COMMISSION STAFF WORKING DOCUMENT Measures adopted by the Member States to protect the EU's financial interests - Implementation of article 325 TFUE Accompanying the document REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT 36th Annual Report on the protection of the European Union's financial interests and the fight against fraud - 2024
Date: 2025-07-25
Institutions: European Anti-Fraud Office, European Commission
Subjects: EU Member State, EU budget, EU strategy, activity report, corruption, digitisation, fight against crime, financial control, fraud, fraud against the EU

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 25.7.2025  SWD(2025) 228 final  COMMISSION STAFF WORKING DOCUMENT Measures adopted by the Member States to protect the EU's financial interests - Implementation of article 325 TFUE Accompanying the document REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT 36th Annual Report on the protection of the European Union's financial interests and the fight against fraud - 2024 {COM(2025) 426 final} - {SWD(2025) 196 final} - {SWD(2025) 197 final} - {SWD(2025) 198 final} - {SWD(2025) 199 final} - {SWD(2025) 229 final} - {SWD(2025) 230 final}  
 
 
2. 

2.2. 

2.1. 

Contents 
List of abbreviations .................................................................................................................................................................. 6 
1. Introduction ........................................................................................................................................................................... 7 
1.  Overview of Measures Taken by Member States ............................................................................................................ 8 
Single and package measures ............................................................................................................................ 8 
1.1. 
Types of measure .............................................................................................................................................. 8 
1.2. 
Nature of measures ............................................................................................................................................ 9 
1.3. 
Anti-fraud cycle .............................................................................................................................................. 10 
1.4. 
Areas reported ................................................................................................................................................. 11 
1.5. 
Overlapping themes ........................................................................................................................................ 12 
1.6. 
1.6.1.  Conflict Of Interest Prevention And Detection ............................................................................................... 12 
Conflict Of Interest Prevention And Detection – Training And Capacity Building ................................... 13 
1.6.1.1. 
Conflict Of Interest Prevention And Detection – Conflict of Interest Management and Deterrence .......... 14 
1.6.1.2. 
1.6.1.3. 
Conflict Of Interest Prevention And Detection – Transparency And Governance Enhancement ............... 14 
1.6.2.  Digitalisation And The Use Of New Technologies In Monitoring And Control Systems ............................... 15 
1.6.3.  Enhanced Cooperation And Information Exchange ........................................................................................ 17 
States ............................................................................................................................................................................. 20 
Austria.................................................................................................................................................................. 20 
2.1.1. Mandatory Annual Compliance Training ............................................................................................................ 20 
2.1.2. High Density Verifications .................................................................................................................................. 20 
2.1.3. Social Benefits Fraud ........................................................................................................................................... 21 
Belgium ................................................................................................................................................................ 22 
2.2.1. E-Commerce VAT compliance strengthening ..................................................................................................... 22 
2.2.2. Mandatory Conflict Of Interest Declarations ....................................................................................................... 23 
2.2.3. Enhancing legal financial oversight ..................................................................................................................... 23 
2.2.4. Additional measures ............................................................................................................................................ 24 
Bulgaria ................................................................................................................................................................ 25 
2.3.1. Management Of Irregularities Under Shared Management ................................................................................. 25 
2.3.2. Strengthening Financial Correction Regulations ................................................................................................. 25 
2.3.3. Revised Procurement Rules for Compliance ....................................................................................................... 26 
Croatia.................................................................................................................................................................. 27 
2.4.1. Removing Double Criminality: Strengthening Money Laundering Legislation .................................................. 27 
2.4.2 Guidance for Enhanced Verification Procedures .................................................................................................. 27 
2.4.3. Enhanced Agricultural Fund Sanctions for Fraud Prevention .............................................................................. 28 
Cyprus .................................................................................................................................................................. 29 
2.5.1. Strengthening AFCOS and OLAF Collaboration in Cyprus ................................................................................ 29 
2.5.2. Guidelines for Ensuring Compliance in Public Procurement And For The Prevention Of Conflicts Of Interest . 29 
2.5.3. Enhancing Anti-Fraud Strategies: CAPO's Internal Group Initiative................................................................... 30 
2.5.4. Additional measures ............................................................................................................................................ 30 
Czech Republic .................................................................................................................................................... 31 
2.6.1. Enhancing Transparency in Regional Decision-Making for EU funds ................................................................ 31 
2.6.2. New Regulation to Improve Czech Tax System for Non-EU Entities ................................................................. 31 
2.6.3. Guidelines for Enhancing Sanctions Enforcement Against Russia and Belarus: Czechia’s Agricultural Focus .. 32 
Denmark .............................................................................................................................................................. 32 
2.7.1. Enhancing Oversight with Automated Wage Checks .......................................................................................... 32 
2.7.2. Online Reporting System For Suspected Fraud ................................................................................................... 33 

2.7. 

2.6. 

2.5. 

2.3. 

2.4. 

1 

 
 
2.8. 

2.9. 

Estonia ................................................................................................................................................................. 34 
2.8.1. Creation Of An Economic And Corruption Crime District .................................................................................. 34 
2.8.2. Estonia's Classification and Dumping Report: Enhancing Customs Fraud Detection .......................................... 34 
2.8.3. Online Training On Conflict of Interest and Corruption ...................................................................................... 35 
2.8.4. Additional measures ............................................................................................................................................ 35 
Finland ................................................................................................................................................................. 36 
2.9.1. Sectoral Anti-Fraud Strategies For EU Programmes ........................................................................................... 36 
2.9.2. Anti-Fraud Training For The EU’s Regional And Structural Policy Programme ................................................ 36 
France .................................................................................................................................................................. 37 
2.10.1. Enhanced EPPO Cooperation: France's Step Towards RRF Fraud Reporting ................................................... 37 
2.11.  Germany .............................................................................................................................................................. 38 
2.11.1. Enhancing Transparency Through Conflicts of Interest Declarations in Baden-Württemberg .......................... 38 
2.11.2. Enhancing EU Fund Management: Bremen's Anti-Fraud Training initiative .................................................... 38 
2.11.3. Thuringia Strengthen Anti-Fraud Strategies With Risk Assessments ................................................................ 39 
2.11.4. Additional measures .......................................................................................................................................... 40 
2.12.  Greece .................................................................................................................................................................. 40 

2.10. 

2.16. 

2.14. 
2.15. 

2.12.1. “Prevent - Detect - Investigate II: Data-driven Protection of the EU Budget” Conference Organised With OLAF
 ....................................................................................................................................................................................... 41 
2.12.2. New Legal Framework Enhances Management of Criminal Assets .................................................................. 41 
2.12.3. Establishment Of A New System Of Financial Corrections And Recovery Procedures .................................... 42 
2.12.4. Additional measures .......................................................................................................................................... 42 
2.13.  Hungary ............................................................................................................................................................... 43 
2.13.1. Increasing The Transparency Of Public Procurement ........................................................................................ 43 
2.13.2. Strengthening the Fight Against Online Fraud................................................................................................... 44 
2.13.3. Hungary’s 2024–2025 Anti-Corruption Strategy ............................................................................................... 45 
Ireland .................................................................................................................................................................. 45 
Italy ...................................................................................................................................................................... 45 
2.15.1. Establishment of the Committee For Combating Fraud Against The EU .......................................................... 46 
2.15.2. Broadening the AFCOS Mandate ...................................................................................................................... 46 
2.15.3. Enhanced Collaboration To Fight Against Cross-Border VAT Fraud ............................................................... 47 
2.15.4. Additional measures .......................................................................................................................................... 48 
Latvia ................................................................................................................................................................... 48 
2.16.1. Improvements to the National Regulatory Framework for Public Procurement ................................................ 48 
2.16.2. AFCOS Job Shadowing ..................................................................................................................................... 49 
Lithuania .............................................................................................................................................................. 49 
2.17.1. Transparency And Fight Against Corruption And Fraud Trainings ................................................................... 49 
2.17.2. New Sanction Framework to Secure EU Agricultural and Fisheries Funds ....................................................... 50 
2.17.3. Competitive Procurement Enhancement Plan .................................................................................................... 51 
Luxembourg ......................................................................................................................................................... 51 
2.18.1. Control And Monitoring System For The National Implementation Of The Recovery And Resilience Facility 51 
2.19.  Malta .................................................................................................................................................................... 51 
2.19.1. Creation Of A Central Document Repository System (CDRS).......................................................................... 52 
2.19.2. Update Of The National Risk Assessment On Fraud And Corruption ............................................................... 52 
2.20.  Netherlands .......................................................................................................................................................... 53 
2.20.1. Coordination Of Antifraud EU Funds As Part Of AFCOS ................................................................................ 53 
2.20.2. Network Meeting With National EU Fund Partners .......................................................................................... 53 
2.20.3. EMFAF Subsidy Risk Evaluation ...................................................................................................................... 54 
Poland .................................................................................................................................................................. 54 

2.21. 

2.18. 

2.17. 

2 

 
2.22. 

2.21.1. Competitive Procurement Enhancement Plan .................................................................................................... 54 
2.21.2. Anti-Fraud Policy in Agriculture and Rural Development under the RRP ........................................................ 54 
2.21.3. SAMPLER Tool for Conflict of Interests Verification ...................................................................................... 55 
Portugal ................................................................................................................................................................ 55 
2.22.1. Monitoring and Evaluating the National Anti-Fraud Strategy (NAFS) ............................................................. 55 
2.22.2. Fraud-Flagging System and Risk Indi cators for Cohesion Policy Funds .......................................................... 56 
2.22.3. Enhanced Risk Management System For Customs Under UCC Provisions ...................................................... 56 
2.22.4. Additional measures .......................................................................................................................................... 57 
Romania ............................................................................................................................................................... 57 
2.23.1. Implementation Of Anti-Bribery Measures For Foreign Public Officials In International Business ................. 57 
2.23.2. Establishment of RO e-Transport System for Monitoring Goods Transport ...................................................... 58 
2.23.3. Increasing Staff Of The National Anticorruption Directorate ............................................................................ 59 
Slovakia ............................................................................................................................................................... 59 
2.24.1. Guidance on Irregularities and Financial Corrections for 2021-2027 ................................................................ 59 
2.24.2. Establishment of Fraud Risk Management Working Groups ............................................................................. 60 
2.24.3. Preventive Control Mechanism for Sensitive Positions in EU Funded Procurements ....................................... 61 
Slovenia ............................................................................................................................................................... 62 
2.25.1. Support for New Participation in Quality Schemes under the CAP Strategic Plan 2023-2027 .......................... 62 
2.25.2. Slovenia's Advanced Tools and Contract Updates Against Fraud ..................................................................... 62 

2.23. 

2.24. 

2.25. 

2.26. 

2.25.3. Strengthening Inter-Institutional Cooperation In The Area Of Economic Crime, Corruption And Protection Of 
The EU’s ........................................................................................................................................................................ 63 
Spain .................................................................................................................................................................... 64 
2.26.1. Strengthening Tax Compliance and Combating VAT Fraud ............................................................................. 64 
2.26.2. Establishment of the Independent Authority for the Protection of Whistleblowers ........................................... 65 
2.26.3. Leveraging Artificial Intelligence in E-commerce Fraud Detection .................................................................. 65 
2.26.4. Additional measures .......................................................................................................................................... 66 
Sweden ................................................................................................................................................................. 67 

2.27. 

3. 

2.27.1. Enhanced protection of the Union’s financial interests when implementing the Recovery and Resilience Facility 
(RRF) ............................................................................................................................................................................. 67 
2.27.2. Anti-Fraud Training Initiative For EU Aid Management .................................................................................. 67 
Case studies ................................................................................................................................................................... 69 
Revenue ............................................................................................................................................................... 69 
3.1. 
3.1.1.  Smuggling ............................................................................................................................................................ 69 
3.1.2.  Misclassification / misdescription ........................................................................................................................ 69 
Expenditure .......................................................................................................................................................... 70 
3.2. 
3.2.1.  Fraud Involving Misuse Or Mismanagement Of Funds ....................................................................................... 70 
3.2.2.  Fraud Related To Procurement And Tenders ....................................................................................................... 71 
Cybercrime case study ......................................................................................................................................... 72 
3.3. 

