COMMISSION STAFF WORKING DOCUMENT Annual overview with information on the results of the Union anti-fraud programme in 2021 Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL 33rd Annual Report on the protection of the European Union's financial interests and the fight against fraud - 2021
Date: 2022-09-23
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

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   EUROPEAN COMMISSION  Brussels, 23.9.2022  SWD(2022) 305 final  COMMISSION STAFF WORKING DOCUMENT Annual overview with information on the results of the Union anti-fraud programme in 2021 Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL 33rd Annual Report on the protection of the European Union's financial interests and the fight against fraud - 2021 {COM(2022) 482 final} - {SWD(2022) 302 final} - {SWD(2022) 303 final} - {SWD(2022) 304 final} - {SWD(2022) 306 final} - {SWD(2022) 307 final}  
 
 
TABLE OF CONTENTS 

1. 

Introduction ....................................................................................................................... 2 

1.1 

1.2 

Final evaluation of the Hercule III programme (2014-2020) ................................................... 2 

2021-2027 Union anti-fraud programme: context and implementation ................................ 3 

1.2.1. 

Context .............................................................................................................................3 

1.2.2. 

Implementation methodology .........................................................................................4 

1.3 

Purpose and scope of this overview ........................................................................................ 5 

2.  UAFP budget implementation in 2021 ............................................................................ 5 

2.1  Activities  to  prevent  and  combat  fraud,  corruption  and  any  other  illegal  activities 
undermining the financial interests of the EU (as in the former Hercule III programme) .................. 7 

2.1.1. 

Grants ...............................................................................................................................9 

a) 

b) 

Call for proposals for technical assistance .................................................................... 11 

Call for proposals for training, conferences, staff exchanges and studies .................... 12 

2.1.2. 

Procurement .................................................................................................................. 13 

a) 

i. 

ii. 

iii. 

b) 

c) 

IT support: databases, IT tools and analyses of samples from tobacco seizures .......... 13 

Databases ...................................................................................................................... 13 

Development of specific IT tools for data analysis with the JRC ................................... 13 

Tobacco analyses (TOBLAB) ........................................................................................... 16 

Procured conferences .................................................................................................... 17 

Procured digital forensics and analysts training ........................................................... 17 

3.  UAFP (Hercule component) - achievements in 2021 ................................................... 17 

3.1. 
Examples of technical assistance projects funded under the Hercule III programme 
and finalised in 2021 ......................................................................................................................... 19 

3.2. 
Examples of training projects funded under the Hercule III programme and finalised 
in 2021 ...................................................................................................................................................  

20 

3.3. 

Examples of procured access to external databases............................................................. 23 

4. 

IMS – implementation in 2021 ....................................................................................... 24 

4.1.  Main activities ....................................................................................................................... 24 

4.2.  What does the AWP involve? ................................................................................................ 26 

4.3.  Maintenance and development ............................................................................................ 26 

4.4. 

Legal basis .............................................................................................................................. 27 

4.5. 

Studies ................................................................................................................................... 27 

5.  AFIS – implementation in 2021 ..................................................................................... 27 

6.  Communication ............................................................................................................... 28 

6.1. 

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

6.2. 

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

6.3.  Workshop for grant beneficiaries .......................................................................................... 29 

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6.4. 

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

7.  Feedback from programme participants ...................................................................... 30 

8.  Conclusions and way forward ........................................................................................ 31 

Annex I – Overview of projects awarded and finalised in 2021 ......................................... 32 

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1 

Introduction 

The  fight  against  fraud  to  protect  the  EU’s  financial  interests  is  a  shared  responsibility  for 
Member  States  and  the  EU.  It  is  thus  in  the  interest  of  the  EU,  and  of  EU  taxpayers  more 
generally,  that  national  and  regional  authorities  are  sufficiently  equipped  to  carry  out  this 
important  mission.  This  is  why  the  EU  has  supported  national  anti-fraud  capacities  for  16 
years with the three successive Hercule programmes.   

The year 2021 not only marks a general transition to a new multiannual financial framework 
(MFF)  for  the  years  2021  to  2027,  but  also  a  specific  transition  to  a  new  anti-fraud 
programme.  

1.1 

Final evaluation of the Hercule III programme (2014-2020) 

Hercule III ended on 31 December 2020, even if some projects initiated under it are still being 
implemented.  Inevitably,  the  COVID-19  pandemic  triggered  some  delays  for  beneficiaries 
struggling with their schedules for project preparation and implementation. 

The  Hercule  III  programme  aimed  to  protect  the  financial  interests  of  the  EU  by  fighting 
fraud, corruption and any other illegal activities. The programme provided this protection by 
making  available  financial  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’. 

This  financial  support  mostly  consisted  of  grants  awarded  to  Member  State  authorities  in 
charge of combating fraud to reinforce their operational and technical capacity to detect and 
investigate activities that are detrimental to the financial interests of the EU. Member States 
have used this support to purchase technical equipment, such as detection, investigation and 
forensic  tools,  or  to  purchase  and  install  integrated  systems  for  number-plate  recognition, 
among other things.  

The  programme  also  financed  training  activities,  conferences,  comparative  research  and 
scientific publications on fraud-related topics.  
Pursuant  to  Article 13(2)(b) of the Hercule  III Regulation (Regulation  (EU) No 250/20141), 
the European Commission presented a final evaluation report on the results and achievements 
of the programme to the European Parliament and to the Council2 in December 2021.  

A  comprehensive  study  prepared  by  an  external  consultant  underpinned  the  report.  In  this 
study, the external consultant analysed 98 case studies and organised more than 50 interviews 
with  a  variety  of  officials.  The  evaluation  contains  a  number  of  conclusions  and 
recommendations.  

The  evaluation  notes  that  the  Hercule  III  programme  was  highly  relevant  in  supporting 
Member States’ anti-fraud activities. Action on technical assistance and training was found to 
be highly effective and generating positive direct (technical equipment) and indirect (training) 
impact.  Overall,  the  evaluation  strongly  supports  the  rationale  and  implementation  of  the 
programme. 

1 Regulation (EU) No 250/2014 of the European Parliament and of the Council of 26 February 2014, OJ L 84 of 

20.03.2014. 

2 Link to the Report of the Commission to the European Parliament and the Council, with its accompanying staff 

working document: https://ec.europa.eu/anti-fraud/policy/hercule-reports_en. 

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For  the  future,  the  evaluation  recommends  a  stronger  focus  on  expenditure  and  emerging 
threats  such  as  cyber  issues.  Finally,  the  programme  is  considered  internally  and  externally 
coherent,  even  if  continued  attention  will  be  required  to  properly  align  the  successor 
programme with relevant other Commission programmes. 

1.2 

2021-2027 Union anti-fraud programme: context and implementation 

1.1.1  Context 

The Hercule III programme has come to a close, but the successful assistance provided under 
this  scheme  continues  under  the  new  Union  anti-fraud  programme  (UAFP).  As  a  key 
milestone,  the  European  Parliament  and  the  Council  adopted  Regulation  (EU)  2021/785 
setting up the UAFP on 29 April 20213. This legal act became applicable retroactively as of 
1 January 2021.  

The UAFP combines three different, previously separated activities, but at its core, it builds 
on  the  success  of  the  Hercule  III  programme.  The  UAFP  provides  a  single  framework, 
bringing together:  

(i) 
(ii) 

(iii) 

the Hercule funding part;  
the  financing  of  the  Anti-Fraud  Information  System  (AFIS,  supporting  Member 
States in providing mutual assistance in customs and agricultural matters); and  
the  Irregularity  Management  System  (IMS,  for  the  reporting  of  irregularities, 
including  fraud,  in  cases  related  to  the  shared-management  funds  and  the  pre-
accession-assistance funds4).  

This single framework increases synergies between its strands and economises on resources. 
For example, it provides financial flexibility to reallocate funding within the programme. 

An  annual  Commission  implementing  decision  sets  out  the  financing  of  the  UAFP  and  the 
annual  work  programme  (AWP).  This  single  legal  act  provides  for  funding  for  all  eligible 
actions supported by the programme, and for the financing of the AFIS and the IMS. 

The UAFP is based on Articles 33 and 325 of the Treaty on the Functioning of the European 
Union (TFEU). It is set up for a period of 7 years, from 2021 to 2027, in line with the MFF 
laid down in Council Regulation (EU, Euratom) 2020/20935.  

The  UAFP  pursues  two  general  objectives.  First,  it  aims  to  protect  the  EU’s  financial 
interests. Second, it aims to support mutual assistance between the administrative authorities 
of  the  Member  States  and  cooperation  between  these  authorities  and  the  Commission  to 
ensure that the law on customs and agricultural matters is correctly applied. 

The programme pursues three specific objectives: 

1.  to  prevent  and  combat  fraud,  corruption  and  any  other  illegal  activities  affecting  the 

financial interests of the EU; 

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

3 OJ L 172, 17.5.2021, p. 110-122. Link:  (http://data.europa.eu/eli/reg/2021/785/oj). 
4 See Chapter 4 for more details, please see Chapter 4 of the present SWD. 
5  Council  Regulation  (EU,  Euratom)  2020/2093  of  17  December  2020  laying  down  the  multiannual  financial 

framework for the years 2021 to 2027 (OJ L 433433I, 22.12.2020, p. 11). 

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3.  to provide tools for information exchange and support for operational activities in the 

field of mutual administrative assistance in customs and agricultural matters. 

To  implement  the  UAFP,  the  EU  has  allocated  EUR 181 207 000  in  current  prices  for  the 
period from 2021 to 2027, as shown in Graph 1. 

Graph 1 – Budget allocation 

2021-2027 budget allocation

IMS - €7 m

AFIS - €60 m

Hercule - €114,2 
m

Hercule - €114,2 m

AFIS - €60 m

IMS - €7 m

1.1.2 

Implementation methodology 

The first component of the programme provides the Member States with targeted assistance in 
achieving  their  obligations  to  protect  the  EU’s  financial  interests.  This  component  will 
support the purchase of specialised anti-fraud equipment and tools, specific trainings as well 
as targeted conferences and studies. 

The Commission implements this component by:  

1.  awarding grants following calls for proposals;  
2.  concluding public-procurement contracts following calls for tenders; 
3.  entering  into  administrative  arrangements  with  the  Commission’s  Joint  Research 

Centre (JRC); 

4.  reimbursing costs incurred by representatives from eligible countries who participate 

in training and operational activities; and 

5.  offering  targeted  support  to  relevant  international  organisations  actively  helping  to 

protect the EU’s financial interests. 

Under the second component,  the Commission maintains the  IMS and makes it available to 
Member  States  to  facilitate  their  compliance  with  the  obligation  (laid  down  in  various 
sectorial pieces of legislation) to report detected irregularities.  

The third component consists of (i) the operation and maintenance of the AFIS platform for 
the  exchange  of  mutual-assistance  information;  and  (ii)  supported  activities,  such  as  joint 
customs operations, courses, and preparatory or evaluation meetings for operational action. 

In  practice,  the  programme  is  implemented  under  direct  management.  The  European  Anti-
Fraud Office (OLAF) is the lead service for programme implementation. 

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The UAFP Regulation identifies four categories of eligible entities: 

1.  public authorities that can help achieve a UAFP objective and are established:  

i) 
in a Member State or an overseas country or territory associated with the UAFP; 
ii)  in  a  third  country  associated  with  the  UAFP  under  the  conditions  specified  in 

Article 4 of the UAFP Regulation; or, 

iii) in a third country not associated with the UAFP under the conditions specified in 

Article 10(3) of the UAFP Regulation. 

