for the dissemination 
of scientific knowledge. 

The Commission received 21 applications from 6 Member States by the deadline of the 
call  for  proposals  on  27  May  2020.  The  total  budget  of  the  21  projects  was 
EUR 2.2 million  and  the  Commission  was  requested  to  contribute  an  amount  of 
EUR 2 million. The initial budget available was EUR 0.5 million. Due to the exceptional 
circumstances of 2020 and unforeseen cancellations and postponements of 2020 procured 
events, an additional budget of EUR 0.45 million was transferred to the legal training and 
studies grants. 

The  Commission  awarded  grants  to  11  applications  for  an  overall  amount  of  about 
EUR 0.9 million  with  a co-financing  rate  of  80%.  The  grants  were  awarded  to  conduct 
studies on: 

  customs control practices; 

  legal  provisions  on  investigations  led  by  the  European  Public  Prosecutor’s  Office 

(EPPO) and OLAF; 

  institutional  cooperation  in  the  EU  in  combating  offences  affecting  EU  financial 

interests; 

  the effect of the COVID-19 crisis on the current regulatory framework relating to the 
fight  against  fraud  affecting  EU  financial  interests,  in  particular  in  the  social,  health 
and economic sectors. 

Also covered under the grants was the publication of a periodical on the protection of EU 
financial interests. Table 7 in Annex 1 gives an overview of the awarded grants in 2020. 

3.  ACHIEVEMENTS 2020 

This  section  provides  an  overview  of  the  main  results  achieved  by  beneficiaries 
implementing awarded grants ending in 2020. 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 outcome of a project. 

12 

 
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  2020  concerned  a  wide  range  of  disciplines  and  topics 
such as:  fighting transit  fraud in the EU; advanced X-ray image interpretation training; 
methodologies  of  detecting  and  investigating  crimes  detrimental  to  EU  financial 
interests; and enhancing the cooperation and control models in the field of prevention of 
fraud affecting the EU’s own resources. 

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,  NGOs  and  educational  institutions  was  also 
noteworthy.  A  total  of  933  people  attended  anti-fraud  training  events  and  conferences 
and  857  event  evaluation  forms  were  received.  The  feedback  received  was 
overwhelmingly positive, with about 99% of the participants giving the events ‘excellent’ 
or  ‘good’  assessments.  The  presence  registered  for  the  projects  finalised  in  2020 
confirmed a growing international dimension. 

Technical  assistance  grants  are  awarded  for  the  purchase  and  installation  of  technical 
equipment  that,  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 EU 
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. 

3.1  Operational objective 1 - To improve the prevention and investigation of fraud 
and  other  illegal  activities  beyond  current  levels  by  enhancing  transnational  and 
multidisciplinary cooperation25. 

This operational objective is achieved mainly through projects funded under the training 
component  of  the  Programme.  A  vast  array  of  anti-fraud  related  topics  were  covered 
during the training actions finalised in 2020. 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; and 

c)  enhanced use of specialised methodologies, tools and techniques to fight against 

fraud affecting EU financial interests. 

An  overview  of  the  training  events  finalised  in  2020  is  given  in  Annex  1,  Table  6 
(Training, conferences and staff exchange) and Table 8 (Legal training and studies). 

25   Article 5(a) of Regulation (EU) No 250/2014. 

13 

 
                                                 
The  National  Anticorruption  Directorate  (Direcția  Națională  Anticorupție  (DNA)) 
of Romania organised a workshop and a European conference — Trends in investigating 
frauds  and  corruption  affecting  the  financial  interests  of  the  European  Union  —  with 
participants  from  18  Member  States  (and  the  Republic  of  Moldova  and  Ukraine).  Its 
focus  was  to  highlight  the  most  relevant  issues  for  fraud  investigations  thereby 
contributing  to  the  prevention,  detection  and  sanctioning  of  irregularities  and  fraud 
detrimental to the financial interests of the EU. 

The  first  activity  was  a  3-day  national  workshop  on  modern  techniques  and  tactics  for 
investigating corruption and fraud in EU-funded projects,  gathering Romania’s relevant 
actors, judicial and administrative authorities involved in preventing and sanctioning the 
irregularities and frauds affecting EU financial interests. The workshop was organised in 
Bucharest in the autumn of 2019 hosting 77 participants. 

(DLAF),  and 

Representatives  of  the  DNA,  management  authorities,  the  Romanian  central  anti-fraud 
department 
the  Romanian  anti-fraud  coordination  service  gave 
presentations that generated debates on: current fraud systems and trends identified in the 
approval  and  implementation  of  EU  financed  activities;  case  studies  on  fraud  methods; 
fraud/corruption  risk  analysis;  fraud  management  in  approving  and  implementing 
activities financed by EU funds; concepts of irregularity; suspected fraud; and fraud. A 
case study presented by  DNA gave the opportunity to  participants to  debate techniques 
and tactics for investigating corruption and fraud in projects supported by EU funds. 

The  2-day  European  conference  on  fraud  affecting  EU  financial  interests  focused  on 
detection and investigation techniques. It brought together representatives of the relevant 
actors  involved  in  preventing  fraud  affecting  EU  financial  interests  from  18  Member 
States and from the Republic of Moldova and Ukraine. The conference was organised in 
Bucharest, in November 2019, hosting 99 participants. 

A major highlight of the event was the presentation of the Romanian study on the impact 
of  Regulation  (EU)  2017/1939  establishing  the  European  Public  Prosecutor’s  Office 
(EPPO) on the national legislative framework. The study was drafted by a working group 
comprised of representatives of DNA, the prosecutor’s office attached to the High Court 
of Cassation and Justice, the Superior Council of Magistracy, DLAF, the Directorate for 
Investigating  Organised  Crime  and  Terrorism  and  the  Romanian  Universities  of 
Bucharest and Cluj-Napoca. 

The  project  facilitated  the  dialogue  and  information  exchange  on  trends  in  the 
investigation  of  fraud  affecting  EU  financial  interests,  so  that  achievements  at  national 
level  could  be  shared  with  other  Member  States.  It  also  promoted  networking  and 
generating new contacts among institutions with responsibilities in combating such fraud, 
as the cross-border nature of the phenomenon of fraud is constantly changing. 

The  National  Revenue  Agency  (NRA)  in  Bulgaria  implemented  a  project  entitled 
Enhancing  the  cooperation  and  the  control  models  in  the  field  of  prevention  of  fraud, 
related to customs regimes 4 200 and 4 000, affecting the EU system of own resources, 
bringing together the revenue administrations of four neighbouring countries and OLAF. 

The project team organised in Sofia six meetings or conferences specifically focused on 
the fight against irregularities and fraud, gathering representatives of the NRA and of the 
revenue administrations of Romania, Greece and Turkey. 

14 

 
 
The first series of meetings was dedicated to holding discussions and making proposals 
for improving the interaction and exchange of information between the tax and customs 
administrations of the countries and proposing a timeline for their implementation. 

The second series centred on the possibilities to draft a cooperation agreement that would 
increase efficiency in the fight against, and prevention of, fraud affecting the application 
of  the  customs  regimes  42  and  40.  Following  fruitful  discussions,  proposals  were 
formulated  following  the  meetings  and  presented  to  senior  management  of  the 
administrations for further approval. 

As a result of this project, NRA Bulgaria’s administrative capacity improved, as did that 
of the revenue administrations of Romania, Greece and Turkey. Moreover, transnational 
cooperation  between  the  revenue  administrations  of  the  Balkan  region  has  been 
reinforced,  leading  to  the  approval  and  optimisation  of  measures  for  combating  fraud 
through the rapid provision and exchange of reliable information. 

This activity resulted in: 

•  improved  prevention  and  investigation  of  fraud  and  other  illegal  activities  beyond 
current levels by enhancing transnational and multidisciplinary cooperation; 
• increased protection of the financial interests of the EU against fraud by facilitating the 
exchange of information, experiences and best practices, including staff exchanges; and 
•  reduced  exposure  of  EU  financial  interests  to  fraud,  corruption  and  other  illegal 
activities, with a view to further reducing the development of an illegal economy in key 
risk areas such as organised fraud. 

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 exchanges26. 

The anti-fraud training  activities and staff  exchanges  contributed to  the  achievement  of 
this  objective.  The  co-financed  projects  involved  several  Member  States  and  created 
opportunities for the exchange of information and experience among participants. OLAF-
procured  training  events  enhanced  the  cooperation  and  exchange  of  information  across 
Member States in relation to anti-fraud prevention and investigation activities. 