3 

 
 
 
 
Tables 
Table 1: Anti-fraud measure reported by Member State in 2024 template ................................................................................ 7 
Table 2: Anti-fraud additional measures reported by Member States in 2024 template ............................................................ 7 
Table 3: Anti-fraud measures reported by Member States in 2024 ........................................................................................... 8 
Table 4: Type of anti-fraud measures reported by Member States in 2024 ............................................................................... 8 
Table 5: Nature of anti-fraud measures reported by Member States in 2024 ............................................................................ 9 
Table 6: Stages of the anti-fraud cycle targeted by the measures reported by Member States in 2024 ................................... 10 
Table 7: Areas targeted by the measures reported by Member States in 2024 ........................................................................ 11 
Table 8: Conflict of interest prevention and detection – Training and capacity building analysis .......................................... 13 
Table 9: Conflict of interest prevention and detection – Conflict of interest management and deterrence analysis ................ 14 
Table 10: Conflict of interest prevention and detection – Transparency and governance enhancement analysis .................... 15 
Table 11: Digitalisation and the use of new technologies in monitoring and control systems analysis ................................... 16 
Table 12: Enhanced cooperation and information exchange - Internal cooperation / National level analysis ......................... 18 
Table 13: Enhanced cooperation and information exchange – External cooperation analysis ................................................ 19 
Table 14: Anti-fraud measure #1 taken by Austria in 2024 ..................................................................................................... 20 
Table 15: Corruption within public procurement – Measure #1 taken by Austria in 2024 ...................................................... 20 
Table 16: Anti-fraud measure #2 taken by Austria in 2024 ..................................................................................................... 21 
Table 17: Anti-fraud measure #3 taken by Austria in 2024 ..................................................................................................... 22 
Table 18: Anti-fraud measure #1 taken by Belgium in 2024 ................................................................................................... 22 
Table 19: Anti-fraud measure #2 taken by Belgium in 2024 ................................................................................................... 23 
Table 20: Corruption within public procurement – Measure #2 taken by Belgium in 2024 .................................................... 23 
Table 21: Anti-fraud measure #3 taken by Belgium in 2024 ................................................................................................... 24 
Table 22: Additional anti-fraud measures taken by Belgium in 2024 ..................................................................................... 25 
Table 23: Anti-fraud measure #1 taken by Bulgaria in 2024 ................................................................................................... 25 
Table 24: Anti-fraud measure #2 taken by Bulgaria in 2024 ................................................................................................... 26 
Table 25: Anti-fraud measure #3 taken by Bulgaria in 2024 ................................................................................................... 26 
Table 26: Corruption within public procurement – Measure #3 taken by Belgium in 2024 .................................................... 26 
Table 27: Anti-fraud measure #1 taken by Croatia in 2024 ..................................................................................................... 27 
Table 28: Anti-fraud measure #2 taken by Croatia in 2024 ..................................................................................................... 28 
Table 29: Anti-fraud measure #3 taken by Croatia in 2024 ..................................................................................................... 28 
Table 30: Anti-fraud measure #1 taken by Cyprus in 2024 ..................................................................................................... 29 
Table 31: Anti-fraud measure #2 taken by Cyprus in 2024 ..................................................................................................... 30 
Table 32: Anti-fraud measure #3 taken by Cyprus in 2024 ..................................................................................................... 30 
Table 33: Additional anti-fraud measure taken by Cyprus in 2024 ......................................................................................... 30 
Table 34: Anti-fraud measure #1 taken by Czech Republic in 2024 ....................................................................................... 31 
Table 35: Corruption within public procurement – Measure #1 taken by Czech Republic in 2024 ........................................ 31 
Table 36: Anti-fraud measure #2 taken by Czech Republic in 2024 ....................................................................................... 32 
Table 37: Anti-fraud measure #3 taken by Czech Republic in 2024 ....................................................................................... 32 
Table 38: Anti-fraud measure #1 taken by Denmark in 2024 .................................................................................................. 33 
Table 39: Anti-fraud measure #2 taken by Denmark in 2024 .................................................................................................. 33 
Table 40: Anti-fraud measure #1 taken by Estonia in 2024 .................................................................................................... 34 
Table 41: Corruption within public procurement – Measure #1 taken by Estonia in 2024...................................................... 34 
Table 42: Anti-fraud measure #2 taken by Estonia in 2024 .................................................................................................... 35 
Table 43: Anti-fraud measure #3 taken by Estonia in 2024 .................................................................................................... 35 
Table 44: Additional anti-fraud measures taken by Estonia in 2024 ....................................................................................... 36 
Table 45: Anti-fraud measure #1 taken by Finland in 2024 .................................................................................................... 36 
Table 46: Anti-fraud measure #2 taken by Finland in 2024 .................................................................................................... 37 
Table 47: Anti-fraud measure #1 taken by France in 2024 ...................................................................................................... 37 
Table 48: Anti-fraud measure #1 taken by Germany in 2024 .................................................................................................. 38 
Table 49: Corruption within public procurement – Measure #1 taken by Germany in 2024 ................................................... 38 
Table 50: Anti-fraud measure #2 taken by Germany in 2024 .................................................................................................. 39 
Table 51: Corruption within public procurement – Measure #2 taken by Germany in 2024 ................................................... 39 
Table 52: Anti-fraud measure #3 taken by Germany in 2024 .................................................................................................. 40 
Table 53: Corruption within public procurement – Measure #3 taken by Germany in 2024 ................................................... 40 
Table 54: Additional anti-fraud measures taken by Germany in 2024 .................................................................................... 40 
Table 55: Anti-fraud measure #1 taken by Greece in 2024 ..................................................................................................... 41 
Table 56: Anti-fraud measure #2 taken by Greece in 2024 ..................................................................................................... 42 
Table 57: Anti-fraud measure #3 taken by Greece in 2024 ..................................................................................................... 42 
Table 58: Additional anti-fraud measure taken by Greece in 2024 ......................................................................................... 42 
Table 59: Anti-fraud measure #1 taken by Hungary in 2024................................................................................................... 43 
Table 60: Corruption within public procurement – Measure #1 taken by Hungary in 2024 .................................................... 44 
Table 61: Anti-fraud measure #2 taken by Hungary in 2024................................................................................................... 44 
Table 62: Anti-fraud measure #3 taken by Hungary in 2024................................................................................................... 45 
Table 63: Corruption within public procurement – Measure #3 taken by Hungary in 2024 .................................................... 45 
Table 64: Anti-fraud measure #1 taken by Italy in 2024 ......................................................................................................... 46 
Table 65: Anti-fraud measure #2 taken by Italy in 2024 ......................................................................................................... 47 
Table 66: Anti-fraud measure #3 taken by Italy in 2024 ......................................................................................................... 47 
Table 67: Additional anti-fraud measures taken by Italy in 2024 ............................................................................................ 48 
Table 68: Anti-fraud measure #1 taken by Latvia in 2024 ...................................................................................................... 49 

4 

 
Table 69: Anti-fraud measure #2 taken by Latvia in 2024 ...................................................................................................... 49 
Table 70: Anti-fraud measure #1 taken by Lithuania in 2024 ................................................................................................. 50 
Table 71: Corruption within public procurement – Measure #1 taken by Lithuania in 2024 .................................................. 50 
Table 72: Anti-fraud measure #2 taken by Lithuania in 2024 ................................................................................................. 50 
Table 73: Anti-fraud measure #3 taken by Lithuania in 2024 ................................................................................................. 51 
Table 74: Anti-fraud measure #1 taken by Luxembourg in 2024 ............................................................................................ 51 
Table 75: Anti-fraud measure #1 taken by Malta in 2024 ....................................................................................................... 52 
Table 76: Anti-fraud measure #2 taken by Malta in 2024 ....................................................................................................... 52 
Table 77: Anti-fraud measure #1 taken by Netherlands in 2024 ............................................................................................. 53 
Table 78: Anti-fraud measure #2 taken by Netherlands in 2024 ............................................................................................. 53 
Table 79: Anti-fraud measure #3 taken by Netherlands in 2024 ............................................................................................. 54 
Table 80: Anti-fraud measure #1 taken by Poland in 2024 ..................................................................................................... 54 
Table 81: Anti-fraud measure #2 taken by Poland in 2024 ..................................................................................................... 55 
Table 82: Anti-fraud measure #3 taken by Poland in 2024 ..................................................................................................... 55 
Table 83: Anti-fraud measure #1 taken by Portugal in 2024 ................................................................................................... 56 
Table 84: Anti-fraud measure #2 taken by Portugal in 2024 ................................................................................................... 56 
Table 85: Anti-fraud measure #3 taken by Portugal in 2024 ................................................................................................... 57 
Table 86: Additional anti-fraud measure taken by Portugal in 2024 ....................................................................................... 57 
Table 87: Anti-fraud measure #1 taken by Romania in 2024 .................................................................................................. 58 
Table 88: Corruption within public procurement – Measure #1 taken by Romania in 2024 ................................................... 58 
Table 89: Anti-fraud measure #2 taken by Romania in 2024 .................................................................................................. 58 
Table 90: Anti-fraud measure #3 taken by Romania in 2024 .................................................................................................. 59 
Table 91: Anti-fraud measure #1 taken by Slovakia in 2024................................................................................................... 60 
Table 92: Anti-fraud measure #2 taken by Slovakia in 2024................................................................................................... 60 
Table 93: Corruption within public procurement – Measure #2 taken by Slovakia in 2024 .................................................... 61 
Table 94: Anti-fraud measure #3 taken by Slovakia in 2024................................................................................................... 61 
Table 95: Corruption within public procurement – Measure #3 taken by Slovakia in 2024 .................................................... 61 
Table 96: Anti-fraud measure #1 taken by Slovenia in 2024................................................................................................... 62 
Table 97: Anti-fraud measure #2 taken by Slovenia in 2024................................................................................................... 63 
Table 98: Anti-fraud measure #3 taken by Slovenia in 2024................................................................................................... 64 
Table 99: Anti-fraud measure #1 taken by Spain in 2024 ....................................................................................................... 65 
Table 100: Anti-fraud measure #2 taken by Spain in 2024 ..................................................................................................... 65 
Table 101: Anti-fraud measure #3 taken by Spain in 2024 ..................................................................................................... 66 
Table 102: Additional anti-fraud measures taken by Spain in 2024 ........................................................................................ 66 
Table 103: Anti-fraud measure #1 taken by Sweden in 2024 .................................................................................................. 67 
Table 104: Corruption within public procurement – Measure #1 taken by Sweden in 2024 ................................................... 67 
Table 105: Anti-fraud measure #2 taken by Sweden in 2024 .................................................................................................. 68 
Table 106: Case studies – Smuggling ...................................................................................................................................... 69 
Table 107: Case studies - Misclassification / misdescription .................................................................................................. 70 
Table 108: Case studies – Fraud Involving Misuse Or Mismanagement Of Funds ................................................................. 71 
Table 109: Case studies – Fraud Related To Procurement And Tenders ................................................................................. 72 
Table 110: Case studies – Cybercrime .................................................................................................................................... 72 

Figures 
Figure 1: Type of measures reported by Member States in 2024 .............................................................................................. 9 
Figure 2: Sector targeted by the measures reported by Member States in 2024 ...................................................................... 10 
Figure 4: Percentage of measures reported by Member States in 2024 for each stage of the anti-fraud cycle ........................ 11 
Figure 3: Number of measures reported by Member States for each stage of the anti-fraud cycle in 2024 ............................. 11 
Figure 5: Areas targeted by the measure reported by Member States in 2024......................................................................... 12 

5 

 
 
 
 
 
List of abbreviations  

AFCOS    

Anti-Fraud Coordination Service  

AFS  

CAP 

CDM  

Anti-Fraud Strategy  

Common Agricultural Policy  

Centralised Direct Management  

EAFRD            

European Agricultural Fund for Rural Development  

EAGF  

European Agricultural Guarantee Fund 

EMFAF   

European Maritime, Fisheries and Aquaculture Fund  

EPPO  

ERDF  

ESF  

EU  

European Public Prosecutors’ Office  

European Regional Development Fund  

European Social Fund EU European Union  

European Union  

FEAD  

Fund for European Aid to the Most Deprived  

MICAF    

Interministerial Anti-Fraud Coordination Office (Mission interministérielle de coordination anti-fraude) 

NAFS  

OECD  

OLAF  

PIF  

RRF  

RRP  

UBO 

VAT  

National Anti-Fraud Strategy  

Organisation for Economic Co-operation and Development 

European Anti-Fraud Office  

Protection of the EU’s Financial Interests  

Recovery and Resilience Facility  

Recovery and Resilience Plan  

Ultimate Beneficial Owner 

Value Added Tax 

6 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
1. Introduction 

Article 325(2) of the Treaty on the Functioning of the European Union mandates that Member States 
implement the same measures to counter fraud affecting the EU’s financial interests as they do for their 
national finances.  

Paragraph 5 further states that, each year, the Commission, in collaboration with Member States, must 
report to the European Parliament and the Council on the actions taken to enforce this article. 

To create this report, the Commission requested Member States to highlight up to three measures they 
deem most crucial for safeguarding the EU’s financial interests. Information from their responses was 
collected via a survey commonly referred to as the ‘PIF Questionnaire’.  

This  survey  included  both  structured  data  and  unstructured  (free  text)  responses.  The  table  below 
outlines the format used to present structured data from the PIF Questionnaire 2024. 

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #1 #2 #3 taken by MS in 2024  

Legislative  

Administrative 

Organisational  

Operational 

Reading guide:  

Prevention

Detection 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Table 1: Anti-fraud measure reported by Member State in 2024 template 

The "Stage in Anti-Fraud Cycle" column uses a colour-coding system to indicate the phases of the anti-
fraud cycle that each reported measure addresses. Dark blue highlights the stages directly targeted by 
the measure, such as the prevention stage, as shown in the template. Light blue indicates stages not 
addressed  by  the  measure,  such  as  Detection,  Investigation  and  Prosecution,  and  Recovery  and 
Sanction, also depicted in the template. 

Each type of measure is identified by specific colours. Blank spaces are common to all measures, while 
distinct colours highlight information unique to each type of measure. 

Legislative 

Administrative 

Organisational 

Operational 

Additionally, Member States were invited to briefly describe any other measures they consider 
necessary. These descriptions are organised into tables following the format below. Any case studies 
provided by Member States are detailed in section 3. 

