COMMISSION STAFF WORKING DOCUMENT Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL FIFTH REPORT UNDER THE VISA SUSPENSION MECHANISM
Date: 2022-12-05
Institutions: Directorate-General for Migration and Home Affairs, European Commission
Subjects: EU visa policy, corruption, external border of the EU, illegal migration, judicial cooperation, money laundering, organised crime, return migration, right of asylum, terrorism, third country

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   EUROPEAN COMMISSION  Brussels, 5.12.2022  SWD(2022) 405 final  COMMISSION STAFF WORKING DOCUMENT      Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL FIFTH REPORT UNDER THE VISA SUSPENSION MECHANISM {COM(2022) 715 final}  
 
 
Table of contents  

Albania ................................................................................................................................................1 

1. 
1.1.  Additional information regarding actions taken in the area of migration, asylum and cooperation 

on readmission .....................................................................................................................................1 

1.2.  Additional  information  regarding  the  monitoring  of  trends  in  irregular  migration,  applications 

for international protection, returns and readmission...........................................................................2 
1.3.  Additional information regarding actions taken in the areas of justice and security ...........................2 

Bosnia and Herzegovina ....................................................................................................................5 

2. 
2.1.  Additional  information  regarding  the  actions  taken  in  the  area  of  migration,  asylum  and 

cooperation on readmission .................................................................................................................5 

2.2.  Additional  information  regarding  the  monitoring  of  trends  in  irregular  migration,  applications 

for international protection, returns and readmission...........................................................................6 
2.3.  Additional information regarding actions taken in the areas of justice and security ...........................7 

Serbia ................................................................................................................................................ 17 

5. 
5.1.  Additional  information  regarding  the  actions  taken  in  the  area  of  migration,  asylum  and 

cooperation on readmission ............................................................................................................... 17 

5.2.  Additional  information  regarding  the  monitoring  of  trends  in  irregular  migration,  applications 

for international protection, returns and readmission......................................................................... 19 
5.3.  Additional information regarding actions taken in the areas of justice and security ......................... 19 

Georgia ............................................................................................................................................. 22 

6. 
6.1.  Additional  information  regarding  the  actions  taken  in  the  area  of  migration,  asylum  and 

cooperation on readmission ............................................................................................................... 22 

6.2.  Additional  information  regarding  the  monitoring  of  trends  in  irregular  migration,  applications 

for international protection, returns and readmission......................................................................... 23 
6.3.  Additional information regarding actions taken in the areas of justice and security ......................... 24 

Moldova ............................................................................................................................................ 27 

7. 
7.1.  Additional  information  regarding  the  actions  taken  in  the  area  of  migration,  asylum  and 

cooperation on readmission ............................................................................................................... 27 

7.2.  Additional  information  regarding  the  monitoring  of  trends  in  irregular  migration,  applications 

for international protection, returns and readmission......................................................................... 28 
7.3.  Additional information regarding actions taken in the areas of justice and security ......................... 29 

Ukraine ............................................................................................................................................. 32 

8. 
8.1.  Additional  information  regarding  the  actions  taken  in  the  area  of  migration,  asylum  and 

cooperation on readmission ............................................................................................................... 32 

8.2.  Additional  information  regarding  the  monitoring  of  trends  in  irregular  migration,  applications 

for international protection, returns and readmission......................................................................... 33 
8.3.  Additional information regarding actions taken in the areas of justice and security ......................... 34 

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1.  Albania  

1.1.  Additional information regarding actions taken in the area of migration, asylum 

and cooperation on readmission  

Member  States`  cooperation  with  Albania  on  returns  and  readmission  is  reported  as  very 
good  where  the  competent  authorities  of  Belgium,  Bulgaria,  Croatia  France  and  Sweden 
reported  strict  application  of  the  readmission  agreements  by  Albania.  The  last  Joint 
Readmission Committee meeting between Albania and EU was held on February 2022.  

As regards operational cooperation with Member States1 in the field of border management, 
migration and asylum, Belgium reported very good cooperation and information sharing on a 
monthly  basis  with  the  Albanian  Embassy  monitoring  the  numbers  of  applications  for 
international  protection  via  regular  contacts  with  air  companies  (not  only  in  relation  to  the 
fight  against  illegal  migration,  but  also  with  regards  to  the  measures  imposed  in  the  fight 
against the COVID-19 pandemic).  

Together with the Netherlands, Belgium supports a project of the International Organization 
for Migration (IOM) ‘Awareness Raising and Information for Safety and Empowerment for 
All  -  Albania  /  ARISE-ALL’.  The  project  started  in  early  2021.  The  preparatory  activities 
(elaboration of the communication strategy, selection of the influencers) were completed and 
the  launching  event  of  the  implementation  of  activities  took  place  in  November  2021.  The 
project  will  last  24  months.  It  will  be  a  multi-channel  campaign  that  will  contribute  to  the 
change  of  behaviour  of  groups  with  high  potential  to  migrate  irregularly  as  well  as  key 
‘enablers’ (family, friends etc.).  

Germany provided a scholarship for an Albanian Police Officer at the German Police College 
–  for  Master's  degree,  as  well  as  equipment  for  border  surveillance  and  migration 
management.  France  appointed  an  Immigration  Liaison  Officer  in  Albania  to  carry  out 
regular advisory tasks to airlines and shipping companies in order to assist them in their task 
of  monitoring  the  conditions  of  entry  into  the  Schengen  area.  Croatia  reported  good 
cooperation  with  Albanian  authorities  and  participated  in  the  joint  Frontex  operation  in 
Albania ‘Joint Operation Albania Land 2021’.  

In  January  2022,  Albania  cooperated  with  Frontex  in  the  organisation  of  the  first  ever 
Frontex-led return operation. This operation brought over 40 Albanian nationals back to their 
home country, from several EU Member States. The presence of Frontex in Albania enables 
strengthened monitoring of compliance with fundamental rights at border crossing points. In 
February 2022, three Frontex Fundamental Rights Monitors visited the border crossing points 
in Kakavija and Kapshtice and met with the country’s Ombudsman.  

1   For  this  staff  working  document,  the  term  ‘Member  States’  refers  to  Member  States  applying  Regulation 
(EU)  2018/1806  (‘the  Visa  Regulation’),  i.e.  all  current  Member  States  (except  Ireland)  and  Schengen 
Associated Countries. 

1 

 
 
                                                      
As regards information campaigns, relevant examples include: an information and awareness-
raising  project2  targeting  specific  groups  with  a  high  potential  to  migrate  irregularly  and 
warning about the risks of irregular migration, which continues to be implemented by IOM, 
Belgium  and  the  Netherlands  with  funding  from  the  EU  Fund  for  Asylum,  Migration  and 
Integration;  as  well  as  a  follow-up  campaign  on  the  ‘prevention  of  unsafe  migration  from 
Albania to the Member States of the European Union’ funded by the Netherlands.  

1.2.  Additional information regarding the monitoring of trends in irregular migration, 

applications for international protection, returns and readmission  

After several  years of  a steady declining trend, the number of applications for international 
protection  of  Albanian  nationals  in  Member  States  in  2021  saw  a  significant  rise  of  34%. 
Similarly  to  2020,  France  remained  the  most  affected  EU  Member  State,  receiving  54%  of 
the  applications  for  international  protection  lodged  by  Albanian  nationals,  followed  by 
Germany (17%) and Greece (13%). The levels remain below the pre-COVID-19 peaks. 

As regards refusals of entry, Croatia (30%), Italy (20%), (Hungary (17%), and Greece (8%) 
reported  more  than  half  of  all  refusals.  Most  were  issued  to  travellers  due  to  lack  of 
appropriate documentation to justify the purpose and conditions of stay (42%). An important 
share  of  entries  were,  furthermore,  refused  on  the  basis  of  alerts  issued  in  the  Schengen 
Information System (SIS) or national register for the purposes of refusing entry (22%) and of 
travellers posing a risk to public policy, internal security, public health  or the relations of a 
Member State of the European Union (22%).  

The number of Albanian nationals found to be irregularly staying in Member States annually 
has  been  in  the  30-40  thousand  range  in  the  last  five  years.  Greece  (26%)  and  Germany 
(19%) remained the most affected EU Member States, similarly to 2020, followed by France 
(18%) and Hungary (13%).  

As regards return decisions, Greece alone reported 39% of all return decisions at  EU level. 
Other main reporting countries included France (23%), Germany (11%), and Italy (8%). The 
number of total returns of Albanian nationals has been decreasing since 2016 and the trend 
continued in 2021 (-8%). In 2021, Greece alone returned 36% of all returnees from Member 
States, followed by France (24%) and Germany (11%).  

1.3.  Additional information regarding actions taken in the areas of justice and security 

As regards cooperation with Member States in the field of security, in May 2021 Bulgarian 
Director  of  the  Combat  against  Organised  Crime  Directorate  held  a  meeting  with  the 
Albanian  Ambassador  discussing  weapons  retained  in  Kosovo*  with  suspected  origin  from 
Bulgaria. The information requested by the Bulgarian government has not been received yet. 
In  November  2021,  Czechia  provided  trainings  to  Albanian  police  authorities  in  improving 
project management for the use of funds in the field of science, research and innovation. A 
follow-up  course  is  scheduled  in  2022.  Germany  organised  instruction  and  qualification 

2   “ARISE-ALL / Awareness and Information for Security and Empowerment for All - Albania".  
*   This designation is without prejudice to positions on status and in line with UNSCR 1244/1999 and the ICJ 

Opinion on the Kosovo declaration of independence  

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course  on  technical  equipment  for  disaster  management  and  rescue  operations  donated  in 
2019 and contributed to police capacity building launching the database ‘Securius’. 

internal  security,   

France  reported  extensive  bilateral  cooperation  with  Albania  on 
professional  culture  and  corruption.  France  provided  several  trainings  of  Albanian  police 
border officers for detection of suspicious  behaviour  in  the field  of  trafficking  (heroin) and 
mass burglary. The Netherlands estimated the cooperation with  Albanian police and justice 
authorities was very fruitful. Dutch and Albanian counterparts have worked together within 
the  framework  of  several  Dutch  investigations  related  to  combatting  organised  crime  and 
money laundering. The Netherlands is also a participant through the Centre for International 
Legal Cooperation in the project funded by the EU (IPA), German and Italian governments 
on  ‘Countering  Serious  Crime  in  the  Western  Balkans’.  In  the  framework  of  this  project  a 
Dutch Prosecutor is  seconded to  Albania to  work with  the Albanian prosecution and police 
offices in fighting serious crimes. The Netherlands reported several other projects with their 
Albanian  counterparts  on  promoting  justice  transparency  and  accountability,  raising 
awareness and accountability in money laundering and enhancing the judicial reform process 
in Albania.  

The  Swedish  Police  Authority  has  participated  in  a  justice  chain  cooperation  on  juvenile 
justice  in  Albania  since  2018.  The  programme,  funded  by  the  Swedish  International 
Development Cooperation Agency focused on transparency, cooperation, human rights, anti-
corruption,  gender  perspective  and  commitment.  After  four  years  of  cooperation  -  clear 
changes  in  the  handling  of  juveniles  in  the  justice  system  and  an  interest  in  continuing  the 
processes reform were noticed.  

During the first 9 months of 2021, the Albanian Liaison Prosecutor to EUROJUST registered 
20  new  cases  and  three  new  Joint  Investigation  Teams  agreements.  In  2021,  the  Albanian 
Liaison Prosecutor registered 21 new cases, while Eurojust National Members registered 30 
new  cases  involving  Albania.  These  relate  mainly  to  drug  trafficking,  organised  crime, 
migrant smuggling and document forgery.  

As regards the fight against illicit trafficking, in 2021 a total of 1 134 criminal offenses were 
detected,  related  to  the  trafficking  of  persons,  minors,  vehicles,  weapons  and  ammunition, 
works  of  art,  explosives  poisonous  and  radioactive  substances  and  assistance  for  irregular 
border crossings, and 146 police operations were carried out (13 more than 2020).  

Compared to  2020, Albania reported  an increase  in  police operations, criminal  proceedings 
and  Joint  Investigation  Teams  in  cooperation  with  international  partners  in  areas  related  to 
organised crime.  

As regards the fight against corruption and organised crime, 586 police operations took place, 
of  which  95  in  cooperation  with  international  partners,  in  the  fields  of  narcotics,  illicit 
trafficking,  economic  and  financial  crime,  crime  against  persons  and  property  and 
cybercrime.  This  represents  an  18%  increase  in  operations  compared  to  the  same  period  in 
2020.  In  2021,  50  criminal  groups  active  in  the  field  of  narcotics,  illicit  trafficking, 
cybercrime,  financial  and  economic  crime,  and  property  crime  were  dismantled,  four  more 
than  in  2020.  There  was  also  an  increase  in  seizures  of  criminal  assets  in  the  same  period, 

3 

 
 
more  than  doubled  compared  to  2020  (EUR  71.4  million  were  seized  in  2021  compared  to 
EUR  19.7  million  in  2020).  These  aspects  are  covered  in  more  detail  in  the  Enlargement 
country report.  

As  regards  the  fight  against  terrorism,  the  Albanian  police  referred  ten  cases  of  terrorist 
offences and financing of terrorism to the Special Prosecution Office and the judicial district 
prosecution  offices  in  2021,  involding  11  suspects.  There  were  no  court  convictions  for 
terrorist offences or terrorism financing in 2021. The authorities repatriated six adult women 
and 18 minors from the camps in Syria in October 2020 and August 2021.  

In 2021, Albania established the Agency of Special Citizenship Programs under the Ministry 
of  Interior  with  the  aim  of  setting  up  special  citizenship  programs.  As  of  April  2022,  the 
Government has approved two Decisions of the Council of Ministers, one on the rules for the 
acquisition of citizenship in the field of Art  and Culture, and one in the field of Education, 
Science and Sport.  