OLAF  organised  a  meeting  of  the  anti-fraud  coordination  services  (AFCOS)  across 
the Member States. Due to the health crisis, the meeting was organised in virtual mode, 
in October 2020. Participants included 57 delegates from all Member States and OLAF 
representatives.  The  topics  discussed  included  the  new  fraud-fighting  landscape 
(AFCOS-OLAF-EPPO),  assessing  and  tackling  COVID-19-related  fraud  risks  in  EU 
spending  by  identifying  specific  risks  and  presenting  a  set  of  measures  that  national 
authorities could take to mitigate them. 

The event offered the opportunity of valuable exchanges across Member State authorities 
and provided a  framework to  reflect  on how best  to  protect  the EU budget  when faced 
with a new wave of irregularities and fraud in the health and research sectors. 

26   Article 5(b) of Regulation (EU) No 250/2014. 

15 

 
 
                                                 
The Financial Directorate of the Slovak Republic organised in  two cycles a training 
programme — for customs officers from 11 Member States27 at the EU’s eastern external 
border — focused on X-ray scanner image interpretation and customs control. Twenty-
two customs officers received training in the first cycle and twenty in the second. 

The eastern border of the EU is susceptible to illicit trade. For that reason, it is important 
to  maintain  the  same  high  level  of  customs  control  efficiency  in  all  countries  at  the 
eastern external border. 

The objective of the training was for customs officers to gain knowledge and experience 
related  to  seizures  by  using  X-ray  scanners  and  image  interpretation  from  vehicle  and 
baggage  X-ray  scanners.  The  training  included  practical  exercises  and  scanner  image 
analysis.  On  the  agenda  were  also  physical  checks  of  vehicles  and  a  canine  unit 
presentation. 

This  training  supported  the  achievement  of  the  objectives  set  by  Celbet,  the  Customs 
Eastern & South-Eastern  Land Border Experts Team.  Celbet, under the coordination of 
DG  TAXUD,  aims  to  strengthen  the  quality  of  operational  management  and  customs 
controls on the external EU border. All members belonging to Celbet participated in this 
training, contributing to greater cooperation. 

Customs officers learned new skills and acquired knowledge, methods and best practices 
in  the  field  of  X-ray  image  interpretation  related  to  the  fight  against  smuggling.  Using 
these in their daily work will improve performance of customs controls and reinforce the 
ability to detect illegal activities. 

3.3  Operational objective 3 - Strengthening the fight against fraud and other illegal 
activities  by  providing  technical  and  operational  support  to  national  investigations,  in 
particular to customs and law enforcement authorities28. 

Beneficiaries received grants for the purchase of technical equipment to support specific 
activities. 

a)  Strengthening  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, for example, smuggled cigarettes 
and tobacco, illicit goods or the identification of new fraud schemes and methods 
of operation. 

b)  Improving skills and qualifications of the beneficiary's staff who are tasked with 

the daily operations of new equipment. 

c)  Improving 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 prosecution or trial stages. 

Technical assistance grants can also cover expenditure for the maintenance of equipment, 
and  for  specific  technical  training  for  operational  staff,  to  ensure  its  optimal  usage  and 
management. 

27   SK, HR, HU, PL, EE, LT, LV, GR, FI, RO, and BG. 

28   Article 5(c) of Regulation (EU) No 250/2014. 

16 

 
                                                 
During  a  given  year,  the  Commission  receives  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.  Consequently,  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-ray  scanners,  for  example,  clearly 
demonstrate a direct relationship. Digital forensics software, devices to monitor vehicles 
or  persons  suspected  of  involvement  in  illicit  activities,  and  verification  of  documents 
and chemicals all enable beneficiaries to improve the overall efficiency and effectiveness 
of the operations carried out in support of investigations to protect EU financial interests. 
Some examples are shown below for technical assistance grants finalised (final technical 
reports  received)  in  2020.  The  complete  list  of  finalised  technical  assistance  grants  is 
found in Annex 1, Table 2. 

The  Ministry  of  the  Interior  of  Spain,  Guardia  Civil  reported  on  its  acquisition  of 
equipment  to  improve  its  investigative  and  operational  capacity  to  seize  illegal 
consignments, reduce investigation time and tackle complex investigations into criminal 
organisations, in its aim to detect and monitor illegal activities affecting the EU budget. 
The tools purchased identify anonymous IP wireless electronic communication devices, 
intercept wireless IP communication devices over Wi-Fi and ensure legal digital content 
extraction  and  end-point  communications  interception.  The  system  comprises  a  central 
server  and  sensors  deployed  in  various  specialised  units.  Twenty  staff  members  have 
been  trained  in  the  use  and  exploitation  of  retrieved  data.  These  tools  support  joint 
international operations and underpin investigations emerging from raw intelligence and 
on-the-spot  checks  by  providing  better  digital  evidence.  The  deployment  of  this 
technology  aims  to  shorten  penal  proceedings  and  seeks  to  have  a  major  impact  on 
prevention and deterrence of crimes against the EU budget. 

Germany’s  Berlin  Police  purchased  equipment  to  check  and  verify  documents.  The 
acquired  system  enables  checks  of  security  features  of  more  than  2 000  different 
documents (ID cards, passports, visas, driving licences, residence permits) from over 200 
countries. Fifty devices to verify embedded electronic chips and both visible and hidden 
security  features  as  well  as  fingerprint  sensors  and  software  were  purchased  and 
distributed  throughout  Berlin.  Checks  in  2019  revealed  anomalies  at  a  level  of  18%, 
leading to further investigation. The project has strengthened the quality, efficiency and 
effectiveness  of  police  investigation  work.  It  prevents  high  financial  losses  caused  by 
organised  fraud  and  strengthens  the  economy  of  the  region,  country  and  the  EU.  A 
reported 20 000 employees have been trained in the use of the equipment and 150 have 
received specialised training. 

Customs  controls  at  a  border  crossing  point  between  Lithuania  and  Belarus  have  been 
strengthened following the procurement and deployment of a stationary vehicle/container 
X-ray inspection system by the Lithuanian Customs. This equipment will increase the 
efficiency of customs controls and reduce the time required for customs formalities. The 
duration of examinations for transport containers has been reduced to approximately 15 
minutes,  significantly  shorter  than  the  previous  2-3  hours  inspection  time.  The 
integration  of  this  X-ray  system  into  BAXE,  the  Baltic  Exchange,  has  reinforced  the 
overall protection of the Baltic region and the external border of the EU. Using this non-

17 

 
 
 
invasive  control  mechanism  has  facilitated  the  detection  of  illicit  cigarettes  smuggling, 
contributing to seizures and to the protection of EU budget revenues. 

The Lithuanian Police Forensic Science Centre (LPFSC) organised forensics training 
for  investigators  Improving  Baltic  States  and  Croatia  police  computer  forensics 
specialists'  skills  in  IT  investigations  by  organising  training  of  UNIX-based  operating 
systems  forensics  and  scripting  bringing  together  18  participants.  The  specialists  were 
trained  in  Linux  Forensics  and  Windows  10  Forensics.  This  project  significantly 
increased  the  number  of  available  skilled  digital  forensic  investigators,  reinforcing 
capacity throughout all the Baltic States. 

The project contributed to: 

• improving the quality of investigations, and reduced time to resolve crime by improving 
investigators' skills in IT investigations; 

•  strengthening  of  the  capability  of  LPFSC  to  fight  against  fraud  and  other  illegal 
activities; 

• ensuring a harmonised ability to support and conduct fraud analysis cases with digital 
forensic investigation throughout the country; 

• strengthening of the existing network between IT investigators of the Baltic States and 
Croatia; 

• reducing the processing queues in the Baltic States and Croatia for pending forensic IT 
investigations; and 

•  harmonising  the  abilities  and  expertise  of  IT  investigators  of  the  Baltic  States  and 
Croatia. 

Technical assistance implementation reports 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  on,  for  example,  the  number 
and  amount  of  cigarettes  and  tobacco  seizures,  estimates  of  the  prevented  losses  to  the 
national and EU budgets, the emergence of new fraud schemes, the detection of networks 
of  organised  crime  groups  or  the  number  of  arrests  made.  In  2020,  18  implementation 
reports were submitted for grants awarded under the 2017 annual budget. 

A grant to the Provincial Police Headquarters in Olsztyn, Poland for the purchase of a 
mobile intelligence centre has led to an improvement in the detection of crime related to 
tobacco smuggling in the Warminsko-Mazurskie province. The equipment enables police 
to obtain data and information from the mobile network to identify subscriber identities 
and other data pertinent  to intelligence operations. The beneficiary reports that data are 
obtained faster and that analytical work and response times have improved. These better 
data  contribute  to  an  improved  quality  of  admissible  evidence.  Seizures  of  20  million 
cigarettes  and 4 500 kilos of cut tobacco, leading to charges filed against more than 50 
people, have been reported. 