2.  research  and  educational  institutes  and  non-profit  making  entities  that  can  help  to 
achieve  the  objectives  of  the  UAFP  and  have  been  established  and  operating  for  at 
least 1 year:  
i) 
ii)  in  a  third  country  associated  with  the  UAFP  under  the  conditions  specified  in 

in a Member State; 

Article 4 of the UAFP Regulation; or  

iii)  in a third country not associated with the UAFP under the conditions specified in 

Article 10(3) of the UAFP Regulation. 

3.  any legal entity created under Union law; or, 
4.  any international organisation. 

1.3 

Purpose and scope of this overview 

Article 12(3) of Regulation (EU) 2021/785 obliges the Commission to report annually on the 
performance of the programme to the European Parliament and to the  Council as part of its 
annual  report  on  the  protection  of  the  EU’s  financial  interests  –  fight  against  fraud.  Article 
12(3)  also  stipulates  that  when  discussing  the  UAFP,  the  European  Parliament  may  make 
recommendations for the AWP, and that the Commission must duly take these into account. 

To this end, this overview covers: (i) information on actions for which financial commitments 
were made under the 2021 Financing Decision and AWP6, adopted on 23 July 2021; and (ii) 
the results of actions finalised in 2021 but for which financial commitments were made under 
the Hercule III programme in previous years.  

The  overview  also  contains  information  on  AFIS  and  IMS  activities  for  which  financial 
commitments  were  made  under  the  same  2021  AWP.  Due  to  the  late  adoption  of  the  MFF 
Regulation7  (17 December 2020)  covering  the  multiannual  budget  of  the  EU  from  2021  to 
2027, a dedicated financing decision was adopted in early 2021 to ensure business continuity 
of the AFIS (namely the uninterrupted provision of important IT systems to Member States) 
during the first months of that year8.  

2  UAFP budget implementation in 2021 

To implement the UAFP in 2021, the budgetary authority had allocated EUR 24.04 million in 
commitment  appropriations  and  EUR 2.54  million 
in  payment  appropriations.  The 
programme  is  financed  under  item  03.03  of  the  EU  budget,  as  shown  in  Table  1  (split  by 
year). 

7   OJ L 433433I, 22.12.2020, p. 111. 
8   Commission Decision C(2021) 2120 of 7.4.2021.  

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Table 1: Financial programming in 2021-2027 

2021 

2022 

2023 

2024 

2025 

2026 

2027 

(in EUR) 

Total 

24,055,021 

24,371,021  24,852,023  25,508,023  26,353,026  27,404,026  28,678,028 

Programme 
total 
181,221,168 

Table 2 shows the commitments made under the available budget for 2021, broken down by 
the programme’s three components. 

Table 2: Available budget and commitments made in 2021 

TYPES OF ELIGIBLE ACTIONS (2021) 

BUDGET 
(EUR) 

COMMITTED 
(EUR) 

COMMITTED 
(%) 

COMPONENT 1: PROTECTION OF THE EU’S FINANCIAL INTERESTS 

TECHNICAL ASSISTANCE 

Grants: technical assistance 

Grants 

9 300 000 

10 678 299 

IT databases 

Procurement 

1 000 000 

IT tools and tobacco analysis  

Procurement 

560 000 

ANTI-FRAUD TRAINING 

Grants: anti-fraud training 

Grants 

1 600 000 

Procured conferences  

Procurement 

700 000 

707 360 

717 961 

802 285 

144 715 

Digital forensics and analyst training  

Procurement 

1 800 000 

1 414 000 

FCTC9 

Grants 

200 000 

53 628 

115% 

70.7% 

128%  

50.1% 

20.7% 

78.6% 

26.8% 

TOTAL COMPONENT 1  

15 160 000 

14 518 248 

95.8% 

COMPONENT 2: AFIS PLATFORM 

IT studies, development and maintenance 

Procurement 

3 200 000 

4 056 540 

Production services 

Procurement 

2 600 000 

1 750 021 

Technical  assistance,  training,  coordination 
and quality-control services 

Acquisition,  maintenance  and  updating  of 
software  and  hardware,  and  related  IT 
services 
the  Directorate-
Funds  co-delegated 
General  for  Taxation  and  Customs  Union 
(DG TAXUD) 
Contingency 

to 

Procurement 

722 000 

194 797 

Procurement 

1 189 721 

1 246 975 

105% 

Procurement 

252 279 

252 279 

100% 

TOTAL COMPONENT 2 

7 964 000 

463 388 

7 964 000 

100% 

127% 

67.3% 

26.9% 

9      Financial  support  to  the  Secretariat  of  the  World  Health  Organization  Framework  Convention  on  Tobacco 
Control (FCTC), in its functions related to the Protocol to Eliminate Illicit Trade in Tobacco Products, and to 
other  activities  organised  by  the  Secretariat  in  connection  with  the  fight  against  illicit  trade  in  tobacco 
products. 

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Study 

Development 

Maintenance, support and training 

TOTAL COMPONENT 3 
GRAND TOTAL 

COMPONENT 3: IMS TOOL 

Procurement 

Procurement 

Procurement 

150 000 

306 000 

473 000 

232 591 

564 722 

117 163 

929 000 
24 053 000 

914 476 
23 396 724 

169% 

184.5% 

27.7% 

98% 
97.3% 

2.1 

Activities  to  prevent  and  combat  fraud,  corruption  and  any  other  illegal 
activities  undermining  the  financial  interests  of  the  EU  (as  in  the  former 
Hercule III programme)  

In 2021, the UAFP’s first  year of implementation, the available  commitment appropriations 
for the programme’s first strand (formerly Hercule) were used to: (i) finance granted projects; 
and  (ii)  conclude  specific  contracts  (procurement)  and  administrative  arrangements  for 
providing  access  to  commercial  databases,  specialised  IT  tools  and  specific  training  and 
conference events, in line with the activities included in the adopted AWP for 202110.  

The  commitment  amounts  earmarked  for  the  2021  granting  cycle  (approximately  EUR 11 
million) were implemented by signing contracts  for the awarded  grant  files and paying pre-
financing.  

The  exceptional  circumstances  of  2020  and  2021  due  to  the  COVID-19  pandemic  had  a 
significant impact on the general implementation of the programme. Many procured training 
activities  and  conferences  had  to  be  postponed  or  cancelled  in  2021.  A  few  of  them  were 
organised in a virtual or hybrid mode (see Annex I, Table 5).  

Following  a  successful  publication  and  evaluation  of  the  2021  ‘technical  assistance  call  for 
proposals’,  unused  amounts  earmarked  for  training  grants,  procured  forensic  and  anti-fraud 
training in the 2021 budget have been transferred to this specific call, where a reserve list had 
been established.  

This  transfer  of  approximately  9%  of  the  total  annual  budget  ensured  an  efficient 
implementation of operational funds and the award of funding to high-quality proposals that 
could not have been financed otherwise.  

Payments under the grant agreements and under some of the procurement contracts signed in 
2021 will be reported at a later stage than the present report, since these payments will only be 
made in the course of 2022 and in the following years. 

Graph 2: Breakdown of the UAFP’s (Hercule component) planned budget and achieved 
commitments11 in 2021 by type of financial support (grants and procurement) 

10  Commission Implementing Decision, C(2021) 5338 final of 23.7.2021. 
11    Around  4%  of  the  annual  budget  was  left  uncommitted  due  to  the  fact  that  few  of  the  planned  procured 
activities  (such  as  training  and  conferences)  did  not  take  place  in  2021,  due  to  the  ongoing  sanitary 
circumstances.  

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Graph 3 provides a breakdown of the planned budget and commitments for 2021 by type of 
action. Technical assistance actions under Regulation (EU) 2021/785 encompass: (i) technical 
assistance grant activities; and (ii) IT support (databases and IT tools).  

Training actions include: (i) grant activities under calls for proposals for training, conferences, 
staff exchanges and studies; and (ii) procured conferences and specialised training. 

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Graph  3:  UAFP  (Hercule  component)  budget  and  commitments  in  2021  by  type  of 
eligible action12 

2.1.1  Grants 

Grants are direct financial contributions to finance an action intended to help achieve an EU 
policy objective. The overall UAFP budget allocated to grants in 2021 was EUR 10.9 million. 
Following  calls  for  proposals  inviting  applicants  to  submit  proposals  for  actions  that  help 
achieve 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.  

In July 2021, the Commission published two calls for proposals on its Funding and Tenders 
Portal. The late adoption of Regulation (EU) 2021/785 setting up the UAFP delayed the 2021 
granting cycle (compared to previous years). However, the Commission envisages a return to 
the usual annual implementation cycle in the following years.  

12 FCTC: Framework Convention on Tobacco Control (also see footnote 10 also). 

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The two 2021 calls covered the following topics:  

1.  technical assistance, with an indicative budget of EUR 9.3 million; and 
2.  training,  conferences,  staff  exchanges  and  studies,  with  an  indicative  budget  of 

EUR 1.6 million.  

The deadline to submit applications was 5 October 2021. The Commission received a total of 
55 applications originating from 14 Member States. First, each application was assessed on its 
eligibility  or  on  a  possible  exclusion.  Then,  a  dedicated  evaluation  committee  with 
Commission  expert  staff  members  assessed  the  content  of  each  application.  The  committee 
evaluated the following four award criteria:  

1.  conformity with the objectives of the UAFP; 
2.  quality of the proposal; 
3.  value for money; and 
4.  added value for the protection of the EU’s financial interests. 

The  evaluation  process  was  finalised  in  early  2022  and  all  applicants  were  informed  of  its 
outcome by the end of March 2022.   

Graph 4 gives an overview of the total value and number of grants for technical assistance and 
training awarded in 2021, by Member State. The graph shows that grants have been awarded 
to applicants from 12 Member States.  

Graph 4: UAFP (Hercule component) commitments (in EUR) and number of grants in 
2021 by Member State and by activity sector 

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a) 

Call for proposals for technical assistance 

The 2021 budget for technical assistance grants was EUR 9.3 million. It was available to fund 
actions proposed by national and regional authorities for the following types of activities: 

1. 

2. 

3. 

4. 

purchasing  and  maintaining  investigation  and  surveillance  tools  and  methods 
used in the fight against irregularities, fraud and corruption perpetrated against 
the  financial  interests  of  the  EU,  including  specialised  training  needed  to 
operate the investigation tools; 
purchasing  digital-forensics  hardware  including  equipment  and  software, 
mobile forensic tools and computer forensic collaborative systems used in the 
fight against (fraudulent) irregularities, fraud and corruption detrimental to the 
EU’s financial interests;  
purchasing  data-analytics  technologies  and  data  including  the  acquisition  and 
maintenance  of:  (i)  commercial  specialised  databases;  (ii)  data-analysis 
platforms  capable  of  running  analyses  in  big-data  environments,  risk  and 
predictive  analyses,  and  data-mining  tools;  and  (iii)  systems  supported  by 
artificial  intelligence  used  in  the  fight  against  irregularities,  fraudulent 
activities and corruption detrimental to the EU’s financial interests; and 
purchasing  equipment  for  the  detection  of  illicit  trade13  to  strengthen 
beneficiaries’  operational  and  technical  capacity  to  detect  smuggled  and 
counterfeited  goods,  including  cigarettes  and  tobacco,  imported  into  the  EU 
with  the  intention  of  evading  value  added  tax,  customs  duties  and/or  excise 
taxes.  