Region 

Measures Implemented in 2024 

Funds or bodies involved 

Table 2: Anti-fraud additional measures reported by Member States in 2024 template 

7 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
1. Overview of Measures Taken by Member States 

OLAF conducted a detailed questionnaire where all Member States reported up to three national anti-
fraud measures for 2024. This document summarises the findings, providing a comprehensive yet non-
exhaustive overview of the reported measures and highlighting recent developments in Member States’ 
anti-fraud efforts to protect the EU’s financial interests. 

In  total,  Member  States  reported  69  measures,  classified  as  either  single  or  packaged.  Packaged 
measures consist of multiple instruments adopted simultaneously to achieve a common objective. As 
shown in the table below, 50 are single measures, while the remaining 19 are packaged. 

1.1. Single and package measures  

The overview below displays the number of single and packaged anti-fraud measures adopted by each 
Member State in 2024. 

Measure 

Single  
Package 
Total  

Member State 
AT  BE  BG  CY CZ  DE  DK  EE  EL  ES  FI  FR  HR  HU  IE  IT  LT  LU LV  MT  NL  PL  PT  RO  SE  SI  SK 
1  3  2  2  2  2  2 
1  3  3 
2  0  1  1  0  1  1 
2  0  0 
3  3  3  3  2  3  3 
3  3  3 

3  3  1  2  3  2  3  1  1  2 
0  0  2  0  0  1  0  1  0  1 
3  3  3  2  3  3  3  2  1  3 

0  0  2  3  0  1 
3  0  1  0  1  1 
3  0  3  3  1  2 

2 
0 
2 

Total 

50 
19 
69 

Table 3: Anti-fraud measures reported by Member States in 2024 

1.2. Types of measure  

All  reported  measures  are  classified  as  administrative,  legislative,  operational,  or  organisational.  An 
administrative measure involves a legal act by an administrative body to implement legislative actions. 
A  legislative  measure  is  an  act  by  a  legislative  body  to  enforce legal  obligations.  An  organisational 
measure  includes  decisions  or  non-legislative  acts  that  change  the  organisational  structure  of  an 
administration  or  body  involved  in  protecting  the  EU’s  financial  interests.  Lastly,  an  operational 
measure  involves  actions  by  an  administration  or  body  that  directly  impact  its  operations  related  to 
protecting the EU’s financial interests. 

The table below presents the number of single and packaged anti-fraud measures implemented by each 
Member State in 2024, organised by type. The data indicates a balanced adoption of anti-fraud measures, 
with legislative, administrative, organisational, and operational measures each comprising around 30% 
of the total. This distribution reflects a comprehensive strategy for tackling fraud across various areas. 

Type of measures 

Legislative 

Administrative 

Organisational  

Operational  

Single  

Package  

Total 

Rate*  

14 

7 

21 

10 

10 

20 

30% 

30% 

13 

7 

20 

30% 

13 

8 

21 

30% 

Table 4: Type of anti-fraud measures reported by Member States in 2024 

8 

 
 
 
 
 
 
 
 
  
 
 
*Rate: The rate for each type of measure—legislative, administrative, organisational, and 
operational—is calculated based on the total number of measures, which is 69. Package measures can 
simultaneously include multiple types of measures. 

1
2

0
2

0
2

1
2

4
1

3
1

3
1

0
1

0
1

7

7

8

Single 

Package 

Total 

d
e
t
r
o
p
e
r

s
e
r
u
s
a
e
m

f
o
r
e
b
m
u
N

25

20

15

10

5

0

L e g i s l a t i v e

A d m i n i s t r a t i v e

O r g a n i s a t i o n a l  

O p e r a t i o n a l  

Type a measures

T y p e  

Figure 1: Type of measures reported by Member States in 2024  

1.3. Nature of measures  

Anti-fraud actions are categorised as either horizontal, applicable across multiple sectors, or sectoral, 
targeting  specific  revenue  or  expenditure  sectors.  In  2024,  Member  States  adopted  27  horizontal 
measures—21 single and 6 packaged—representing 39% of the total measures (see Table 5). Sectoral 
measures constituted 61% of the total, with 42 measures adopted, including 29 single and 13 packaged, 
as shown in the table below. 

Single  
Package  
Total 
Rate  

Horizontal  
21 
6 
27 
39% 

Sectoral 
29 
13 
42 
61% 

Total  
50 
19 
69 
100% 

 Table 5: Nature of anti-fraud measures reported by Member States in 2024 

Figure 2 illustrates the sectors targeted by anti-fraud measures adopted by Member States in 2024. It 
shows that sectoral measures primarily focus on expenditure, particularly in agriculture, cohesion 
policy, and the RRF (Recovery and Resilience Facility). 

9 

 
 
 
 
 
 
 
 
 
 
 
Sector

Revenue 

Expenditure 

d
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r
a
t

s
r
o
t
c
e
s

s
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i
r
a
V

Expenditure - Cohesion policy
Expenditure – Recovery and Resilience Facility
Expenditure - Fisheries
Expenditure - Agriculture
Revenue - Tax fraud
Expenditure - Fund for the most deprived
Revenue - Customs
Expenditure - Migration and asylum
Expenditure – Globalisation Fund
Expenditure - Centralised direct management

0

5

10

15

20

Number of measures reported

Figure 2: Sector targeted by the measures reported by Member States in 2024  

1.4. Anti-fraud cycle  

The fight against fraud requires a holistic and comprehensive approach, covering all stages of the anti-
fraud  cycle.  Protecting  the  EU’s  financial  interests  involves  a  diverse  range  of  players  and 
interconnected  processes  that  influence  each  other.  The  anti-fraud  cycle  consists  of  four  stages:  (1) 
prevention through risk analysis and self-assessment to quantify the likelihood and impact of fraud, (2) 
detection  through  reporting  processes  (e.g.,  IT  tools)  aimed  at  increasing  comparability  and 
interoperability, (3) investigation and prosecution through audit controls, and (4) imposing recovery and 
sanctions, often executed by Member States. 

In 2024, like previous years, most measures—both single and packaged—focus on the first two stages 
of the anti-fraud cycle: prevention and detection, as shown in Table 6 and Figure 3. Figure 4 reveals 
that 91% of all measures target the prevention stage, while 86% focus on detection. This indicates a 
strategic emphasis on stopping fraud early and identifying fraudulent activities quickly. 

Despite this primary focus, Member States also address the other stages of the anti-fraud cycle. Of all 
measures, 46% target investigation and prosecution, while 45% address recovery and sanctions. This 
reflects a balanced and comprehensive approach, ensuring every stage of the cycle receives adequate 
attention. 

The  significant  overlap  in  targeting  multiple  stages  suggests  a  comprehensive  strategy,  where  each 
measure supports multiple stages of the cycle. 

Single 

Package 

Total 

Fraud prevention 
Fraud detection 
Investigation and prosecution  
Recovery and sanction 

38 
33 
16 
15 

55%* 
48% 
23% 
22% 

25 
26 
16 
16 

36% 
38% 
23% 
23% 

63 
59 
32 
31 

91% 
86% 
46% 
45% 

Table 6: Stages of the anti-fraud cycle targeted by the measures reported by Member States in 2024 

*Rate: The rate for each stage of the anti-fraud cycle is calculated based on the total number of 
measures, which is 69.  

10 

 
 
 
 
 
 
  
 
 
 
 
d
e
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a
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f
-
i
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a
e
h
t

f
o
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g
a
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S

Single

Package

F R A U D   P R E V E N T I O N

F R A U D   D E T E C T I O N

38

33

25

26

I N V E S T I G A T I O N   A N D  
P R O S E C U T I O N  

16

16

R E C O V E R Y   A N D   S A N C T I O N

15

16

0

20

40

60

80

Number of measures reported

91% 
Of all 
measures 

45% 
Of all 
measures 

Prevention       Detection 

Recovery 
and sanction 

Investigation 
and 
prosecution 

86% 
Of all 
measures 

46% 
Of all 
measures 

Figure 3: Number of measures reported by Member States for each 
stage of the anti-fraud cycle in 2024  

Figure 3: Percentage of measures reported by Member 
States in 2024 for each stage of the anti-fraud cycle  

1.5. Areas reported  

In 2024, Member States reported various measures targeting key areas in their anti-fraud efforts. Table 
7 and Figure 5 provide a comprehensive overview of these priority areas. 

The  most  targeted  area  is  the  shared  management  and  control  of  EU  funds,  with  32  measures 
representing 46% of the total. Conflict of interest is another significant focus, addressed by 30 measures, 
accounting for 43% of the total. Public procurement is targeted by 21 measures, making up 30% of the 
total. 

Area targeted  
Shared management and control of EU funds 
Conflict of interest 
Public procurement  
Antifraud or anticorruption strategy  
Financial crime (including money laundering) 
Corruption  
Fraud definition 
Other 
AFCOS 
Organised crime 
Whistleblower 
Customs/ToR/illicit trade 

Number of 
measures 
32 
30 
21 
20 
15 
15 
13 
11 
9 
8 
7 
3 

Percentage* 
46% 
43% 
30% 
29% 
22% 
22% 
19% 
16% 
13% 
12% 
10% 
4% 

 Table 7: Areas targeted by the measures reported by Member States in 2024 

*Rate: The rate for each area targeted cycle is calculated based on the total number of measures, which 
is 69. Each measure can target several areas. Each measure can target several areas simultaneously. 

11 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
d
e
t
e
g
r
a
t
a
e
r
A

Shared management and control of EU funds

Conflict of interest

Public procurement

Antifraud or anticorruption strategy

Corruption

Financial crime (including money laundering)

Fraud definition

Other

AFCOS

Organised crime

Whistleblower

Customs/ToR/illicit trade

0

5

10

15

20

25

30

35

Number of measures reported

Measures reported

Figure 5: Areas targeted by the measure reported by Member States in 2024 

1.6. Overlapping themes 

In 2024, three overlapping themes emerge as the key priorities for Member States: the prevention and 
detection of conflicts of interest, the digitalisation and use of new technologies in monitoring and control 
systems, and enhanced cooperation and information exchange. 

1.6.1.  Conflict Of Interest Prevention And Detection 

The data in Table 7 reveals that a significant number of measures are addressing conflicts of interest. 
Various  Member  States  have  reported  single  or  packaged  measures  focusing  on  this  issue,  with 
administrative measures being the most common. 

Many measures aim to prevent and detect conflicts of interest using various strategies. Recognising the 
multifaceted nature of conflicts of interest, the analysis identified key trends that show how Member 
States  address  this  challenge.  The  focus  was  on  whether  each  initiative  emphasised  prevention, 
detection,  or  both,  and  categorised  the  measures  into  three  strategic  themes:  training  and  capacity 
building,  conflict  management  and  deterrence,  and  enhancing  transparency  and  governance.  This 
analysis  provides insights into  the  specific  strategies that Member  States  use  to manage  conflicts of 
interest, showcasing distinct trends in handling fraud. 

The analysis shows a strong emphasis on prevention in conflict of interest measures. Many Member 
States  prioritise  establishing  robust  frameworks  and  procedures  to  address  potential  conflicts  pre-
emptively.  For example,  Belgium  requires mandatory  conflict  of interest declarations,  and  Germany 
promotes transparency through conflict declarations in Baden-Württemberg. Preventing fraud before it 
occurs  is  the  first  stage  of  the  anti-fraud  cycle,  with  Member  States  focusing  on  building  a  solid 
foundation on this principle. 

12 

 
 
 
 
 
 
 
While prevention is key, several measures incorporate new sophisticated detection mechanisms. With 
the advent of new technologies, innovative tools are emerging, such as Poland's SAMPLER tool, which 
uses data analytics to identify conflicts of interest early, especially in project selection processes. 

This  combination  of  prevention  and  detection  strategies  highlights  a  shift  towards  comprehensive 
conflict of interest management systems that use both human oversight and technological innovation to 
reduce fraud risks. 

1.6.1.1.  Conflict Of Interest Prevention And Detection – Training And Capacity 

Building  

A significant focus on training indicates an understanding of the human element in managing conflicts 
of interest. Estonia, Finland, Lithuania, and the Bremen State in Germany have launched comprehensive 
training programmes to equip public officials with the skills needed to identify and manage conflicts of 
interest  effectively.  These  initiatives  are  vital  for  fostering  a  culture  of  integrity  and  empowering 
individuals to actively combat fraud and uphold high ethical standards. Such capacity-building efforts 
not only enhance individual skills but also strengthen institutional resilience against potential conflicts 
of interest. 

Training and capacity building  

Member 
State 

Focus 

Measure taken 

Type of measure 

Description 

a
i
n
o
t
s
E

d
n
a
l
n
i
F

y
n
a
m
r
e
G

a
i
n
a
u
h
t
i

L

n
o
i
t
n
e
v
e
r
P

n
o
i
t
n
e
v
e
r
P

n
o
i
t
n
e
v
e
r
P

Online Training On 
Conflict of Interest and 
Corruption 

Organisational 

This measure is a comprehensive online training programme designed to 
equip  officials  and  employees  involved  in  grant  management  with  the 
knowledge and tools needed to recognise and prevent conflicts of interest 
and corruption in their daily work and at the level of grant recipients. 