18 

 
 
 
An  estimated  EUR 5 million  in  seizures  and  averted  financial  damage  to  EU  funds 
resulted from investigations by the Brasov County Police Inspectorate, Romania using 
digital  hardware  and  software  forensic  equipment.  Using  the  technology  to  target 
smuggling  and  tax/VAT  evasion  for  products  including  cigarettes,  sugar,  counterfeit 
drugs and wood supplies, the beneficiary identified various types of wrongdoing leading 
to  investigations  of  individuals  submitting  falsified  VAT  returns,  smuggling,  ghost 
companies  and  money  laundering.  From  its  inception  in  August  2019,  the  Fraud 
Investigation  Unit  and  the  Forensic  Unit  recovered  and  analysed  data  on  262  storage 
media  devices  in  six  financial  crime  cases  in  relation  to  VAT,  money  laundering, 
smuggling and tax evasion. Another 82 devices were searched for other types of illegal 
activities. The time required to recover data decreased by half, from 90 days to 45 days. 
The  quality  and  quantity  of  evidence  secured  from  digital  devices  have  significantly 
improved. The beneficiary reported the arrest of 12 people up to December 2020. 

Forensic  examination  capacity  of  documents  and  inks  has  been  boosted  in  the  SFSB 
Document  Investigation  Department  of  Latvia  after  the  purchase  of  a  Raman 
spectrometer  and  an  ultra-performance  liquid  chromatography  system.  Experts  from 
France, Germany  and Switzerland provided two training  events  to  experts  from  Latvia, 
Lithuania  and  Estonia.  The  items  have  now  been  in  use  since  mid-2019,  reinforcing 
capacity  to  provide  high-quality  evidence  for  investigation  of  financial  and  economic 
crimes. Examinations of evidence are linked to illegally produced goods amounting to a 
possible EUR 1.5 million. 

Examples of procured access to external databases 

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

Member  State  customs  services  use  a  commercial  database  of  worldwide  trade 
statistics. It is used primarily to assist investigations into cases involving trans-shipment, 
anti-dumping  or  countervailing  duties,  misdescription  of  country  of  origin,  exporter, 
container swapping and undervaluation. One Member State reported an identification via 
the database by noting significant changes in trade flows as part of a risk analysis profile, 
e.g. Brexit-related trade flows. 

Member State customs authorities use a database on vessel information and movements 
in combination with other databases, to support risk analysis and intelligence regarding 
commercial vessels operations worldwide. It is regularly used to check the actual routes 
of vessels in order to cross-check 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 to detect potentially suspicious cases of import 
transactions.  Moreover,  it  is  regularly  used  to  monitor  vessels  transporting  cargo 
containers  directed  to  the  EU  customs  territory  to  help  identify  risky  shipments, 
including smuggling of tobacco products. 

19 

 
 
 
Member  States  used  this  database  in  2020  to  monitor  container  ships  (in  particular 
carrying high-risk consignments such as cigarettes) and tankers, as part of actions aimed 
at countering anti-dumping violations. It is instrumental in detecting violations associated 
with  embargoes  of  mineral  oils  imported  from  areas  of  high  political  and  military 
instability  in  North  Africa  and  the  Eastern  Mediterranean,  and  to  counter  violations 
related to misdescription of origin of agricultural and other products imported to the EU. 
In one case, 22 tonnes of agricultural products claiming false origin were seized. 

Use of the aforementioned database contributed to the seizures of more than 16 million 
cigarettes  and,  in  another  seizure,  a  big  shipment  containing  undeclared  chewable 
tobacco. 

information  on  companies  has  significantly  contributed 

A  database  with 
to 
investigations  led  by  Member  State  customs  authorities  related  to  fraud  affecting  the 
financial interests of the EU. In a number of cases, the database has been used in several 
tax  audits  and  checks  conducted  by  a  Member  State  authority.  The  quality  of  data 
available in the database led to the successful pursuit of an investigation related to a case 
of  international  tax  evasion  that  enabled  the  competent  authority  to  identify  all  the 
corporate structures and persons involved. 

One particularly useful characteristic of having access to this database is that it provides 
the  possibility  for  Member  State  authorities  to  create  risk  profiles  and  to  verify  certain 
information on companies, company structures and beneficiary owners. They may trace 
companies  and  gather  intelligence  to  assist  with  relevant  customs  investigations  of 
particular interest using this data. 

The database contributed to the establishment of the customs debt for suspicious import 
consignments using customs procedure CP 42. This procedure allows importers to obtain 
a  VAT  import  exemption,  when  goods  are  imported  from  outside  the  EU  into  one 
Member State and subsequently transported to another Member State, to evade customs 
duties  and  VAT.  It  was  also  instrumental  in  detecting  fake  exports  from  the  EU  to  a 
certain third-country company. 

Examples of operational results obtained from the use of the automated monitoring tool, 
the  data  analysis  project  and  the  laboratory  for  the  analysis  of  tobacco  products 
(developed with the Joint Research Centre). 

The automated monitoring tool (AMT) is an IT tool developed by the JRC and made 
available to Member State customs services for the identification of anomalies in patterns 
of  import  prices  or  quantities.  Some  Member  States  use  the  AMT  to  determine  the 
threshold of lower  prices  for  customs  valuation  by  combining  estimates  of EU  average 
product prices with the results of their customs controls. Several Member States use these 
estimates and the related price anomalies of specific products or origins for integration in 
their  national  risk  profile  systems.  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 
EU and Member State budgets in customs duties, excises and VAT. The use of the AMT, 
hosted  on  two  separate  platforms,  increased  considerably  in  2020.  The  tool  received 
more than 220 000 data queries from almost 2 000 customs officers. 

20 

 
 
In 2020, the AMT was  used for monitoring and examining imports of medical supplies 
needed for fighting the COVID-19 pandemic. It was also used to assess the findings from 
joint  customs  operations  carried  out  in  previous  years,  such  as  the  one  aimed  at  the 
identification of undervaluation in imports of textiles and footwear. 

The  JRC  submitted  to  OLAF  the  2020  INTEL4CUSTAF  project  deliverables, 
summarising  the  work  completed  under  the  administrative  arrangement  in  relation  to 
pilot  projects  on:  estimated  container  weight;  misdescription  of  goods;  data  analysis 
methods for the detection of e-traders and undervaluation; and tobacco track and trace. 

In 2020, INTEL4CUSTAF activities fell into two main categories: 

1.  Networking and community building 

 

 

 

Visits  to  Member  States  to  find  out  how  they  organise  and  conduct  analysis, 
discussing interesting projects and sharing OLAF/JRC expertise. Previously, these 
visits have led to presentations from the visited Member States during a workshop 
and have greatly influenced the identification of wider pilot projects. 

Discussions  and  sharing  experience  of  analytical  and  data  issues  during  the  pilot 
project meetings, leading also to informal contacts on other relevant issues among 
Member State analysts. 

A 4th workshop,  to  present  the information and  work undertaken during  the  year, 
share experiences and discuss needs, challenges and ideas for future work. 

2.  Pilot projects 

 

Five  data  analysis  (pilot)  exercises,  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  five  pilot  projects  undertaken  in  2020  are  summarised  in 
Figure 5. Four of the 2020 pilot  projects  build on work started in  2019;  the 2019 
project  using  the  Europe  Media  Monitor  to  identify  reports  of  illicit  tobacco  has 
been  discontinued,  although  related  text-mining  analysis  is  incorporated  into  the 
misdescription pilot project. 

21 

 
 
Figure 5: 2020 INTEL4CUSTAF pilot projects 

Although it was not possible to conduct the planned visits, all the events, including the 
pilot project meetings, were held online. The planned physical workshop was replaced by 
six 3-hour online events organised in November 2020. 

Despite the difficulties posed by the virtual environment, work advanced on all five pilot 
projects and over 50 colleagues from 18 Member States participated actively. Across the 
four pilot projects where there was a need to collect data29, 22 datasets were provided by 
13 Member States.  At the workshop plenary session, organised on 25  November 2020, 
OLAF  and  JRC  presented  the  main  conclusions  and  proposals  for  the  programme  in 
2021. Overall, the workshop brought together 88 representatives from 21 Member States 
and  44  Commission  officials  from  OLAF,  JRC,  DG  TAXUD,  DG  BUDG  and  DG 
SANTE, with most participants attending more than one session. About 30 Member State 
participants  responded  to  an  (anonymous)  online  survey  at  the  end  of  the  plenary.  In 
the 
general, 
INTEL4CUSTAF  events  very  useful)  and  strongly  supported  continuation  of  the 
INTEL4CUSTAF initiative. 

the  virtual  workshop  (26  found 

they  were  very  positive  about 

OLAF has usually presented and discussed the activities of the INTEL4CUSTAF project 
with Member State representatives at the expert group on mutual assistance in customs 
matters. A presentation summarising the outcomes of the 2020 activities and the proposal 
for  the  2021  activities  was  given  at  the  expert  group  meeting  (virtual,  16  December 
2020). Overall, the project received positive feedback and delegates to the expert group 
supported its continuation in 2021. 