4 

 
 
 
 
2.  Bosnia and Herzegovina  

2.1.  Additional  information  regarding  the  actions  taken  in  the  area  of  migration, 

asylum and cooperation on readmission  

The  Ministry  of  Security  of  Bosnia  and  Herzegovina  coordinates  activities  on  the 
implementation  of  integrated  border  management  strategy  and  action  plan,  for  the  period 
2019-2023. The report on the implementation of the strategy in 2019 and 2020 was adopted 
by the Council of Ministers in June 2021. 

Bosnia and Herzegovina is working, with the assistance of IOM Development Fund, on the 
creation  of  an  Advanced  Passenger  Information/Passenger  Name  Record  system.  The 
International Organization for Migration (IOM) provided also financial support to Bosnia and 
Herzegovina, through the IPA Project ‘Special Measures to Support Response to the Refugee 
and Migration Situation in Bosnia and Herzegovina’.  

Bosnia  and  Herzegovina  reported  persistent  issues  in  dealing  with  irregular  migrants,  in 
particular  communication  problems  and  the  very  frequent  lack  of  identification  documents. 
The  costs  of  interpretation  are  a  heavy  burden;  the  use  of  translation  applications  in  most 
basic contacts provide only a partial solution.  

In  2021  significant  reinforcement  of  police  were  deployed  to  support  the  Border  Police  in 
surveillance and protection of the State border.  

Member  States  report  good  cooperation  with  Bosnia  and  Herzegovina  in  the  area  of 
migration,  including  as  regards  returns  and  readmission  of  nationals  of  Bosnia  and 
Herzegovina, despite restrictions due to COVID-19. A readmission agreement with Pakistan 
was signed in November 2020 and entered into force in July 2021, but obstacles remain in its 
implementation. 

As  regards  cooperation  with  Member  States  in  the  field  of  migration  in  2021,  Bosnia  and 
Herzegovina  engaged  in  cooperation  activities  with  Croatia,  France,  Germany  and  the 
Netherlands. For example, Germany cooperated with Bosnia and Herzegovina and continued 
to  provide  support  through  training  in  and  technical  expansion  of  existing  GPS  tracking 
systems and equipment for border surveillance.  

Croatia  participated  in  the  work  of  the  Police  Cooperation  Joint Contact  Centre  in  order  to 
intensify  cooperation  with  Bosnia  and  Herzegovina  on  migration  management.  France 
provided IT equipment and training for immigration officers of Bosnia and Herzegovina on 
networks of human traffickers and migrant smugglers that could potentially pose a threat to 
the  security  of  the  country  and  neighbouring  countries.  The  Netherlands  continued  their 
participation  in  a  project  funded  by  the  Centre  for  International  Legal  Cooperation  on 
strengthening asylum and migration management of Bosnia and Herzegovina.  

As regards other aspects of international cooperation, activities on the implementation of the 
Convention on Police Cooperation in Southeast  Europe  continue. Agreements with Croatia, 
Montenegro and Serbia on blocking secondary roads for the crossing of motor vehicles across 
the common state borders were fully implemented. Bosnia and Herzegovina also signed the 
amendments to the agreements on border crossings and border traffic with Montenegro, the 

 
      
annex  to  the  agreement  on  conducting  border  checks  at  joint  border  crossings  with 
Montenegro; and the   agreements on border crossings and border traffic with Serbia.  

Also as part of implementation of the Convention on police cooperation in Southeast Europe, 
joint  patrols  with  Montenegro  and  Croatia  restarted  in  the  end  of  July  2021,  after  a  pause 
caused  by  COVID-19  pandemics.  Bosnia  and  Herzegovina  is  working  on  an  additional 
protocol  on  joint  mixed  patrols  with  Austria,  with  intended  focus  on  combating  irregular 
migration.  

2.2.  Additional information regarding the monitoring of trends in irregular migration, 

applications for international protection, returns and readmission  

In 2021, the number of persons irregularly entering Bosnia and Herzegovina was comparable 
to  the  previous  year,  and  much  lower  than  in  2018  and  in  2019.  In  2021,  the  authorities 
detected  15  812  arrivals.  Out  of  14  688  persons  expressing  intention  to  claim  asylum  in 
Bosnia and Herzegovina, 167 persons applied for international protection, while 154 asylum 
requests were pending from 2021.. Of them, five persons were granted refugee status and 28 
persons were granted subsidiary protection. 

In  2021,  Member  States  continued  their  cooperation  in  readmission  with  Bosnia  and 
Herzegovina  and  reported  overall  good  implementation  of  the  EU  readmission  agreement. 
There  were  however  several  issues  reported  by  Croatia  and  Sweden  in  relation  to  the 
readmission of third country nationals. 

The  number  of  applications  for  international  protection  lodged  by  nationals  of  Bosnia  and 
Herzegovina has been declining since 2014. However in 2021, it marked a considerable rise 
of  78%  compared  to  2020.  In  2021,  Germany  received  57%  of  applications  lodged  by 
nationals of Bosnia and Herzegovina, followed by France (32%), and Italy (6%). 

As  regards  refusals  of  entry  issued  to  nationals  of  Bosnia  and  Herzegovina,  65%  of  all 
reported  refusals  occurred  in  Croatia,  followed  by  Slovenia  (19%),  Hungary  (8%),  and 
Germany  (5%).  The  majority  of  refusals  were  due  to  lack  of  appropriate  documentation  to 
justify  the  purpose  and  conditions  of  stay  (60%).  The  rest  of  the  refusals  were  issued  to 
travellers posing a risk to public policy, internal security, public health or the relations of a 
Member State (15%) and on the basis of alerts issued in the SIS or national register (9%).  

As  regards  the  number  of  nationals  from  Bosnia  and  Herzegovina  found  to  be  irregularly 
staying in Member States, in 2021, Germany (35%) and Slovenia (22%) continued to be the 
most affected countries, similarly to 2020, followed by Hungary (12%) and France (10%).  

The  number  of  return  decisions  issued  by  Member  States  slightly  increased  in  2021  (1%) 
with  Germany  (23%),  France  (21%)  and  Croatia  (20%)  who  ordered  more  than  half  of  the 
returns while the total returns of Bosnia and Herzegovina nationals decreased (-11%). Croatia 
(26%),  Germany  (19%)  and  Austria  (18.3%)  reported  more  than  half  of  all  returns  of 
nationals of Bosnia and Herzegovina, followed by France (16%) and Sweden (10%). 

In  particular,  Croatia  signalled  that,  in  the  context  of  accelerated  readmission  procedures, 
Bosnia and Herzegovina does not respect the 24-hour deadline for accepting the request for 

6 

 
 
return, requiring Croatia to temporarily accept the migrants. In 2021, out of 17 000 identified 
cases  of  irregular  immigration  to  Croatia  via  Bosnia  and  Herzegovina,  only  376  were 
readmitted. The reason for this is that Bosnia and Herzegovina only accepts documents issued 
by its official bodies as evidence (e.g. certificates of expressed intention for asylum in Bosnia 
and Herzegovina, entry stamp, ID cards of asylum seekers, etc.). 

Sweden,  however,  reported  two  categories  of  cases  where  there  are  difficulties  in 
identification,  issuance  of  travel  documents  and  return,  such  as  children  without  birth 
certificate and the persons that renounced at Bosnian citizenship.  

2.3.  Additional information regarding actions taken in the areas of justice and security  

The  Agency  for  the  Prevention  of  Corruption  and  Coordination  of  the  Fight  Against 
Corruption (APIK), created in 2009, assists the anti-corruption bodies at entity and cantonal 
level.  The  Agency  considers  that  the  efforts  to  achieve  increased  efficiency  of  those  local 
bodies  were  successful  in  Sarajevo  Canton,  Brčko  District,  partly  successful  in  Tuzla  and 
Zenica-Doboj  cantons  and  there  were  signs  of  progress  in  Una-Sana  and  Central  Bosnia 
cantons. The Agency considered that there was no progress in seven other jurisdictions.  

In  October  2020  the  Regional  Anti-Corruption  Initiative  (RAI)  and  APIK  concluded  a 
memorandum of understanding and cooperation to strengthen whistle-blowers’ protection by 
reforming  the  legislative  and  institutional  framework,  in  line  with  the  EU  Directive  on  the 
protection of whistle-blowers. A legislative gap analysis was finalised in 2021.  

The  Public  Procurement  Agency  received  and  treated  a  total  of  110  submissions  with 
indications of corrupt  behaviour  in  2021.  The Agency prepared  legislative  amendments  on 
public  procurement  which  were  adopted  by  the  Council  of  Ministers  and  sent  for 
parliamentary procedure in February 2021 the government accepted the proposal and send it 
to  the Parliament.  The proposal  of the  law introduces  a public procurement  officer, models 
exemptions according to EU directives, prescribes preliminary market checks and obligatory 
division into lots, improves provisions on personal capacity, envisages disqualification due to 
conflict of interest and corruption according to EU directives, specifies provisions on active 
legitimacy and deadlines, and the action of the contracting authority on appeals. Adoption in 
Parliament remains pending.  

The Chief Prosecutor of the Prosecutor’s Office of Bosnia and Herzegovina is also the Head 
of  the  Counter  Terrorism  Task  Force,  a  coordination  body  consisting  of  heads  and 
representatives of the police and security agencies from the state and entity levels.  The task 
force met three times in 2021.  In 2021 five people were judged for organising a terrorist or 
illegal paramilitary groups and one person was judged for acts of terrorism.  

The High Judicial and Prosecutorial Council of Bosnia and Herzegovina held three meetings 
in 2021. The number and the large autonomy of local prosecutor offices make country-wide 
cooperation  very  difficult.  When  it  comes  to  cooperation  between  prosecutors’  offices  and 
police bodies at the operational level, 17 operational forums are established and functioning 
independently.  

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As concerns the fight against organised crime, the State Investigation and Protection Agency 
(SIPA)  is  the  State-level  body  providing  assistance  and  cooperation  to  law  enforcement 
agencies  at  entity  and  cantonal  level.  As  for  the  prosecution,  the  large  autonomy  of  local 
police forces makes the cooperation difficult and diminishes the efficiency. In 2021 only 58 
people were judged for  participating in  organised crime activities.  SIPA  is  also  involved in 
the fight against terrorism.  

Due to the number of institutions and their large autonomy, there is not only a considerable 
lack  of  state  coordination  on  all  security  and  law  enforcement  issues,  but  also  unavoidable 
cases of conflicts of jurisdiction  and redundant use of resources.  

As  regards  cooperation  with  Member  States  in  the  field  of  security,  Germany  provided 
material  assistance  to  Bosnia  and  Herzegovina  law  enforcement  agencies  (Police  Capacity 
Building) in  2021, including protective  equipment  related to  COVID-19  and  IT equipment. 
Czechia cooperated with Bosnia and Herzegovina in a project on detecting and disposing of 
ammunition  from  rivers  and  lakes  where  Czech  police  divers  participated  in  demining 
dangerous  areas  in  Bosnia  and  Herzegovina.  Furthermore,  Czechia  provided  a  training 
programme  for  families,  educators,  journalists  and  general  public  on  building  resilience  to 
disinformation. The Netherlands reported cooperation with the police agencies of Bosnia and 
Herzegovina in strengthening the fight against corruption between November 2019 and April 
2022,  based  on  a  project  implemented  by  the  Centre  for  International  Legal  Cooperation. 
Under  that  project,  a  senior  Dutch  prosecutor  was  seconded  to  the  Cantonal  Prosecutor’s 
Office  in  Sarajevo  as  advisor  on  corruption  and  organised  crime  cases.  The  immigration 
liaison  officer  from  the  Dutch  police  stationed  in  Zagreb  also  covers  trafficking  in  human 
beings and smuggling of migrants in Bosnia and Herzegovina.  

8 

 
 
 
 
3.  Montenegro  

3.1.  Additional  information  regarding  the  actions  taken  in  the  area  of  migration, 

asylum and cooperation on readmission  

Member  States  report  good  cooperation  on  readmission  with  Montenegro  and  an  adequate 
implementation  of  the  EU  readmission  agreement.  During  the  last  Joint  Readmission 
Committee  meeting  held  in  November  2021,  the  Member  States  reported  a  smooth 
cooperation  with  the  Montenegrin  authorities,  most  Member  States  confirming  compliance 
with the time limits as stipulated in the EU Readmission Agreement.  

As  regards  operational  cooperation  with  Member  States  in  the  field  of  border  management 
and migration, Montenegro has engaged in joint activities with Croatia, France, Germany and 
the  Netherlands.  Croatia  cooperates  with  Montenegro  bilaterally  as  well  as  through  the 
participation  of  the  Croatian  Police  in  the  Frontex  joint  operation  in  Montenegro.  The 
Ministry of Interior of Croatia cooperates with the Ministry of Interior of Montenegro in the 
area of Prevlaka peninsula, the so-called ‘Zona’, an area under temporary special monitoring 
and sailing regime. In 2021, the cooperation was carried out by planning and conducting joint 
patrols at sea. Despite the fact that some planned training measures could not take place due 
to the COVID-19 pandemic, the cooperation is assessed as good.  

In  2021,  the  French  authorities  launched  three  projects  on  migration  management  in 
Montenegro  training  officials  from  the  Department  for  Combating  Organised  Crime  and 
Corruption  on  dismantling  organised  migrant  smuggling  networks  and  investigating 
techniques used to combat this phenomenon. France provided also training for the staff of a 
new  airline  on  cross-border  regulation,  in  particular  concerning  traveling  to  France  or  the 
Schengen  area.  Germany  provided  equipment  for  border  surveillance,  transport  vehicles  to 
transport  persons  who  have  been  taken  into  custody,  summer  uniforms  for  border  officers; 
tactical  uniforms  for  Mobile  Units.  Additionally,  in  2021,  the  Netherlands  supported  the 
Balkan Refugee and Migration Council.  

3.2.  Additional information regarding the monitoring of trends in irregular migration, 

applications for international protection, returns and readmission  

In 2021 the number of applications for international protection by Montenegrin nationals in 
Member States significantly rose (65%) and interrupted the continued decreasing trend since 
2015. The most affected Member State was Germany (68%), followed by France (20%), Italy 
(5%), and Sweden (3.6%).  