Anti-Fraud Training For 
The EU’s Regional And 
Structural Policy 
Programme 

Through  specialised  follow-up  anti-fraud  training,  this  measure  equips 
officials  with  the  skills  to  identify  and  prevent  potential  conflicts  of 
interest and shares good practices. 

Administrative 

Enhancing EU Fund 
Management: Bremen's 
Anti-Fraud Training 
initiative 

Administrative 

Organisational 

By  providing  comprehensive  information  on  fraud  prevention  and 
incorporating  these  topics  into  regular  meetings,  the  measure  aims  to 
equip  personnel  with  the  essential  skills  and  knowledge  to  minimise 
conflicts of interest. 

n
o
i
t
n
e
v
e
r
P

n
o
i
t
c
e
t
e
D

Transparency And Fight 
Against Corruption And 
Fraud Trainings 

Organised  by  the  Managing  Authority,  these  training  sessions  aim  to 
enhance the competence of institutions managing EU Structural Funds by 
focusing on transparency, corruption prevention, and conflict of interest. 

Organisational 

Table 8: Conflict of interest prevention and detection – Training and capacity building analysis 

13 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
1.6.1.2.  Conflict Of Interest Prevention And Detection – Conflict of Interest 

Management and Deterrence 

Within this overlapping theme, another focus is on managing and deterring conflicts of interest. These 
measures aim to prevent conflicts from arising, deter them effectively, and quickly detect and address 
them if they occur. Belgium enforces mandatory declarations for public procurement to ensure legal 
compliance.  Poland  enhances detection  using the  SAMPLER  Tool to  uncover complex connections. 
Germany’s Baden-Württemberg emphasises transparency through required declarations, while Slovakia 
implements a preventive control mechanism for EU-funded procurements. 

Conflict of Interest Management and Deterrence 

Member 
State 

Focus 

Measure taken 

Type of measure 

Description 

m
u
i
g
l
e
B

d
n
a
l
o
P

y
n
a
m
r
e
G

a
i
k
a
v
o
l
S

Mandatory Conflict Of 
Interest Declarations 

Administrative 

By  requiring  written  declarations  from  individuals  involved  in  public 
procurement,  the  measure  ensures  that  employees  consistently  remain 
aware of and adhere to the legal standards intended to prevent conflicts 
of interest. 

SAMPLER Tool for 
Conflict of Interest 
Verification 

Operational 

Utilising  a  sophisticated  data-analysis  tool,  this  measure  identifies 
complex  personal  and  financial  connections,  thereby  enhancing  the 
detection and prevention of conflicts of interest. 

Enhancing Transparency 
Through Conflicts of 
Interest Declarations in 
Baden-Württemberg 

By  instituting  mandatory  conflict  of  interest  declarations,  this  measure 
formalises impartiality in decision-making, reducing the risk of biased or 
unethical behaviour in project management and contract awards. 

Administrative 

n
o
i
t
n
e
v
e
r
P

n
o
i
t
c
e
t
e
D

n
o
i
t
n
e
v
e
r
P

n
o
i
t
n
e
v
e
r
P

n
o
i
t
c
e
t
e
D

Preventive Control 
Mechanism for Sensitive 
Positions in EU Funded 
Procurements 

This measure establishes a preventive control mechanism, with an expert 
team  monitoring  conflicts  of  interest  in  critical  positions  to  ensure 
rigorous compliance and transparency in EU-funded procurements. 

Organisational 

Table 9: Conflict of interest prevention and detection – Conflict of interest management and deterrence analysis 

1.6.1.3.  Conflict Of Interest Prevention And Detection – Transparency And 

Governance Enhancement  

Another  key  aspect  of  measures  to  prevent  and  detect  conflicts  of  interest  is  the  enhancement  of 
transparency and governance. Member States prioritise these areas to strengthen regulatory compliance 
and  mitigate  conflicts  of  interest.  The  measures  involve  reinforcing  compliance  in  procurement 
processes and providing clear guidance and instructions to officials, thereby fortifying ethical standards 
and accountability within public administration. 

14 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Transparency and governance enhancement  

Member 
State 

Focus 

Measure taken 

Type of measure 

Description 

a
i
t
a
o
r
C

a
i
k
a
v
o
l
S

a
i
r
a
g
l
u
B

d
n
a
l
o
P

s
u
r
p
y
C

d
n
a
l
o
P

Guidance for Enhanced 
Verification Procedures 

Operational 

By providing technical instructions for verification, the measure ensures 
that  competent  authorities  conduct  thorough  checks  using  available 
databases,  preventing  conflicts  of  interest  during  grant  awards  and 
procurement processes. 

Establishment of Fraud 
Risk Management Working 
Groups 

Operational 

By  creating  specialised  working groups before project  implementation, 
this  measure  ensures  early  identification  and  systematic  handling  of 
potential  conflicts  of  interest,  significantly  reinforcing  regulatory 
compliance and reducing fraud in the targeted EU-funded programmes. 

Revised Procurement Rules 
for Compliance 

Legislative 

By updating procurement rules, the measure enforces strict checks and 
balances to prevent conflicts of interest in public contracts, aligning with 
recent legislative changes. 

Competitive Procurement 
Enhancement Plan 

Organisational 

By  introducing  a  'rotation'  mechanism,  this  measure  enhances  the 
impartial assessment of aid applications, ensuring they are processed by 
agency units outside the applicant's local area, thereby minimising local 
bias and conflicts of interest. 

Guidelines for Ensuring 
Compliance in Public 
Procurement 

Administrative 

These  guidelines  aim  to  consolidate  existing  rules  and  improve  the 
effectiveness of public procurement processes by preventing conflicts of 
interest through well-defined management and control systems. 

n
o
i
t
n
e
v
e
r
P

n
o
i
t
n
e
v
e
r
P

n
o
i
t
n
e
v
e
r
P

n
o
i
t
n
e
v
e
r
P

n
o
i
t
n
e
v
e
r
P

n
o
i
t
n
e
v
e
r
P

n
o
i
t
c
e
t
e
D

Anti-Fraud Policy in 
Agriculture and Rural 
Development under the 
RRP 

Administrative 

This  policy  from  the  Ministry  of  Agriculture  and  Rural  Development 
establishes clear rules and procedures to manage fraud risks and conflicts 
thereby 
of 
strengthening the management of fraud risks. 

the  Recovery  and  Resilience  Plan, 

interest  within 

Table 10: Conflict of interest prevention and detection – Transparency and governance enhancement analysis 

1.6.2.  Digitalisation And The Use Of New Technologies In Monitoring And Control 

Systems  

This year, continuing the trend observed in the previous year and aligning with the recommendations of 
the PIF Report 2023, there has been a significant emphasis on digitalisation. The focus is on measures 
that use digitalisation and new technologies in monitoring and control systems, specifically highlighting 
initiatives that leverage new IT tools and enhance interoperability between systems. 

These  digital  initiatives  primarily  target  cohesion  policy  and  revenue,  with  particular  emphasis  on 
combating tax fraud and enhancing customs operations. The implemented tools facilitate verification 
checks, anomaly detection, real-time monitoring, and the identification of connections between entities 
and individuals. A notable example is Spain's integration of artificial intelligence to detect e-commerce 
fraud, addressing the insufficiency of traditional methods in managing the growing volume of online 
fraud activities. As fraudsters increasingly exploit new technologies, accelerating digitalisation in the 
EU's anti-fraud efforts is essential to staying one step ahead. 

15 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Digitalisation and the use of new technologies in monitoring and control systems 

Member 
State 

Tool or technology 
used 

New tool /  
Interoperability  

Measure taken 

Sector 

Description and added value of digitalisation 

  Automated checks 
k
r
a
m
n
e
D

system “e-
indkomst” digital 
platform 

New IT tool 

Enhancing Oversight 
with Automated Wage 
Checks 

Expenditure: 
Cohesion 
policy 

Classification and 
Dumping Report 
tool 

New IT tool 

Estonia's Classification 
and Dumping Report: 
Enhancing Customs 
Fraud Detection 

Revenue: 
Customs 

This  measure  enhances  monitoring  and  control  by 
automatically checking if wages listed in project reports have 
been  paid,  swiftly  identifying  any  payment  discrepancies. 
The  automated  system,  e-indkomst,  uses  digitalisation  to 
register and verify wages, making it easier to detect whether 
a payment has occurred. 

This measure introduces a new IT tool to identify customs 
evasion schemes by automating customs declaration analysis 
and  detecting  irregularities.  It  ensures  proper  taxation, 
prevents  potential  fraud,  and  ensures  compliance  with  EU 
regulations. Digitalisation is used to analyse large datasets, 
detect  importers'  customs  declarations,  and  highlight  the 
need for corrections. 

Sampler Tool 
(business 
intelligence / data 
analysis tool) 

New IT tool 

SAMPLER Tool for 
Conflict of Interests 
Verification 

Expenditure: 
Cohesion 
policy 

This measure identifies personal and capital links  between 
entities  and  individuals,  detecting  conflicts  of  interest  and 
preventing 
tool  uses 
irregularities.  The  SAMPLER 
digitalisation to analyse large datasets, checking connections 
between identifiers such as Tax ID or Personal ID numbers. 

ARACHNE data 
transmission 
automation 

Interoperability/ 
data 
transmission 

Fraud-Flagging 
System and Risk 
Indicators for 
Cohesion Policy Funds 

Expenditure: 
Cohesion 
policy 

This measure includes the development of a fraud-flagging 
system and risk indicators, automating data transmission to 
ARACHNE within Portugal 2030 programmes. 

Interoperability 

Enhanced Risk 
Management System 
For Customs Under 
UCC Provisions 

Revenue: 
Customs 

This  measure  focuses  on  developing  an  enhanced  risk 
management  system  for  customs,  aligning  with  new  data 
models  and  risk  management  procedures.  Developed  with 
the  IT  department,  this  system  improves  interoperability 
with control management and national customs information 
systems through digitalisation. 

Digital platform 

New IT tool 

Establishment of RO 
e-Transport System for 
Monitoring Goods 
Transport 

Revenue: 
Tax fraud 

This  measure  establishes  a  national  system  for  monitoring 
the road transport of goods. The digital platform uses data 
analytics and real-time tracking to identify high-risk goods 
and individuals. 

New application 
within Qlick 
Sense analytic 
platform 

New IT tool 

Slovenia's Advanced 
Tools and Contract 
Updates Against Fraud 

Revenue: 
Tax fraud 

n
i
a
p
S

Artificial 
Intelligence 

New tool / 
integration of 
artificial 
intelligence 

Leveraging Artificial 
Intelligence in E-
commerce Fraud 
Detection 

Revenue: 
Customs 

This  measure  strengthens  monitoring  and  control  by 
identifying  actual  owners,  detecting  irregularities,  and 
preventing  VAT  evasion  through  real-time  data  analysis 
from multiple daily updated sources. 

It  uses  technology  to  create  a  comprehensive  view  of  risk 
patterns and identify potential discrepancies between import 
records  and  VAT  returns,  enabling  immediate  action  on 
suspicious  activities  and  preventing  price  distortion  by 
recording actual owners and connections. 

This  measure  integrates  artificial  intelligence  to  detect  e-
commerce  fraud,  addressing  the  challenges  posed  by  the 
growth in imports linked to online commerce. As traditional 
tools become insufficient to manage this surge, the use of AI 
enhances  capabilities 
for  monitoring  and  analysing 
transactions.  This  technology  improves  the  detection  of 
suspicious transactions, reducing the risk of financial loss. 

a
i
n
o
t
s
E

d
n
a
l
o
P

l
a
g
u
t
r
o
P

l
a
g
u
t
r
o
P

a
i
n
a
m
o
R

a
i
n
e
v
o
l
S

  Table 11: Digitalisation and the use of new technologies in monitoring and control systems analysis 

16 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
1.6.3.  Enhanced Cooperation And Information Exchange 

Enhancing internal and external cooperation and information exchange is a key focus area of this year's 
reported measures, aligning with Recommendation 3 of the PIF 2023 to improve the governance of the 
anti-fraud architecture. A total of 11 measures have been reported in this regard. 

Seven of these measures focus on internal cooperation at the national level by establishing dedicated 
anti-fraud  bodies,  departments,  or  sections.  These  initiatives  include  setting  up  contact  points  and 
organising network meetings to improve coordination, along with a job-shadowing programme within 
the AFCOS network to facilitate the exchange of best practices. 

Additionally, four measures target external cooperation, focusing on strengthening collaboration with 
EU  bodies.  This  includes  organising  an  EU-wide  anti-fraud  conference  and  implementing  efforts  to 
encourage broader, cross-border cooperation. 