By  the  deadline  of  5 October 2021,  the  Commission  received  45  applications  from  13 
Member  States.  The  total  (cost)  of  the  proposed  actions  was  EUR 24.9  million  and  the 
requested  funding  (UAFP  financial  support)  amounted  to  EUR 20.3  million  (or  more  than 
double  the  available  budget).  Following  the  evaluation  committee’s  recommendation,  the 
authorising  officer  decided  to  award  grants  for  19  actions  and  to  place  5  proposals  on  a 
reserve list (see Annex I – Overview of projects awarded and finalised in 2021, Table 1).  

All applicants were informed of the outcome of the evaluation procedure in March 2022. The 
overall  amount  approved  for  technical  assistance  grants  was  EUR 9.1  million.  One  of  the 
selected  beneficiaries  decided  to  withdraw  their  project  due  to  objective  organisational  and 
financial  constraints.  Given  the  availability  of  these  funds  and  of  those  under  other 
programme  sections  (e.g.  training  activities),  grants  were  awarded  to  all  five  proposals 
initially placed on the reserve list by the end of May 2022 (resulting in an adjusted total of 23 
awarded grants). 

Grants  were  awarded  for  the  purchase  of  investigation  equipment  (including  forensics 
equipment),  data-analysis  systems,  IT  tools  and  detection  equipment.  The  UAFP  grants 
financed 80% of the eligible costs of the actions.  

Table  1  in  Annex  I  provides  an  overview  of  the  beneficiaries,  project  titles,  grant  amounts, 
and co-financing rates. 

13  OLAF, in close cooperation with DG TAXUD, ensured that there was no overlap with projects submitted for 

support under the new Customs Control Equipment Instrument (CCEI). 

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To  best  describe  the  implementation  of  technical  assistance  grants  in  2021,  a  selection  of 
examples of finalised projects is presented in Chapter 3. 

b) 

Call for proposals for training, conferences, staff exchanges and studies 

The  UAFP  provides  grants  to  beneficiaries  for  organising  targeted  specialised  trainings, 
conferences and staff exchanges. These activities aim to strengthen cross-border cooperation 
and networking activities between experts and to facilitate the exchange of best practices on 
protecting the financial interests of the EU.  

The following four types of activities were proposed for funding, with an indicative budget of 
EUR 1.6 million: 

1. 

2. 

3. 

4. 

(iii) 

specialised  training  sessions  to  improve  investigation  and  data-analysis 
abilities by  acquiring new skills  and knowledge  of specialised methodologies 
and techniques; 
conferences,  workshops  and  seminars  to:  (i)  facilitate  the  exchange  of 
information,  experience  and  best  practices,  including  in  the  field  of  data 
analysis;  (ii)  create  networks  and  improve  coordination  between  Member 
States,  candidate  countries,  other  third  countries,  EU  institutions  and 
international  organisations; 
facilitate  multidisciplinary  cooperation 
between  anti-fraud  practitioners  and  academics  on  protecting  the  EU’s 
financial interests, including support to associations for European criminal law 
and  for  the  protection  of  the  EU’s  financial  interests;  and  (iv)  raise  the 
awareness of the judiciary and other legal professionals of this matter; 
staff  exchanges  between  national  and  regional  administrations  (including 
candidate  and  neighbouring  countries)  to  help  further  develop,  improve  and 
update staff’s competences in protecting the EU’s financial interests; and 
developing  comparative  law  studies  and  organising  activities  to  raise 
awareness  among  the  judiciary  and  other  branches  of  the  legal  profession  on 
protecting the EU’s financial interests, including the dissemination of relevant 
scientific knowledge through periodical publications. 

The call received ten applications from seven Member States. The total amount of requested 
grants  was  EUR 1.4  million.  It  should  be  acknowledged  that  because  the  COVID-19 
pandemic  continued  in  2021,  the  circumstances  were  not  favourable  to  the  organisation  of 
conferences and training events.  

Six  applications  were  selected  for  an  award  under  this  call,  for  an  overall  amount  of 
approximately EUR 0.8  million,  mostly receiving  a co-financing  rate of  80% of the  eligible 
costs14.  

Grants  were  awarded  for,  amongst  others:  (i)  carrying  out  studies  on  rules  and  practices  on 
detection and reporting of suspected fraud in EU agricultural funds; (ii) carrying out studies 
on  the  applicability  of  the  non-incrimination  principle  in  administrative  proceedings  and 

14  The maximum co-financing rate is 80% for the training grants, but the Commission may award in exceptional 
and  duly        justified  cases,  the  Commission  may  award  a  grant  up  to  90%  of  eligible  costs.  One  project 
covering  one  of  the  priority  areas  listed  in  the  call  was  awarded  a  90%  co-financing  rate.  See  Table  4  of 
Annex I. 

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OLAF investigations; and (iii) publishing a periodical on the protection of the EU’s financial 
interests.  

Table  4  in  Annex  I  gives  an  overview  of  the  awarded  grants  and  the  corresponding  co-
financing rates. 

2.1.2  Procurement 

About 27% of the 2021 budget allocated to the first component of the UAFP (EUR 4 060 000) 
was allocated to fund activities by concluding procurement contracts linked to the protection 
of the EU’s financial interests. 

In 2021, the Commission concluded specific contracts under existing framework contracts for 
technical  assistance  support  and  training  activities.  The  purchased  equipment,  tools  and 
services were made available to UAFP beneficiaries (mainly Member State authorities). 

a) 

IT support: databases, IT tools and analyses of samples from tobacco seizures 

i. Databases 

In  2021,  the  overall  amount  committed  to  procured  contracts  was  EUR 707 360.  The 
programme provides funds for the procurement of subscriptions to commercial databases, on 
behalf  of  law-enforcement  authorities  in  Member  States,  to  support  operations  and 
investigations, in particular in the area of protecting the EU’s financial interests.  

The  Commission  procures  and  manages  the  access  to  these  databases  enabling  substantial 
economies  of  scale  and  a  common  data  framework.  Relevant  staff  are  trained  to  ensure 
optimal  usage.  OLAF  staff  also  uses  these  databases  for  operational  activities  jointly 
undertaken with their Member State partners and for their own investigations15.  

In 2021, the programme provided Member States with access to commercial databases, such 
as  worldwide  trade  statistics,  detailed  company  information  and  global  vessel  movements. 
The databases were highly used by customs and other law-enforcement authorities, supporting 
both investigations and risk analyses. Table 3 in Annex I gives an overview of the contracts 
awarded in 2021.  

ii. Development of specific IT tools for data analysis with the JRC 

In 2021, OLAF and the JRC continued the administrative arrangement (AA) for the Customs 
Anti-Fraud  Enabling  Technologies’  project.  Funded  by  the  Hercule  III  programme,  the  AA 
was  concluded  at  the  end  of  201716  between  OLAF  and  the  JRC  to  provide  ‘scientific  and 
technical support in advancing the EU’s customs anti-fraud data-analytics capacity’17.  

15   The use of databases made by OLAF staff is paid from the administrative budget of the Commission.    
16  The first administrative arrangement was signed in late December 2017. It covered work carried out 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). 

17    This  work  falls  under  the  activity  described  in  point  (a)(v)  of  Article  8  of  Regulation  (EU)  No  250/2014 
establishing a programme to promote activities in the field of the protection of the financial interests of the 
European Union (Hercule III programme). 

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At  the  end  of  202018,  the  project  was  made  more  efficient  by  incorporating  work  packages 
previously carried out under separate AAs, such as the automated monitoring tool (AMT) and 
container-movement analytics. Currently, the CAFET projects consists of five work packages. 

The project, with a duration of three years, is part of a wider effort to provide knowledge to 
and facilitate the work of customs services in the Member States for the effective and efficient 
use of data and analytical approaches in their anti-fraud activities.  

In  line  with  the  objectives  of  the  UAFP,  the  main  beneficiaries  of  this  project  are  customs 
authorities in the Member States. Since this project aims to improve the overall effectiveness 
and  efficiency  of  anti-fraud  data  analysis  carried  out  by  customs  services  across  the  EU, 
OLAF will also benefit from the results.  

Work package 1: AMT 

The AMT generates signals on anomalies in international trade. The UAFP funding allocated 
to the AMT, under the CAFET umbrella, amounts to EUR 505 200 for 2021. The number of 
AMT users reached almost 3 300 in 2021, with 1 900 of them regularly retrieving information 
on long-term trends and further analyses of potential undervaluation.  

The  AMT  is  an  algorithm  that  retrieves  and  processes  subsets  from  Eurostat’s  COMEXT 
database.  It  links  this  selection  with  information  from  customs  declarations  and  the 
Commission’s  tariff  database  (TARIC)  to  identify  patterns  and  long-term  trends  of  imports 
into the EU.  

Long-term trends  are presented as  average  aggregated prices of imports from one exporting 
country into the EU and are further broken down by Member State. The AMT identifies any 
import that deviates substantially from these long-term trends and flags it as anomalous.  

The  results  of  the  AMT  are  shown  with  the  help  of  dashboards  (i.e.  interactive,  read-only 
displays with  the results  of predefined queries).  The results cover, for example, the average 
monthly prices  over 48 months of imported goods broken down by product  code, exporting 
country and importing Member State. The AMT generates results to support risk-management 
activities carried out by Member States’ 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  valuation  purposes.  These  estimates  are  the  basis  for 
assessing the amount of duty that should be collected and the related potential total losses due 
to undervaluation in the EU.  

Work package 2: Container-movement analytics 

Container-movement analytics and analyses of potential origin fraud (ConTraffic) have been 
further consolidated and developed. In the first nine months of 2021, ConTraffic averaged 115 
user logins (covering 45 distinct users). 

Checks  on  potential  origin  detected  that  about  2%  of  the  analysed  goods/items  had  a 
mismatching  origin.  Based  on  these  mismatches,  OLAF  identified  332  possible  signals  of 
anomalies and communicated these to Member States’ customs services. 

Work package 3: Tobacco track and trace analytics (T&T) 

18  Administrative arrangement SI2.842203/451 / JRC.35809-2020, December 2020. 

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This project was initiated under the INTEL4CUSTAF project in 2020 and is currently being 
further explored under the CAFET project. Under this work package, the Commission’s aims 
to investigate the potential of the new tobacco (T&T) data to identify signals of suspicious or 
potentially  fraudulent  activities  involving  tobacco  products.  The  Directorate-General  for 
Health and Food Safety (data owner) and OLAF (business owner) are involved together with 
the JRC. 

Work package 4: e-Commerce  

Progress  with  this  work  package  was  held  up  in  2021  due  to  the  unavailability  of  suitable 
e-commerce  data.  Several  initiatives  and  negotiations  are  ongoing  between  Commission 
services  and various e-commerce platforms, which will hopefully lead to providing relevant 
data for analysis in 2022. 

Work package 5: Other analytical tools and exploratory work  

This work package brings together activities related to the development of smaller analytical 
tools  or  new  analyses  of  potential  interest,  based  on  experience  with  the  previous  AAs, 
interaction with Member States and OLAF operational activities.  

In 2021, research looked into the correspondence between textual descriptions of imports and 
their  declared  commodity  codes,  to  identify  potential  cases  of  misdescription  fraud.  On  a 
limited data set, some promising results were identified. 