As  regards  the  number  of  refusals  of  entry,  as  in  the  previous  years,  Croatia  (39%)  and 
Hungary  (27%)  were the most affected  countries in  2021, followed by Slovenia (11%)  and 
Germany  (10%).  41%  of  the  refusals  resulted  from  a  lack  of  documents  to  justify  the 
travellers’  purpose  and  conditions  of  stay.  These  were  followed  by  refusals  issued  on  the 
basis  of  alerts  registered  in  the  SIS  or  national  register  (19%).  A  considerable  number  of 
refusals  was  issued  to  travellers  representing  a  risk  to  public  policy,  internal  security  or 
public health (17%), and the travellers who had already stayed on the territory of a Member 
State for the permitted 90 days in the preceding 180-day period (15%).  

9 

 
 
As regards the number of Montenegrin nationals found to be irregularly staying in Member 
States, in 2021, Hungary was the most affected Member State (44% of the total), followed by 
Germany (29%), France (8%), and Slovenia (6%).  

As  regards  return  decisions,  Germany  (33%),  France  (18%),  Austria  (17%),  and  Sweden 
(10%) ordered most of the returns at EU level. The number of the total returns continued to 
decrease following the trend in the last five years (-12%) with Germany (29%) and Austria 
(21%) who reported most effective returns of nationals of Montenegro in 2021, followed by 
Sweden (15%) and Luxembourg (11.5%).  

3.3.  Additional information regarding actions taken in the areas of justice and security  

As  regards  cooperation  with  Member  States  in  the  field  of  security,  Germany  provided 
capacity  building  assistance  to  the  Montenegrin  police  in  the  form  of  vehicles,  language 
courses,  surveillance  equipment,  IT  equipment,  mobile  phones  and  analysis  software.  The 
Netherlands continued to cooperate with Montenegro on mutual legal assistance activities - a 
human  rights  project  ‘MATRA’  covering  also  Serbia  and  a  52  months-project  on 
strengthening  the  probation  and  the  system  of  alternative  sanctions  in  Montenegro  and 
Serbia. In addition, Latvia participated in the ‘Online Intensive Programme in European Law 
and  Economics  for  European  Neighbourhood  Policy  Countries,  Central  Asia  and  Western 
Balkans’ – a project of the Riga Graduate School of Law providing interdisciplinary training 
on legal, political and economic functioning of the EU.  

With  regard  to  the  activities  of  the  Special  State  Prosecutor's  Office,  in  2021  three 
indictments were lodged with the Higher Court of Podgorica against nine individuals and 11 
indictments  against  68  persons  and  21  legal  entities.  Financial  investigations  have  been 
launched in seven cases against 40 individuals and six legal entities (compared to four cases 
against 30 individuals and two legal entities in 2020).  

In  2021,  21  plea  bargain  agreements  were  concluded  in  four  cases  with  21  individuals  and 
nine legal entities; out of this, 16 agreements were adopted by the court ruling, one agreement 
was rejected, and four agreements are pending the court’s ruling. In 2021, the High Court of 
Podgorica issued three final and enforceable judgements, resulting in suspended sentence and 
imprisonment served in residential premises.  

The Special Prosecutor’s Office has launched investigations leading to arrests into two high-
level  corruption  and  organised  crime  cases.  On  17  April  2022,  the  former  President  of  the 
Supreme  Court  was  arrested  on  charges  of  suspicion  of  abuse  of  office  and  of  creating  a 
criminal organisation. On 10 May 2022, the President of the Commercial Court was arrested 
on suspicion of forming an organised criminal, embezzlement, and abuse of office.  

With regard to the fight against corruption, in 2021, the Anti-corruption agency instituted 1 
164  proceedings  before  misdemeanour  courts,  which  is  more  than  twice  compared  to  2020 
(510  proceedings).  808  proceedings  were  completed  (including  those  from  previous  years) 
and  sanctions  were  imposed  in  88.6%  of  the  cases.  In  2021,  the  Agency  issued  136  direct 
misdemeanour orders (compared to 42 in 2020). The total amount of fines, including direct 
misdemeanour  orders,  amounted  to  EUR  149  242  (compared  to  EUR  89  659  in  2020).  In 

10 

 
 
2021, the ACA requested seizure of material  gain before the competent  courts in  one case, 
and the courts approved confiscation in two cases.  

Furthermore,  between  January  and  March  2022,  the  Agency  instituted  298  proceedings 
before  misdemeanour  courts.  233  proceedings  were  completed  (including  those  from  the 
previous period) and sanctions were imposed in 92% of the cases.  

In  2021,  the  Agency  issued  186  opinions  (compared  to  135  in  2020)  on  incompatibility  of 
functions  and  conflict  of  interests.  26  public  officials  (compared  to  41  in  2020)  resigned, 
whilst two were dismissed. Furthermore, between January and March 2022, 62 opinions on 
incompatibility of functions were issued, one public official resigned, and one was dismissed.  

In  2021,  the  ACA  received  10,657  income  and  asset  declarations  (compared  to  8  108  in 
2020). Some 974 reports (compared to 966 in 2020) were verified by the Agency, exceeding 
its  annual  plan  by  more  than  10%.  In  2021,  the  Agency  initiated  295  administrative 
proceedings  (compared to  138 in  2020) and violations of the  Law were  found in  160 cases 
(compared  to  60  in  2020).  Sanctions  were  imposed  in  nine  cases  (2020:10).  Moreover, 
between January and March 2022, the Agency received 7 214 income and asset declarations 
and verified 90.7% of the reports. Some 380 administrative proceedings were initiated, and 
violations of the Law were found in 62 cases.  

In 2021, the Agency concluded the additional checks of 20 high-level officials and continued 
to  monitor  the  lifestyle  of  public  officials,  using  publicly  available  data  and  media  reports. 
The  ACA  also  initiated  procedures  for  examining  the  lifestyle  of  three  public  officials  and 
one  case  was  submitted  to  the  prosecution  services.  Further  work  is  needed  to  effectively 
address  the  April  2021  EU  peer  review  recommendations  on  conflict  of  interest  and 
incompatibility of functions and asset declarations.  

Concerning funding of political parties and electoral campaigns, in line with its competences, 
the  Agency  oversaw  all  local  elections  held  in  2021.  36  irregularities  in  the  reports  of 
political  entities  were  registered.  In  2021,  out  of  141  misdemeanour  proceedings  issued  by 
the Agency (compared to 62 in 2020), 128 concerned electoral campaigns.  

The  Special  Prosecutor’  Office  conducted  26  financial  investigations  regarding  156  people 
and 11 legal entities in 2021, a stable number compared with the 25 financial investigations 
launched  in  2020.  In  most  cases,  financial  investigations  are  launched  after  the  criminal 
investigation, with the aim to proceed to an extended confiscation. The strengthened capacity 
of the Asset Recovery Office (ARO), established in the Police Directorate within the unit in 
charge of international police cooperation, led to an increase in the number of assets detected 
and traced. Despite this positive trend, there was no court order on final  asset confiscations 
pronounced  in  2021  (compared  to  15  in  2020).  Two  decisions  on  temporary  seizures  were 
issued, including real estate.  

In 2021, the Special Prosecutors Office conducted 13 investigations in organised crime cases 
(from  25  in  2020),  targeting  103  people.  Some  13  indictments  were  lodged  for  organised 
crime-related offences (from 29 in 2020) against 70 people.  

Regarding  the  fight  against  money  laundering,  no  clear  timeline  has  been  given  by 
Montenegro  Authorities  for  adopting  the  new  Law  on  the  prevention  of  money  laundering 

11 

 
 
and  terrorism  financing  aligning  with  the  fifth  EU  Anti  Money  Laundering  Directive  and 
International Restrictive Measures.  

As  regards  Montenegro’s  citizenship  by  investment  scheme,  the  nationalities  of  successful 
applicants (for the January – December 2021 reporting period) include Russia (176 successful 
applicants),  Lebanon  (19),  Egypt  (14),  Pakistan  (12),  China  (6),  Turkmenistan  (5),  Turkey 
(4), Belarus (3), Ukraine (2), Saudi Arabia (2), USA (1), Kazakhstan (1) and Iran (1). 

12 

 
 
 
 
4.  North Macedonia  

4.1.  Additional  information  regarding  the  actions  taken  in  the  area  of  migration, 

asylum and cooperation on readmission  

Member  States’  cooperation  with  North  Macedonia  on  returns  and  readmission  was  very 
good.  Germany  reported  a  decrease  in  the  rate  of  negative  replies  of  readmission  requests 
sent  to  North  Macedonia,  noting  however  that  further  improvements  are  needed.  Some  of 
those readmission requests are coming from persons declaring wrong identity or unregistered 
children born from undocumented parents from North Macedonia. The last Joint Readmission 
Committee meeting between North Macedonia and the EU was held in June 2022.  

As  regards  operational  cooperation  with  Member  States  in  the  field  of  migration 
management, Croatia provided continuous bilateral support to North Macedonia and reported 
good  cooperation  in  the  area  of  migration.  Germany  provided  equipment  for  border 
surveillance;  vehicles;  border  control  stamps;  tactical  vests;  laptops  with  software  package 
for further education and training needs; projectors for further education and training needs; 
as well as a training system for the previously established need of the Department for Border 
Police.  In  addition,  Germany  organised  a  qualification  course  for  document  and  identity 
checks  and  issuance  of  personal  document  identifiers  for  20  border  officers  of  North 
Macedonia.  France  reported  cooperation  in  training  on  migration  control  for  the  airport 
officers  dedicated  to  check-in  and  checks  of  passenger  entry  documents  at  Skopje  airport 
with destination the Schengen area. Additionally, in 2021, France provided a training course 
to the Border Police on the fight against document fraud, carried out by the Internal Security 
Service of the French Embassy in Skopje and for some of them in cooperation with Frontex.  

The Netherlands provided capacity-building support to prevent migrant smuggling and other 
transnational organised crime in North Macedonia, as well as to enhance border security. The 
overall objective was to increase the national law enforcement officials’ knowledge and skills 
in  the  areas  of,  inter  alia,  information  collection  and  analysis,  identification  of  smuggling 
cases,  investigation  methods  and  techniques  to  respond  to  migrant  smuggling  and  other 
transnational  organised  crime;  to  improve  inter-institutional  cooperation  skills  pertaining  to 
countering  transnational  organised  crime,  including  smuggling  of  migrants.  The  Dutch 
authorities  also  provided  copies  of  the  Passport  Examination  Procedure  Manual  to  the 
national  law  enforcement  authorities.  Another  major  project  initiated  by  the  Netherlands  in 
2021  concerns  strengthening  the  capacities  of  the  Financial  Intelligence  Office  of  North 
Macedonia,  including  upgrading  the  current  static  webpage  into  a  dynamic,  user  accessible 
web platform; updating indicators for identifying suspicious activities related to financing of 
terrorism; engaging experts to recommend and prepare a legal framework to regulate virtual 
currencies  in  accordance  with  Financial  Action  Task  Force  recommendations  and  EU 
directives;  adapting  new  methodology  and  improving  the  Financial  Intelligence  Unit’s  IT 
system  for  conducting  Strategic  Analysis.  A  study  visit  to  the  Netherlands’  Financial 
Intelligence Unit’s was organised.  

13 

 
 
Poland reported that the Polish Border Guard  continued to participate in the Police Support 
Mission of North Macedonia in the section of the state border between North Macedonia and 
Greece.  

The activity funded by IPA II to upgrade the IT and communication structure to improve the 
identification  and  registration  process  of  mixed  migrant  flows  was  launched  in  2019  and 
continued to be implemented successfully in 2021, with the support of Frontex.  

4.2.  Additional information regarding the monitoring of trends in irregular migration, 

applications for international protection, returns and readmission  

After  six  years  of  steady  decrease,  in  2021,  the  number  of  applications  for  international 
protection  by  citizens  of  North  Macedonia  marked  a  record  increase  of  almost  300%.  In 
2021, Germany continued to be the most affected Member State receiving the highest number 
of applications for international protection (85% of the total), followed by France (8%) and 
Belgium (3%).  

Relating  to  the  number  of  refusals  of  entry,  Hungary  (29%),  Croatia  (19%)  and  Slovenia 
(17%) reported most  cases in  2021. Besides the  biggest  share of refusals issued because of 
lack  of  appropriate  documents  to  justify  the  purpose  and  conditions  of  stay  (26%)  and  the 
alerts registered in the SIS or national register (25%), travellers from North Macedonia were 
mostly  refused  entry  for  posing  a  risk  to  public  policy,  internal  security  or  public  health 
(23%, stemming partly from the COVID-19 pandemic) and for having already stayed on the 
national territory of Member States for the permitted 90-day stay (19%).  

As  regards  the  number  of  nationals  of  North  Macedonia  found  to  be  irregularly  staying,  in 
2021, similarly to 2020, Germany was the most affected Member State (38%), followed by 
Hungary (30%) and Slovenia (15%).  

Germany (46% of the total), France (13%) and Austria (7.5%) reported most return decisions 
of  nationals  of  North  Macedonia  in  2021.  As  regards  total  returns,  2021  marked  another 
important  decrease  in  returns  of  nationals  of  North  Macedonia  (-31%)  which  is  however 
almost  twice  smaller  than  the  one  recorded  in  2020  (-57%).  Germany  reported  most  of  the 
returns (36%), followed by France (14%), Austria (13%) and Sweden (9%).  

4.3.  Additional information regarding actions taken in the areas of justice and security  

As  regards  cooperation  with  Member  States  in  the  field  of  justice  and  security,  Bulgaria 
continued  to  exchange  information  on  persons  involved  in  drug  trafficking,  smuggling  and 
illegal  production  of  cigarettes  and  money  laundering.  It  also  participated  in  a  joint  police-
customs  operation  coordinated  by  Europol  to  counter  the  illegal  trafficking  of  weapons, 
drugs,  smuggling  of  migrants  and  the  use  of  forged  documents.  Due  to  the  current 
administrative  reforms  in  North  Macedonia,  the  contacts  in  the  field  of  cybercrime  and 
operational  international  cooperation  have  been  put  on  hold.  France  provided  behavioural 
training courses for border police officers in  North  Macedonia.  Germany  provided capacity 
building  assistance  to  the  police  of  North  Macedonia  in  the  form  of  police  emergency 
vehicles, language training courses and office equipment.  