29   Tobacco track and trace data was already available in a central database. 

22 

 
 
 
                                                 
Contribution of the action to the protection of EU financial interests 

During  its  3  years  of  activities,  the  INTEL4CUSTAF  project  has  delivered  important 
progress  under  several  of  the  Hercule  III  operational  objectives.  It  has  created  an  open 
and  informal  environment  where  practitioners  are  free  to  exchange  their  ideas  and 
provide  valuable  feedback  on  the  activities  performed.  The  result  is  a  community  of 
experts, which, at the end of 2020, totals around 150 members from Member States and 
50 from the Commission. Through strengthening the community of practice and the work 
performed in  pilot  projects,  the project  has improved EU transnational  cooperation and 
collaboration,  promoted  the  sharing  of  good  practices  among  Member  States  and 
supported the strengthening of national capacities to identify and combat fraud30. 

The  laboratory  for  the  analysis  of  tobacco  products  (TOBLAB)  at  the  JRC-Geel 
facility  has  been  operational  since  April  2016  and  is  regularly  used  by  Member  State 
customs  services  and  OLAF.  The  laboratory  carries  out  analyses  on  samples  of  seized 
tobacco  products.  The  results  obtained  make  it  possible  to  identify  the  chemical 
composition and the geographical origin of the analysed tobacco. The analytical methods 
applied also enable the identification of counterfeit tobacco products and can contribute 
to  forensic  investigations  aiming  to  dismantle  criminal  networks.  TOBLAB  aims  to 
provide intelligence on analysed tobacco products, including so-called cheap whites, and 
on raw and  cut  tobacco. TOBLAB is  assembling a repository of  raw tobacco  grown in 
Europe  from  different  production  regions,  including  different  varieties  from  within 
regions,  in  order  to  provide  information  about  the  geographical  origin  of  seized  raw 
tobacco. 

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 
customs services  and OLAF.  For the last  reporting period (July 2019  – July 2020), the 
JRC  received  from  14  Member  States  and  OLAF  149  requests  for  analysis  of  seized 
cigarettes  and  raw/fine-cut  tobacco  samples.  Final  reports  have  been  uploaded  in  the 
Tobacco  Seizure  Management  Application  (ToSMA)  for  113  cases  (the  remaining  36 
cases  were  being  processed  at  the  time  of  reporting).  All  cigarette  samples  have  been 
categorised  according  to  their  elemental  composition,  the  volatile  and  semi-volatile 
constituents, and by visual observation. 

It was possible to identify cigarettes smuggled into the European market and to establish 
connections between tobacco products seized in various places and at different moments 
within  the  EU.  A  total  of  89  seizures  could  be  connected  to  each  other  or  to  previous 
seizures. 

Following  the  restrictions  in  place  related  to  the  COVID-19  pandemic,  the  TOBLAB 
facilities  were  closed  from  mid-March  to  mid-May  2020.  Due  to  the  lockdown,  the 
annual workshop of Member State enforcement staff and customs laboratories could not 
take place. 

3.4  Operational  objective  4  -  To  limit  the  currently  known  exposure  of  the  EU’s 
financial interests to fraud, corruption and other illegal activities with a view to reducing 

30   Operational objectives (a), (b) and (c) of Hercule III Programme. 

23 

 
 
                                                 
the  development  of  an  illegal  economy  in  key  risk  areas  such  as  organised  fraud, 
including cigarette smuggling and counterfeiting31. 

Several actions contributed to achieving this objective in 2020. 

In 2018, OLAF awarded a contract to the research institute RAND Europe (UK) CIC to 
conduct  a  Study  to  identify  an  approach  to  measure  the  illicit  market  for  tobacco 
products. The study was co-funded by the Hercule III programme and by the third EU 
Health  Programme  (2014-2020).  The  total  cost  of  the  study  was  EUR 290 100  and  the 
OLAF  contribution  was  funded  from  the  2017  budget.  OLAF  managed  the  study  in 
cooperation with DG SANTE. 

This study intends to support efforts to better understand the scope and scale of the illicit 
tobacco  market  and  thereby  inform  future  policy  and  investigative  actions  of  the 
European  Commission  and  Member  States.  The  primary  objective  was  to  develop  a 
reliable,  robust,  replicable  and  independent  methodology  to  measure  the  illicit  market, 
one  which  can  be  applied  both  at  EU  and  Member  State  level.  Given  the  exploratory 
nature  of  the  study,  no  data  was  collected  and  no  measurements  attempted.  The  study 
identified  a  shortlist  of  preferred  methods  (i.e.  discarded  pack  survey,  comparison  of 
sales/tax  paid  and  self-reported  consumption,  consumer  survey  with  and  without  pack 
inspection/surrender,  econometric  modelling)  and  some  interesting  new  data  sources. 
Taken  individually,  no  individual  method  was  sufficient  to  meet  the  stated  objective. 
Instead,  the  shortlisted  methods  were  combined  in  various  ways,  creating  as  a  final 
output  options  for  methodologies  that  also  take  into  account  the  different  levels  of 
resource  intensity  required  to  apply  them.  The  study  was  finished  in  April  2020  and 
published  online  by 
in  January  2021 
(https://data.europa.eu/doi/10.2784/272064). This study will be a useful reference for any 
future action in this area. 

the  Publications  Office  of 

the  EU 

The  Latvian  Customs  Administration  implemented  an  advanced  X-ray  image 
interpretation  training  (AXIIT)  project  for  three  Baltic  states  (Estonia,  Lithuania,  and 
Latvia). It provided a partial continuation of the Hercule III BAXE project (Development 
of joint data exchange network between X-ray scanners used by customs administrations 
of  Baltic  States,  a  unified  network  for  information  exchange  about  vehicles  crossing 
national borders and mechanism of control and information exchange). 

The  action  consisted  in  the  organisation  of  two  sessions  of  advanced  training  of  X-ray 
image interpretation in order to provide in-depth training to 100 Latvian customs officials 
directly  involved  in  work  with  customs  controls  carried  out  with  X-ray  equipment. 
Topics  covered  included  methodology  of  X-ray  image  interpretation,  objects  concealed 
in various types of cargo and tests of X-ray performance. 

A  further  condition  for  successfully  fighting  smuggling  is  close  cooperation  between 
neighbouring  countries  in  order  to  move  towards  more  harmonised  controls  at  the 
external EU border. To this end, a regional workshop was held for the customs officers of 
Latvia, Lithuania and Estonia. 

31   Article 5(d) of Regulation (EU) No 250/2014. 

24 

 
 
                                                 
An increase of 17% in the number of scans in the first quarter of 2020 compared with the 
first quarter of 2019 attests to the effectiveness of this reinforced capacity. This training 
provided  support  to  the  successful  operation  and  development  of  the  recently  formed 
Customs  Controls  Support  Centre.  Furthermore,  this  action  has  substantially  increased 
the capacities of X-ray image operators in the Latvian customs, resulting in a significant 
increase in the number of cigarettes seized by Latvian customs. The amount of cigarettes 
seized in the first quarter of 2020 increased by 225% compared with the first quarter of 
2019. 

The  project  has  contributed  to  the  continued  cooperation  between  Baltic  State  customs 
administrations  regarding  X-ray  controls  carried  out  at  the  external  border.  These 
controls  aim  to  prevent  smuggling  of  cigarettes  by  providing  an  incentive  to  look  for 
innovations and possible future development of the joint data exchange network between 
X-ray scanners (BAXE). 

3.5  Operational objective 5 - To enhance the degree of development of the specific 
legal  and  judicial  protection  of  the  EU’s  financial  interests  against  fraud  by  promoting 
comparative law analysis32. 

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

The Programme continued funding the publication of eucrim (the European criminal law 
associations’ forum) by the Max Planck Institute for Study of Crime, Security and Law 
in  Germany  during  2019  and  2020.  The  eucrim  project  aims  to  support  associations  of 
European  lawyers  and  to  foster  their  networks.  The  journal  raises  awareness  of  legal 
practitioners  and  other  stakeholders  throughout  Europe  with  regard  to  relevant  legal 
provisions and policies associated with the protection of the EU’s financial interests and 
European  criminal  law.  The  periodical  promotes  a  deeper  understanding  of  long-term 
developments in this field by means of its news and articles sections. 