17 

 
 
 
 
 
Internal cooperation / National level  

Member State 

Measure taken 

Measure focus 

Information exchange and cooperation highlights 

s
u
r
p
y
C

a
i
n
o
t
s
E

y
l
a
t
I

a
i
v
t
a
L

e
h
T

e
h
T

s
d
n
a
l
r
e
h
t
e
N

s
d
n
a
l
r
e
h
t
e
N

a
i
n
e
v
o
l
S

Enhancing Anti-Fraud 
Strategies: CAPO's Internal 
Group Initiative 

Establishment of an internal 
group 

• 

• 

Insights  collected  from  all  operational 
levels of CAPO 
Leverage of collective knowledge 

Creation Of An Economic 
And Corruption Crime 
District 

Establishment of an Economic 
and Corruption Crime District 
in the Prosecutor’s Office 

Establishment of the 
Committee For Combating 
Fraud Against The EU 

Internal reorganisation  

•  Reorganisation of existing bodies to set 

• 

a focus on economic crimes 
Enhancement  of 
resource allocation  

competence 

and 

•  Reorganisation  of  the  Office  of  the 
Prosecutor  Genera  at  the  Court  of 
Auditors  

•  Dedicated section for the Committee for 
Combating  Fraud  against  the  European 
Union  established  in  the  International 
Affairs Unit 
Ensured collaboration with both national 
and supranational bodies  

• 

AFCOS Job Shadowing 

Job shadowing for employee 
within the AFCOS network 
institutions 

Network Meeting With 
National EU Fund Partners 

Network meetings among 
national partners 

Coordination Of Antifraud 
EU Funds As Part Of 
AFCOS 

Designation of a coordinator 
within the AFCOS 

• 

• 

• 
• 

• 
• 

cooperation 
from 

between 
various  AFCOS 

Improved 
employees 
network instructions  
Provided  better  understanding  of  the 
anti-fraud cycle steps and of improving 
cooperation 
different 
authorities 

between 

Fostering collaboration 
Exchanging  best  practices  and  learning 
from each other’s experience 

Ensuring smooth information flow 
Prioritising  anti-fraud  efforts  on  the 
agenda  

Strengthening Inter-
Institutional Cooperation In 
The Area Of Economic 
Crime, Corruption And 
Protection Of The EU’s 

Adoption of a strategic plan for 
inter-institutional cooperation 

•  Reorganisation of existing bodies 
• 

Setting-up  of  contact  points  with  the 
competent bodies  

Table 12: Enhanced cooperation and information exchange - Internal cooperation / National level analysis 

18 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Member State 

Measure taken 

Measure focus 

Information sharing and cooperation highlights 

External cooperation   

s
u
r
p
y
C

e
c
e
e
r
G

y
l
a
t
I

a
i
n
a
m
o
R

Strengthening AFOCS And 
OLAF Collaboration In 
Cyprus 

Strengthening AFOCS and 
OLAF cooperation  

• 

Protocols  developed  for  collaboration 
and  effective 
information  exchange 
between Cyprus and OLAF 

“Prevent - Detect - 
Investigate II: Data-driven 
Protection of the EU 
Budget” Conference 
Organised With OLAF 

EU-wide cooperation 
conference  

•  Gathering  of  anti-fraud  authorities 

across the EU 

•  Dedicated topics such as digitalisation / 

new tools 

Enhanced Collaboration To 
Fight Against Cross-Border 
VAT Fraud 

Cross-Border cooperation to 
fight VAT Fraud 

• 

• 

Enhancing  international  cooperation  in 
addressing tax fraud 
collaboration  with  key 
Improving 
entities 
the 
Agricultural Payments Agency (AGEA), 
and  the  Institute  for  Agri-Food  Market 
Services (ISMEA) 

the  EPPO, 

such  as 

Increasing Staff Of The 
National Anticorruption 
Directorate 

Strengthen resources to improve 
cooperation with the EPPO  

• 

Increased 
collaboration 

resources 

to 

improve 

Table 13: Enhanced cooperation and information exchange – External cooperation analysis 

19 

 
 
 
 
 
 
 
 
 
 
 
 
 
2. States 

2.1. Austria 

Austria reported three key measures in 2024 involving mandatory compliance training for staff involved 
in EU fund management, high-density verifications to check the accuracy of expenditure submissions, 
and  a  proactive  approach  to  combating  social  benefits  fraud  through  a  structured  network  of  law 
enforcement agencies. 

2.1.1. Mandatory Annual Compliance Training 

Annual mandatory training sessions focused on compliance, corruption prevention, and the Whistle-
blower Protection Act have been instituted at the Federal Ministry of Finance.  

The reason for highlighting this measure is that Austria has been allocated just under EUR 4 billion in 
EU funds under the Recovery and Resilience Facility (RRF) until 2026, and the deployment of these 
funds  are  subjected  to  strict  audit  and  compliance  standards.  This  package  of  administrative  and 
organisational  measures  aims  to  ensure  that  all  staff  at  the  Ministry  involved  in  the  Recovery  and 
Resilience plans are thoroughly educated in audit and control requirements. 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #1 Taken by Austria in 2024  

Administrative  
(Circulaire/ Circular, 
Instructions, 
Guidelines, Manuals) 

New 
measure 
Update  

Prevention       Detection 

e
g
a
k
c
a
P

Organisational 
08/03/2024 

New 
measure 
Update  

Sectoral: 
•  Expenditure 
- Recovery 
and 
Resilience 
Facility 

•  Public 

procurement 

•  Corruption 
•  Conflict of 
interest 

•  Whistleblower 
•  Shared 

management 
and control of 
EU funds 
•  Antifraud or 

anticorruption 
strategy 

•  Irregularities 
reporting 

•  Other:  

corruption 
prevention, 
notification of 
irregularities, 
conflicts of 
interest 

• General 
trainings 

• Fraud 

awareness 
trainings 

• To clarify or 
consolidate 
existing 
rules  

• To enhance 
existing 
measure 

•  Neutral on 
resources 

Table 14: Anti-fraud measure #1 taken by Austria in 2024 

Corruption within public procurement – Austria #1 

Public / 
Private sector 
Public sector  
Private sector 

Fight against corruption in public procurement 

Comment 

•  Measures to prevent corruption amongst 

personnel, including management 

Table 15: Corruption within public procurement – Measure #1 taken by Austria in 2024 

2.1.2. High Density Verifications  

Following  last  year  measure,  this  high  density  of  verifications  package  of  measures  is  carried  out 
pursuant to Article 125(4) of Regulation (EU) No 1303/2013 for the 2014-2020 programming period 
and should serve to prevent irregularities. The verification procedure should allow the administrative 
bodies to check 100% of the expenditure submitted by the beneficiary. 

20 

 
 
 
  
 
 
  
 
 
 
Single / 
Package 

Type 

New / 
Update 

Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Anti-Fraud Measure #2 Taken by Austria in 2024  

Administrative  
(Circulaire/Circular, 
Instructions, Guidelines, 
Manuals) 

Update  

e
g
a
k
c
a
P

Prevention       Detection 

Recovery 
and sanction 

Organisational 
01/01/2024 

Update  

Operational 
08/10/2015 

Update 

Reason / Expected 
Result 

• Cross-cutting 

measure, 
multi-agency 
measure / 
measure with 
impact on 
various 
bodies* 

• Other: 

Monitoring of 
the proper use 
of funds and 
of reporting of 
irregularities  

•  Management of 

funds  

•  On the spot 

checks 

•  Audit checklist 
•  Irregularities 
reporting 

.                                                                                               
.                                      

•  Public 

.                            .                          
procurement 
•  Conflict of 
interest 

Sectoral: 
•  Expenditure – 
Cohesion 
policy 

•  Whistleblower 
•  Shared 

management and 
control of EU 
funds 

•  Antifraud or 

anticorruption 
strategy  

• Reorganisation 

of existing 
bodies 

• Inter-agency 
cooperation 

• General 
trainings 

• Fraud awareness 

trainings 

• Simplification 
of procedures  

•  Neutral on 
resources 

• IT tools (“IT 

data feeding”, 
“Other IT”) 

• Other** 

•  Enhanced 

information 
flow 

•  Targeting of 

checks 

Table 16: Anti-fraud measure #2 taken by Austria in 2024 

**Cross-cutting measure: Formal requirements in the national rules on eligibility and in the management and control system 
should increase efficiency. Standardised forms (checklists) improve the quality of the accounts submitted. 

*Other: Presentation of the entire funding operation, including the accounting process, in a central database. In addition, the 
Arachne data-mining tool, provided by the Commission, is used for risk evaluation and risk analysis. 

2.1.3. Social Benefits Fraud 

Following last year measure, this measure presents a general, comprehensive, and proactive approach 
to  combating  the  unlawful  collection  of  social  benefits  (social  benefit  fraud)  through  a  structured 
network  established  within  the  Austrian  police.  This  includes  collaboration  among  the  Criminal 
Intelligence Service (Bundeskriminalamt, BK), the Criminal Police Office (Landeskriminalamt, LKA), 
and  district  police  headquarters  (Bezirkspolizeikommando,  BPK).  The  initiative  prioritises  repeated 
actions against social benefit fraud, particularly through airport and GVS checks in Austria’s provinces 
(‘Länder’).  This  measure  aims  at  launching  and  conducting  inquiries  and  international  investigative 
measures in more than 80 countries around the world, through Europol, Interpol, Austrian embassies 
and liaison officers.  This legislative measure  pursues facilitating information exchanges between the 
money laundering reporting unit and competent national and foreign authorities, as well as with Europol. 

21 

 
 
 
 
  
 
                                                                                            
 
  
 
 
Single / 
Package 

Type 

New / 
Update 

Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Reason / Expected 
Result 

Anti-Fraud Measure #3 Taken by Austria in 2024  

e
l
g
  Operational 01/01/2024 
n
i
S

Update  

Prevention       Detection 

Investigation 
and 
prosecution 

Horizontal 

•  Financial crime 

(including money 
laundering) 

•  Structured 

cooperation 
with law 
enforcement  

•  Structured 

cooperation 
with judicial 
authorities  

• Enhanced 

coordination  

Table 17: Anti-fraud measure #3 taken by Austria in 2024 

2.2. Belgium  

Belgium reported three single measures adopted in 2024, two of a horizontal nature and one related to 
the tax fraud sector. These measures aim to strengthen compliance with tax obligations, prevent conflicts 
of interest in public procurement, and ensure rigorous monitoring of financial activities associated with 
legal professionals. 

2.2.1. E-Commerce VAT compliance strengthening 

The measure regarding the liability of electronic interfaces for Value Added Tax (VAT) compliance is 
articulated in the supplemented Article 51bis, section 3bis of the VAT Code. This regulation imposes 
joint and several liability on electronic interfaces for the payment of VAT due from their users when the 
interface fails to act in good faith or is negligent. Specifically, these interfaces are  required to verify 
users' valid VAT numbers, notify users of their VAT obligations when administrative suspicions arise, 
and ban non-compliant users. 

The purpose of emphasising this measure is to address and reduce the loss of VAT receipts and enhance 
the efficiency of VAT collection in e-commerce transactions. By designating the electronic interface as 
an  additional  responsible  party,  the  regulation  seeks  to  ensure  that  VAT  obligations  are  accurately 
fulfilled  and  collected.  This  approach  incentivises  electronic  interfaces  to  implement  rigorous 
compliance checks on their users and actively discourages non-compliance. 

The  legislative  measure  introduces  a  system  where  e-commerce  platforms  bear  joint  and  several 
accountabilities for VAT in situations where Article 13bis of the Code does not apply (presumption that 
the platform is considered the buyer/seller of the goods). This liability is not absolute and the platform 
may be discharged from it if it demonstrates that it acted in good faith and was not at fault or negligent. 
However, this accountability is not absolute; platforms can be discharged if they can prove that they 
acted in good faith and were neither at fault nor negligent. This was formally established by the Law of 
23 November 2023, which outlines various VAT provisions and specific recovery rules under the 1992 
Income  Tax  Code,  as  referenced  in  [C  −  2023/47474]  -  MONITEUR  BELGE  /  BELGISCH 
STAATSBLAD — 01.12.2023. 

Anti-Fraud Measure #1 Taken by Belgium in 2024  

Single / 
Package 

Type 

New / 
Amendment 

Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Reason / Expected 
Result 

e
l
g
n
i
S

Legislative 
(Law/Act) 
23/11/2023 
Loi du 23 novembre 2023* 

Amendment 

Prevention      

Recovery 
and sanction 

Sectoral: 
•  Revenue – Tax 

fraud  

•  Antifraud or 

anticorruption 
strategy 

•  Recovery 

• To remedy 

flaws 

Table 18: Anti-fraud measure #1 taken by Belgium in 2024 

22 

 
 
  
 
 
 
 
  
 
 
*Loi du 23 novembre 2023 portant des dispositions diverses en matière de taxe sur la valeur ajoutée et des règles particulières 
de recouvrement du Code des impôts sur les revenus 1992. [C − 2023/47474] - MONITEUR BELGE — 01.12.2023. 

2.2.2. Mandatory Conflict Of Interest Declarations 

The second measure reported by Belgium involves conflict of interest awareness in public procurement, 
as specified in the ministerial circular of 11 June 2024, published in the Belgian Official Gazette on 8 
July 2024. This directive mandates that all individuals working within the federal public sector involved 
in public procurement provide a written confirming that they have taken notice of the legal provisions 
relating to conflicts of interest in public procurement (in specific, article 6 of the law of 17 June 2016 
on  public  procurement).  This  declaration  must  be  renewed  every  two  years  to  ensure  ongoing 
compliance  and  awareness.  The  circular  also  contains  a  model  declaration  in  case  there  is  a  legal 
presumption or an appearance of a conflict of interest. 

The purpose of this measure is to remind those concerned of the legal prescriptions and make them 
aware that conflicts of interest in public procurement are absolutely prohibited. The legislative measure 
includes a standard clause to be incorporated into public procurement documents, designed to prevent 
and  address  concerns  related  to  revolving  door  constructions.  This  initiative  serves  as  a  proactive 
measure  to  prevent  violations  and  supports  compliance  by  providing  clear  guidelines  and  model 
declarations. 