14 

 
 
Czechia  provided  training  in  improving  professional  competences  and  skills  of  the  special 
police  ‘Tigar’  unit  of  North  Macedonia  between  October  and  November  2021,  as  well  as 
equipment.  

The  Netherlands  engaged  in  a  number  of  operational  activities  with  North  Macedonia, 
including  activities  and  training  courses  aimed  at  strengthening  the  resilience  of  local 
communities  to  gender-based  violence  and  domestic  violence,  anti-corruption  trainings 
prevention of organised crime.  

Additionally,  the  Netherlands  and  North  Macedonia  conducted  mutual  legal  assistance 
activities in the form of several regional projects. In the framework of the project ‘Countering 
Serious  Crime  in  the  Western  Balkans’  funded  by  the  German  and  Italian  governments,  a 
Dutch  Prosecutor  is  seconded  to  North  Macedonia  to  work  with  the  local  prosecution  and 
police offices in fighting serious crime. The Netherlands reported several other projects with 
their counterparts in North Macedonia on promoting justice transparency and accountability, 
increasing  the  overall  usage  rate  of  mediation  and  an  alternative  dispute  resolution 
mechanisms,  enhancing  the  judicial  reform  process  in  North  Macedonia  and  rule  of  law 
capacity building.  

As  regards  corruption,  in  2021,  indictments  were  filed  against  29  persons,  first  instance 
verdicts  were  reached  for  35  persons  and  second  instance  verdicts  were  reached  for  24 
persons.  As  regards  terrorism,  in  2021,  indictments  were  filed  against  six  persons,  first 
instance verdicts were reached for 15 persons and second instance verdicts were reached for 
13 persons.  

As regards the fight against corruption and organised crime, during the reporting period, the 
National  Coordination  Centre  for  Fighting  organised  crime  and  corruption  acted  on  539 
requests and performed checks on 1 330 natural persons, 131 legal entities and 1 334 motor 
vehicles.  Its  operations  in  2021  allowed  swifter  information  and  data  exchanges  between 
participating institutions, including in the area of international police cooperation, as well as 
further coordination between participating institutions in case of overlapping investigations.  

In May 2021, a large criminal network involved in investment fraud and money laundering 
was  dismantled  as  a  result  of  a  cross-border  operation  supported  by  Europol  and  Eurojust. 
The  German-led  investigation  involved  law  enforcement  and  judicial  authorities  from 
Bulgaria, Israel, Latvia, North Macedonia, Poland, Spain and Sweden. As a result, 11 people 
were convicted, nine sites were searched and assets were confiscated for a total of about EUR 
2 million.  

As regards money laundering, in 2021, indictments were filed against 8 persons, first instance 
verdicts were reached for 7 persons and second instance verdicts were reached for 2 persons.  

North  Macedonia  participated  in  17  EMPACT  operations  with  regard  to  the  fight  against 
trafficking  of  human  beings,  firearms,  drugs,  vehicles  and  waste,  as  well  as  irregular 
migration, document fraud, combatting money laundering, counter-terrorism and combatting 
terrorist propaganda.  

As regards the acquisition of  citizenship for special economic interest, during the  reporting 
period,  the  successful  applicants’  nationalities  include  Nigeria,  Russia,  Sudan,  India,  Iraq, 

15 

 
 
Yemen, Lebanon, Libya, Pakistan, Saudi Arabia, Syria, and Uzbekistan.  In 2021, there were 
15 successful applications and four rejected applications.  

16 

 
 
 
 
 
5.  Serbia  

5.1.  Additional  information  regarding  the  actions  taken  in  the  area  of  migration, 

asylum and cooperation on readmission  

The  COVID  19  pandemic  considerably  affected  the  work  of  all  law  enforcement  agencies, 
including border police, however without disrupting their activities.  

The  Twinning  project  ‘Development  of  the  Schengen  Action  Plan’  continued  to  be 
implemented  by  the  Ministry  of  the  Interior,  in  partnership  with  Lithuania  and  Hungary 
between  February  and  December  2021.  The  project  evaluated  Serbia’s  legal  framework 
Serbia and its conformity with the Schengen acquis and contributed to the alignment of the 
legal  provisions  of  the  Republic  of  Serbia  with  the  Schengen  acquis.  A  Proposal  of  the 
Schengen  Action  Plan  for  accession  to  the  Schengen  area  has  been  drafted,  including 
elements  on  Border  management,  Return  and  readmission,  Schengen  Information  System 
(SIS), Visa policy, Police cooperation, Data protection, Legislation on firearms and Judicial 
cooperation.  

The regulation on the conditions to be met by the border crossing point in terms of premises, 
devices,  equipment,  infrastructure,  sufficient  number  of  employees  and  other  material  and 
technical means necessary for the functioning of the border crossing point was adopted on 1 
October 2021. The programme of professional training of participants in basic police training 
for the position of border policeman was  adopted  in  January 2021.  In September 2021, the 
Ministry of Interior submitted the programme to Frontex to determine its compliance with the 
Common Core Curriculum in September 202.  

Within  the  project  ‘EU  Support  for  Efficient  Border  Management’,  the  report  on  the 
implementation  of  the  20172020  Integrated  Border  Management  Strategy  was  prepared. 
The project included a comparative analysis of the most important European legal framework 
for integrated border management (IBM) to identify and define the obligations to be included 
in the new IBM strategy. The current IBM strategy has been compared to the Technical and 
Operational Strategy for Integrated Border Management (Frontex), while the activities to be 
changed have been defined. At the same time, the Action Plan for Chapter 24 of the Republic 
of Serbia and the reports prepared by the Coordination Body for Border Crossing Points of 
the Government of the Republic of Serbia were analysed to define the activities that need to 
be further elaborated in the new Strategy.  

In  August  2021,  a  special  Working  Group  was  established  and  tasked  with  drafting  the 
Integrated Border Management Strategy in the Republic of Serbia 20222027. As first stage, 
the  draft  text  of  the  Integrated  Border  Management  Strategy  in  the  Republic  of  Serbia  and 
Action Plan for the period 20222024 has been prepared. The process of adoption is ongoing.  

In  February  2021,  a  Working  Group  was  established  to  draft  the  text  of  the  Draft  Law  on 
Amendments  to  the  Law  on  Asylum  and  Temporary  Protection.  The  work  of  this  body  is 
ongoing.  

The twinning project ‘Support to the preparation for participation in the EUROSUR network 
and EURODAC system’ was carried in 2021 and ended in June 2022. The beneficiary of the 

17 

 
 
project is the Ministry of the Interior of the Republic of Serbia, while the twinning partners 
are Sweden and Lithuania. The results are among others a roadmap for EUROSUR, including 
the proposal for establishing the National Coordination Centre (NCC) within the Operational 
Centre of the Border Police and a roadmap for EURODAC. The existing Operational Centre 
of the Border Police Directorate will most likely become the NCC.  

Serbia  was  one  of  the  participants  in  the  global  program  ‘Migration  for  Development’ 
implemented by the German Federal Ministry for Economic Cooperation and Development, 
supporting  efforts  to  improve  living  conditions  and  prospects  of  people  to  stay  in  their 
country, both now and in the future. The support is intended not only for the local population 
and internally displaced persons but also for those returning from Germany or third countries.  

In  2021  37  police  officers  were  trained  to  use  the  system  for  fingerprinting  of  migrants 
(‘Papilon’).  327  agents  of  the  border  police  were  also  trained  by  e-learning.  In  total  7  981 
irregular migrants were registered in the AFIS database in 2021.  

The  Commission  for  monitoring  the  visa-free  regime  with  the  European  Union  was 
established  in  its  fifth  mandate  for  a  period  of  two  years  on  6  May  2021.  The  task  of  the 
Commission  is  to  monitor  and  reduce  the  number  of  unfounded  asylum  applications  in  the 
EU.  

In  the  reporting  period,  from  January  to  December  2021,  the  strategy  for  reintegration  of 
returnees under the readmission agreement continued to be implemented. 

In 2021, about 1 000 information booklets dedicated to the rights and obligations of returnees 
under readmission agreements were distributed. The same number of information booklets on 
free legal aid was also distributed. About 400 flyers of the German Info Centre for Migration, 
Vocational Education and Career were distributed.  

As regards the reintegration of returnees, 120 municipalities and cities revised existing local 
action  plans  to  introduce  the  category  of  returnees.  The  government  provides  financial 
resources for the local self-governments to implement measures and activities to address the 
problem  of  returnees.  Additionally,  the  Ministry  of  the  Interior,  within  its  competence, 
actively  participates  in  the  implementation  of  the  Strategy  for  Reintegration  of  Returnees 
under the Readmission Agreement, especially those from vulnerable minorities.  

The Returnee Reintegration Strategy Implementation Team did not hold meetings in 2021.  

The  foreign  citizens  staying  in  Serbia  and  having  the  status  of  irregular  migrants,  asylum 
seekers or  rejected asylum  seekers are regularly informed about  the possibilities of assisted 
voluntary  return  by  the  Commissariat  for  Refugees  and  Migration  officials  in  cooperation 
with IOM officials.  

France cooperated with Serbia to train airport border personnel in knowledge on requirements 
to enter Schengen area and France, in order to prevent the departures of persons who would 
be denied access and would have to be returned.  

18 

 
 
5.2.  Additional information regarding the monitoring of trends in irregular migration, 

applications for international protection, returns and readmission  

The  number  of  applications  for  international  protection  by  Serbian  nationals  has  been 
decreasing since 2014, however as for the rest of the Western Balkans partners, 2021 changed 
the  trend  and  marked  an  important  increase  (22%).  Germany  remained  the  Member  State 
with the highest number of applications lodged (54% of the total), followed by France (31%) 
and Belgium (4%).  

As  regards  refusals  of  entry  of  Serbian  nationals,  Hungary  was  the  most  affected  country, 
reporting half of the total cases in 2021 (53%), followed by Croatia (14%), Bulgaria (11%) 
and Slovenia (8.5%). The main reasons for refusing entry related to stays of Serbian nationals 
on the national territory of Member States over the permitted 90-day stay (28%), followed by 
a  lack  of  appropriate  documentation  justifying  the  purpose  and  conditions  of  stay  (24%). 
Considerable  number  of  refusals  of  entry  were  issued  to  travellers  posing  a  risk  to  public 
policy, internal security or public health and because of alerts registered in the SIS or national 
register (20% each).  

As regards the number of Serbian nationals found to be irregularly staying, Hungary (48%) 
and Germany (26%) were the most affected countries in 2021, followed by Austria (9%).  

In 2021, Germany (25%), Austria (21%) and France (19%) ordered most returns of Serbian 
nationals.  The  number  of  the  total  returns  decreased  (-15%)  which  is  an  improvement 
compared  to  2020  (-38%)  with  Austria  (31%),  Germany  (23%)  and  France  (12%)  who 
returned to third countries most of the Serbian nationals.  

5.3.  Additional information regarding actions taken in the areas of justice and security  

In 2021 the fight against organized crime intensified, with no less than 660 police operations. 
In the field of cooperation within the EMPACT, a Working Group was established within the 
Ministry  of  the  Interior  to  align  with  the  instruments  of  police  cooperation  and  further 
develop  international  cooperation  through  the  implementation  of  the  EU  Policy  Cycle 
(EMPACT).  Serbian  police  participated  in  several  international  operations  in  line  with  the 
activities  within  EMPACT  Operational  Action  Plans,  including  in  the  field  of  fight  against 
trafficking in arms, drug smuggling and sexual exploitation of migrants.  

Serbian police joined a new analytical project in the field of combating serious and organised 
crime that supports prevention and combating crimes of intellectual property, counterfeiting 
products and piracy.  

As concerns the fight against Trafficking in Human Beings, the proposal of the Action Plan 
for  the  period  20212022  for  the  implementation  of  the  Strategy  for  Prevention  and 
Suppression of Trafficking in Human Beings, Especially Women and Children and Protection 
of Victims 20172022 was prepared and a public debate held. A special Department for the 
Suppression of Trafficking in Human Beings and Smuggling of People has been established 
within the Criminal Police Directorate, Service for Suppression for Organised Crime (SSOC). 
In 2021, a total of 17 criminal charges were filed against 27 persons suspected of trafficking 
in human beings.  

19 

 
 
In  2021,  Serbia  continued  efforts  to  combat  the  illegal  manufacturing,  possession  and 
trafficking  of  weapons  and  explosives.  1  909  firearms,  57  244  pieces  of  ammunition,  167 
bombs and 34 other explosive devices were seized. A total of 1 633 persons were charged for 
weapon offenses.  

As  concerns  the  fight  against  cybercrime,  Serbia  continued  to  implement  the  Strategy  and 
Action  plan  for  fight  against  cybercrime,  for  the  period  2019-2023.  A  particularly  strong 
effort targeted the illegal pornography sites exploiting minors. A great number of trainings to 
fight cybercrime were carried out, including some supported by TAIEX.  

As  concerns  the  fight  against  corruption,  Serbia  is  implementing  an  operational  plan  for 
Preventing Corruption in Areas of Special Risk. The plan was adopted by the government on 
30 September 2021, for  the period 2021-2022.  The Government  established a Coordination 
Body  for  its  implementation  in  November  2021.  The  work  on  a  new  National  Anti-
Corruption  Strategy  is  beginning.  Serbia  has  taken  a  number  of  steps  to  implement  the 
recommendations  of the  Group of States  against  Corruption (GRECO) related to  the  fourth 
round  of  evaluation,  including  constitutional  changes  and  amendments  to  the  law  on  the 
prevention of corruption.  