The  ongoing  analysis  by  the  Max  Planck  Institute  enabled  systematic  and  regular 
reporting  on  developments  in  the  protection  of  the  EU’s  financial  interests  and  related 
topics  of  European  criminal  law.  Readers’  awareness  and  a  deeper  understanding  of 
European law were enhanced. The use of the modernised and redesigned eucrim website 
(https://eucrim.eu)  and  the  steadily  increasing  number  of  subscribers  to  the  eucrim 
newsletter  indicate  that  all  interested  parties  have  become  increasingly  aware  of  the 
eucrim  project,  the  associations,  the  various  networks,  and  other  ongoing  relevant 
developments  at  European  and  national  levels.  Each  issue  focused  on  a  specific  topic 
related to the protection of the EU’s financial interests and was printed in 2 000 copies. 
Four issues per year were published and distributed to universities, libraries, courts, law 
enforcement authorities and individual subscribers. 

The journal gathers contributions from an increasing number of authors from academia, 
legal policy, the judiciary and other branches of the legal profession, leading to a wider 

32   Article 5(e) of Regulation (EU) No 250/2014. 

25 

 
                                                 
distribution and exchange of information and knowledge. As a consequence, awareness 
of  the  need  for  the  protection  of  the  EU’s  financial  interests  has  increased.  Research 
activities  and  statements  on  highly  relevant  topics  were  presented  during  2019-2020, 
such  as  assessments  of  the  EU  anti-fraud  strategy,  whistleblowing  legislation,  OLAF 
investigations  outside  the  EU,  and  the  state  of  play  regarding  the  establishment  of  the 
European Public Prosecutor’s Office. 

Eucrim continues to be the only medium that consistently monitors, analyses and reports 
on  matters  of  protection  of  financial  interests  and  related  (background)  topics  of 
European criminal law and the area of freedom, security and justice. It offers added value 
by  combining  the  news  section  with  the  publication  of  sound  scientific,  and  policy-
aligned  and  practically  orientated,  information  on  protection  of  financial  interests  and 
European criminal law in three languages (English, French, and German). Publication of 
the electronic version of the eucrim journal, including direct links to the electronic news 
sources,  guarantees  that  information  is  accessible  at  any  time  free  of  charge.  This  is 
creating  the  foundation  for  a  database  on  all  relevant  developments  of  protection  of 
financial interests and European criminal law in the long term. 

The  Croatian  Association  of  Criminal  Sciences  and  Practice  received  a  grant  for  a 
project  that  dealt  with  implementation  of  the  European  Public  Prosecutor’s  Office 
(EPPO)  in  national  criminal  justice  systems.  The  objectives  of  this  project  were:  to 
improve  the  prevention  and  investigation  of  fraud  and  other  illegal  activities  beyond 
current levels by enhancing national criminal justice systems; to strengthen transnational 
and multidisciplinary cooperation; to increase protection of EU financial interests against 
fraud;  and  to  facilitate  the  exchange  of  information,  experience  and  best  practice 
regarding the integration of the EPPO in national criminal proceedings. 

The project was composed of three activities. 

i) An international conference was held in April 2019 in Zagreb, Croatia. The conference 
gathered  200  participants,  including  public  prosecutors,  judges,  attorneys-at-law, 
ministry officials, professors, and other experts. They came from European and national 
institutions  from  seven  EU  Member  States  and  one  EU  candidate  state.  The  general 
objective  of  the  conference  was  to  analyse  the  integration  of  the  EPPO  in  national 
criminal justice systems. The conference was dedicated to four topics: 

a) institutional challenges at national and EU levels, addressing EPPO’s structure 
and  powers,  the  selection  and  appointment  of  the  European  Chief  Prosecutor  and 
European  Delegated  Prosecutors,  EPPO’s  independence  and  responsibility,  and  the 
possibility of extending the term of office; 

b)  procedural  challenges,  focusing  on 

investigation  powers,  procedural 
guarantees,  the  prosecutor’s  oversight,  disciplinary  liability,  the  language  of  criminal 
proceedings  and  linguistic  problems  of  the  Permanent  Chambers,  judicial  control, 
procedural guarantees, and the admissibility and legality of evidence; 

c)  challenges  in  cooperating  with  Member  States  and  EU  agencies,  with 
discussions addressing EPPO cooperation with EU Member States that do not participate 
in it, with third countries, and with Eurojust, OLAF and Europol; and 

26 

 
 
 
d)  EPPO  integration  in  the  Croatian  criminal  justice  system,  addressing  various 

issues regarding institutional and procedural challenges. 

ii)  The  annual  meeting  of  the  presidents  of  the  associations  for  European  criminal  law 
and for the protection of EU financial interests, held in April 2019 in Zagreb, Croatia. 

in 

iii) Publication of the papers presented at the international conference, ‘Integration of the 
EPPO 
the  National  Criminal  Justice  Systems:  Institutional,  Procedural  and 
Cooperative Challenges’ as a special issue of the Croatian Annual of Criminal Sciences 
and Practice, which is an open access journal published by the beneficiary and is widely 
distributed. The publication contains 15 papers and 7 meeting abstracts that analyse the 
various  institutional,  procedural  and  cooperation  challenges  brought  about  by  the 
establishment of the EPPO. The articles were double-blind peer-reviewed and 12 of them 
were categorised as scientific papers, attesting to their quality. The publication is freely 
journals 
available 
(https://hrcak.srce.hr/hljkzp?lang=en), released in 2020 (Vol. 27, No. 1). 

the  portal  of  Croatian 

and  professional 

scientific 

at 

The  project  contributed  to  enhancing  the  legal  and  judicial  protection  of  EU  financial 
interests against fraud. The research activities and discussions at the conference between 
participants from EU Member States and candidate countries raised awareness about the 
EPPO and provided insight into the current problems in protecting EU financial interests, 
and offering possible solutions. The conference itself served as a forum for the exchange 
of  knowledge  and  practices  between  academics  and  practitioners  acting  in  the  area  of 
protection  of  EU  financial  interests,  and  for  improving  transnational  cooperation. 
Croatian  practitioners  improved  their  knowledge  and  gained  valuable  insight  into  the 
establishment,  jurisdiction  and  implementing  issues  of  the  EPPO.  The  conference 
publication aims to raise awareness for a wider audience. 

The  University  of  Bologna  received  a  grant  to  develop  comparative  research  on  the 
rules for conducting digital forensic operations in anti-fraud administrative and criminal 
investigations. Taking into consideration the challenges posed by digital technology and 
the requirements to  handle digital  evidence in  investigations,  the project  analysed three 
main  profiles  of  digital  forensic  operations  from  a  multidisciplinary  and  transnational 
perspective: 

(i) rules to ensure the integrity and the chain of evidence (also when data are stored in the 
cloud),  and  safe  storage  of  the  information  collected;  a  special  focus  was  put  on  the 
authenticity of evidence collected in relation to its admissibility in light of the proposal to 
amend Regulation (EU, Euratom) No 883/2013; 

(ii)  rules  to  ensure  an  effective  exercise  of  defence  rights  (examination  of  digital 
evidence,  documentation  of  the  operation,  potential  participation  of  the  defence, 
identification  of  effective  remedies  including  the  prompt  destruction  of  irrelevant  or 
disproportionate information); and 

(iii) rules on the use and assessment of digital evidence at trial. 

27 

 
 
 
The project produced a comprehensive comparative analysis of the standards for digital 
forensic  evidence  in  selected  Member  States  (Germany,  Italy,  Spain,  Luxembourg  and 
the Netherlands) to understand which rules are most effective in anti-fraud administrative 
and criminal investigations on EU financial interests. 

The  project  developed  recommendations  to  create  uniform  European  standards  on  the 
handling  of  digital  evidence  in  anti-fraud  investigations.  These  could  contribute  to 
establishing  legislation  on  digital  forensics  at  EU  level,  and  also  improve  existing 
national legislation on the matter. In doing so, the project helped shape a shared concept 
of authenticity of evidence that fosters cooperation between relevant national authorities 
and OLAF to make anti-fraud investigations more effective. 

The project results were presented at an international conference in December 2020, held 
online due to the COVID-19 pandemic, attended by 80 participants including researchers, 
students, legal practitioners, digital forensic experts and specialised police officers. The 
final  publication  Digital  Forensic  Evidence:  Towards  Common  European  Standards  in 
Anti-fraud Administrative and Criminal Investigations, released in January 2021, collects 
the  results  of  the  research  and  is  available  free  of  charge  at  the  project’s  website 
(https://site.unibo.it/devices/en/results).  The  publishing  house  has  also  printed  and 
(https://shop.wki.it/libri/digital-forensic-evidence-
distributed  a  paperback  version 
s741940/). 