Work  was  also  carried  out  to  make  an  open-source  version  (coded  in  Python)  of  the 
Doppelganger  method,  ready  to  be  implemented  in  the  AFIS  or  in  the  IT  system  of  any 
Member  State’s  customs  services.  Doppelganger  is  an  analytical  technique  created  by  the 
Belgian customs that analyses national import data to identify possible cases of misdescribed 
import declarations (signals). It does this by cross-checking information from known cases of 
misdescribed import declarations with information from new import declarations. 

From its inception, the project was conceived as a data and risk-analysis project, facilitating 
efficient  EU-wide  cooperation  and  use  of  customs  data,  including  sharing  of  best  practices 
and  strengthening  analytical  capacities  to  better  target  anti-fraud  checks  carried  out  by 
customs services and to improve investigations.  

The CAFET is  intended to  support the  analytical  activities of Member State authorities and 
OLAF to combat fraud in a wider sense. It continues work on well-known and to some extent 
already researched fraud-control problems, for example undervaluation (addressed here using 
AMT)  and  misdescription  of  origin  (addressed  here  using  container-movement  analysis). 
However,  it  has  also  started  new  research  into  problems  such  as  illicit  tobacco  trade  and 
product misdescription fraud, which have been identified as priorities by Member States. As 
data  becomes  available,  provision  has  also  been  made  to  look  into  the  growing  issue  of  e-
commerce fraud. 

In  the  past,  wider  communication  and  network  building  with  Member  States  took  place. 
Unfortunately, due to the continued problems caused by COVID-19, this remained difficult in 
2021. However, updates were provided at the regular meetings of the Expert Group on Mutual 
Assistance in Customs Matters. 

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iii. Tobacco analyses (TOBLAB) 

It  is  estimated  that  cigarette  smuggling  costs  the  EU  budget  and  Member  States’  national 
budgets  at  least  EUR 10  billion19  a  year  in  lost  customs  and  tax  revenue  and  undermines 
health policy. OLAF takes the view that Member State authorities must have access to state-
of-the-art  specialised  testing  facilities  for  investigative  purposes  and  to  enable  proper 
implementation of cooperation agreements with tobacco manufacturers.  

This is in line with the Commission’s Communication Stepping up the fight against cigarette 
smuggling  and  other  forms  of  illicit  trade  in  tobacco  products  of  6 June 2013,  the  progress 
report  on  the  implementation  of  this  Communication20  and  the  new  action  plan  for  2018-
202221. This 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,  the  JRC’s  Institute  for  Reference  Materials  and 
Measurements  in  Geel  (Belgium)  set  up  a  laboratory  for  the  analysis  of  tobacco  products, 
TOBLAB,  in  2016.  The  JRC  in  Geel  is  specialised  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 
(including customs laboratories) and maintains related databases. 

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

Member  States  and  OLAF  can  submit  requests  for  analysis  of  tobacco  products  using  a 
dedicated  IT  application  (ToSMA)  administered  by  OLAF  on  the  AFIS  platform.  In  the 
period from 12 July 2020 to 11 July 2021, the JRC processed 144 requests from 11 Member 
States  for  analysis  of  seized  cigarettes  and  raw/fine-cut  tobacco  samples.  It  was  possible  to 
identify  cigarettes  that  had  been  smuggled  into  the  EU  market  and  to  draw  connections 
between cigarettes seized in various places in the EU at various moments. Some 100 seizures 
were connected to each other. 

To  build  statistical  models,  the  JRC  maintains  a  repository  of  commercially  available 
cigarettes  purchased  at  licensed  tobacconists  across  the  world.  The  repository  now  contains 
1 165 tobacco products from 72 countries worldwide. In this way, the JRC can identify new 
products. 

Due  to  lockdown  measures,  the  annual  workshop  with  participation  of  Member  States’ 
enforcement staff and customs laboratories could not take place in 2021.  

The  annual  AA  with  the  JRC’s  institute  in  Geel  was  renewed  in  2021  with  programme 
funding amounting to EUR 212 761. 

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

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

20   COM(2017) 235 final.   
21   COM(2018) 846 final. 

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b) 

Procured conferences 

The  programme  also  finances  high-level  conferences  and  training  activities  focused  on  the 
protection  of  the  EU’s  financial  interests  organised  by  the  Commission.  During  2021,  11 
events were planned to take place, using an existing framework service contract. The overall 
budget available for procured conferences was EUR 0.7 million.  

This  part  of  the  programme,  along  with  the  procured  digital  forensics  and  analysts  training 
(see the next point), was significantly impacted by the exceptional circumstances of 2021 due 
to the COVID-19 pandemic. The procured conferences were postponed to the second half of 
2021 or to 2022. Holding these events in a virtual format was not usually considered feasible 
due to the nature of the planned topics and the professional backgrounds of the participants. 

Nevertheless, one of the planned events was organised in a virtual format, another took place 
as a hybrid (both online and physical) meeting, and the third one was a physical meeting in 
Brussels, in April 2022. Table 5 in Annex I provides an overview of the events that took place 
under the 2021 budget. 

c) 

Procured digital forensics and analysts training  

The  digital  forensics  and  analysts  training  (DFAT),  organised  by  OLAF  aims  to  strengthen 
law-enforcement  agencies’  ability  to  combat  fraud,  including  cigarette  smuggling  and 
counterfeiting.  It  provides  improved  detection  skills  to  extract  and  use  data  from  digital 
devices.  

This annual training helped create a network of certified digital-forensics specialists, starting 
back in 2007. 

Investigations related to EU funds have become more complex, with more data that need to be 
processed.  This  has  led  to  a  growing  need  to  train  digital  analysts.  To  address  this  need, 
courses  for  analysts  were  added  to  the  original  digital-forensics  training  (DFT)  since  2018. 
The aim is to improve digital-forensics investigations by ensuring that data are processed in a 
way  that  strengthens  the  quality,  accuracy  and  efficiency  of  investigations  related  to  EU 
funds. 

A  physical  training  session  (the  21st  one  organised  since  2007)  was  scheduled  for  2021; 
however,  since  the  unfavourable  circumstances  due  to  the  pandemic  did  not  improve,  the 
2021 session was eventually organised in a virtual mode. Between March and May 2022, 29 
experienced trainers delivered a total of 16 five-day online courses for 240 participants. The 
various  subjects  proposed  covered  the  most  requested  by  Member  State  authorities,  such  as 
advanced  ‘Windows’  forensics,  open-source  intelligence,  operational  analysis,  etc. The 
budget committed to this training was EUR 1 414 000.  

3  UAFP (Hercule component) - achievements in 2021 

As  the  UAFP  has  just  started  and  no  tangible  results  are  available  for  reporting  yet,  this 
section  provides  an  overview  of  the  main  results  achieved  by  beneficiaries  implementing 
grants  awarded  under  Hercule  III  and  of  the  outcomes  of  the  procured  projects  finalised  in 
2021.  

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Beneficiaries report on the outcomes of grant projects in the final technical report they submit 
with  their  final  payment  requests.  Final  technical  reports  also  describe  issues  encountered 
during the implementation of the action, such as delays or staff changes. The reports set out 
how these issues were resolved and list possible impacts on the outcome of a project.  

Beneficiaries  of  UAFP/Hercule  technical  assistance  grants  are  requested  to  submit  a  final 
implementation  questionnaire  one  year  after  the  grant  contract’s  closing  date.  This 
questionnaire  contains  information  on  the  results  achieved  by  using  the  equipment  and  the 
beneficiary’s  assessment  of  the  equipment’s  contribution  to  achieving  the  programme’s 
objectives.  

The reported results illustrate how the purchased technical equipment, such as detection tools, 
enabled  the  beneficiaries  to  seize  substantial  amounts  of  smuggled  cigarettes,  counterfeit 
goods  and  tobacco  products.  National  authorities  reported  that  equipment  to  support 
investigations,  such  as  communication  equipment,  cameras,  IT  tools  and  forensic  soft-  and 
hardware,  facilitated  the  lawful  gathering  of  evidence  during  operations  supporting 
investigations aimed at protecting the EU’s revenues, expenditures and assets. 

Beneficiaries  of  grants  for  training  activities  (conferences,  seminars  and  training  sessions) 
also  carried  out  participant  surveys  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 2021 concerned a wide range of disciplines and topics, such as: 
(i) fighting  transit  fraud  in  the  EU;  (ii)  advanced  training  on  interpreting  X-ray  images; 
(iii) methodologies  for  detecting  and  investigating  crimes  detrimental  to  the  EU’s  financial 
interests; and (iv) strengthening cooperation and control models in the field of prevention of 
fraud undermining the EU’s own resources.  

Most  of  the  training  projects  were  targeted  at  representatives  of  government  departments 
responsible  for  managing  EU  funds  and  law-enforcement  agencies  (police,  customs). 
Nevertheless, the participation of students, professionals, non-governmental organisations and 
educational institutions was also noteworthy.  

A total of 516 persons attended anti-fraud trainings and conferences and OLAF received 286 
event-evaluation forms.  

The  feedback  received  was  overwhelmingly  positive,  with  about  91%  of  the  participants 
assessing the events as excellent or good.  

3.1 

Examples  of  technical  assistance  projects  funded  under  the  Hercule  III 
programme and finalised in 2021 

A grant awarded to the Department of Customs and Excise of the Spanish Tax Agency 
(AEAT) to acquire two observation vehicles equipped with elements for communications 
system  surveillance and  data storage. The recordings obtained were used  as  evidence for 
criminal prosecution.  

The  beneficiary  reported  that  numerous  products  and  machinery  destined  for  illicit 
tobacco-related  activities  were  identified  and  retained  during  the  searches,  including 
crushing machines, mixers, packaging machines. 

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The Police of Lublin in Poland has purchased a multifunction mobile unit for automated 
number  plate  recognitions  system,  surveillance  technology,  recording  and  covert 
monitoring.  The  equipment  purchase  aimed  mainly  to  strengthen  the  operational  and 
investigative capacity of operational police officers.  

The equipment is specifically designed for difficult terrain conditions such as forests and 
muddy  areas.  The  beneficiary  reported  seizures  of  3.6  million  pieces  of  cigarettes,  from 
January  2019  to  February  2020.  The  beneficiary  also  reported  that  following  the 
undertaken operational activities, 60 people were investigated. 

The Attica Security Directorate of Hellenic Police received a grant for modernization of 
technical  equipment  for  detection  and  investigative  operations.  This  equipment  spans  a 
variety  of  items  including  laptops,  cameras,  antennas,  video  recorders,  pinhole  cameras, 
thermal monoculars and radios.   

This  equipment  contributed  to  faster  and  effective  inspections  especially  to  detect 
contraband  cigarette  and  tobacco  products  and  to  tackle  financial  crime  and  criminal 
organisations.  The  beneficiary  reported  that  the  project  contributes  to  operational 
efficiencies  of  the  Security  Directorate  to  facilitate  the  daily  activities  in  preventing  and 
combatting the smuggling of counterfeit goods in the black market.  

The  operations  conducted  during  2018-2019  led  to  seizures  of  almost  130  tonnes  of 
tobacco,  40  handguns,  120  vehicles,  thousands  of  kilos  of  drugs  and  narcotics  and  more 
than EUR 2 million in cash. The estimated value from Non-Payment VAT exceeds EUR 
5.5 million for the tobacco-related operations. As for the other criminal activities detected, 
the  estimated  value  of  the  quantities  that  have  been  seized  is  estimated  to  be  more  than 
EUR 120 million. 