With  regard  to  sectors  particularly  vulnerable  to  corruption,  in  September  2021  Serbia 
adopted the Operational Plan for the Prevention of Corruption in Areas of Special Risk. The 
plan covers public procurement, police, customs, local self-government and the privatisation 
process.  Its  implementation  is  coordinated  through  a  Coordination  Body,  established  by  a 
Government  decision  in  November  2021,  and  chaired  by  the  Prime  Minister.  The 
Coordination body is yet to hold any meetings.  

In addition, the Ministry of Education adopted in October 2021 a specific operational plan for 
the  fight  against  corruption  in  the  field  of  education.  In  December  2021,  the  Ministry  of 
Health  adopted  an  operational  plan  for  the  fight  against  corruption  in  the  sector  of  health, 
with timelines for 2022. An operational plan for the fight against corruption in the sector of 
taxation  was  also  adopted  in  December  2021,  focusing  on  a  one-year  timeline  for 
implementation.  

As concerns the fight against terrorism, Serbia continued to implement the Joint Action Plan 
on Counter-Terrorism for the Western Balkans. Radical/extremist propaganda materials were 
regularly  seized  and  illegal  content  eliminated  from  social  media  and  other  internet  sites. 
Numerous trainings were carried out, especially focusing on early detection of radicalization. 
Serbia  also  implemented  a  series  of  actions  in  education  sector,  to  prevent  extremism  and 
radicalization in schools and universities. Serbia is working on an updated counter terrorism 
and prevention of violent extremism strategy. A baseline study on all forms of radicalisation 
and violent extremism present in Serbia is not finalized yet.  

As  concerns  the  fight  against  money  laundering  and  terrorism  financing,  the  Serbian 
government carried out  a national risk assessment, which was finalized in September 2021. 
The main conclusions were that the overall money laundering risk in Serbia is ‘medium’ and 
overall terrorism financing risk assessment is ‘medium low’. Serbia is currently preparing an 
updated 2022-2024 Action Plan accompanying the national AML/CFT Strategy.  

20 

 
 
The  cooperation  with  EUROPOL  continued  and  improved.  In  2021,  the  three  joint 
investigation teams, which had been established in the previous period, continued operating 
against  respectively  investment  fraud,  drug  production  and  drug  smuggling.  The  system  of 
exchange  of  information  SIENA  was  regularly  used.  Cooperation  with  CEPOL  continued, 
including by training and exchange programs.  

21 

 
 
 
 
6.  Georgia  

6.1.  Additional  information  regarding  the  actions  taken  in  the  area  of  migration, 

asylum and cooperation on readmission  

In order to prevent irregular migration and asylum system abuse of Georgian citizens a new 
law on Georgian citizens leaving and entering Georgia’ entered in force on 1 January 1 2021. 
Additionally  the  criminal  code  was  reformed  imposing  criminal  responsibility  for 
creating/organising  conditions  for  illegal  stay  of  citizens  of  Georgia  in  the  foreign  country, 
for  financial  gain  or  other  material  benefits,  and/or  facilitating/organising  the  provision  of 
false information on the alleged violation of the rights and freedoms of the Georgian citizen 
for requesting asylum in a foreign country.  

In  order  to  mitigate  the  flow  of  Georgian  irregular  migrants,  bilateral  cooperation  with  EU 
Member  States  was  also  enhanced,  including  by  deployment  of  Georgian  police  officers 
abroad and by organisation of trainings, especially on detection of document fraud and other 
suspicious  activities  at  the  border  crossing  points.  There  were  also  deployments  of  law 
enforcement  agents  from  EU  Member  States  in  Georgia.  In  2021,  several  measures  were 
taken  to  improve  conditions  of  the  irregular  migrants  at  the  temporary  accommodation 
centres; in particular additional accommodation space (quarantine rooms) was added in order 
to reduce the spread of COVID-19.  

In order to improve communication on rules of travel to EU Member States, the Ministry of 
Foreign  Affairs,  in  cooperation  with  the  International  Centre  for  Migration  Policy 
Development (ICMPD), upgraded the mobile application on visa free travel to the EU, taking 
over this task from  the  Ministry of Justice. The  modified application was introduced on 11 
June  2021.  It  is  available  for  users  located  in  Georgia;  the  work  on  global  availability  is 
ongoing.  Information  about  the  new  application  has  been  disseminated  through  the  social 
media, published on the official web-page of the Ministry and also by distribution of leaflets 
by key public administration agencies.  

In  2021  the  Ministry  of  Foreign  Affairs  launched  its  preliminary  works  on  the  information 
campaign to celebrate the 5th anniversary of visa-free travel to the EU.  

As concerns border protection, one border sector was built  in  2021.  In  addition  to  that, the 
border  protection  police  acquired  two  mobile  surveillance  vehicles  equipped  with  a 
sophisticated  surveillance  system.  The  development  of  GBP  aviation  continued  with  the 
planned transfer of two helicopters from Latvia to Georgia, supported financially by the EU 
via ICMPD. The modernization of the fleet of the Georgian Coast Guard (GCG) continues, 
with the launching of the acquisition process of new fast response boats.  

In  2021  the  EU  funded    border  safety  and  security  equipment  including  passport  readers, 
document  inspection  equipment,  vehicles,  mobile  radio  communication  units  and  facial 
recognition cameras.  

The Ministry of Interior carried out in 2021 a comprehensive analysis of the border protection 
operations and produced a unified risk analysis system; the purpose was to be able to better 
identify  threats  and  weak  spots  in  advance,  allowing  a  faster  response.  Georgia  uses  two 

22 

 
 
separate  risk  analyses  systems  –  one  for  border  management  and  one  for  migration 
management.    The  introduction  of  one  single  efficient  new  risk  analysis  system  for  border 
and migration management is not considered at this stage.  

Furthermore,  since  2019  Georgian  Police  officers  have  been  monthly  deployed  to  most 
affected  EU  Member  States’  airports  within  the  framework  of  Frontex  Joint  Operations. 
Cooperation  with  Frontex  intensified  in  2021,  with  the  deployment  of  Georgian  law 
enforcement agents on airports in selected EU Member States. After a pause in 2020, due to 
the COVID 19 pandemic, in 2021 Georgian law enforcement agencies participated again in 
other  common  activities  with  Frontex,  both  on  land  and  at  sea.  One  of  the  results  of  this 
cooperation was the safe return of 890 Georgian citizens from the EU.  

In  2021  law  enforcement  agents  detected  63  cases  of  fraudulent  documents,  prevent  63 
irregular border crossings, refused entry in 8544 cases and detected various violations of the 
visa regime in 6117 cases.  

In March 2021 Georgia became an observer in the European Migration Network (EMN).  

6.2.  Additional information regarding the monitoring of trends in irregular migration, 

applications for international protection, returns and readmission  

In  2021  Georgia  received  743  asylum-seekers.  The  main  countries  of  origin  were  Turkey, 
Iran, Russia, Jordan and Afghanistan.  At the end of 2021  there were  1 227 beneficiaries of 
international  protection  in  Georgia,  including  493  refugees  and  734  humanitarian  status 
holders.  

The last EU-Georgia Joint Readmission Committee was held in November 2021, where the 
EU  commended  Georgia  for  the  very  good  cooperation  and  efforts  to  prevent  irregular 
migration.  

After  the  downward  trend  in  2020,  the  number  of  applications  for  international  protection 
increased by 69% in 2021. France was the most affected EU Member State recording 38% of 
the  applications  for  international  protection  lodged  by  Georgian  nationals,  closely  followed 
by Germany (29.6%) and Italy (9%).  

The decrease in refusals of entry of Georgian nationals in 2020 was followed by a new rise of 
50% in 2021. Poland (48%), Bulgaria (12%) and Germany and Portugal (5% each) reported 
most of the cases. The refusals were largely issued to the traveller being a person for whom 
an alert had been issued in the SIS or in the national register (40%) and on the basis of lack of 
proper documents that justified the purpose and conditions of stay (30%). 16% of the refusals 
of  entry  were  issued  to  travellers  posing  a  risk  to  public  policy,  internal  security  or  public 
health.  

As regards irregular stayers from this country, 2021 marked a record with the highest number 
of detections of Georgian irregular stayers in the Schengen Area (28% more than in 2020). 
Germany  reported  37%  of  the  irregular  stays  of  Georgian  nationals,  followed  by  France 
(27%) and Greece (8%).  

23 

 
 
The  number  of  return  decisions  reported  by  EU  Member  States  in  2021  was  lower  (-13%) 
than  in  2020,  changing  the  overall  upward  trend  for  this  indicator  in  the previous  years.  In 
2021, France (30%), Germany (17%), Cyprus (13%) and Greece (11%) had the highest share 
of decision orders at EU level.  

Despite  the  decrease  in  total  returns  (-13%)  due  partly  to  the  effects  of  the  COVID-19 
pandemic, an assessment of the evaluation of total returns of Georgian nationals over a longer 
timeframe suggests that  the trend may  continue to rise over the next  few  years. As  regards 
effective returns, in 2021 Germany reported most of the returns of Georgian nationals (24%), 
followed by France (19.3%) and Greece (15%).  

6.3.  Additional information regarding actions taken in the areas of justice and security  

The National Strategy for Combating Organised Crime for 2021-2024 and its Action Plan for 
2021-2022 were adopted on 14 September 2021. The strategy focuses heavily on repression 
of  large  and  well-structured  groups  of  organised  crime,  so-called  ‘legalised  thieves’  or 
‘thieves  who  are  law’  (vory  v  zakone).  A  new  element  was  the  introduction  of  public 
awareness  campaigns  in  order  to  try  to  prevent  juveniles  from  joining  organised  crime 
groups.  

The National Drug Observatory was established in January 2020 by the Order of the Minister 
of  Justice  analyses  the  drug  situation  in  the  country.  It  operates  under  the  Inter-Agency 
Coordinating Council for Combating Drug Abuse and it is chaired by a representative of the 
Ministry of Justice. NDO is composed of experts of prevention, treatment and rehabilitation, 
reduction,  addictology,  sociology  or  epidemiology  and 
harm 
representatives  from  the  state  agencies.  It  cooperates  with  the  European  Monitoring  Centre 
for Drugs and Drug Addiction. In 2021, the Observatory elaborated its second National Drug 
Situation  Report,  providing  information  to  the  government  on  the  current  situation  and 
proposed actions concerning illegal drugs.  

reduction,  supply 

As concerns the fight against corruption, on 16 March 2021 the functions of coordination in 
this  field  were  transferred  from  the  Ministry  of  Justice  to  the  administration  office  of  the 
government  (AOG),  answering  directly  to  the  Prime  Minister.  On  9  June  2021  the  Anti-
Corruption  Secretariat  was  established  within  the  AOG,  to  exercise  the  functions  of  the 
Secretariat of the Anti-Corruption Council, develop the new anti-corruption strategy and its 
action plans, and then monitor their implementation.  

In  April  2021,  GRECO  made  public  its  Second  Compliance  Report  of  Fourth  Evaluation 
Round  on  Georgia,  to  assess  Georgia’s  implementation  of  recommendations  on  combatting 
corruption.  According  to  the  report,  Georgia  has  largely  implemented  most  of  GRECO 
recommendations issued in 2017; additionally, compared to the previous report, the status of 
implementation  of  3  recommendations  has  improved.  In  its  report  GRECO  welcomed 
Georgia’s progress, such as  growing transparency  of the legislative process,  the creation of 
the  Parliament’s  Ethics  Council,  ethics  trainings  for  MPs,  improved  regulations  under  the 
rules  for  appointing  judges,  the  improved  reasoning  of  decisions  on  appointing  judges  and 
possibility  to  appeal  such  decisions,  the  upgraded  Norms  of  Judicial  Ethics,  enhanced 
disciplinary  proceedings  against  judges,  practical  steps  toward  the  implementation  of  the 

24 

 
 
Code of Ethics for Prosecutorial Service, and improved Rules on Recruitment and Promotion 
of Prosecutors.  

In December 2020, the Secretariat of the Anti-Corruption Interagency Coordination Council 
of  Georgia  (Ministry  of  Justice)  started  the  preparation  process  of  development  of  a  new 
Anti-Corruption  Strategy  and  Action  Plan  for  2021-2022.  In  the  first  phase,  the  Secretariat 
requested  initiatives  from  the  Anti-Corruption  Council  (Council)  member  civil  society 
organizations as well as donor organizations involved in the process. In collaboration with the 
USAID project Good Governance Initiative (GGI), workshops were held with representatives 
of 16 municipalities to identify challenges and priorities at the local level. The Secretariat has 
also started the process of situation analysis.  

In  March  2021,  in  accordance  with  the  amendments  to  the  Law  of  Georgia  on  Conflict  of 
Interest and Corruption in Public Institutions, the organizational and analytical support to the 
Anti-Corruption  Council  of  Georgia,  the  functions  of  the  Secretariat  were  transferred  from 
the Ministry of Justice of Georgia (MoJ) to the Administration of the Government of Georgia 
(AoG), in order to place the anticorruption policy coordination mechanism  under the direct 
supervision of the Prime-Minister of Georgia. 

Following  the  amendments  to  the  law,  the  AoG  has  commenced  procedures  for  the 
establishment of the Anti-corruption Secretariat. In June 2021 the Anti-Corruption Secretariat 
the 
the  AoG 
was  established  within 
implementation of the anti-corruption strategy and action plan.  

to  ensure  sufficient  resource  allocation  for 

In  2021,  218  investigations  were  launched,  197  individuals  were  prosecuted  and  117 
individuals  were  convicted  in  connection  to  corruption.  Out  of  the  2021  prosecutions  and 
convictions,  14  high-ranking  officials,  including  the  deputy  minister,  deputy  district 
prosecutor,  head  and  deputy  head  of  the  legal  entity  of  the  public  law,  governors,  deputy 
governors, deputy mayor and members  of the local  councils (at  the time  of committing the 
crime) were prosecuted and 7 were convicted for corruption.  