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  results  of  actions  that  received 
funding33. 

4.1. 

Informing potential applicants 

Full  documents  for  the  calls  for  proposals  were  made  available  on  the  Commission's 
Funding and Tenders portal and notices concerning the launch of calls were published in 
the Official Journal34 and on the Commission's website35. Potential applicants were also 
informed  about  the  publication  of  calls  via  emails  sent  to  members  of  the  Advisory 
Committee  for  the  Coordination  of  Fraud  Prevention  (COCOLAF),  to  the  anti-fraud 
coordination services (AFCOS) and to the network of associations for European criminal 
law and the protection of EU financial interests. 

4.2.  Dissemination of results 

Dissemination  of  the  results  of  training  activities  was  made  through  the  distribution  of 
electronic  and/or  paper  reports  summarising  the  events.  Some  beneficiaries  posted  the 
recorded  event(s)  and  the  projects'  outputs  on  their  websites  or  created  dedicated 

33   Article  13(1)  of  Regulation  (EU)  No  250/2014:  ‘The  Commission  shall  on  an  ongoing  basis 
disseminate,  including  on  relevant  websites,  the  results  of  the  activities  supported  under  the 
Programme to increase transparency on the use of the funds.’ 

34 OJ C 58 of 21.2.2020. 

35 http://ec.europa.eu/anti-fraud/policy/hercule_en  

28 

 
                                                 
websites in order to disseminate results and conclusions. 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  actions,  all  beneficiaries  of  grants  were  requested  to  mention  the 
support from the Hercule III programme: 

d) 

e) 

f) 

g) 

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); and 

by inserting a link from their website to the site of the Hercule III programme. 

Beneficiaries  of  technical  assistance  grants  were  requested  to  mention  the  Hercule  III 
programme 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 Programme-funded equipment, for example, should refer to the EU 
funding. 

5.  FEEDBACK FROM PARTICIPANTS OF THE PROGRAMME 

As indicated in Section 3, beneficiaries of grants for training, conferences and seminars 
carry out surveys among the participants to collect information on the perceived quality 
and relevance of the event attended. Concerning the final reports received in 2020 for the 
training grants, a total number of 933 participants attended activities co-financed by the 
Hercule III programme. 

The Commission received 857 completed questionnaires (92% response rate), indicating 
a  very  high  level  of  satisfaction.  The  feedback  received  was  overwhelmingly  positive, 
with nearly 99% of participants assessing the events as ‘excellent’ or ‘good’. Participants 
appreciated  the  cooperation  and  exchange  of  information  opportunities  offered  by  the 
training  events  and  considered  the  activities  as  having  a  practical  impact  on  their  daily 
work. Based on the feedback results, it can be concluded that the events have largely met 
their  stated  objectives  and  led  to  increased  awareness  of  the  risks  to  which  the  EU’s 
financial interests are exposed. 

6.  CONCLUSIONS AND WAY FORWARD 

The Hercule III programme was an important and effective tool in the protection of EU 
financial  interests.  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 EU financial interests. 

The  Programme's  relevance  is  supported  also  by  the  findings  of  the  mid-term 
evaluation36 that was carried out in 2017. Stakeholders reported that the Programme has 

36   COM(2018)3 final of 10 January 2018. 

29 

 
                                                 
been  efficiently  implemented  and  that  it  effectively  addresses  Member  State  needs.  In 
2020, the Commission launched the final evaluation of the Programme, due by the end of 
2021. Its effectiveness,  efficiency, added value and sustainability are being assessed by 
an external contractor, on the basis of results of its whole duration. 

The  Hercule  III  programme  ended  on  31  December  2020.  Acknowledging  its 
contribution, the Commission made a proposal for a new Union Anti-Fraud Programme 
under the multiannual financial framework 2021-2027. The proposal was adopted on 29 
April 2021 as Regulation (EU) 2021/785, with total financing of EUR 181 207 000. 

The new Union Anti-Fraud Programme pursues three specific objectives: 

a) 

b) 

c) 

to prevent and combat fraud, corruption and any other illegal activities affecting 
the financial interests of the Union; 

to provide tools for information exchange and support for operational activities in 
the field of mutual administrative assistance in customs and agricultural matters; 
and 

to support the reporting of irregularities, including fraud, with regard to the shared 
management funds and pre-accession assistance funds of the Union budget. 

This expanded scope, merging the previous Hercule, the Anti-Fraud Information System 
(AFIS) and the Irregularity Management System (IMS), will enable the achievement of 
operational  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 
multiannual financial framework. 

The strand of the new Programme that will continue the anti-fraud activities will build on 
the  successes  of  the  Hercule  III  programme  and  on  the  findings  of  the  ongoing  final 
evaluation. The Union Anti-Fraud Programme will also tackle anti-fraud aspects related 
to the EU’s priorities, such as climate change or digital transition. 

30 

 
 
 
ANNEX  1:  GRANTS  AND  CONTRACTS  AWARDED  AND  FINALISED  UNDER  THE  2020 
FINANCING DECISION 

Table 1 – TECHNICAL ASSISTANCE grants AWARDED under the 2020 Financing 
Decision 

  MS 

Beneficiary 

Title and description 

1  RO  Directorate 

for 

Investigating 
Organized  Crime  and 
Terrorism - DIICOT 

and 

the  efforts 

in 
indictment 

the 
Strengthening 
prosecution 
of 
smuggling organised groups at the EU 
borders  through  improved  analytical 
and digital forensic capabilities  

Awarded 
grant 
(EUR) 

Co-
fin 
% 

362 072 

80 

2 

IE  Revenue 

Commissioners 

Procurement 
container scanner  

of  mobile  X-ray 

1 440 000 

80 

3  RO  General 

Inspectorate 

of Romanian Police 

Enhanced 
forensic 
Romanian 
capabilities  for  ensuring  the  judicial 
evidence  in  fight  against  financial 
crimes at the EU’s external borders 

541 035 

80 

4 

5 

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

of 

PL  Police  Voivodeship 
in 

Command 
Bialystok 

Strengthening  and  improvement  of 
the 
investigative 
Lithuanian Customs  

capacities 

of 

Implementing 
operational/reconnaissance  activities 
and  evidence  collection  that  improve 
process of detecting offenders against 
financial  interests  of  the  European 
Union  

6 

EL  European 

and 

Development 
Programs 
(EDPD) 

Division 

equipment 

Monitoring 
for 
investigation  of  international  tobacco 
smuggling  and  anti-fraud  operations 
via  regional  surveillance  of  European 
borders  

7 

PL  Police  Voivodeship 
in 

Command 
Bialystok 

enforcement 

Technical and operational support for 
law 
in 
combating illegal cross-border actions 
threatening  financial  interests  of  the 
European Union  

authorities 

695 835 

80 

129 294 

80 

536 760 

80 

96 584 

80 

8 

ES  State 

Administration 
Agency 

Tax 

Tobacco 
detection 
backscattering device of X-ray  

by  manual 

101 411 

80 

9 

IT  Ministry  of  Economy 

and Finance 

Cigarettes  & 
videoscope  

tobacco 

scanner 

415 178 

80 

31 

 
  MS 

Beneficiary 

Title and description 

10  PL  National 

Revenue 

Administration 

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

National 

of 

Awarded 
grant 
(EUR) 

Co-
fin 
% 

312 133 

80 

11  BG  Bulgarian  National 

Revenue Agency 

Improvement  of  the  fiscal  control 
mechanism  in  order  to  strengthen  the 
protection of financial interests of the 
Republic of Bulgaria and the EU  

476 960 

80 

12  PL  National 

Revenue 

Administration 

Development  of  the  ANPRS  system 
by  implementing  the  mobile  OCR 
system  

426 234 

80 

13  RO  Anti-Corruption 

General Directorate 

the 

Improving 
investigation, 
operational  and  technical  methods  in 
fight against corruption  

131 715 

80 

14  PL  Police  Voivodeship 
Command 
in 
Bialystok 

Strengthening 
detection  methods, 
leading  to  effective  eradication  of 
cross-border crime that would lead to 
a financial loss for the EU  

256 262 

80 

15  ES  Ministry of Interior 

Taking measures against and pursuing 
experienced crime organisations in the 
transport,  distribution 
manufacture, 
and export of illegal tobacco  

728 408 

80 

16  PL  Provincial 

Headquarters 
Gdansk 

Police 
in 

Police  as  a  successful  guard  of  the 
EU’s financial interests  

126 424 

80 

17  LV  State Revenue Service  Advanced  analytics  usage  to  provide 

510 000 

80 

effective fraud detection in sales  

18  PL  Police  Voivodeship 
in 
Command 
Bialystok 

Providing  technical  and  operational 
support  in  the  process  of  obtaining 
digital  material 
in 
proceedings  on  illegal  acts  aimed  at 
EU financial interests 

evidence 

370 912 

80 

19  HR  Ministry of Finance 

Inspection equipment and tools for the 
EU external border (2020)  