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The  Revenue  Administration  Regional  Office  in  Lublin  (IAS  Lublin)  purchased  the 
three handheld X-ray scanners currently deployed at the border crossing points on the EU’s 
external  border.  The  handheld  scanners  control  packages  and  luggage,  as  well  as  objects 
whose transfer to a stationary X-ray device could be troublesome.  

During  customs  controls  conducted  at  the  border  crossing  points  the  handheld  scanners 
have  been  used  to  also  scan  pallets  and  structural  elements  of  buses,  passenger  cars  and 
trucks.  

In the first  year of use of those detection tools, inspections  have led to  the detection and 
seizure  of  845  000  cigarettes,  8  kg  tobacco  as  well  as  tobacco  products.  With  the 
acquisition and use of X-ray handheld scanners, these results have even improved. 

The Guardia Civil (Spain) obtained technical support to strengthen the fight against fraud 
and counterfeiting (especially tobacco smuggling) throughout the Spanish border with the 
Mediterranean  Sea.  This  Spanish  border  links  ports  and  roads  from  Algeciras  (near  the 
North of Africa) up to the French border.  

The equipment provided the Guardia Civil with enhanced ability to carry out spot-checks 
aiming to reinforce legal access to intelligence in the framework of criminal investigations 
carried  out  against  fraud  and  corruption  activities  nationwide.  These  capabilities  should 
assist joint international operations carried out in the EU territory and beyond.  

The beneficiary reported seizures of round 5 000 cartons of cigarettes, 98 000 kg ground 
tobacco,  62  drawers  of  rolled  cigarettes  and  cash  for  around  EUR  7.9  million.  The  total 
seized value is an estimated EUR 24 million, involving the arrest of 100 people. 

3.2 

Examples  of  training  projects  funded  under  the  Hercule  III  programme  and 
finalised in 2021  

An  overview  of  the  training  events  finalised  in  2021  (for  which  grants  had  been  awarded 
under  the  Hercule  III  programme)  is  given  in  Annex  I  –  Overview  of  projects  awarded  and 
finalised in 2021, Tables 6 (Training, conferences and staff exchange) and 7 (Legal training and 
studies). 

Examples of projects for training and conferences that ended and were reported on in 2021: 

The General Prosecutor’s Office of the Italian Court of Auditors organised, together with 
the  national  Anti-fraud  Coordination  Service,  two  training  sessions  based  on  cooperation 
agreements and experience exchanges between five Member States.  

The events created a valuable framework enabling the exchange of experiences between the 
prosecutors  of  the  Courts  of  Auditors  of  Spain,  France,  Greece,  Portugal  and  Italy,  the 
relevant national and European anti-fraud services, and criminal-court judges from the various 
Member States involved. 

The meetings made it possible to compare activities and operational procedures between the 
General  Prosecutor’s  Office  and  the  representatives  of  the  criminal  judiciary  and  the  anti-
fraud offices of the countries involved.  

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In  their  contributions,  the  presidents  of  the  central  control  sections  of  the  Italian  Court  of 
Auditors  provided  the  overall  picture  of  the  control  systems  for  auditing  EU  and  national 
resources  affected  by  the  National  Plan  for  Rebirth  and  Resilience  (i.e.  the  Italian  recovery 
and resilience plan).  

A protocol of operational collaboration between the General Prosecutor’s Office of the Italian 
Court  of  Auditors  and  the  newly  set  up  European  Public  Prosecutor’s  Office  (EPPO)  was 
announced during the four days of workshops. This protocol constitutes the first cooperation 
agreement  between  the  EPPO  and  an  accounting  judiciary  of  a  Member  State  (signed  in 
September 2021).  

The Lithuanian Criminal Investigation Centre of the Police Department organised a ten-
day course on forensic examination with participants from  customs authorities of Lithuania, 
Latvia, Estonia and Croatia.  

The  training  increased  the  investigative  capacities  of  the  participating  Member  States  and 
identified  new  fraud  patterns  and  threats,  and  the  main  fraudulent  routes  followed  in  the 
region.  It  also  provided  a  platform  for  increased  practical  cooperation  between  Baltic  and 
Croatian  forensic  investigators  and  consolidated  the  network  of  points  of  contacts,  sharing 
information for a better targeting system based on a common approach to risk profiling. 

A workgroup on computer forensics was set up under the Baltic Network of Forensic Science 
Institutes (BNFSI). 

The  Dolj  County  Gendarmerie  Inspectorate  (Romania)  received  funding  to  organise  two 
international conferences and two working seminars on good practice in the fight against the 
illicit trade of cigarettes. In total,242 people from various professional backgrounds related to 
the  protection  of  the  EU’s  financial  interest  participated  in  the  events.  They  contributed  by 
exchanging experience and best practice.  

The two seminars aimed to strengthen cooperation, information exchange and the know-how 
needed  in  the  fight  against  tobacco  smuggling.  This  includes  alternative  methods  and 
techniques  that  can  be  used  to  protect  the  EU’s  financial  interests,  including  proposals  to 
improve  legislation  on  illicit  cigarette  trade.  The  closing  conference  led  to  the  drafting  of  a 
practice guide for future reference. 

The  events  helped  increase  cooperation  between  law-enforcement  authorities  and  other 
related  public  authorities,  identifying  common  high-risk  areas  and  commercial  routes  in  the 
field  of  cross-border  tobacco  criminality.  A  comprehensive  network  of  highly-trained 
professionals  was  set  up  to  investigate  tobacco  fraud  and  thus  protect  the  EU’s  financial 
interests. 

Examples of projects for legal training and studies that ended and were reported on in 2021: 

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The  programme  continued  to  fund  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  2020  and  2021.  This  journal  strives  to  support  European  criminal-law 
associations and to foster their network.  

The journal raises awareness of legal practitioners and other stakeholders throughout Europe 
of relevant legislation and policies in the area of 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 article sections. Each issue focuses on a 
specific topic related to the protection of the EU’s financial interests.  

The Eucrim journal is primarily published electronically (https://eucrim.eu/) in four issues per 
year  and  can  be  downloaded  free  of  charge.  The  journal  has  joint  contributions  from 
academics,  practitioners  and  several  other  branches  of  the  legal  profession,  leading  to  the 
exchange of information and knowledge.  

Research  activities  and  statements  on  highly  relevant  topics  were  presented,  e.g.  forms  of 
crime  control  (including  implementation  of  effective  measures  against  fraud  and  illegal 
activities  in  cohesion  policies),  the  legal  effects  of  the  COVID-19  pandemic  (including  the 
impact  of  the  pandemic  on  corruption  and  bribery),  and  steps  taken  to  set  up  the  EPPO 
(Eucrim dedicated a special issue to the operational start of the EPPO on 1 June 2021, which 
included contributions from 11 European prosecutors on their views of and challenges for the 
new  body  and  a  guest  editorial  from  the  European  Chief  Prosecutor,  Ms  Laura  Codruța 
Kövesi).  

During  this  period  influenced  by  the  pandemic,  Eucrim’s  news  section  focused  on 
investigations  into  fraud  related  to  public  spending  to  overcome  the  pandemic,  smuggling 
activities of criminal networks, and the work of EU institutions, including OLAF. 

The  Academy  of  European  Law  (ERA)  in  Germany  organised  the  conference  entitled 
“Transposition of the PIF Directive into national legislation” that took place online due to the 
sanitary circumstances in February 2021. 

This conference took stock of the transposition status of the Directive (EU) 2017/1371 on the 
fight  against fraud to  the European Union's financial interests by means of criminal  law (so 
called  “PIF  Directive”).  The  Directive  seeks  to  harmonise  the  definitions,  sanctions  and 
prescription periods of the offences affecting the EU’s financial interests.  

The  conference  also  presented  the  initiatives  recently  put  forward  by  the  European 
Commission  to  revamp  EU’s  policies  on  fraud  in  an  integrated  manner,  an  approach  made 
possible by the adoption in 2017 of the PIF Directive. There was a debate on ideas on how to 
improve  the  EU's  fight  against  fraud  by  enhancing  transnational  and  multi-disciplinary 
cooperation.  

This  conference  encompassed  65  legal  practitioners,  discussing  cooperation  between 
investigators and prosecutors in Member States in cross-border fraud and corruption cases. 

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The University of Burgos in Spain implemented a project to develop a toolkit for preventing 
fraud  involving  EU  funds,  in  particular  the  European  Regional  Development  Fund  (ERDF) 
and the Cohesion Funds (CF).  

The project consisted in a comparative research analysis of cases in multiple EU countries on 
obtaining,  managing  and  using  EU  funding,  for  example  from  the  ERDF  and  the  CF.  It 
developed  a  toolkit  with  a  model  and  a  map  to  predict  corruption  risk.  It  also  developed 
guidelines (freely downloadable (http://www.ubu.es/eumodfraud) by target users in the field 
of  fraud  prevention  and  criminal  law,  at  national  and  EU  level).  The  project  used  neural 
networks to create an interactive web page to prevent fraud related to public procurement in 
the EU. 

In  this  study,  a  practical  tool  to  identify  new  red  flags  is  proposed,  focusing  on  the  early 
stages of the drafting and launching of public procurement notices. It is an interactive website 
that aims to summarise and provide useful visualisations on the set of public tenders carried 
out  in  the  EU  over  the  years.  An  international  network  of  researchers  at  regional  and  local 
level  from  various  areas  and  EU  universities  has  been  set  up.  The  online  workshops,  the 
training sessions and the final conference were attended by 190 participants from 8 countries.  

The main results  of the  project  were:  (i) to  develop  an in-depth  knowledge of the diversion 
mechanisms  of  the  ERDF  and  the  CF,  and  their  interconnections;  and  (ii)  consequently,  to 
help  increase  national  and  EU  institutions’  capacity  for  the  early  detection  of  the  misuse  of 
EU funds. The medium and long-term effects of the project consist in reducing corruption and 
fraud in the management of the ERDF and the CF by incorporating appropriate measures and 
strategies derived from the project. 

3.3 

Examples of procured access to external databases   

In  2021,  the  Commission  procured  access  to  commercial  databases  for  use  by  law-
enforcement  authorities  of  the  Member  States.  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.  These  databases  also 
provide input for risk analyses and intelligence used by customs authorities to target checks. 

Member-State customs services use a commercial database of worldwide trade statistics.  
The  database  is  used  primarily  to  find  indications  that  goods  that  are  subject  to  anti-dumping  or 
countervailing measures may have been transhipped in a third country by replacing the container, the 
exporter and the country of origin of the goods.  
The data downloaded monthly from the database feeds into an online tool. It includes the quantities 
and values of certain goods imported to a Member State from non-EU countries. 
In  this  way,  the  database  can  support  investigations  into  transhipment,  evasion  of  anti-dumping  or 
countervailing  duties,  misdescription  of  country  of  origin,  exporter  or  container  swapping,  and 
undervaluation.  

One Member State reported using the database reports as an indicative and comparable index mainly 
to identify undervaluation fraud involving goods.  
Another  Member  State  feeds  information  from  this  database  into  its  domestic  risk-analysis  tool  to 
assist customs officers dealing with customs declarations in the initial assessment of the accuracy of 

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these documents, i.e. whether the goods appearing on customs declarations could be undervalued. 

Member  State  customs  authorities  use  a  database  on  vessel  information  and  movements  in 
combination  with  other  databases,  to  support  risk  analysis  and  intelligence  related  to 
worldwide  commercial-vessel  operations.  It  is  regularly  used  to  check  the  actual  routes  of 
vessels  to  cross-verify  the  origin  of  the  goods  in  containers,  for  instance  when  fraud  in  the 
form of evasion of anti-dumping and/or countervailing duties is detected.  
The database also contains ownership information of a vessel.  