Throughout 2021, including in cooperation with the EU and Council Europe, the Prosecution 
Service  of  Georgia  (PSG)  continued  efforts  for  building  the  capacity  of  anticorruption 
investigators  and  prosecutors.  In  the  framework  of  the  CoE/EU  Partnership  for  Good 
Governance  (PGG  II)  Project  on  “Enhancing  the  Systems  of  Prevention  and  Combating 
Corruption, Money Laundering and Terrorist Financing in Georgia” a training course on fight 
against  corruption  was  conducted  for  25  prosecutors  and  PSG  investigators.  The  course 
covered the topics such as investigation and prosecution of corruption, asset tracing, freezing 
and  confiscation,  international  cooperation,  corporate  criminal  liability,  investigative 
techniques, collection and admissibility of evidence.  

In  addition,  in  the  framework  of  the  same  project,  the  training  on  covert  investigative 
techniques  and  collection  of  information  was  conducted  for  12  prosecutors  and  PSG 
investigators.  

Apart from the above-mentioned trainings, 5 prosecutors and PSG investigators participated 
in two training events on investigation and prosecution of corruption.  

25 

 
 
 
In  2021  Georgia  signed  agreements  of  cooperation  on  combatting  crime  and  police 
cooperation with Czech Republic and Lithuania. At the end of the year Georgia had therefore 
such  agreements  with  following  17  EU  Member  States:  Austria,  Bulgaria,  Czech  Republic, 
Estonia,  France,  Germany,  Greece,  Hungary,  Italy,  Latvia,  Lithuania,  Malta,  Poland, 
Romania, Slovakia, Spain and Sweden.  

Georgia  keeps  also  expanding  the  network  of  police  attachés.  In  December  2021  Georgia 
maintained  police  attachés  in  following  11  EU  Member  States:  Austria  (also  covers 
Hungary),  Belgium  (liaison  officer  to  NATO,  also  covers  Luxemburg),  Czech  Republic, 
France,  Greece,  Germany,  Italy,  Netherlands  (also  liaison  officer  to  Europol),  Poland  (also 
covers Estonia, Latvia and Lithuania), Spain and Sweden (also covers Denmark, Norway and 
Finland.  Following  10  EU  Member  States  deployed  police  attachés/liaison  officers  to 
Georgia:  Austria,  Bulgaria,  France,  Germany,  Greece,  Italy,  Latvia,  Poland,  Spain  and 
Sweden.  In  addition,  police  attachés/liaison  officers  from  Belgium  and  Netherlands  cover 
Georgia from third states.  

In the framework of the CoE/EU Partnership for Good Governance Project on ‘Enhancing the 
Systems  of  Prevention  and  Combating  Corruption,  Money  Laundering  and  Terrorist 
Financing in Georgia’ the special training course on fight against corruption was conducted 
for 25 prosecutors and PSG investigators. The course covered the topics such as investigation 
and  prosecution  of  corruption,  asset  tracing,  freezing  and  confiscation,  international 
cooperation,  corporate  criminal 
techniques,  collection  and 
admissibility of evidence. In addition, in the framework of the same project, the training on 
covert  investigative  techniques  and  collection  of  information  was  conducted  for  12 
prosecutors and PSG investigators.  

investigative 

liability, 

As regards anti-money-laundering, Georgia still need to take the relevant measures to address 
the  deficiencies  highlighted  in  the  2017  MONEYVAL  in  particular  to  ensure  a  better 
assessment of the ML/TF risks it is facing, notably linked to the use of cash and the lack of 
transparency  of  legal  entities,  linked  to  the  absence  of  proper  mechanisms  allowing  to 
identify beneficial ownership of legal entities established in Georgia.  

26 

 
 
 
 
 
7.  Moldova  

7.1.  Additional  information  regarding  the  actions  taken  in  the  area  of  migration, 

asylum and cooperation on readmission  

As  regards  document  security,  with  the  expiration  of  the  last  non-biometric  passports  on  1 
January  2021,  citizens  of  Moldova  held  only  biometric  passports.  On  31  December  2021  a 
total of 2 409 271 citizens of Moldova had valid biometric passports.  

As  regards  border  protection,  Moldova  continues  to  implement  the  national  strategy  on 
integrated border management for 2018-2023 and its action plan for 2021-2023. The current 
action plan prioritises the development of the system for coordination of border security and 
inter-institutional  cooperation  between  law  enforcement  agencies,  as  well  as  an  increase  of 
capacities  for  border  control,  prevention  and  combating  of  cross  border  crime.  Additional 
effort  on  recruitment  and  training,  in  order  to  increase  the  numbers  of  agents  and  improve 
their  qualification  is  also  included.  The  communication  system  TETRA  used  by  the  border 
police  was  extended.  The  agency  received  also  additional  equipment,  including  cars, 
intervention boats, air cushion crafts and unmanned aerial vehicles (UAV).  

Moldova  border  police  continued  common  patrols  with  relevant  services  of  neighbouring 
countries.  In  2021  there  were  168  joint  patrols  with  Romania  and  163  joint  patrols  with 
Ukraine, including at the Transnistrian segment of the Moldova-Ukraine state border.  

In  2021  the  border  police  put  a  strong  accent  on  integrity  training  of  the  employees.  132 
agents  were  trained  on  integrity  and  anticorruption  in  the  framework  of  8  training  courses, 
reminding  participants  of  the  rules  of  the  2017  code  of  ethics  and  deontology  of  public 
servants and the 2016 code of ethics and behaviour of customs officers.  

As  regards  cooperation  with  Member  States,  on  28  May  2021  Lithuania,  under  the  Grant 
Contract between the  International Centre for Migration Policy Development (ICMPD), the 
State Border Guard Service (SBGS) and the General Inspectorate of the Border Police of the 
Ministry  of  Internal  Affairs  of  the  Republic  of  Moldova,  started  implementing  an  action 
‘Enhancing capacities of Border Police forces to detect forged identity and travel documents 
for  preventing  and  combating  irregular  migration  and  trafficking  in  human  beings’.  The 
expected  date  of  the  implementation  of  the  action  is  30  November  2022.  In  addition, 
Lithuania  implemented  measures  in  the  framework  of  the  Bilateral  Cooperation  Plan  for 
2021-2022 between SBGS and the General Inspectorate of the Border Police of the Ministry 
of Internal Affairs of the Republic of Moldova consisting of a meeting of the heads of border 
guard institutions on management of the flows of irregular migrants, IT solutions and use of 
drones / anti-drones in border management; and an expert meeting on exchange of experience 
in border security.  

Latvia  reported  very  good  cooperation  with  the  Moldovan  Border  Police  based  on  the 
Cooperation Agreement. The Latvian State Border Guard in accordance  with the agreement 
provides  expertise  and  exchanges  best  practices  with  the  Moldovan  side  on  border 
management  issues,  risk  analysis,  developing  IT  systems  documents  inspections,  trainings 
and  other  activities.  In  order  to  raise  the  capacity  of  Georgian  and  Moldovan  border  guard 

27 

 
 
agencies, the State Border Guard implemented capacity building projects, which were aimed 
at improving their capacity in the field of dog handling (K9). Since November 2021, the State 
Border Guard of Latvia posted an Immigration Liaison Officer (ILO) in Ukraine, who is also 
responsible  for  Moldova  and  Belarus.  The  ILO  maintains  cooperation  with  the  Moldovan 
public  agencies  and  implements  exchange  of  information  with  other  EU  ILOs  posted  in 
Ukraine,  Moldova  and  Belarus,  as  well  as  with  public  agencies  involved  in  combating 
irregular migration. In October 2021, the Head of the State Border Guard of Latvia and the 
Chief of Moldavan Moldovan Border Police agreed on plans for further cooperation.  

France  engaged  in  cooperation  actions  on  capacity  building  covering  a  study  visit  to  Nice 
airport by the Air and Border Police of the Republic of Moldova for senior Chisinau Border 
Police officers on aviation safety, border control, technical and technological means, training 
of officers and use and implementation of Advanced Passenger Information System (APIS). 
Germany continued the English language course for first line officers at the airport Chisinau 
to CEF level ‘B2’and provided a service vehicle for the document verification unit.  

7.2.  Additional information regarding the monitoring of trends in irregular migration, 

applications for international protection, returns and readmission  

In  2021  Moldova  identified  2  736  cases  of  illegal  stay  and/or  employment  by  foreigners, 
mostly from Ukraine, Russia, Romania, Turkey and Israel. 1 250 decisions on withdrawal of 
the  right  to  stay  were  issued  and  347  foreigners  received  return  decisions.  There  were  48 
cases of escorted removals.  

In 2021 the Bureau for Migration and Asylum received 75 asylum applications. 59 decisions 
on asylum applications were issued, of which 13 for  granting refugee status,  8 for  granting 
humanitarian  protection  and  38  for  rejecting  asylum  applications.  Examination  of  the 
remaining  applications  continued.    In  2022  the  number  of  asylum  seekers  in  Moldova  grew 
considerably  as  a  result  of  Russia’s  aggression  against  Ukraine  –  by  mid-June  there  were 
7898 asylum applications in Moldova.  

On  31  December  2021  there  were  437  persons  in  the  asylum  system  of  the  Republic  of 
Moldova, of whom 77 were at the stage of examining asylum applications, 173 had refugee 
status and 187 were beneficiaries of humanitarian protection. 168 applications for recognition 
of statelessness status were submitted in 2021. The rate of recognition of stateless status was 
33%.  On  31  December  2021  there  were  288  applicants  in  the  procedure  for  recognition  of 
statelessness status.  

As regards applications for international protection, Germany (63% of the total) and France 
(23%)  received  the  majority  of  the  applications  in  2021,  followed  by  Belgium  (6%)  and 
Austria (2%).  

As  regards  the  number  of  Moldovan  nationals  being  refused  entry,  Romania  remained  the 
most  affected  country  accounting  for  57%  of  all  refusals  of  entry,  followed  by  Hungary 
(22%) and Poland (15%). 53% of refusal were due to the lack of appropriate documentation 
to  justify  the  purpose  and  conditions  of  stay.  The  second  biggest  share  of  refusals  were 
related  to  alerts  issued  in  the  SIS  or  in  the  national  register  (24%),  followed  by  10%  of 

28 

 
 
refusals  issued  to  travellers  who  have  already  stayed  on  the  national  territory  of  Member 
States  for  the  permitted  90-days  and  8%  of  refusals  motivated  by  a  risk  to  public  policy, 
internal security, public health or the relations of one or more Member States.  

As  regards  the  number  of  nationals  of  Moldova  found  to  be  irregularly  staying  in  the  EU 
Member States in 2021, it marked a triple expansion. Hungary was the most affected country, 
accounting for 70% of the total which is the highest number that has ever been recorded by 
the country, followed by Germany (12%) and France (7%).  

In  2021,  France  reported  the  highest  number  of  return  decisions  of  Moldovan  nationals 
(34.6% of the total), followed by Germany (22%) and Czechia (14%). The decreasing trend 
of  2020  continued  in  2021  with  a  decrease  in  total  returns  (-14%).  Germany  (23%)  and 
France (21%) carried out most of the returns, followed by Hungary (18%) and Poland (7%).  

The  last  meeting  of  the  EU-Moldova  Joint  Readmission  Committee  was  held  virtually  in 
November 2020.  Member States  confirmed that  relevant  provisions  of the EU Readmission 
Agreement are generally well respected.  

7.3.  Additional information regarding actions taken in the areas of justice and security  

As  concerns  the  fight  against  organised  crime  in  2021  a  total  of  18  criminal  organisations 
were  investigated  and  44  of  their  members  were  arrested.  Most  investigations  concerned 
cases of blackmail/extortion, fraud and drug trafficking.  

As concerns the fight against drug production and trafficking, in 2021 a total of 598 people 
were prosecuted and 8 laboratories producing illegal drugs were dismantled.  

As  concerns  the  fight  against  money  laundering,  since  February  2018  this  activity  is  the 
responsibility of the Office for Prevention and Fight against Money Laundering (OPFML). It 
supervises  and coordinates the 2020-2025 national  Anti-Money  Laundering and Countering 
the  Financing  of  Terrorism  strategy,  which  started  to  be  implemented  in  the  beginning  of 
2021.  In  2021  amended  AML  rules  extended  the  supervision,  which  previously  concerned 
only  banks,  to  non-bank  payment  service  providers,  foreign  exchange  offices  and  hotels. 
Legislation was also modified to oblige all legal persons to provide and publish information 
on effective ownership.  

As concerns the fight  against trafficking in  human beings, on 10  November 2021 Moldova 
adopted a new Action Plan for 2021-2022 to implement the 2018-2023 National Strategy for 
Preventing  and Combating Trafficking in  Human Beings. The new plan  contains actions to 
implement the recommendations of the international evaluation mechanisms, including those 
made by Group of Experts on Action  against Trafficking in  Human  Beings  (GRETA).  The 
new  plan  gives  major  importance  to  the  development  of  services  for  victims  of  trafficking 
and vulnerable  groups, including migrants  and asylum seekers, as  well as  to  the systematic 
and  continuous  training  of  investigators,  prosecutors  and  judges  to  deal  with  human 
trafficking cases.  

During 2021, a total of 63 criminal cases were filed regarding trafficking in human beings, 50 
concerning  adults  and  13  concerning  children.  A  total  of  357  victims  were  identified,  335 

29 

 
 
 
adults and 22 children. Most victims (90%) were trafficked for labour exploitation, with the 
remaining being destined either to sexual exploitation or begging.  

In  2021  Moldova  continued  to  implement  the  cooperation  agreement  with  Europol.  The 
SIENA information exchange application was widely used.  

In 2021 the cooperation with Eurojust continued through the EUROJUST Contact Point. Four 
Joint Investigation Teams (JIT) have been set up with EU Member States (Bulgaria, France, 
Italy and Romania); two more were created with Montenegro and Ukraine. The JITs targeted 
criminal cases regarding money laundering, cybercrime, trafficking in human beings, sexual 
exploitation,  labour  exploitation  and  drug  smuggling.  As  a  result,  some  large  scale  police 
operations were carried out together by Moldova and EU Member States in 2021 and in the 
beginning  of  2022,  most  of  them  targeting  the  groups  trafficking  human  beings  for  labour 
exploitation.  