799 524 

80 

20  PL  Provincial 

Headquarters 
Gdansk 

Police 
in 

Increasing the level of detection of the 
Pomeranian  Police  through  technical 
support  

162 198 

80 

32 

 
  MS 

Beneficiary 

Title and description 

21  LT  Financial 

Crime 
Investigation  Service 
under The Ministry of 
the Interior 

Purchase of special investigation tools 
and equipment  

Awarded 
grant 
(EUR) 

Co-
fin 
% 

97 790 

80 

22  PT  Portuguese  Tax  and 

Customs Authority 

Commodities  and  luggage  scanner  at 
Lisbon airport  

98 400 

80 

23  PT  Ministry of Justice  

Automatic  number  plate  recognition 
systems for criminal investigation  

164 998 

80 

24  PL  Police  Voivodeship 
Command in Olsztyn 

Extension  of  mobile  police  teams  to 
fight and prevent tobacco crime  

411 444 

80 

25  PL  Central 

Anti-

Corruption Bureau 

Integration 
investigation and analysis networks  

digital 

forensics, 

of 

397 425 

80 

26  CZ  General Directorate of 
Customs 

Analytical tool for voice analysis  

132 000 

80 

27  RO  National 

Anticorruption 
Directorate (DNA) 

technical 
Further  developing 
capacity of DNA in protecting the EU 
financial interest 

the 

279 934 

80 

28  RO  General 

Inspectorate 

of Romanian Police 

29  RO  General 

Inspectorate 

of Romanian Police 

Strengthening  the  action  capacity  of 
the  Directorate 
for  Countering 
Organized  Criminality  in  order  to 
protect  EU 
in 
financial 
Romania  

interests 

Integrated  monitoring  system 
for 
illicit  activities  linked  with  cigarette 
smuggling at the eastern border of the 
EU  

290 380 

80 

676 000 

80 

TOTAL 

11 167 310 

33 

 
 
 
 
  
Table 2 – TECHNICAL ASSISTANCE grants FINALISED in 2020 

  MS 

Beneficiary 

Title 

1  LT  Customs 

Department 
the  Ministry 
Finance 
Republic 
Lithuania 

of 

under 
of 
the 
of 

Strengthening  of  operational  and 
technical  capacities  of  the  Customs 
Department 
to  detect  smuggled 
goods in particular cigarettes 

Amount 
paid (EUR) 

Amount 
paid as 
% to 
initial 
commit-
ment37 

1 499 114 

83.11 

2  RO  General 

Inspectorate 
Romanian Police 

of 

Electronic  system  for  investigating 
financial  and  economic  crimes  that 
affect EU financial interests 

376 923 

76.61 

3  DE  Der Polizeipräsident 
in Berlin  

Preventing  and  combating  identity 
fraud and related offences  

259 081 

52.20 

4  EL  Ministry  of  Citizens 
Protection 

Find  –  Fix  –  Finish  –  Exploit  – 
Analyse – Disseminate 

777 830 

86.22 

5  ES  Ministry of Interior 

Sunrise Hawk 

1 172 098 

69.59 

6  LT  Financial 

Crime 

Purchase of intelligence equipment 

88 378 

85.33 

Investigation 
Service  

7 

PL  Revenue 

Administration 
Regional  Office  in 
Lublin 

of 

Purchase 
hand-held  X-ray 
scanners for detecting smuggled and 
illicit tobacco products 

135 031 

58.76 

8  LV  State 

Revenue 

Service (SRS) 

Strengthening  the  SRS  capacity  in 
combating smuggling 

540 000 

97.72 

9 

PL  Police  Voivodeship 
Command in Lublin 

10  PL  Tax  Administration 
Chamber 
in 
Rzeszów 

Enhancing  the  operational  control 
and  technical  possibilities  against 
activities  detrimental  to  the  EU’s 
financial  interests  on  its  eastern 
border  

Increasing  security  of 
the  EU 
customs  area  along  with  combating 
fiscal  crimes  through  introducing 
hand-held 
smuggling 
X-ray 
detectors 

98 274 

100.00 

232 380 

80.05 

37   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.  

34 

 
 
                                                 
  MS 

Beneficiary 

Title 

11  LT  Special 

Investigation 
of 
Service 
Republic 
Lithuania 

Strengthening 
enforcement 
law 
analytical  capacity  in  preventing 
and  detecting  corruption  crimes 
against EU financial interests 

the 
of 

Amount 
paid (EUR) 

Amount 
paid as 
% to 
initial 
commit-
ment37 

322 251 

88.14 

12  RO  National 

Anticorruption 
Directorate 

Consolidating the technical capacity 
of 
the  National  Anticorruption 
Directorate 

349 473 

90.97 

TOTAL 

5 850 833 

Table 3 – DATABASES that were CONTRACTED under the 2020 Financing Decision 

Name 

Content 

1 

IHS Maritime Portal 

Information  on  ship  movements  (expired  5  Jan 
2021) 

2  GTA 

3  DUN 

BRADSTREET 

Trade statistics data 

& 

Company  information  and  financial  details  of 
companies all over the world 

4 

INFORMA  UK  Ltd. 
(Lloyds) 

Information  on  ship  movements  (as  from  15  Dec 
2020) 

Commitment 
in Euro 

129 754  

154 545 

419 290 

233 100 

Total committed under the 2020 budget  

936 689 

Table 4 – ANTI-FRAUD TRAINING, CONFERENCES AND STAFF EXCHANGE 
grants AWARDED under the 2020 Financing Decision 

  MS 

Beneficiary 

Title 

1 

LT  Special 

Investigation 
Service  of  the  Republic 
of Lithuania 

regional 

Strengthening  multidisciplinary 
in 
and 
fighting  corruption  and  fraud 
affecting  EU  financial  interests 
in the Baltic region  

approach 

Awarded 
grant (EUR) 

Co-
fin 
% 

46 772  

80 

2 

EE  Agricultural  Registers 

and Information Board 

Smart protection of EU financial 
interests  in  the  field  of  CAP 

109 972 

80 

35 

 
 
 
 
 
 
 
 
  MS 

Beneficiary 

Title 

expenditures  

Awarded 
grant (EUR) 

Co-
fin 
% 

3 

PL  Police 

Voivodeship 

Command in Lublin 

Safe  Europe  –  together  against 
fraud  on  the  external  border  of 
the EU  

42 709 

80 

4 

IT  Associazione Ethic Safe  Drone  unit  network  against 

59 252 

80 

5 

RO  National  Anticorruption 

Directorate 

environmental crime  

Enhancing 
the  efficiency  of 
investigations  in  complex  cases 
of  fraud  and  corruption  against 
the financial interests of the EU  

90 344 

80 

6 

ES  Ministry of Interior 

Helm of Hades 

71 461 

80 

7 

RO  Anticorruption  General 

Directorate 

8  MT  Malta 

Services 
(MFSA) 

Financial 
Authority 

9 

RO  General  Inspectorate  of 
Romanian Police 

10 

PL 

Chamber 
of 
Administration 
Lublin 

Tax 
in 

11 

IT 

Foundation Lelio e Lisli 
Basso 

12  HU  National 

Institute  of 

Criminology 

13  RO 

General  Inspectorate  of 
Romanian Police 

Valuing  the  efficiency  of  the 
anti-corruption  system  through 
specialised  training  sessions  in 
the technical field  

66 035 

80 

 MFSA AML/CFT Conference  

39 148 

80 

Sharing  knowledge  and  best 
practices  among  relevant  actors 
from  national  and  international 
level  involved  in  fight  against 
financial  crimes  affecting  the 
EU’s budget  

Cross-border  e-commerce:  new 
challenges,  trends  and  control 
methods 
in  preventing  and 
combating tax and customs fraud 
affecting  the  financial  interests 
of the European Union  

The  new  anti-fraud  institutional 
and  legislative  landscape  of  the 
European Union  

risk, 

of 
risk 
Corruption 
corruption? 
Distinguishing 
criteria  between  petty  and  high-
ranking corruption  

and 
Transnational 
multidisciplinary 
cooperation 
between  the  law  enforcement 

36 

108 926 

80 

36 740 

80 

62 474 

80 

138 236 

80 

116 880 

80 

 
 
  MS 

Beneficiary 

Title 

Awarded 
grant (EUR) 

Co-
fin 
% 

in  countering 

authorities 
the 
smuggling  and  intra-community 
fraud affecting the EU budget  

TOTAL 

988 951 

Table  5  –  ANTI-FRAUD  PROCURED  CONFERENCES  organised  by 
Commission under the 2020 Financing Decision 

the 

Dates 

Conference title 

Location 

N° of 
particip. 