Single / 
Package 

Type 

New / 
update 

Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Anti-Fraud Measure #2 Taken by Belgium in 2024  

e
l
g
n
i
S

Administrative 
(Law/Act) 
23/11/2023 

New 
measure 

Prevention      

Horizontal 

•  Public 

procurement 

•  Corruption 
•  Conflict of 
interest 

•  Other: 

knowledge of 
existing legal 
provisions 

Reason / Expected 
Result 

• Cross-cutting 

measure, 
multi-agency 
measure/ 
measure with 
impact on 
various 
bodies* 
• Other** 

Table 19: Anti-fraud measure #2 taken by Belgium in 2024 

*Cross-cutting measure: The measure applies to all persons within the federal public sector involved in public procurement. 
Consequently, the measure affects a lot of federal organisations. 

** Other: Raising awareness of existing legislation to prevent violations. The measure also seeks to support compliance with 
legal prescriptions (in case of a presumption of a conflict of interest or in case of the appearance of a conflict of interest) 
through the provision of model declarations. 

Public / 
Private sector 

Public sector 

Corruption within public procurement – Belgium#2 

Fight against corruption in public procurement 

Comment 

•  Measures to prevent corruption amongst 

personnel, including management 

•  The measure aims to prevent conflicts of 
interest in public procurement by raising 
awareness and reminding persons within the 
federal public sector involved in public 
procurement of the existing legal provisions in 
this regard. By preventing conflicts of interest, 
it obviously also seeks to prevent corruption. 

Table 20: Corruption within public procurement – Measure #2 taken by Belgium in 2024 

2.2.3. Enhancing legal financial oversight 

The third measure reported is a legislative measure. It refers to the Royal decree of 9 June 2024 that lays 
down detailed rules on management, control and oversight of, and access to, third-party accounts and 
subaccounts within the meaning of Article 446quater of the Judicial Code. 

The reason for highlighting this measure is that it aims at fighting against money laundering as it ensures 
rigorous  monitoring  of  financial  activities  associated  with  legal  professionals,  thereby  enhancing 
transparency and preventing illicit activities such as money laundering. By facilitating oversight, the 

23 

 
 
 
 
 
 
decree reinforces the integrity of financial operations and supports the broader fight against financial 
crimes. 

The  decree  establishes  regulations  that  enable  bar  council  presidents  to  automatically  monitor  and 
oversee  lawyers'  third-party  accounts  and  subaccounts.  Under  this  measure,  the  account  holder  is 
required to grant an irrevocable power of attorney to the bar council president. This authorisation allows 
the financial institution to provide the president full access to view and obtain copies of all transactions 
related  to  these  accounts. Additionally,  the  account holder  gives  the  financial  institution  irrevocable 
permission to make all transaction data available to the oversight body. 

Single / 
Package 

Type 

New / 
amendment 

Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Anti-Fraud Measure #3 Taken by Belgium in 2024  

e
l
g
n
i
S

Legislative 
(Decision) 
09/06/2024 
Number: 2024006238 – 
Dossier number: 2024-06-
09/12 

New 
legislation 

Prevention       Detection 

Horizontal 

•  Financial crime 

(including money 
laundering) 
•  Antifraud or 

anticorruption 
strategy 

•  Other: fight 

against money 
laundering 

Reason / Expected 
Result 

• To remedy 

flaws 
• Other: 

automation 
and 
optimisation 
of the existing 
rules 

Table 21: Anti-fraud measure #3 taken by Belgium in 2024 

2.2.4. Additional measures  

Belgium  shared  several  additional  measures  that  all  aim  at  enhancing  integrity,  transparency  and 
accountability across multiple funding and administrative programs in Wallonia, Flanders, Brussels, and 
the German-speaking Community in Belgium. 

Region 

Measures Implemented in 2024 

Funds or bodies involved  

• 

Effort  to  prevent  double  funding  and  conflicts  of 
interest 
the 
ARACHNE risk management tool 

through  data  cross-checks  using 

• 
ERDF  
• 
ESF  
•  RRF 

•  Wallonia 

•  Appointment of contact persons to report irregularities 

•  Adoption of  anti-fraud policy  and  implementation  of 

anti-fraud training 

• 

Ex-ante  use  of  ARACHNE  for  conflict  of  interest 
assessments 

•  Quarterly upload of ESF+ project data via Arachne 

• 

Flanders 

•  Adaptation  of  manuals  and  procedures  for  enhanced 

•  Brussels 

detection and correction of irregularities 
Ex-ante verification instructions issued 

• 

• 

Federal 
level 

•  Utilisation  of  ARACHNE  for  both  pre-  and  post-
transaction  controls,  utilising  risk  indicators,  and 
conducting  site  visits  while  consulting  the  Ultimate 
Beneficial Owner (UBO) register 

•  Annual  organisational  control  reporting,  along  with 

training sessions and joint network meetings 

• 

• 

• 

FOREM (Walloon Public 
Service  for  Employment 
and Vocational Training) 
IFAPME 
(Walloon 
Institute for Ongoing and 
Freelance  Training  and 
SMEs) 
SWL  (Walloon  Housing 
Corporation) 

•  CGT  (Walloon  Tourist 

Board) 

• 

ESF 

FEDER 

• 
•  RRF 

• 

FOD  BOSA:  Belgian 
Federal  Public  Service 
Policy and Support 

24 

 
 
 
 
 
 
 
 
Region 

Measures Implemented in 2024 

Funds or bodies involved  

•  Circular on post-employment conflicts of interests 

•  Amendment  of  laws  for  increased  transparency  in 

public access to government information 

• 
• 

FPS Justice 
(Federal 
Public 
Service) 

•  German-
Speaking 
Community 

• 

Establishment  of  clear  procedures  for  prevention, 
control,  and  detection  of  irregularities  at  the  project 
level in the Management and control systems 

•  RRF 
• 
ESF 

Table 22: Additional anti-fraud measures taken by Belgium in 2024 

2.3. Bulgaria  

In 2024, Bulgaria reported the adoption of three single horizontal legislative measures, showcasing a 
comprehensive approach to enhancing the governance of EU funds and other financial activities across 
various sectors.  

2.3.1. Management Of Irregularities Under Shared Management 

The  first  legislative  measure  reported  by  Bulgaria  is  an  amendment  of  the  Regulation  on  the 
administration of irregularities involving EU funds under shared management. It aims to improve the 
operating rules of the Information System for Management and Monitoring of EFSF Funds as regards 
the reporting of irregularities and fraud. 

This adopted measure was shared as it introduces a new function for the AFCOS Directorate, enhancing 
the management of EU funds in Bulgaria by defining requirements and parameters for the UMIS system. 
It  strengthens  data  integration  and  module  connections,  with  AFCOS  providing  methodological 
instructions  for  managing  irregularity-related  data.  This  ensures  standardised  processes,  improved 
oversight, and alignment with EU standards. 

Anti-Fraud Measure #1 Taken by Bulgaria in 2024  

Single / 
Package 

Type 

New / 
amendment 

Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Reason / Expected 
Result 

e
l
g
n
i
S

Legislative 
(Law/Act) 
26/11/2024 
Decree of the Council of 
Ministers No 399 of 21 
November 2024 

Prevention       Detection 

Amendment 

Horizontal 

•  AFCOS 
•  Shared 

management and 
control of EU 
funds 

•  Competences 

• To clarify or 
consolidate 
exiting rules 

Table 23: Anti-fraud measure #1 taken by Bulgaria in 2024 

2.3.2. Strengthening Financial Correction Regulations 

The second legislative measure reported by Bulgaria is the amendment of the Regulation on reporting 
irregularities to improve financial corrections. The update revises how percentage indicators are used to 
calculate financial corrections, and introduces Article 7a, which imposes a 100% financial correction 
for confirmed offenses under the Criminal Code.  

The measure was highlight as it aligns the Regulation with the 2021-2027 legislative framework and 
builds  on  insights  from  managing  financial  corrections  during  the  2014-2020  period.  It  addresses 
previously identified shortcomings by refining processes for financial corrections.  

25 

 
 
 
 
 
 
 
 
Single / 
Package 

Type 

New / 
amendment 

Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Anti-Fraud Measure #2 Taken by Bulgaria in 2024  

e
l
g
n
i
S

Legislative 
(Law/Act) 
05/07/2024  
Decree No 248 of the 
Council of Ministers of 5 
July 2024 

Prevention       Detection 

Amendment 

Horizontal 

•  Public 

procurement  
•  Financial crime 

(including money 
laundering) 
•  Conflict of 
interest 
•  Shared 

management and 
control of EU 
funds  

•  Financial 
penalties 

•  Other 

administrative 
penalties  

Reason / Expected 
Result 

• To clarify or 
consolidate 
exiting rules 
• To enforce the 
rules in line 
with 
development 
in EU law 

Table 24: Anti-fraud measure #2 taken by Bulgaria in 2024 

2.3.3. Revised Procurement Rules for Compliance 

The third legislative measure reported by Bulgaria in 2024 involves amending the Rules implementing 
the Public Procurement Act to align with the 2023 amendments of the Act. This update focuses on public 
procurement,  corruption,  and  conflict  of  interest,  introducing  new  e-forms  and  mandatory  ex-ante 
checks for contracts over BGN 5 million. The new rules specify the conditions for appointing observers 
in award procedures and outline requirements for individuals conducting legality checks under Article 
237b of the Public Procurement Act. 

The  measure  was  highlighted  as  it  aligns the  procurement  framework  with  EU  standards  and  fulfils 
commitments under the implementation of RRP to strengthen checks, introduce new standard e-forms 
for public procurement, reduce non-competitive procurement and improve transparency in the system, 
as well as facilitate and harmonise practice in implementing the law. 

Anti-Fraud Measure #3 Taken by Bulgaria in 2024  

Single / 
Package 

Type 

New / 
amendment 

Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Reason / Expected 
Result 

e
l
g
n
i
S

Legislative 
(Law/Act) 
23/07/2024 
Decree No 257 of 22 July 
2024 

Prevention      

Amendment 

Horizontal 

•  Public 

procurement  

•  Corruption 
•  Conflict of 
interest 
•  Shared 

management and 
control of EU 
funds  

•  Competences  
•  Powers 
•  Definition of a 
specific topic 

• To clarify or 
consolidate 
exiting rules 

• To remedy 

flaws 
• Other*  

Table 25: Anti-fraud measure #3 taken by Bulgaria in 2024 

*Other: Some of the amendments adopted to the Rules implementing the Public Procurement Act relate to commitments made 
to  the  European  Commission  in  the  implementation  of  the  National  Recovery  and  Resilience  Plan,  as  well  as  in  the 
implementation of the State policy to increase transparency and the lawful award of public contracts by introducing new forms 
of checks in the process, as well as by applying mandatory ex-ante control by the Public Procurement Agency of all contracts 
above BGN 5 million. 

Public / 
Private sector 

Public sector 

Corruption within public procurement – Bulgaria#3 

Fight against corruption in public procurement 

Comment 

•  Measures addressing transparency in 

public procurement 

•  Measures to improve the effectiveness of 

management of the public procurement 
•  Measures to prevent corruption amongst 
personnel, including management 
•  Measures to improve the effectiveness of 

control and audit 

Table 26: Corruption within public procurement – Measure #3 taken by Belgium in 2024 

26 

 
 
 
 
 
  
 
 
 
  
 
 
2.4. Croatia  

Croatia reported three anti-fraud measures implemented in 2024, comprising two single measures and 
one package measure. Together, these initiatives address the entire anti-fraud cycle, covering prevention, 
detection,  investigation,  and  sanctioning  of  fraud,  and  demonstrate  a  comprehensive  approach.  The 
measures  collectively  enhance  legal  frameworks,  improve  verification  processes,  and  strengthen 
sanctions. 

2.4.1. Removing Double Criminality: Strengthening Money Laundering Legislation 

The  first  legislative  measure  reported  by  Croatia  in  2024  involves  amending  the  Criminal  Code  to 
remove the  requirement  of  double  criminality for predicate offenses committed in  a  foreign  country 
concerning money laundering. This change enhances the capacity to prosecute money laundering under 
Article 265 of the Criminal Code by no longer requiring the predicate offense to be a crime in both 
Croatia and the foreign country where it was committed. 

This measure is significant as money laundering is one of the offences prescribed by Directive (EU) 
2017/1371 on combating fraud against the EU's financial interests through criminal law (Article 4(1)) 
when involving property derived from the criminal offences covered by this Directive. By addressing 
money  laundering  more  robustly,  especially  when  linked  to  international  criminal  activities,  the 
amendment supports the efforts of the European Public Prosecutor’s Office (EPPO) to tackle offenses 
within its material competence. 

Single / 
Package 

Type 

New / 
amendment 

Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Reason / Expected 
Result 

Anti-Fraud Measure #1 Taken by Croatia in 2024  

e
l
g
n
i
S

Legislative 
(Law/Act) 
02/04/2024 
Narodne novine No 36/24 

Amendment 

Horizontal 

Recovery 
and sanction 

Investigation 
and 
prosecution 

•  Financial crime 

(including money 
laundering)  

•  Other* 

• Other** 

Table 27: Anti-fraud measure #1 taken by Croatia in 2024 

* Other: The legislative measure concerns the punishment of perpetrators of the crime of money laundering where the proceeds 
derive from a predicate offence committed abroad and the predicate offence is not punishable under the law of the country in 
which it was committed. In that situation, if the act committed abroad resulting in the generation of proceeds is a criminal 
offence under Croatian law, that will be sufficient. 