Several Member States reported extensive joint activities with Moldova in the field of justice 
and security. In 2021, a German Immigration Liaison Officer (ILO) followed Moldova being 
deployed  in  a  neighbouring  country.  Germany  continued  the  Police  Capacity  Building 
program  by  providing  training  courses  and  scholarship  to  Moldovan  officials.  Furthermore, 
Germany reported a second exchange of experience with 12 senior MDA officers on the topic 
of  ‘Fighting  corruption  and  modern  methods  for  building  professional  integrity’.  France 
signalled  that  Moldovan  organised  crime  groups  are  mainly  involved  in  jackpots  on  its 
territory  and  initiated  cooperation  actions.  Among  other  initiatives,  France  delivered  a 
presentation of the organisation and missions of the French Internal Security Forces for staff 
to  the  Moldovan  Border  Police  in  order  to  assist  them  in  clearly  identifying  their  potential 
French partners in the context of international police cooperation, and more particularly in the 
fight against trafficking between Moldova and France.  

Lithuania  continues  its  support  to  transportation  safety  of  Moldova.  In  2021,  Lithuanian 
Transport  Safety  Administration  and  Moldovan  Ministry  of  Infrastructure  and  Regional 
Development  participated  in  common  project  ‘Safe  and  interoperable  transport  system  in 
Moldova  (III)’.  The  project  is  funded  by  the  Development  Cooperation  and  Democracy 
Support Program of the Ministry of Foreign Affairs of the Republic of Lithuania. In the frame 
of  the  aforementioned  project  the  meetings  were  held  in  Lithuania  and  Moldova  where  the 
experts  discussed  the  assurance  of  safe,  efficient  and  interoperable  road,  railway,  civil 
aviation  and  maritime  transport  system.  A  visit  to  Lithuanian  State  Port  of  Vilnius  was 
arranged to present the implementation of international maritime treaties and conventions in 
the field of maritime safety to Moldovan specialists.  

Latvia  report  that  State  Police  investigators  have  established  close  cooperation  in  specific 
criminal  cases  with  their  respective  counterparts  in  Moldova.  State  Police  College  has 
cooperation  agreement  with  Moldova  Interior  Ministry  Academy  ‘Stefan  cel  Mare’  and 
cooperates  in  the  fields  of  scientific  research,  improvement  of  the  quality  of  professional 
activities, exchange programs for teachers and police cadets, as well as in the organisation of 
joint  cultural  and  sports  activities.  Latvia  participated  in  several  projects  on  judicial 
cooperation and assistance provided to Moldova. The first project ‘Strengthening the capacity 
of  the  Legal  Department  of  the  Constitutional  Court  of  the  Republic  of  Moldova’  of  the 

30 

 
 
Constitutional  Court  of  the  Republic  of  Latvia  aims  at  strengthening  the  professional 
expertise of the lawyers of the Constitutional Court of Moldova and the ability of the courts 
to  conduct  constitutional  examination  consistently,  to  apply  international  human  rights 
norms.  The  second  project  ‘Online  Intensive  Programme  in  European  Law  and  Economics 
for  European  Neighbourhood  Policy  Countries,  Central  Asia  and  Western  Balkans’  of  the 
Riga  Graduate  School  of  Law  provides  interdisciplinary  training  on  the  legal,  political  and 
economic functioning of the EU.  

Sweden continues to engage in bilateral development cooperation to support police reform in 
line  with  the  Moldovan  Police  Reform  Strategy  (2016-2020),  including  on  community 
policing and basic tactics in policing. The cooperation has focused on capacity building and 
transfer  of  know-how,  in  order  to  ensure  that  the  Moldovan  Police  have  a  competent  and 
sufficient  set  of  instructors  to  maintain  and  disseminate  these  core  policing  capacities 
throughout  the  country,  with  the  aim  of  bringing  citizens’  needs  to  the  forefront  of  police 
work, ultimately increasing the public trust in the police. In terms of community policing, the 
model suggested to gather, compile, analyse and react to the input from citizens, as regards 
their security concerns. The model builds on existing local structures to form so called ‘local 
security councils’, thus gathering local stakeholders to find joint solutions to identified crime-
related problems.  

In  2021,  Moldova  also  received  support  from  the  Swedish  Police  Authority  on  institution-
building  to  enhance  democratic  policing  which  is  governed  by  the  different  needs  of  the 
citizens based on gender and age. This human rights based approach, in addition to the rule of 
law,  is  decisive  for  the  activities  promoted  within  the  police  organisation,  as  well  as  in 
activities  involving  citizens  directly,  for  example  when  implementing  community  policing 
and applying basic tactical methods in everyday police work.  

31 

 
 
 
 
8.  Ukraine  

8.1.  Additional  information  regarding  the  actions  taken  in  the  area  of  migration, 

asylum and cooperation on readmission  

Ukraine  made  a  significant  effort  to  inform  its  citizens  about  their  rights  and  obligations 
under the EU-Ukraine visa-free regime and the various aspects of EU migration legislation. 
News  and  announcements  on  those  topics  are  regularly  published  on  web  portals  of  the 
Ukrainian  News  Agency  and  broadcasted  by  Ukrainian  public  TV.  The  State  Migration 
Service  conducted  in  2021  information  campaigns  on  this  topic,  especially  before  public 
holidays, when there is a greater number of departures abroad.   In addition, the information 
campaign  ‘Safe  Migration’  take  place  on  a  permanent  basis,  via  websites  and  publications. 
Posters with explanations of the rules of travel under the visa liberalization are posted in all 
SMS territorial subdivisions where citizens obtain passports.  

As concerns document security new draft legislations on passports (terms of validity, reasons 
for  exchange  grounds  for  invalidating)  and  on  use  of  stolen/forged  documents  (liability  for 
theft,  appropriation,  sale  and/or  forgery)  were  presented  to  the  Parliament  for  adoption. 
Legislative procedure is ongoing.  

Ukraine systematically provides data on invalid, lost and stolen travel documents to Interpol. 
As  of  1  January  2022,  the  Interpol  database  contained  358  695  records  of  Ukrainian 
documents, including 278 009 invalid documents and 80 686 lost and stolen documents (138 
559 records were put into the Interpol databases in 2021).  

As concerns the border control Ukraine uses the National System of Biometric Verifications 
and  Citizen  Identification  that  allows  automatically  to  check  all  types  of  biometric 
documents.  From  1  January  2017  at  all  international  and  interstate  border  crossing  points 
(157) and 3 entry/exit control points (on the administrative line with Crimea) biometric data 
are  collected  from  citizens  of  70  countries  considered  as  ‘migration  risk’.  All  the  157 
international and interstate border-crossing points are connected to Interpol databases.  

In 2021, Ukrainian law enforcement agencies dismantled 35 groups involved in smuggling of 
migrants. One of them was part of a larger, international organised crime network, involved 
in  smuggling  Asian  migrants  to  EU  by  sea.  This  group  attempted  to  recruit  experienced 
Ukrainian  sailors  to  operate  boats  transporting  migrants.  Ukrainian  element  of  this  crime 
operation was dismantled.  

On  14  December  2021  draft  laws  on  amendments  to  migration  legislation  passed  the  first 
reading  in  the  Parliament.  Those  texts  should  simplify  the  procedures  for  decisions  on 
extended stay/residence in Ukraine but also strengthen the sanctions for irregular stay on the 
territory. Both texts still have to be adopted in the second reading.  

In 2020-2021, the State Migration Service continued implementation of the EU-funded IOM-
implemented project ‘Support for Migration and Asylum Management in Ukraine (IMMIS)’. 
In  this  context,  a  number  of  IT  systems  were  implemented,  including  on  visas,  biometric 
identification  and  verification,  migration  management  and  readmission.  An  information 
campaign was organised to present the results of the project.  

32 

 
 
Ukraine  continued  the  preparations  to  join  as  observer  the  European  Migration  Network 
(EMN). On 29 October 2021 Ukraine representatives participated in the EMN Council Board 
meeting to officially present its position and to confirm Ukraine’s desire to join the Network. 
Before the war began, Ukraine expected to join the EMN by mid-2022.  

In 2021, several Member States reported bilateral cooperation activities with Ukraine in the 
field of migration and border management. Belgium informed that Ukraine participated in the 
pilot phase of the rollout of the automated readmission system (RCMS) aiming at reinforcing 
the  readmission  process.  Belgium  plan  to  use  the  system  in  2022.  Germany  continued 
development of a joint border police situation report and provided equipment for immigration 
control  departments  of  Kyiv  airports.  Estonia  provided  trainings  and  signalled  regular  and 
good cooperation with the Ukrainian border guard officials.  

In the frame of the Bilateral Cooperation Plan for 2021-2022 between the State Border Guard 
Service  (SBGS)  of  Lithuania  and  State  Border  Guard  Service  of  Ukraine,  a  meeting  on 
exchange  of  experience  in  border  security  was  held  in  Lithuania.  The  topics  discussed 
included  management  of  the  state  border  and  irregular  migration  flows  and  adoption  and 
amendment  of  legal  acts.  Latvia  reported  that  in  November  2021  the  Immigration  Liaison 
Officer of the State Border Guard was deployed to Ukraine (also for Moldova and Belarus). 
The  Immigration  Liaison  Officer  is  deployed  in  the  mentioned  third  countries  with  the 
purpose to  strengthen the control  of the European Union’s external  borders and to  promote 
the  effective  management  of  migration  flows  in  accordance  with  the  requirements  of  the 
Schengen acquis. The State Border Guard Liaison Officer promotes cross-border cooperation 
and  the  expansion  of  professional  contacts  between  law  enforcement  authorities  of  the  EU 
Member  States  and  third  countries,  thus  reducing  illegal  cross-border  activities  and 
combating illegal immigration to the EU Member States. 

In 2021, Poland reported activities organised for the Ukrainian officials through the national 
Asylum,  Migration  and  Integration  Funds  Strengthening  Migration  and  Border  Service 
capacity  of  Ukraine  in  the  area  of  migration  management.  These  activities  consisted  of 
trainings and workshops hosted in Poland and Ukraine; meetings and official visit organised 
in Poland; study visits in Poland in the Polish Border Guard Headquarters and Regional Units 
(Nadwiślański  oraz  Nadbużański)  and  Border  Guard’s  posts;  internships  for  Ukrainian 
counterparts  at  the  Border  Guard  HQ  and  guarded  centres  for  foreigners.  The  overall 
objective was to improve the Ukrainian ability to manage migration flows on the Ukrainian 
side  through  more  efficient  implementation  of  the  return  policy;  sealing  the  EU  external 
border  protection;  counteracting  secondary  migration  movements;  streamlining  an  existing 
operational cooperation carried out within the signed EU Readmission Agreement.  

8.2.  Additional information regarding the monitoring of trends in irregular migration, 

applications for international protection, returns and readmission  

In 2021 8 308 irregular migrants were detected in Ukraine, a 97.95% increase compared to 
2020 (4197 irregular migrants). Most of those persons entered legally and extended their stay 
irregularly; only 7.98% (663) irregularly entered the territory. The main countries of origin of 
irregular  migrants  in  2021  were  Azerbaijan  (1634),  Russia  (1169),  Uzbekistan  (862), 

33 

 
 
Armenia (841), Moldova (566), Georgia (507), Tajikistan (249), Turkmenistan (177), Nigeria 
(151), Belarus (138) and Vietnam (132). Numbers for other countries of origin (in all 18% of 
the total) were significantly lower.  

In  2021  a  total  of  810  irregular  migrants  were  detained  in  the  temporary  holding  facilities 
(THF),  for  identification  before  expulsion.  The  vast  majority  of  these  migrants  were  from 
Azerbaijan, Bangladesh, Uzbekistan, Vietnam and Afghanistan.  

In 2021, Member States consider that in general Ukraine complied with the terms of the EU 
Readmission  Agreement.  Ukraine  signed  implementation  protocols  to  the  agreement  with 
five  EU  Member  States:  Austria,  Czechia,  Estonia,  Poland  and  Lithuania.  A  readmission 
dialogue on the drafting of protocols is underway with a further sixteen EU Member States: 
Bulgaria, Croatia, Cyprus, France, Germany, Greece, Hungary, Italy, Latvia, Malta, Portugal, 
Romania, Slovakia, Slovenia, Spain and Sweden.  

Estonia  reported  very  good  cooperation  with  the  Ukrainian  Embassy  in  identification  and 
issuing travel documents. Croatia signalled that there was no return of Ukrainian nationals to 
Ukraine,  but  the  cooperation  with  the  Ukrainian  Embassy  in  Zagreb  in  the  procedures  of 
returning  Ukrainian  citizens  in  previous  years  can  be  assessed  as  very  good.  The  Swedish 
Police Authority’s cooperation with the State Migration Service of Ukraine in relation to the 
readmission agreement has improved since 2020, when the cooperation was unsatisfactory.  

As regards applications for international protection in the EU by Ukrainians in 2021, the most 
concerned  Member  States  were  France  (36%  of  the  total),  followed  by  Spain  (16%)  and 
Germany (12.5%).  

Similarly to 2019 and 2020, in 2021 more than half of all refusals of entry issued to nationals 
of  the  monitored  countries  were  to  Ukrainian  nationals.  Hungary  (44%  of  the  total)  and 
Poland (43%) issued the majority of refusals, followed by Romania (6%). The biggest part of 
the refusals were motivated by a risk to public policy, internal security, external relations or 
public health, partly due to the COVID-19 pandemic (40%). Considerable number of refusals 
were  issued  on  the  basis  of  lack  of  appropriate  documentation  to  justify  the  purpose  and 
conditions of stay (33%) and 12% of the refusals were related to alerts issued in the SIS or in 
the national register.  