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 (e.g. related to 
the smuggling of tobacco products) and to set corresponding risk profiles. 
In  2021,  use  of  the  above  database  helped  ensure  vessels’  compliance  with  applicable 
legislation. Even though it is not directly linked to the programme’s objectives, the database 
also played part in seizures of around 1.7 tonnes of cocaine and 20 tonnes of cannabis (with a 
value of around EUR 400 million).  

A database with information on companies is considered an important tool in investigations 
carried out by Member States’ customs authorities related to fraud undermining the financial 
interests of the EU.   
One  particularly  useful  characteristic  of  this  database  is  that  it  enables  Member  State 
authorities  to  create  risk  profiles  and  to  verify  certain  information  on  companies,  company 
structures and  beneficiary  owners, also  against other sources of data/information. They may 
trace  companies  and  gather  intelligence  to  support  relevant  customs  investigations  of 
particular interest.  

For example, in 2021, one Member State identified a suspicious case of caviar import worth 
around  EUR 2.3  million  by  cross-checking  the  links  between  domestic  and  foreign 
companies.    
The database was also used to determine the customs debt on suspicious import consignments 
using a specific customs procedure (CP 42). This procedure allows importers to obtain a VAT 
import  exemption  when  goods  are  imported  from  outside  the  EU  into  a  Member  State. 
However, this can be misused to evade customs duties and VAT by subsequently transporting 
the  goods  to  another  Member  State.  The  database  was  also  instrumental  in  detecting  fake 
exports from the EU to a certain third-country company.   

4 

IMS – implementation in 2021 

4.1 

Main activities  

To protect the EU’s financial interests, EU law (see below) requires Member States managing 
EU  spending  under  shared  management  and  countries  benefiting  from  pre-accession 
assistance  to  notify  the  Commission  of  any  irregularities  (including  suspected  and  proven 
fraud) detected in areas where the EU provides financial support.  

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To facilitate the reporting of irregularities, the IMS has been developed and put at the disposal 
of  the  Member  States  and  other  beneficiary  countries.  This  dedicated  electronic  system  is 
being used by 35 countries.  

Member  States,  candidate  countries  and  other  non-EU  countries  have  set  up  a  hierarchical 
reporting structure with multiple levels of responsibility. Around 700 reporting organisations, 
covering over 3 000 IMS users, are responsible for the timely reporting of irregularities.  

The  reporting  workflow  includes  multiple  hierarchical  levels  and  various  roles  within  the 
same level to ensure that several quality checks are performed before the reports are sent to 
the Commission. 

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Reporting authorities have responsibilities in one or more of the following fields: 

FIELD 

EU FUND 

Agriculture 

European Agricultural Guarantee Fund (EAGF), European Agricultural Fund for Rural 
Development  (EAFRD)  ,  European  Agricultural  Guarantee  and  Guidance  Fund  – 
Guidance Section (GUID) 

Asylum 

Asylum, Migration and Integration Fund (AMIF), Internal Security Fund (ISF) 

Cohesion 

Fisheries 

Cohesion  Fund  (CF),  European  Globalisation  Adjustment  Fund  (EGF),  European 
Regional  Development  Fund  (ERDF),  European  Social  Fund  (ESF),  Youth 
Employment Initiative (YEI) 

European  Fisheries  Fund  (EFF),  European  Maritime  and  Fisheries  Fund  (EMFF), 
Financial Instrument on Fisheries Guidance (FIFG) 

Most deprived 

Fund for European Aid to the Most Deprived (FEAD) 

Neighbourhood 

Cross-border Cooperation – European Neighbourhood Policy (CBC-ENP) 

Pre-accession 

Recovery, 
Resilience 

Instrument for Structural Policies for Pre-Accession, Poland and Hungary: Assistance 
for  Restructuring  their  Economies,  Rural  Development,  Regional  Development, 
Special  Accession  Programme  for  Agriculture  and  Rural  Development,  Transition 
Facility, Turkish Instrument for Pre-Accession Assistance, and others 

Recovery and Resilience Facility (RRF) 

Reporting authorities provide information on: 

  who committed the irregularity/fraud (persons involved); 

 

 

the support measure such as fund, programme, project, budget line; 

the financial impact (expenditure and irregular/fraudulent amount); 

  how the irregularity/fraud was committed; 

  when the irregularity/fraud was committed; 

  where the irregularity/fraud was committed; 

  how the irregularity/fraud was detected; and 

  what administrative, judicial or penal follow-up sanctions were imposed. 

4.2 

What does the AWP involve? 

The 2021 AWP has a budget of EUR 929 000 dedicated to maintenance, IT development, and 
studies. 

4.3 

Maintenance and development 

In 2021, the four major developments were: 

 

the RRF: the field ‘RRF’ was added to the IMS to make it possible to use the IMS to 
report RRF irregularities; 

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  B2B: development of the feature to upload cases of irregularities in the IMS directly 
from  a  national  database  (without  manually  processing  data  in  the  IMS);  the 
development was finalised on 27 April 2022; 

  IMS country officer: development of additional rights; and 

  IMS statistics:  development of the feature to  upload reports created by the business 

owner; for this activity, the total budget was EUR 696 000. 

4.4 

Legal basis 

The following legal acts provide for the reporting of irregularities and the use of the IMS: 

4.5 

Studies 

The  IMS  is  based  on  software  dating  back  to  2014  which  is  approaching  the  end  of  its 
lifetime. In recent  years, the European Parliament and the European Court of Auditors have 
repeatedly called for improvements to the IMS.  

A study was commissioned (contract signed on 15 November 2021) to explore the potential of 
the IMS, not least because of the ongoing discussion on the digitalisation of the fight against 
fraud and the interoperability of relevant  IT tools at EU and Member State level. The study 
should  also  help  better  understand  user  needs  and  preferences,  how  data  quality  can  be 
improved and what the IT options are.  

The total budget for this study was EUR 233 000. It was completed in May 2022. 

5  AFIS – implementation in 2021 

Under  the  programme’s  third  strand,  the  AFIS,  8  platform  releases  (i.e.  a  bundle  of 
application  releases),  consisting  of  more  than  50  application  releases  in  total,  and  25 
additional  application  releases  and  fixes  were  developed  in  2021.  Among  these,  there  were 
several major releases, such as: 

1.  the Mutual Assistance System, an entirely new application that automates the manual 
collection and processing of data and gathers all mutual-assistance-related files in one 
central place; 

2.  two  major  upgrades  of  the  Container  Status  Message  directory:  the  first  makes  it 
possible to track the complete trip of a container based on its reported movements, by 
using a machine-learning algorithm; the second makes it possible to visualise the flow 
of containers that have been transported between two ports; and 

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3.  a  new  module  for  the  Customs  Information  System  (CIS+)  to  support  the  new  Cash 

Control Regulation (Regulation (EU) 2018/167222). 

The new CIS+ module went live on 1 June 2021, on time for the application of the new Cash 
Control Regulation. CIS+ ensures the timely and effective exchange of cash-declaration data 
and  related  infringements  between  Member  States’  customs  services,  national  financial-
intelligence units, and the competent EU bodies.  

In  December  2021,  six  months  after  going  live,  CIS+  had  more  than  2 200  users  and 
contained data on 31 500 cash declarations and 1 800 infringements of the Regulation. 

CIS+  is  not  only  very  important  from  an  operational  point  of  view,  but  also  for  key 
monitoring indicator of the AFIS: the number of information items on mutual assistance made 
available. Under the previous programme, this indicator has been stagnating for the last two 
years, causing the AFIS to miss its 2019 milestone and its target for 2020.  

However, because the infringements of the new Cash Control Regulation are now shared via 
the new CIS+ module, the AFIS is back on track to meet its target for this indicator under the 
new programme. 

6  Communication 

The  successful  implementation  of  the  programme  and  the  achievement  of  its  objectives 
require  a  structured  approach  to  inform  potential  beneficiaries  on  funding  opportunities  as 
best as possible. 

On an annual basis, the Commission also disseminates information on the achievements and 
the results of the actions that received funding, for example by means of this document. 

On information, communication and visibility, Article 15(2) of the UAFP Regulation states: 

‘The Commission shall on a regular basis implement information and communication actions 
relating  to  the  Programme,  to  actions  taken  pursuant  to  the  Programme  and  to  the  results 
obtained. Financial resources allocated to the Programme shall also contribute to the corporate 
communication of the political priorities of the Union, insofar as those priorities are related to 
the objectives referred to in Article 2.’ 

6.1 

Informing potential applicants 

For the anti-fraud component (Hercule), the full texts of the calls’ documents and the related 
templates are made available on the Commission’s Funding and Tenders Portal.  

Potential applicants  were also  informed about  the publication of calls via emails  sent  to  the 
Delegates  of  the  Working  Party  on  Combating  Fraud  of  the  European  Council  (GAF),  the 
members of the Advisory Committee for the Coordination of Fraud Prevention (COCOLAF), 
the  Anti-Fraud  Coordination  Services  (AFCOS),  the  network  of  associations  for  European 
criminal law and for the protection of the EU’s financial interests, and to the Expert Group on 
Mutual Assistance in Customs Matters (EMAC). 

22 OJ L 284, 12.11.2018, p. 6. 

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6.2 

Dissemination of results 

Disseminating  the  results  of  technical  assistance  projects  (Hercule)  is  not  always  possible 
since most of the achievements relate to investigations for which information often cannot be 
disclosed.  

The  results  of  training  activities  were  disseminated  by  distributing  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  websites  to  disseminate  results  and 
conclusions.  

For the IMS, there is, in particular, the follow-up that is given to IMS notifications, either by 
the reporting Member State or by the Commission services involved in the financial follow-up 
of  identified  financial  irregularities  or  cases  of  fraud  detrimental  to  the  EU’s  financial 
interests.  OLAF  reports  within  the  Commission  on  the  performance  of  the  tool  and  the 
received notifications. It also reports annually to the European Parliament and the public.  

There  is  no  specific  dissemination  of  results  stemming  from  the  use  of  the  AFIS  platform, 
except for the annual activity reporting by OLAF and the programme statements disseminated 
by  the  Commission.  In  this  reporting,  the  (yearly)  number  of  information  items  on  mutual 
administrative assistance made  available in  the relevant  AFIS  applications is  communicated 
as a performance indicator. 

6.3 

Workshop for grant beneficiaries 

For the first time, the 2021 UAFP budget financed a dedicated workshop for beneficiaries of a 
Hercule III technical assistance grant. The event took place in Brussels in April 2022.  

The  event,  bringing  together  65  practitioners  from  18  Member  States,  built  on  the  recently 
completed  final  evaluation  of  the  Hercule  III  programme,  and  presented  the  Commission’s 
priorities for the UAFP’s future implementation.  

Aspects  of  practical  application  and  implementation  were  discussed  with  past  and  possible 
future  beneficiaries  and  a  valuable  exchange  of  views  took  place  on  future  programme 
priorities and challenges to be tackled.      

The  event  also  provided  the  stage  for  sharing  best  practices  and  lessons  learnt  in  the 
implementation  of  grants.  Around  25  individual  projects  were  presented  in  two  parallel 
sessions, highlighting not only the successes and results obtained, but also the hurdles met.   

Beneficiaries warmly welcomed this OLAF initiative as it enabled delegates to meet peers in 
other Member States working on similar projects.  