**  Other:  As  part  of  the  process  leading  up  to  Croatia’s  accession  to  the  Organisation  for  Economic  Co-operation  and 
Development (OECD), the Working Group on Bribery in International Business Transactions adopted the report on the Phase 
1  evaluation  in  December  2023.  As  regards  the  offence  of  money  laundering  under  Article  265  KZ,  the  Working  Group 
recommended removing the condition of double criminality for a predicate offence committed in a foreign country, in order to 
comply  with  Article  7  of  the  Convention  on  Combating  Bribery  of  Foreign  Public  Officials  in  International  Business 
Transactions (NN-MU [international section of NN], 10/23). 

2.4.2 Guidance for Enhanced Verification Procedures 

By  this  operational measure,  Croatia  has introduced  a  technical  guidance for  Competent  Authorities 
(CA)  and  Implementing  Bodies  (IB)  responsible  for  the  national  recovery  and  resilience  plan.  This 
operational  measure  focuses  on  using  available  databases  to  document  verification  procedures, 
particularly  for  checks  on  double  funding  and  potential  conflicts  of  interest.  It  serves  to  clarify  and 

27 

 
 
 
 
 
 
 
 
 
 
supplement  existing  procedures  during  grant  awarding  and  procurement  processes  by  grant 
beneficiaries. 

This measure was highlighted as it offers crucial guidance to Competent Authorities and Implementing 
Bodies,  enhancing  existing  procedures  for  verifying  double  funding  and  conflicts  of  interest.  By 
ensuring thorough checks during grant awarding and procurement processes, it strengthens the integrity 
and transparency of the national recovery and resilience plan's implementation. 

Anti-Fraud Measure #2 Taken by Croatia in 2024  

Single / 
Package 

Type 

New / 
Update 

Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Reason / Expected 
Result 

e
l
  Operational 
g
n
08/03/2024 
i
S

Update 

Prevention       Detection 

•  Public 

procurement  

•  Other: 

Sectoral: 
•  Expenditure – 
Recovery and 
Resilience 
Facility 

•  Conflict of 
interest 
•  Shared 

management and 
control of EU 
funds  

performing 
checks 
and 
controls  related 
to  the  eligibility 
of expenditures 

• Targeting of 

checks 

• Enhanced ex-
ante controls 
• Enhanced ex-
post controls  

2.4.3. Enhanced Agricultural Fund Sanctions for Fraud Prevention 

Table 28: Anti-fraud measure #2 taken by Croatia in 2024 

The third measure reported by Croatia is a package measure of both legislative and administrative type. 
This package measure involves legislative and administrative amendments to the Law on Agriculture to 
enhance the prevention and sanctioning of fraud, thereby protecting the EU's financial interests. The key 
provision mandates that the Paying Agency withhold support from both the European Agricultural Fund 
for  Rural  Development  (EAFRD)  and  the  European  Agricultural  Guarantee  Fund  (EAGF)  for  any 
beneficiary  convicted  of  fraud.  This  interconnected  response  means  that  fraud  detected  in  one  fund 
affects all support payments for the same beneficiary, reinforcing the integrity of fund use. 

The measure is significant for its strong deterrent effect on potential fraudsters. By implementing this 
policy, a clear message is conveyed that committing fraud disqualifies beneficiaries from receiving any 
EU  agricultural  funds.  Furthermore,  offenders  are  placed  on  an  exclusion  list,  barring  them  from 
accessing  EU  funds  for  the  next  three  years.  This  systematic  approach  enhances  vigilance  and 
compliance, underlining the seriousness of fraud prevention in agricultural funding. 

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle   Horizontal / Sectoral  

Area  

Scope  

Reason / Expected 
Result  

Anti-Fraud Measure #3 Taken by Croatia in 2024  

Legislative  
(Law/Act) 
24/12/2024 
Narodne Novine broj: 
152/2024 

Amendment 

e
g
a
k
c
a
P

Administrative 
(Circulaire/circular, 
Instructions, Guidelines, 
Manuals) 

New 
measure  

Recovery 
and sanction 

Investigation 
and 
prosecution 

Sectoral: 
•  Expenditure - 
Agriculture 

•  Public 

procurement 

•  Conflict of 
interest 
•  Shared 

management and 
control of EU 
funds 

•  Financial 
penalties 

•  Other 

administrative 
penalties 

• Other* 

• Investigation  
• Penalty 
• Recovery 

•  To enhance 
existing 
measure 
•  Other** 

Table 29: Anti-fraud measure #3 taken by Croatia in 2024 

* Other: This amendment to the national legal framework strengthens the protection of the financial interests of the EU and 
Croatia and increases the deterrent effect with regard to potential fraud as, if a final court judgment states that the beneficiary 
has  committed  fraud  with  respect  to  resources  from  one  fund,  they  no  longer  receive  aid  from  that  fund  or  from  another 
agricultural  fund.  The  beneficiary  concerned  is  also  placed  on  an  exclusion  list:  not  only  are  they  obliged  to  return  aid 

28 

 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
  
connected to claims that are being processed but also they are not allowed to apply for aid in the following three years, which 
shows that a beneficiary who is proved to have committed fraud suffers substantial financial consequences. 

** Other: The main goal (reason) was to  strengthen protection of financial interests of EU by improving internal controls 
system of Paying Agency. 

2.5. Cyprus  

The three measures reported by Cyprus for 2024 concern one legislative, one administrative and one 
operational measure. They cover the establishment of a national coordinating body for combating fraud 
affecting  the  EU’s  financial  interests,  the  issuance  of  guidelines  for  the  procedures  to  ensure 
compatibility with the National and Union Law for public procurement and to ensure the prevention, 
detection  and  correction  of  cases  of  fraud,  corruption  and  conflict  of  interest  in  the  context  of  the 
programming  period  2021-2027  and  the  implementation  of  the  establishment  of  an  ad-hoc  internal 
group. 

2.5.1. Strengthening AFCOS and OLAF Collaboration in Cyprus 

The first legislative measure reported by Cyprus implements key EU regulations and includes provisions 
for the operation of Cyprus AFCOS (it defines its members and observers), as well as the competences 
and powers of the Service. The law outlines protocols for collaboration between Cyprus AFCOS and 
OLAF, ensuring OLAF officials receive necessary assistance for their tasks. It facilitates cooperative 
efforts  for  conducting  on-the-spot  checks,  safeguards  evidence  through  partnerships  with  relevant 
authorities, grants access to Central Bank of Cyprus information, mandates irregularity reporting, and 
coordinates  actions  among  competent  authorities.  Additionally,  it  defines  criminal  offenses  for  data 
destruction or falsification and sets the grounds for Memoranda of Understanding. 

This adopted measure was shared as it established a robust framework to protect EU financial interests 
by supporting OLAF with the necessary resources for effective investigations. 

Single / 
Package 

Type 

New / 
amendment 

Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Anti-Fraud Measure #1 Taken by Cyprus in 2024  

e
l
g
n
i
S

Legislative 
(Law/Act) 
10/05/2024 
Law 62(I)/2024 

New 
legislation 

Detection 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Horizontal 

•  Public 

procurement 

•  Conflict of 
interest 
•  AFCOS 
•  Whistleblower 
•  Shared 

management and 
control of EU 
funds 

•  Competences 
•  Powers 
•  Financial 
penalties 
•  Criminal 
sanctions 
(new)* 

Reason / Expected 
Result 

• To clarify or 
consolidate 
exiting rules 

• To remedy 

flaws 

• To enforce the 
rules in line 
with 
development 
in EU law 

* Criminal sanctions (new): indicates that no sanctions were foreseen before 

Table 30: Anti-fraud measure #1 taken by Cyprus in 2024 

2.5.2. Guidelines for Ensuring Compliance in Public Procurement And For The Prevention Of 
Conflicts Of Interest 

This administrative measure addresses all the stages of the anti-fraud cycle. It introduces comprehensive 
guidelines aimed at ensuring compliance with national and EU laws concerning public procurement for 
the programming period 2021-2027. The guidelines are designed to prevent, detect, and correct instances 
of fraud, corruption, and conflicts of interest across all parties involved in the management, monitoring, 
and  implementation  of  programs.  They  specifically  address  public  procurement  projects  and  the 
evaluation process for proposals seeking inclusion in grant schemes.  

This  measure  is  highlighted  as  it  seeks  to  achieve  uniform  and  consistent  compliance  with  public 
procurement  regulations  and  specifically  address  ex-ante  controls  for  the  prevention  of  conflicts  of 
interest using the European Commission’s ARACHNE tool, access to the UBO register and the Cyprus 
Civil Registry through the Government Data Warehouse. The guidelines enhance the management and 
control  system's  effectiveness  by  preventing,  detecting,  and  rectifying  conflicts of  interest  and  other 
irregularities.  

29 

 
 
 
 
 
Single / 
Package 

Type 

New / Update  Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Anti-Fraud Measure #2 Taken by Cyprus in 2024  

Prevention       Detection 

e
l
g
n
i
S

Administrative 
(Circulaire/circular, 
Instructions, Guidelines, 
Manuals) 

New 
measure 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Horizontal 

•  Public 

procurement 

•  Conflict of 
interest 

•  Whistleblower 
•  Shared 

•  Management of 

funds 

•  Monitoring / 
desk checks 
•  On the spot 

checks 

management and 
control of EU 
funds 

•  Irregularities 
reporting 
•  Recovery  

Reason / Expected 
Result 

• To clarify or 
consolidate 
exiting rules 
• To enhance 
existing 
measure 

• Cross-cutting 

measure, 
multi-agency 
measure/ 
measure with 
impact on 
various 
bodies* 

Table 31: Anti-fraud measure #2 taken by Cyprus in 2024 

*Cross-cutting measure: Impact of various bodies, multiagency. The guidelines include provisions for all involved bodies for 
monitoring and control of EU funds (cohesion policy and EMFAF). 

2.5.3. Enhancing Anti-Fraud Strategies: CAPO's Internal Group Initiative 

This third measure reported by Cyprus in 2024 is an operational initiative establishing an ad hoc internal 
group  within  the  Cyprus  Agricultural  Payments  Organisation  (CAPO).  The  group  is  focused  on 
identifying gaps in current anti-fraud procedures and recommending additional measures to enhance the 
organisation's fraud prevention capabilities.  

This measure was reported because it allows collecting insights from all operational levels of CAPO. It 
aims  to  leverage  collective  knowledge  for  implementing  more  effective  anti-fraud  strategies  while 
reducing resistance to necessary changes.  

Single / 
Package 

Type 

New / 
Update 

Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Anti-Fraud Measure #3 Taken by Cyprus in 2024  

e
l
  Operational 
g
n
16/04/2024 
i
S

New 
measure 

Prevention      

Sectoral: 
•  Expenditure - 
Agriculture 

•  Conflict of 
interest 

•  Whistleblower 
•  Antifraud or 

anticorruption 
strategy  

•  Flagging 
practice  

•  Risk indicators 
•  Increased 
number of 
checks 

Reason / Expected 
Result 

• Enhanced 

coordination 

• Enhanced 

cooperation 

• Enhanced 

information 
flow 

• Enhanced ex-
ante controls 
• Enhanced ex-
post controls  

Table 32: Anti-fraud measure #3 taken by Cyprus in 2024 

2.5.4. Additional measures  

Cyprus shared an additional measure. 

Region 

Measures Implemented in 2024 

Funds or bodies involved 

•  National 

• 

through 

Strengthening  conflict  of  interest  controls  for  EU 
funds,  Cyprus  is  using  access  to  data  of  the  Cyprus 
Civil  Registry 
the  Government  Data 
Warehouse, to monitor relationships up to the fourth 
degree  of  all  individuals  involved  in  the  preparation 
and  assignment  of  co-financed  contracts  following  a 
public  procurement  call  for  tenders  or  evaluating 
submitted  by  potential  beneficiaries 
proposals 
(applicants)  in  state  aid  schemes  following  calls  of 
proposals. 

•  Cohesion  Policy  Funds 

• 

and the EMFAF 
Treasury of the Republic 
of Cyprus 

Table 33: Additional anti-fraud measure taken by Cyprus in 2024 

30 

 
 
 
 
 
 
 
 
  
2.6. Czech Republic  

In 2024, the Czech Republic implemented a series of targeted single measures to enhance transparency, 
improve tax processes, and enforce international sanctions effectively. Together, these initiatives cover 
the entire anti-fraud cycle, addressing prevention, detection, investigation and recovery and sanction. 
They span both revenue and expenditure sectors, demonstrating a comprehensive approach to their anti-
fraud efforts by tackling various stages of financial management and complying with EU standards. 

2.6.1. Enhancing Transparency in Regional Decision-Making for EU funds  

The  first  measure  introduced  by  Czech  Republic  in  2024  focuses  on  enhancing  transparency  and 
reducing corruption within regional decision-making processes related to EU funds. By adjusting these 
processes,  this  administrative  measure  aims  to  reinforce  procedural  integrity  during  the  2021-2027 
programming period, particularly through the Methodological Guideline for the Use of Integrated Tools 
and Regional Action Plans. The measure includes mandatory online publication of meeting outcomes, 
adherence to unified deadlines, and requires participants to sign an ethical code of conduct. 