In 2021, the number of irregular stays marked an important decline (27%) compared to 2020. 
As  regards  the  number  of  Ukrainian  nationals  found  to  be  irregularly  staying  in  2021, 
Hungary was the most affected Member State (37% of the total), followed by Czechia and 
Germany (16%) and Poland (14%).  

In 2021, Poland issued most of the return decisions to Ukrainian nationals (31%) in the EU, 
followed  by  Czechia  (20%),  Germany  (10%)  and  France  (9%).  The  number  of  the  total 
returns  decreased  in  2021  (-21%),  with  Poland  reporting  about  half  of  all  returns  of 
Ukrainian nationals (48%), followed by Sweden (8%) and Estonia (7%).  

8.3.  Additional information regarding actions taken in the areas of justice and security  

As  concerns  the  fight  against  organised  crime,  Ukraine  implements  a  national  strategy 
adopted  in  September  2020.  Following  EU  recommendations,  the  Department  of  Strategic 

34 

 
 
Investigations  of  the  national  police  (NPU)  was  established  with  the  key  objective  to  fight 
organised crime in Ukraine. In 2021 NPU sent to the court 428 cases concerning  organised 
groups and 41 cases concerning criminal organisations. Ukrainian organised crime groups are 
involved in a wide spectrum of illegal activities; one of the particularly lucrative ones is the 
tobacco smuggling.  

Concerning  the  clarification  and  delineation  of  competences  of  law  enforcement  agencies, 
there were some efforts to rationalize the functioning and operation between various bodies, 
however the concrete results were limited. The Action Plan accompanying the 2020 Strategy 
for Combating Organized Crime, the new legislation on State Bureau of Investigation (SBI), 
Security Service of Ukraine (SBU) and State Bureau of Economic Security (tax police) are all 
in  various  stages  of  legislative  work,  but  none  was  as  of  yet  adopted.  As  result  the 
competences  of  numerous  security  and  law  enforcement  agencies  in  Ukraine  remain  not 
sufficiently delineated.  

 According  to  second  follow-up  report  by  the  MONEYVAL  of  2020  that  was  published  in 
2021,  Ukraine  achieved  full  compliance  with  eleven  out  of  40  FATF  recommendations 
constituting  the  international  AML/CFT  standard.  Ukraine  retains  minor  deficiencies  in  the 
implementation  of  another  twenty-two  recommendations  where  it  has  been  found  “largely 
compliant”,  and  larger-scale  deficiencies  for  the  remaining  six  where  it  has  been  rated 
“partially compliant”.  

Ukraine  saw  some  progress  in  2021  on  disclosure  of  information  on  ultimate  beneficial 
ownership. Moreover, in 2021 the draft legislation on verification of the beneficial ownership 
information  was  registered  with  the  Verkhovna  Rada  of  Ukraine.  This  addresses  the 
recommendation  by  the  Mutual  Evaluation  Report  of  2017,  which  advised  Ukraine  to  take 
reasonable steps to verify the information on UBOs submitted to the Unified State Register is 
accurate  and  up  to  date.  However,  the  effective  mechanism  for  verification  of  the  ultimate 
beneficial ownership information, in particular through cross-checking with other resources, 
is missing.  

The MONEYVAL in  its follow-up report assessed the implementation  of new international 
requirements  for  virtual  assets  and  the  providers  of  these  assets.  While  registering  some 
progress,  MONEYVAL  downgraded  Ukraine’s  rating  on  the  implementation  of  the  FATF 
Recommendation 15 from “largely compliant” to “partially compliant”.  

There is a regular effort in increasing the competences and improving the equipment of NPU. 
In  2020  a  Criminal  Analysis  Centre  became  operational.  In  2021  most  of  agents  received 
training  in  latest  versions  of  analytical  software.  ‘A  Serious  and  Organised  Crime  Threat 
Assessment Methodology in Ukraine’, based on Europol SOCTA Methodology, was created 
and finally adopted on 26 January 2022.  

As concerns the fight against money laundering, the entry in force of ‘Law on prevention and 
counteracting  legalisation  (laundering)  of  proceeds  from  crime,  financing  of  terrorism  and 
financing  of  proliferation  of  weapons  of  mass  destruction’  of  28  April  2020  allowed  to 
accelerate  the  actions  of  Ukrainian  law  enforcement.  As  a  result,  in  2021  transactions 
concerning  a  total  of  8.8  billion  hryvnias  (the  equivalent  of  EUR  275  million)  were 

35 

 
 
investigated.  Frequently  related  to  money  laundering  were  cases  of  investment  fraud  –  in 
2021 a total of 1132 people were indicted on those charges.  

As  concerns  the  fight  against  drug  production  and  trafficking,  Ukraine  is  currently 
developing a new State Drug Policy Strategy for the period up to 2030. Before the war started 
Ukraine was preparing a large overhaul of its drug legislation, including a revision of lists of 
forbidden substances, the question of drug trade on internet, the illicit trade of precursors and 
procedures of destruction of seized illegal drugs.  

In  compliance  with  the  requirements  of  the  Memorandum  of  Understanding  between  the 
MHU  and  the  European  Monitoring  Centre  for  Drugs  and  Drug  Addiction  (EMCDDA), 
Ukraine prepares an annual report on the drug situation in Ukraine. Last National Report was 
submitted to EMCDDA in 2020.  

As concerns the fight against cybercrime law enforcement agencies increased their efforts – 
as result the number of cases investigated progressed from 11 621 in 2020 to 17 884 in 2021. 
Roughly  60%  of  all  cases,  both  in  2020  and  in  2021,  concerned  online  fraud  and  financial 
crimes  against  bank  sector,  the  rest  being  various  other  cases  of  hacking  as  well  as 
production/distribution of illegal content.  

As  concerns  the  fight  against  illegal  firearms,  this  is  one  of  priorities  of  the  Ministry  of 
Interior. The main obstacle in this effort is the lack of legislative  basis for the creation of a 
comprehensive,  nationwide  register  of  weapons.  There  were  several  attempts  to  draft  a 
specialised  legislation  but  still  they  were  not  approved.  The  scale  of  the  problem  is 
considerable. In 2021 the police registered 4003 criminal offences related to illegal handling 
of weapons, ammunition and explosives, illicit manufacturing, reconstruction or repair of the 
firearms or illicit manufacturing of the ammunition, explosives and explosive devices. 3098 
various firearms, 3236 grenades and 201 grenade launchers were confiscated. Those numbers 
are comparable to those of 2020.  

As concerns the fight against terrorism, in 2021 the Security Service of Ukraine (SSU) acted 
against  activities  in  Ukraine  of  international  terrorist  and  religious-extremist  organisations 
from North Africa, the Middle East, Central and Southeast Asia (including Islamic State and 
Al  Qaeda).  27  persons  were  detained.  601  foreigners  suspected  of  involvement  in 
international  terrorist organisations  activities were banned  from  entering Ukraine. 7  foreign 
nationals were deported and 101 were forcibly returned to their countries of origin, following 
suspicion  of  involvement  in  the  activity  of  international  terrorist  and/or  extremist 
organisations.  

Cooperation  with  Europol  is  regular  and  systematic.  The  International  Police  Cooperation 
Department  has  its  24/7  Duty  Station  and  ensures  fast  information  exchange.  However,  for 
the  moment  the  limited  accesses  to  SIENA  was  provided  only  for  8  Departments  within 
NPU. After ratification of Memorandum of Understanding between Ukraine and Europol on 
confidentiality and ensuring safety of information the discussions will restart on connecting 
some other competent Ukrainian authorities to SIENA.  

Cooperation with CEPOL was slowed by COVID 19 pandemic, but in February 2021, after 
cancellation of quarantine restrictions CEPOL EXCHANGE program  2021 could  begin.  37 

36 

 
 
law  enforcement  officers  from  Ukraine  participated,  including  in  study  visits  to  Lithuania, 
Portugal and Romania.  

As regards measures against corruption, the amended Law on NABU stipulates a commission 
for  the  selection  of  the  NABU  Director  composed  of  six  persons,  three  appointed  by  the 
government  and  three  appointed  on  the  basis  of  proposals  from  international  and  foreign 
organisations.  On  28  December  2021,  the  EU  and  US  jointly  nominated  3  experts  to  the 
Selection Commission and subsequently, on 15 February, after the Ukrainian government had 
announced  its  3  Selection  Commission  members,  appointed  the  commission  with  all  6 
members. The government decree on the establishment of the Selection Commission included 
a conditionality clause that would allow one of the international members, who also serves in 
the parallel Selection Commission for the leadership of SAPO, to assume his role only after 
completion or his prior resignation from the SAPO head selection process. Thus, due to this 
conditionality  clause  and  the  continued  blockage  of  the  SAPO  selection  process,  also  the 
NABU selection process could not proceed further. A new SAPO Head was appointed only 
on July 28, 2022, following a selection process that lasted for almost two years. 

Until 1 September 2021, the selection was made under a temporary procedure in which the 
Prosecutor General and heads of regional prosecutor's offices appointed the candidates after 
their  appropriate  approval  by  the  Commission  for  selection  of  senior  executives  of  the 
prosecutor's offices. Its composition and rules of procedure were approved by the Prosecutor 
General.  The  Commission  was  composed  of  an  equal  number  of  prosecutors  and  external 
members.  The  selection  procedure  was  transparent,  fair  and  competitive,  and  included  a 
thorough  integrity,  professionalism  and  leadership  check.  In  2021,  the  Commission  for 
selection of senior executives of the prosecutor's offices  approved the appointment of more 
than  100  persons  to  administrative  positions  in  the  Office  of  the  Prosecutor  General  and 
almost  600 persons for administrative positions in regional and district  prosecutor's offices. 
The Commission refused to approve the nomination of 56 candidates.  

On 1 September 2021, the prosecutorial self-government body - the Council of Prosecutors of 
Ukraine  -  resumed  its  work,  taking  over  the  tasks  assumed  previously  by  the  above-
mentioned commission.  The powers of the Council include making recommendations on the 
appointment  and  dismissal  of  the  First  Deputy  Prosecutor  General,  Deputy  Prosecutor 
General,  Head  of  the  Regional  Prosecutor's  Office,  First  Deputy  Head  of  the  Regional 
Prosecutor's  Office,  Deputy  Head  of  the  Regional  Prosecutor's  Office  and  the  District 
Prosecutor's Office. When taking a decision regarding the recommendation for appointment 
to  an  administrative  position,  the  Council  of  Prosecutors  of  Ukraine  takes  into  account  the 
professional and moral qualities of the candidate, as well as management and organisational 
skills and work experience.  Yet, its procedures lack transparency, meritocracy and integrity-
check elements that were part of the temporary regime until 1 September 2021.  

There  is  a  legal  obligation  to  carry  an  annual  secret  integrity  check  for  all  prosecutors, 
including senior executives. The procedure is conducted by the Internal Security Unit of the 
Inspectorate General of the Prosecutor General’s Office.  

37 

 
 
As regards the selection of the head of Asset Recover and Management Agency (ARMA), a 
temporary  head  was  appointed  on  4  August  2021.  The  competition  for  the  selection  of  the 
new head started, but the process was not finalised. In September 2021 the composition of the 
competition  commission  for  a  new  head  of  ARMA  was  approved.  The  commission  is 
composed of eight members, appointed by the Parliament (3), the Prosecutor General (1), the 
Director of NABU (1), the Minister of Justice (1), the Minister of Finances (1) and the head 
of the State Financial Monitoring Service (1). 

Czechia  provided  assistance  in  order  to  introduce  new  procedures  and  methods  for 
conducting  interrogations  particularly  with  vulnerable  victims,  including  equipment  for 
training  interrogation  room.  Czechia  further  provided  anti-corruption  training  led  by  the 
General  Inspection of Security Units (GIBS) of their counterparts in Ukraine (SBI, NABU) 
on know-how and best practice through lectures and practice. The country participated also in 
a training for filling and processing of complaints to the National police of Ukraine with the 
objective  to  identify  weak  points  in  the  Ukrainian  legislation.  Czechia  reported  the  project 
‘Safe  City’  of  Team4Ukraine  NGO  with  participation  of  Czech  Police  which  aims  at 
developing prevention practices in Uzhhorod area to be used in municipal police reform and 
will  continue  in  2022.  The  Czech  Ministry  of  Foreign  Affairs  launched  also  the  project  on 
data utilisation in the fight against manipulation and disinformation.  

investment  frauds 

through  participation 

Estonia  signalled  close  cooperation  with  Ukraine  in  the  field  of  cyber  security  and 
investigation  of  cybercrimes  and 
in  Joint 
Investigation  Teams.  Latvia  reported  State  Police  College  has  cooperation  agreement  with 
Ukrainian  National  Interior  Academy  in  fields  of  scientific  research,  improvement  of  the 
quality of professional activities, exchange programs for teachers and police cadets, as well 
as  in  the  organisation  of  joint  cultural  and  sports  activities.  State  Police  Forensic  Service 
Department  has  participated  in  experts  exchange  program  with  Ukrainian  law  enforcement 
agency experts. The Netherlands informed of an agreement signed on 20 September 2021 by 
Head of National Police of Ukraine and Dutch Ambassador to Ukraine on the Privileges and 
Immunities  of  Liaison  Officers  Seconded  by  Ukraine  to  Europol.  The  Netherlands  and 
Ukraine cooperate bilaterally on cyber issues. The main focus is on the MH-17 investigation 
and cybercrime.  

In 2021, France implemented several cooperation projects in Ukraine, including training on 
democratic crowd management during demonstrations or major events  for the benefit of 50 
staff in the centre of the Ukrainian National Guard (GNU) in Staré. The main objective of the 
initiative  was  to  strengthen  the  cooperation  links  between  GNU  and  the  Internal  Security 
Service (ISS). A thematic training course GN-D18 Protection-Stage on protective techniques 
at the Intervention Group of the National Gendarmerie (GIGN) took place in France with the 
aim at assimilating various techniques in the field of security/terrorism. France provided also 
thematic  information  traineeship  GN-D2C  on  the  best  European  policing  techniques  for 
commanders of a squadron from the Ukrainian mobile gendarmerie.  

38