6.4 

Visibility of EU funding 

On information, communication and visibility, Article 15(1) of the UAFP Regulation states: 

‘Except  where  there  is  a  risk  of  compromising  the  effective  performance  of  anti-fraud  and 
customs operational activities, the recipients of Union funding shall acknowledge the origin of 
those funds and ensure the visibility of the Union funding, in particular when promoting the 
actions  and  their  results,  by  providing  coherent,  effective  and  proportionate  targeted 
information to multiple audiences, including the media and the public.’ 

Equipment purchased under technical assistance grant projects is often labelled with logos or 
stickers  referring  to  EU/Commission  funding  (except  for  covert  equipment  and  operations). 

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When possible, beneficiary organisations disseminate information about purchased equipment 
on project websites or press releases, mentioning the support from EU funding. 

Under the training type  of actions, all beneficiaries of grants  were requested to  mention  the 
support from the UAFP (or Hercule for previous grants), where applicable: 

1.  in  every publication (title page) or related material  developed (e.g. studies, booklets, 

newsletters and leaflets); 

2.  in electronic information (e.g. websites, audiovisual material, videos and software); 
3.  at information events (conferences and seminars); and 
4.  by creating a link from their website to the programme’s site.  

This  aspect  of  EU-support  visibility  is  not  applicable  to  AFIS  and  IMS  components,  as  no 
similar grant projects are implemented. 

7  Feedback from programme participants  

As  indicated  in  Section  3,  beneficiaries  of  UAFP/Hercule  grants  for  trainings,  conferences 
and seminars carry out surveys among the participants to collect information on the perceived 
quality and relevance of the event  attended.  According to  the final  reports received in  2021 
for  the  training  grants,  a  total  number  of  516  participants attended  activities  co-financed  by 
Hercule.  

The  number  of  participants  in  projects  that  ended  in  2021  is  lower  than  usual,  due  to  the 
reduced amount of training and conference events that took place in 2020 and 2021.  

The Commission received 286 completed questionnaires, which reflected, in the assessments 
done, a high level of satisfaction. The feedback received was overwhelmingly positive, with 
nearly  91%  of  the  participants  assessing  the  events  as  excellent  or  good.  Participants 
appreciated  the  opportunities  for  cooperation  and  exchange  of  information  offered  by  the 
training events and considered that the activities had a practical impact on their daily work.  

Based  on  the  feedback  results,  it  can  be  concluded  that  the  events  have  largely  met  their 
objectives  and  have  helped  increase  awareness  on  the  risks  to  which  the  EU’s  financial 
interests are exposed.     

For  technical  assistance  grants,  the  beneficiaries  provide  feedback  on  the  programme  in  the 
final  technical  report.  The  satisfaction  question  concerns  the  suitability  of  the  purchased 
equipment and tools for the needs of the organisation. In 2021, 90% of beneficiaries reported 
an excellent level of satisfaction and 10% reported a good level of satisfaction. 

For the use of the IMS tool, the Commission (OLAF) holds, in principle, a yearly survey on 
the satisfaction rate expressed by the users on the use of the tool and the support received. The 
latest survey was carried out at the end of 2020; its outcome was received in early 2021. The 
IMS  users’  feedback  showed  a  satisfaction  level  of  84%23,  compared  to  72%  in  the  2019 
survey.  In  2021,  a  study  was  launched,  including  interviews  and  workshops  in  late  2021  / 
early 2022, to identify ways to improve the IMS. Therefore, no satisfaction survey was held in 
2021. 

For  the  AFIS  platform,  used  for  information  exchange,  there  is  no  specific  reporting  on 
feedback from participants or beneficiaries. OLAF has the task to keep the platform up to date 
and running. OLAF registers as a performance indicator the number of information items on 

23 230 of 273 respondents, scoring 6 to 10 (scale 1 to 10). 

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mutual  administrative  assistance  made  available  in  the  relevant  AFIS  applications:  the 
Customs  Information  System,  the  Customs  File  Identification  Database,  and  the  Mutual 
Assistance System. 

8  Conclusions and way forward  

The UAFP builds on the well-established  foundations laid by 16  years of implementing the 
successive  Hercule  programmes.  It  is  developing  into  an  important  and  effective  tool  in 
protecting the financial interests of the EU. The increased potential of the new programme is 
also a consequence of the increased agility and coherence resulting from combining the three 
previously isolated components that today make up the UAFP. 

Despite  the  disruption  caused  by  the  pandemic  and  the  switch  to  a  new  programming 
framework,  the  support  provided  by  the  Commission  under  the  three  components  of  the 
UAFP continued largely unabated, leaving aside some delays in organising in-person events 
in 2021.  

On  the  anti-fraud  component  (i.e.  the  former  Hercule  programme)  specifically,  the  tangible 
results outlined above demonstrate that in 2021, the operational programmes (under both the 
UAFP  and  Hercule  III)  played  an  important  part  in  preventing  and  combating  fraud, 
corruption  and  other  illegal  activities  undermining  the  financial  interests  of  the  EU.  This 
means  that  the  programmes  helped  protect  taxpayers’  money  from  being  diverted  from  its 
purpose. Some of the equipment financed also produced positive results in other areas, such 
as detecting large shipments of drugs. 

When looking at the first batch of successful grant applications received under the UAFP in 
2021, the transition to adapt to the evolving anti-fraud priorities is already beginning to show. 
First of all, there is a stronger focus of support on the expenditure side.  

This shift in focus reflects the existence of a new instrument specifically for Member States’ 
customs  authorities  (Customs  Control  Equipment  Instrument)  and  the  increased  EU  budget 
with its new forms of expenditure.  

The  programme  is  also  aligning  more  strongly  with  the  Commission’s  anti-fraud  strategy. 
This strategy was revised in 2019 and places a much larger focus on the collection and use of 
data for anti-fraud purposes.  

in 

Future activities financed under the anti-fraud component will aim to emphasise cross-border 
cooperation 
interoperability  with 
equipment/tools purchased under other EU-funded programmes. Importantly, the programme 
is  also  supporting  the  digital  transition  of  Member  State  administrations  (for  example  by 
helping them to learn how to use advanced tools for data analysis). 

the  anti-fraud  area  and  complementarity  and 

EN 

  EN 

 
 
 
 
 
Annex I – Overview of projects awarded and finalised in 2021 

Grants and contracts awarded and finalised under the 2021 Financing Decision 

Table 1 – TECHNICAL ASSISTANCE grants AWARDED under the 2021 Financing Decision  

  MS 

Beneficiary 

Title and description 

Awarded grant 
(EUR) 

Co
-fin 
% 

1 

ES  Ministry of Interior 

ANH  –  A  NEW  HOPE  –  Surveillance  systems 
update 

691 396.00 

80 

2 

RO 

The National Anticorruption 
Directorate – DNA 

LINK – Improving the DNAs technical and 
operational capacity in the field of data analysis to 
support the investigation in cases of corruption 
detrimental to the EU financial interests 

91 920.00 

80 

3 

IT 

Ministry of Economy and 
Finance 

M.A.F.M.O – Mobile Anti-Fraud Mineral Oil 

420 000.00 

80 

4 

LV  State Revenue Service 

POC – Specialized Equipment to Reinforce the 
Latvian Tax and Customs Police Operational 
Capabilities 

709 040.00 

80 

5 

LT 

Financial Crime 
Investigation Service under 
the Ministry of the Interior 

FCIS2021  –  Purchase  of  the  investigation  and 
surveillance equipment 

102 196.00 

80 

6  RO 

General Inspectorate of the 
Romanian Police 

the  operational 
DETECT-X  –  Strengthening 
capacity  of 
Investigating 
the  Directorate 
Economic  Crimes  in  order  to  protect  the  financial 
interests of the European Union and Romania at the 
EU’s external border 

for 

302 400.00 

80 

7 

IT 

Ministry of Economy and 
Finance 

S.A.C.U.P. – Spectrometers Against Counterfeiting 
and Unsafe Products 

405 380.00 

80 

8 

IT 

Ministry of Economy and 
Finance 

ENTERPRISE – ENabling TEchnologies for 
Repression of frauds and Protection of Interests and 
Security of European Union 

224 720.00 

80 

9 

EL 

Independent Authority for 
Public Revenue (IAPR) 

HBX – Τhe supply of handheld backscatter x-rays 

739 840.00 

80 

10  PL 

Revenue Administration 
Regional Office in Olsztyn 

ACAP  –  Support  for  operational  and  analytical 
capabilities  of 
the  Revenue  Administration 
Regional Office in Olsztyn 

433 305.60 

80 

EN 

  EN 

 
 
 
 
 
 
11 

FI  TULLI 

ELTO – Improving Automation and Quality 

432 844.80 

80 

12 

IT 

Ministry of Economy and 
Finance 

A.F.A.S.T. – Αnti-fraud and anti-smuggling tools 

388 727.20 

80 

13  PL 

Municipal Police 
Headquarters in Lublin 

SIIOCP  –  Strengthening  and  improvement  of 
investigative and operational capability of Police on 
the external border of the EU 

130 954.40 

80 

14  HU 

National Tax And Customs 
Office 

DFCD – Digital Forensic Capacity Development of 
the NTCA 

297 228.80 

80 

15  RO 

General  Inspectorate  of  the 
Romanian Police 

SIS  –  Surveillance  system  for  protecting  the 
financial 
in 
Romania 

the  European  Union 

interest  of 

720 000.00 

80 

16  ES  Ministry of Interior 

RVSC – ROVSCAN 

306 032.00 

80 

17  LV 

Corruption prevention and 
combating bureau 

ADFH – Advanced Digital Forensics Hardware 

165 961.60 

80 

18 

IE 

THE REVENUE 
COMMISSIONERS 

PRCC – Procurement of Revenue Customs Cutter 

1 860 000.00 

80 

19  LV 

Corruption prevention and 
combating bureau 

Strengthening Analytical Capacity 

872 000.00 

80 

20  RO 

The National Anticorruption 
Directorate – DNA 

Better  protection  of  EU  financial  interests  by 
improving 
investigative  capacity 
through surveillance equipment and know-how 

the  DNA’s 

400 448.00 

80 

21  PL 

Provincial Police 
Headquarters in Gdansk 

Digitization  and  modernization  of  the  Pomeranian 
Police for the protection of the financial interests of 
the European Union 

188 346.40 

80 

22  RO 

The National Anticorruption 
Directorate – DNA 

Improving  the  protection  of  the  EU  financial 
interests  in  Romania  by  enhancing  the  technical 
endowment of DNA in the field of digital forensics 

646 748.00 

80 

23  PL 

Revenue Administration 
Regional Office in Olsztyn 

Expansion and modernization of computer forensics 
resources  of  the  Revenue  Administration  Regional 
Office  

148 809.60 

80 

TOTAL AWARDED 

10 678 298.40 

 - 

EN 

  EN 

 
 
 
 
 
 
 
Table 2 – TECHNICAL ASSISTANCE grants FINALISED in 2021 

MS 

Beneficiary 

Title 

Amount paid 
(EUR) 

Amount 
paid as 
% of 
initial 
commit-
ment24 

1 

PT 

Tributary and customs 
authority 

2 

BG  Customs Agency 

SCANNER – SETUBAL PORT (2017) 

913 866.66 

60.1 

FAST DETECTION (2018)  – Purchase of portable 
Raman  spectroscopic devices for fast identification 
of chemicals at customs inspections 