Amount 
paid 
EUR38 

October 2020 

Anti-fraud 
(AFCOS) meeting 

coordination 

services 

virtual 
event  

November 2020 

Network  of  the  investigative  units  of 
external aid 

virtual 
event 

84 

24 

TOTAL 

108 

0 

0 

0 

Table 6 – ANTI-FRAUD TRAINING, CONFERENCES and STAFF EXCHANGES 
grants FINALISED in 2020 

  MS 

Beneficiary 

Title 

Amount 
paid 
(EUR) 

Amount 
paid as 
% to 
initial 
commit-
ment39 

1  FR  Robert 

Schuman 

Foundation 

Fighting transit fraud in the European 
Union 

67 243 

67.36 

2  DE  General  Customs 
Directorate 

International  fight  against  waterpipe 
tobacco  

47 569 

73.98 

3  BG  Center 
Study 
Democracy 

for 

the 
of 

Innovative  methods 
investigate 
fraud  and  corruption  in  EU  funding 
for agriculture 

to 

41 047 

67.24 

38   The conferences were organised in a virtual mode, using the available Commission IT tools, triggering 

no costs.  

39  

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.  

37 

 
 
 
 
 
 
                                                 
  MS 

Beneficiary 

Title 

Amount 
paid 
(EUR) 

Amount 
paid as 
% to 
initial 
commit-
ment39 

4  LV  State 

Revenue 

Service 

Advanced  X-ray  image  interpretation 
training 

44 676 

87.87 

5  LT  Lithuanian  Police 
for 

Centre 
Criminal 
Investigation 

in 

Improving  Baltic  States  and  Croatia 
police  computer  forensics  specialists' 
skills 
by 
organising  training  of  UNIX-based 
operating 
and 
scripting 

investigations 

forensics 

systems 

IT 

59 201 

88.11 

6  SK  Financial 

Directorate  of  the 
Slovak Republic 

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

47 571 

84.95 

7  PO  Police 

Voivodeship 
Command 
Lublin 

in 

8  BG  National  Revenue 
Agency 

of 

detecting 

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

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

the 

61 503 

80.85 

79 305 

59.46 

9  RO  National 

Anti-

Corruption 
Directorate 

Trends  in  investigating  frauds  and 
financial 
corruption  affecting 
interests of the European Union 

the 

40 933 

46.33 

TOTAL 

489 049 

Table  7  –  LEGAL  TRAINING  &  STUDIES  grants  AWARDED  under  the  2020 
Financing Decision 

  MS 

Beneficiary 

Title 

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 

Awarded 
grant (EUR) 

Co-
fin 
% 

150 570 

80 

2 

IT  University 

of 

European common custom evaluation  

108 240 

80 

Bologna 

38 

 
 
 
  MS 

Beneficiary 

Title 

3  DE 

JUSTUS-LIEBIG 
University 
Giessen 

of 

EPPO/OLAF 

The 
comparative 
procedural  manual  (CPM)  27+1:  The 
Member  States’  (27)  and  Union  (1) 
law’s  provisions  on  investigations  by 
the  EPPO  and  OLAF, 
thoroughly 
compiled and explained  

Awarded 
grant (EUR) 

Co-
fin 
% 

106 072 

80 

4 

PL 

Institute  of  Legal 
Sciences  of 
the 
Polish Academy of 
Sciences 

5 

IT  University 

of 

Perugia 

Vertical  and  horizontal  cooperation  in 
combating organised fraud in the EU  

62 256 

80 

Financial information exchange among 
national 
laundering 
anti-money 
investigative  authorities: 
towards  a 
stronger  cooperation  in  a  European 
legal framework  

73 267 

80 

6  UK  King's 

College 

London 

Understanding  the  impact  of  China’s 
Belt  and  Road  Initiative  and  COVID-
19 lockdown on illicit supply chains  

32 189 

80 

7 

IT 

Free 

Better knowledge and better solution  

97 634 

80 

Luiss 
International 
University 
Social 
Guido Carli 

of 
Studies 

8 

IT  University 

of 

Bologna 

Financial  interests  of  European  scale: 
of 
assessing 
preventive administrative approach  

effectiveness 

the 

9  DE  Academy 

of 
European  Law  - 
ERA 

Towards  a  multi-tiered  system 
the  protection  of 
ensure 
financial 
means  

to 
the  EU 
interests  by  all  available 

10  HU  University 

of 

Miskolc 

the  external, 
Certain  questions  of 
internal  and  criminal  investigation  of 
the  criminal  offences  affecting  the 
financial  interests  of  the  European 
(fraud,  corruption,  money 
Union 
laundering,  and  other  illegal  activities 
against  the  financial  interests  of  the 
EU)  with  special  focus  on  the  role  of 
OLAF, EPPO, Eurojust, and Europol  

72 102 

80 

45 036 

80 

85 980 

80 

11 

IT  University 

of 

Perugia 

Diversion,  restorative  and  mediation 
procedures  in  protection  of  financial 
interests  

75 508 

80 

TOTAL 

908 851  

39 

 
 
 
 
  
Table 8 – LEGAL TRAINING and STUDIES grants FINALISED in 2020 

  MS 

Beneficiary 

Title 

1  DE  Max Planck Institute  

2  DE  Max Planck Institute 

associations' 

eucrim:  the  European  criminal 
law 
- 
publication of a periodical on the 
protection  of  the  EU’s  financial 
interests (2017) 

forum 

associations' 

eucrim:  the  European  criminal 
law 
- 
publication of a periodical on the 
protection  of  the  EU’s  financial 
interests (2018) 

forum 

Amount 
paid 
(EUR) 

Amount 
paid as 
% to 
initial 
commit-
ment40 

74 146 

100 

78 302 

79.84 

TOTAL 

152 449 

Table  9  –  GLOBAL  OVERVIEW  per  Member  State  of  awarded  grants  and  rejected 
applications in 2020 

Number of 
applications 
received 

Number 
of 
awarded 
grants 

Grants 
requested (EUR) 

Grants 
awarded 

(EUR) 

TECHNICAL 
ASSISTANCE 2020 

47 

29 

24 384 460 

11 167 310 

Bulgaria 

Croatia 

Czech Republic 

Finland 

France 

Greece 

Hungary 

Ireland 

Italy 

1 

1 

1 

1 

1 

2 

1 

1 

2 

1 

1 

1 

0 

0 

1 

0 

1 

1 

476 960 

476 960 

899 465 

799 524 

132 000 

132 000 

2 160 000 

1 353 182 

- 

- 

1 369 080 

536 760 

717 437 

- 

1 440 000 

1 440 000 

1 415 952 

415 178 

40   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.  

40 

 
 
 
 
 
 
                                                 
Latvia 

Lithuania 

Poland 

Portugal 

Romania 

Spain 

TRAINING, 
CONFERENCES AND 
STAFF EXCHANGE 2020 

Cyprus 

Czech Republic 

Estonia 

Hungary 

Italy 

Latvia 

Lithuania 

Malta 

Poland 

Romania 

Serbia 

Slovakia 

Spain 

United Kingdom 

LEGAL TRAINING and 
STUDIES 2020 

Germany 

Hungary 

Italy 

Poland 

Romania 

3 

4 

14 

3 

10 

2 

37 

1 

1 

2 

1 

13 

1 

2 

2 

3 

6 

1 

1 

2 

1 

21 

4 

1 

12 

1 

2 

1 

2 

10 

2 

6 

2 

2 089 042 

510 000 

1 515 620 

793 625 

3 529 740 

2 688 911 

2 637 414 

263 398 

3 727 698 

2 281 136 

920 870 

829 819 

13 

4 956 988 

988 951 

0 

0 

1 

1 

2 

0 

1 

1 

2 

4 

0 

0 

1 

0 

89 889 

81 847 

- 

- 

859 973 

109 972 

193 894 

138 236 

998 836 

121 727 

76 774 

136 607 

122 967 

118 711 

- 

46 772 

39 148 

79 450 

639 912 

382 185 

1 360 706 

33 932 

142 877 

100 063 

- 

- 

71 461 

- 

11 

2 069 144 

908 851 

3 

1 

5 

1 

0 

41 

465 914 

301 677 

98 856 

85 980 

1 161 000 

426 749 

70 841 

62 256 

240 344 

- 

 
United Kingdom 

TOTAL  

1 

105 

1 

53 

32 189 

32 189 

31 410 592 

13 065 112 

42