277 006.65 

72.6 

3 

SI 

Ministry of Finance, 
Financial Administration 
of the Republic of 
Slovenia 

X-ray  FURS  (2018)  –  Technical  assistance  for  the 
customs  X-ray  scanning  in  the  Slovenian  maritime 
cargo  port  –  Financial  Administration  of  the 
Republic of Slovenia (FURS) 

1 510 400 

91.2 

4  MT  Department of Customs 

5 

EL 

Ministry of Interior / 
European & 
Development 
Programmes Agency 

6 

PL 

Police Headquarters 

7 

BG 

National 
Agency 

Revenue 

8 

RO 

General Inspectorate of 
the Romanian Police 

Herculepara2018  –  DETECT:  Strengthening  the 
capacity of Malta  Customs to detect smuggled and 
counterfeited 
goods 

180 000 

86.9 

EX.E.C.U.T.I.V.E. 
(2018)  –  EXtending  and 
Empowering  the  Capacity  of  Digital  Evidence 
Examination 
of 
Specialized  Hardware  and  ForensIc  Software  and 
ReleVant Trainings of PolicE personnel 

the  ProcUremenT 

through 

CIIB-LargeVolDatAn  (2018)  –  Implementation  of 
IT tool for analysis of large volumes of data stored 
on various electronic devices 
BG-NRA-ITF-2018  –  Supporting  the  fight  against 
tax fraud and the  grey economy in the Republic of 
Bulgaria through 
improving  the  NRA  technical  means  to  perform 
computer investigations 
CARGOSCAN  2018  –  Improving  detection  and 
working 
towards  preventing  and 
fighting  against  smuggling,  tax  evasion  and  other 
related crimes in Romania 

tools  aimed 

252 513.60 

92.5 

247 929.35 

69.7 

109 187.32 

92.6 

1 230 726.21 

99 

9  MT  Malta Police Force 

12 MPF 2018 – Strengthening the MPF’s Capacity 
through  I2 
to  Protect  EU  Financial  Interests 
Software 

793 905.30 

92.3 

10 

EL 

Ministry of Interior / 
European & 
Development 
Programmes Agency 

HE.F.E.ST.O.S. (2018) – Hellenic anti-Fraud 
Equipment and relevant trainings for STrengthening 
the Operability against Smuggling 

250 401.29 

54.2 

24   Final payment as  a percentage of the awarded grant.  A percentage  lower than 100% means  either  that the 

action was not fully implemented or that the beneficiary managed to achieve cost savings.  

EN 

  EN 

 
 
 
 
 
                                                           
11 

LT 

Financial Crime 
Investigation Service 
under the Ministry of the 
Interior 

12 

PL 

Tax Administration 
Chamber in Lublin 

13 

SK 

Financial Directorate of 
the Slovak Republic 

14 

PL 

National Tax 
Administration 

15 

CZ 

Customs Administration 
of the Czech Republic 

FNTT (2019) – Purchase of investigation tools 

102 816.67 

100 

(2019)  – 

MOBILE  SCANNER  (2019)  –  Strengthening  the 
operational  capacity  of  Mobile  Control  Units  in 
combating cigarettes smuggling and financial fraud 
at EU Eastern border 
FLOODGATE 
Improving  customs 
surveillance  and  trade  facilitation  at  the  border 
crossing  Point  Vyšné  Nemecké  (SK)  –  Užhorod 
(UA) 
AFKA (2019) – Purchase of a technical equipment 
for Department  for Combating Economic  Crime of 
National Revenue Administration 
AER (2019) – A mobile X-ray unit for detection of 
smuggled and/or counterfeited goods transported in 
luggage and parcels through aerodromes 

710 704.85 

65.2 

1 800 000 

100 

305 215.82 

100 

213 763.18 

84.8 

TOTAL 

8 898 436.9 

- 

Table 3 – DATABASES CONTRACTED under the 2021 Financing Decision 

1 

2 

3 

Name 

Content 

GTA 

Trade statistics data 

DUN & BRADSTREET 

Global companies’ information and financial details  

INFORMA UK Ltd. 
(Lloyds) 

Information on ship movements  

Total committed under the 2021 budget  

Commitment 
(EUR) 

154 545 

300 815 

252 000 

707 360 

Table 4  – Grants for  TRAINING, CONFERENCES,  STAFF EXCHANGES  AND  STUDIES AWARDED 
under the 2021 Financing Decision 

MS 

Beneficiary 

Title 

1 

DE  Max Planck Society 

2 

3 

IT 

Pisa University 

PL  Municipal Police 

Eucrim – The European Criminal Law 
Associations’ Forum – publication of a periodical 
on the protection of the EU’s financial interests 
AFRADE – Agricultural Frauds Detection: towards 
a more effective risk analysis and a stronger 
cooperation among Member States tackling frauds 
in European agricultural subsidies 
CIAUF – Combating irregularities in the allocation 
and use of the EU’s funds – crime schemes, 

Awarded 
grant (EUR) 

Co-fin 
% 

239 352.14 

80 

127 501.20 

90 

37 255.61 

80 

  EN 

EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Headquarters in Lublin 

mechanisms and investigation strategies 

4 

BE 

Catholic University of 
Leuven 

NonIncrimInA – Non-Incrimination principle In 
Administrative and OLAF investigations 

230 587.52 

80 

5 

LT 

Lithuanian Police Center 
for Criminal 
Investigation 

6 

DE 

Academy of European 
Law – ERA 

BBS Mobile Forensics – Improving Baltic States, 
Croatian and North Macedonian Police Computer 
Forensics Specialists' Skills in IT Investigations by 
Organizing Mobile Forensics Training 

ERA – Preventing and detecting fraud: Special 
toolkits of (new) investigation techniques to better 
protect the EU financial interests 

100 112.00 

80 

67 477.00 

80 

TOTAL 

802 285.47 

- 

Table  5  –  PROCURED  CONFERENCES  on  COMBATING  FRAUD  organised  by  the  Commission  under  the 
2021 Financing Decision 

Dates 

Conference title 

Location 

N° of particip. 

Amount paid 
(EUR)25 

9-10 Nov. 
2021 

Anti-Fraud Intelligence Analysis Conference 

virtual event 

60 

0 

9 Dec. 2021 

Second OLAF Anti-Corruption Conference 

mixed 
(hybrid) event 

Approx. 1 000 
virtual and 100 in-
person participants 

6 000 

29 April 2022 

Workshop  with  beneficiaries  of  Hercule  III  – 
Technical assistance 2017-2020 

physical 
meeting, 
Brussels 

60 

134 729 26 

TOTAL 

1 220 

140 729 

25    The  conferences  were  organised  in  a  virtual  mode,  using  the  available  Commission  IT  tools,  triggering  no 

costs.    

26    This  amount  represents  the  committed  amount  based  on  the  financial  offer.  The  final  amount  will  be 

communicated by the external contractor. 

EN 

  EN 

 
 
 
 
 
 
 
 
 
 
                                                           
Table 6 – Grants for ANTI-FRAUD TRAINING, CONFERENCES AND STAFF EXCHANGES FINALISED 
in 2021 

MS 

Beneficiary 

Title 

1 

LT 

Lithuanian Police 
Criminal Investigation 
Center 

BS-HR-UnixTraining  (2018)  –  Improving  Baltic 
States  and  Croatia  Police  Computer  Forensics 
Specialists'  Skills 
Investigations  by 
Organizing  Training  of  UNIX-based  Operating 
Systems Forensics and Scripting 

IT 

in 

Amount 
paid (EUR) 

Amount 
paid as 
% of 
initial 
commit-
ment27 

60 057.44 

89.4 

2 

RO 

The County Gendarmerie 
Inspectorate Dolj 

3 

HU 

Transparency 
International 
Magyarorszag 
Alapitvany 

GRILLER-EU (2018) – Good practices in the fight 
against the illicit trade of cigarettes which help 
protect the financial interests of the European 
Union  

27 302.83 

56.9 

NEALHU  (2019)  –  New  European  Antifraud 
Landscape  in  Hungary:  Challenges  and  Missed 
Opportunities 

31 678.15 

55.3 

TOTAL 

119 038.42 

- 

Table 7 – Grants for LEGAL TRAINING and STUDIES FINALISED in 2021 

MS 

Beneficiary 

Title 

Amount 
paid (EUR) 

Amount 
paid as 
% of 
initial 
commit-
ment28 

1  MT  Malta University 

IEnforcE (2017) Implementing Enforcing EU 
Criminal Law – Theory Practice 

45 624.03 

77.9 

2 

DE 

Academy  of  European 
Law – ERA 

Intelligence-led  (2018)  –  Towards  a  more 
proactive, 
to 
detecting  and  preventing  fraud  affecting  the 
financial interests of the EU 

intelligence-led 

approach 

3 

IT 

Alma Mater Studiorum 
– Bologna University 

4 

HR 

Croatian  Association 
for  Criminal  Sciences 
and Practice 

5 

ES 

Burgos University 

DEVICES (2018) – Digital forensic Evidence: 
towards Common European Standards in 
antifraud administrative and criminal 
investigations 
IEPPO (2018) – Integration of the EPPO in 
the national criminal justice systems: 
institutional, procedural and cooperative 
challenges 
EUMODFRAUD (2019) – Toolkit for the 
Prevention of frauds in European Funds with 
special attention to ERDF and CF 

24 676.09 

54.4 

66 865.37 

97.4 

89 141.08 

72.6 

61 212.71 

77.5 

TOTAL  287 519.28 

- 

27   Final payment as  a percentage of the awarded grant.  A percentage  lower than 100% means  either  that the 

action was not fully implemented or that the beneficiary managed to achieve cost savings.  

28   See previous footnote.  

EN 

  EN 

 
 
 
 
 
 
 
 
                                                           
Table 8 – GLOBAL OVERVIEW of awarded grants and rejected applications per Member State in 2021 

Number of 
applications 
received 

Number of 
awarded 
grants 

Grants requested 
(EUR) 

Grants awarded 
(EUR) 

2021 TECHNICAL 
ASSISTANCE 

45 

23 

18 051 224.00 

10 678 298.40 

Germany 

Estonia 

Greece 

Spain 

Finland 

Hungary 

Ireland 

Italy 

Lithuania 

Latvia 

Poland 

Romania 

2021 TRAINING, 
CONFERENCES, STAFF 
EXCHANGES AND STUDIES  

Germany 

Italy 

Poland 

Belgium 

Lithuania 

Spain 

Hungary 

TOTAL  

1 

1 

1 

2 

1 

1 

1 

4 

2 

4 

17 

9 

9 

2 

2 

1 

1 

1 

1 

1 

- 

- 

1 

2 

1 

1 

1 

4 

1 

3 

4 

5 

6 

2 

1 

1 

1 

1 

- 

- 

81 055.20 

93 004.00 

- 

- 

739 840.00 

739 840.00 

997 428.00 

997 428.00 

432 844.80 

432 844.80 

297 228.80 

297 228.80 

1 860 000.00 

1 860 000.00 

1 438 827.2 

1 438 827.20 

183 404.00 

102 196.00 

2 078 945.60 

1 747 001.60 

5 588 180.80 

901 416.00 

3 580 549.60 

2 161 516.00 

1 369 808.77 

802 285.47 

306 829.14 

306 829.14 

296 396.75 

127 501.20 

37 255.61 

37 255.61 

230 587.52 

230 587.52 

100 112.00 

100 112.00 

84 047.75 

314 580.00 

- 

- 

54 

29 

19 421 032.77 

11 480 583.87 

EN 

  EN