This measure is important because it improves processes, increasing transparency and reducing the risk 
of corruption in decision-making on project at regional level. 

Single / 
Package 

Type 

New / 
Update 

Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Anti-Fraud Measure #1 Taken by Czech Republic in 2024  

e
l
g
n
i
S

Administrative 
Other:  Methodological 
Guideline for the Use of 
Integrated Tools and 
Regional Action Plans for 
the 2021-2027 

Update 

Prevention      

Sectoral: 
•  Expenditure – 
Fisheries 
•  Expenditure – 
Cohesion 
policy  

•  Corruption  

•  Other* 

Reason / Expected 
Result 

• To enhance 
existing 
measure 

• Cross-cutting 

measure, 
multi-agency 
measure/ 
measure with 
impact on 
various 
bodies** 

Table 34: Anti-fraud measure #1 taken by Czech Republic in 2024 

*Other: In the context of the methodological environment for EU funds, the decision-making procedures for projects at the 
regional level have been adjusted to reduce the risk of corrupt practices. The Methodological position on the Methodological 
Guideline  for  the  Use  of  Integrated  Tools  and  Regional  Action  Plans  for  the  2021-2027  programming  period  introduced 
transparency  standards  for  the  implementation  of  the  Integrated  Territorial  Investment  tool  in  metropolitan  areas  and 
agglomerations. 

**Cross-cutting  measure:  Regional  decision-making  for  EU  funds  was  revised  to  reduce  corruption  in  2021-2027. 
Transparency standards were introduced for Integrated Territorial Investment tools in metropolitan areas. Changes include 
unified  deadlines,  meeting  procedures  and  mandatory  online  publication  of  minutes,  schedules,  and  calls.  Participants  in 
steering committees must sign an ethical code and internal procedures must also be disclosed publicly. These measures aim to 
ensure consistent and transparent practices. 

Public / 
Private sector 

Public sector 

Corruption within public procurement – Czech Republic #1 

Fight against corruption in public procurement 

Comment 

•  Measures to improve the effectiveness of 

management of the public procurement 
•  Measures to prevent corruption amongst 
personnel, including management 

Table 35: Corruption within public procurement – Measure #1 taken by Czech Republic in 2024 

2.6.2. New Regulation to Improve Czech Tax System for Non-EU Entities 

This measure introduced in 2024 requires non-EU taxpayers to use a local agent for sending documents 
electronically. This rule aims to accelerate tax processes by preventing delays in international document 
delivery from countries outside of the EU, especially with countries like the People’s Republic of China. 
It ensures quick communication, enhancing Czechia's ability to manage taxes and fight VAT fraud. 

31 

 
 
 
 
  
 
This  measure  is  crucial  because  it  addresses  major  VAT  abuses  by  non-EU  taxpayers.  It  facilitates 
efficient  document  exchanges,  boosting  compliance  with  EU  customs  rules  and  improving  tax 
administration.  

Anti-Fraud Measure #2 Taken by Czech Republic in 2024  

Single / 
Package 

Type 

New / 
Amendment 

Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Reason / Expected 
Result 

e
l
g
n
i
S

Legislative 
(Law/Act) 
01/01/2025 
461/2024 Sb 

Amendment 

Prevention       Detection 

Investigation 
and 
prosecution 

Sectoral: 
•  Revenue – 
Customs 
•  Revenue –  
Tax fraud  

•  Financial crime 

(including money 
laundering) 

•  Organised crime 

•  Definition of a 
specific topic 

•  Financial 
penalties 

•  Other* 

• Other** 

Table 36: Anti-fraud measure #2 taken by Czech Republic in 2024 

*Other:  An  arrangement  for  serving  VAT-related  documents  on  persons  abroad  (i.e.  taxable  persons  who  do  not  have  a 
registered office or establishment in the EU), setting rules and financial sanctions (fines) in the event of non-compliance. 

**Other: The need to respond to the current situation in the field of imports and VAT and to resolve related complications in 
serving documents in tax proceedings on persons abroad. Dysfunctional cooperation with certain non-EU States (China, for 
example) has led to delays in properly serving documents in tax proceedings, which has allowed for prolonged tax evasion. 
The new measure will make it possible to serve documents in tax proceedings, without actually sending them to third countries. 

2.6.3. Guidelines for Enhancing Sanctions Enforcement Against Russia and Belarus: 
Czechia’s Agricultural Focus 

This third measure reported by Czech Republic in 2024 introduced internal guidelines to ensure that 
employees of the State Agricultural Intervention Fund effectively apply international sanctions against 
Russia  and  Belarus.  These  methodological  instructions  outline  the  necessary  steps  for  compliance, 
helping staff follow the sanctions accurately. By standardising procedures, this measure strengthens the 
enforcement of the international sanctions.  

Anti-Fraud Measure #3 Taken by Czech Republic in 2024  

Single / 
Package 

Type 

New / 
Update 

Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Reason / Expected 
Result 

e
l
  Organisational 
g
n
i
S

14/05/2024 

New 
measure 

Recovery 
and sanction 

Horizontal  

•  Antifraud or 

anticorruption 
strategy  

•  General 
trainings 

• Neutral on 
resources 

Table 37: Anti-fraud measure #3 taken by Czech Republic in 2024 

2.7. Denmark 

In  2024,  Denmark  implemented  two  operational  measures  based  on  a  digital  approach  with 
implementing a new it tool as well as a web reporting tool. Both address the detection stage in the anti-
fraud cycle in specific targeted sectors: cohesion policy, or fisheries.  

2.7.1. Enhancing Oversight with Automated Wage Checks  

In 2024, Denmark fully implemented an automated system within e-indkomst check if wages have been 
paid to people listed in project reports that seek reimbursement. This system swiftly identifies payment 
discrepancies, which enhances fraud prevention and strengthens the accountability of fund management. 

32 

 
 
 
 
 
 
 
 
 
 
Single / 
Package 

Type 

New / 
Update 

Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Reason / Expected 
Result 

Anti-Fraud Measure #1 Taken by Denmark in 2024  

e
l
  Operational 
g
n
01/05/2024 
i
S

New 
measure 
Update 

Detection 

Sectoral: 
•  Expenditure – 
Cohesion 
policy  

•   Other: integrity 
and transparency 
measures, anti-
fraud strategy 

•  IT tools (“IT 

checks 

• Targeting of 

data feeding”, 
“Other IT”) 

• Targeting of 

investigations 
• Enhanced ex-
post controls 

Table 38: Anti-fraud measure #1 taken by Denmark in 2024 

2.7.2. Online Reporting System For Suspected Fraud  

The second measure reported by Denmark in 2024 is the Danish Agricultural and Fisheries Agency's 
initiative to launch an online reporting system for suspected fraud. This tool simplifies and streamlines 
the  process for  individuals  to  report fraudulent  activities,  enhancing transparency  and  accountability 
within the agency. 

Single / 
Package 

Type 

New / 
Update 

Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Anti-Fraud Measure #2 Taken by Denmark in 2024  

e
l
  Operational 
g
n
01/03/2023 
i
S

Update 

Detection 

Sectoral: 
•  Expenditure – 

Fisheries  

•   Whistleblower 

•  Web reporting 

/Hotline 

Reason / Expected 
Result 

• Enhanced 

information 
flow 

• Targeting of 

investigations 

Table 39: Anti-fraud measure #2 taken by Denmark in 2024 

33 

 
 
 
 
  
 
 
 
 
2.8. Estonia 

Estonia  reported  three  key  measures  to  prevent  and  detect  fraud,  including  customs  evasion  and 
corruption. The measures include the creation of an Economic and Corruption Crime District, an IT tool 
to identify and address customs evasion schemes, and an online training program to raise awareness and 
prevent conflicts of interest and corruption in grant management.  

2.8.1. Creation Of An Economic And Corruption Crime District 

This first measure reported by Estonia is a significant modification to its Prosecutor's Office structure, 
establishing an Economic and Corruption Crime District. This measure was highlighted as the focuses 
of this new office were set to economic crimes, including the misuse of various subsidies. By focusing 
on these specific crimes, Estonia enhances its competence and resource allocation at the national level, 
effectively reinforcing its commitment to combating financial fraud and corruption.  

Single / 
Package 

Type 

New / 
Update 

Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Reason / Expected 
Result 

Anti-Fraud Measure #1 Taken by Estonia in 2024  

e
l
  Organisational 
g
n
i
S

04/03/2024 

New 
measure 

Horizontal  

Investigation 
and 
prosecution 

•  Public 

procurement  
•  Financial crime 

(including money 
laundering) 
•  Corruption  
•  Conflict of 
interest  

•  Reorganisation 
of existing 
bodies 

•  Competence 
•  Inter-agency 
cooperation 

• Neutral on 
resources 

Public / 
Private sector 

Public sector 
Private sector  

Table 40: Anti-fraud measure #1 taken by Estonia in 2024 

Corruption within public procurement – Estonia #1 

Fight against corruption in public procurement 

Comment 

•  Measures to prevent corruption amongst 
personnel, including management  

•  Measures addressing transparency of 
companies participating in public 
procurement. 

Table 41: Corruption within public procurement – Measure #1 taken by Estonia in 2024 

2.8.2. Estonia's Classification and Dumping Report: Enhancing Customs Fraud Detection  

In 2024, Estonia introduced an IT tool that helps identify and address customs evasion schemes and 
individuals.  Classification  and  dumping  report  identifies  customs  declarations  involving  risky 
commodity codes. By detecting these declarations, it ensures proper taxation, such as correcting customs 
duties,  dumping,  or  countervailing  duties.  When  importers  change  commodity  codes,  the  report 
highlights the need to correct retroactive customs declarations (factual). Additionally, it helps identify 
importers who may need to change their commodity codes based on future checks (calculated).  

This measure was highlighted because it helps identifying importers' customs declarations involving 
risky commodity codes from a large dataset. 

34 

 
 
 
 
 
 
 
 
Single / 
Package 

Type 

New / 
Update 

Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Reason / Expected 
Result 

Anti-Fraud Measure #2 Taken by Estonia in 2024  

e
l
  Operational 
g
n
01/01/2024 
i
S

New 
measure 

Prevention       Detection 

Sectoral: 
•  Revenue - 
Customs  

•   Customs / TOR / 

illicit trade 

•  IT tools (“IT 

data feeding”, 
“Other IT”) 

•  Flagging 
practice 

•  Risk indicators 

• Targeting of 

checks 

• Enhanced ex-
ante controls  
• Enhanced ex-
post controls 

2.8.3. Online Training On Conflict of Interest and Corruption   

Table 42: Anti-fraud measure #2 taken by Estonia in 2024 

The third measure reported by Estonia in 2024 is a three-part online training called "Recognizing and 
Preventing Conflicts of Interest and Corruption in the Implementation of Grants and Official Ethics". 
This comprehensive training aims to raise awareness and enhance the understanding of officials and 
employees involved in grant management, equipping them with the knowledge and tools necessary to 
recognise and prevent conflicts of interest and corruption in their daily work and at the level of grant 
recipients. The training modules focus on official ethics, conflicts of interest in public procurement, and 
private sector transactions concerning the use of grants. Estonian experts with experience in preventing 
and investigating economic crimes deliver the training, ensuring a high level of expertise. The sessions 
are recorded, allowing participants to revisit and review the content as needed, which also serves as an 
introductory training for new employees. 

This measure was reported as it was a cross-administrative training benefiting many grant administration 
employees  from  various  levels,  including  managing  authorities,  ministries,  auditing  authorities,  and 
implementing bodies, who play a direct role in coordinating, overseeing, planning, and evaluating grant-
supported projects. 

Anti-Fraud Measure #3 Taken by Estonia in 2024  

Single / 
Package 

Type 

New / 
Update 

Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Reason / Expected 
Result 

e
l
  Organisational 
g
n
i
S

10/06/2024 

Update 

Sectoral: 
•  Expenditure  – 

Cohesion 
policy 

Prevention       Detection 

for 

•  Expenditure  – 
the 

Fund 
most deprived 
•  Expenditure  – 
Recovery  and 
Resilience 
Facility 

•  Conflict of 
interest 
•  Shared 

management and 
control of EU 
funds 

•  Competence  
•  Fraud awareness 

trainings  

• Neutral on 
resources 

2.8.4. Additional measures  

Table 43: Anti-fraud measure #3 taken by Estonia in 2024 

In  2024,  Estonia  implemented  additional  measures  to  enhance  security  and  oversight  in  public 
procurement and tax risk management. This included updating a comprehensive guide on security risks 
in public procurement and training contracting authorities to better mitigate these risks. Estonia also 
improved  control  and  audit  effectiveness  by  introducing  a  smart  IT  tool  through  the  Central  e-
procurement system, ensuring secure data exchange. Moreover, the Tax and Customs Board created 
new tax risk management positions and coordinated their efforts under an Intelligence department risk 
manager to identify and mitigate tax risks efficiently.  

35 

 
 
 
 
 
  
 
 
 
Region  

Measures Implemented in 2024 

Funds or bodies involved  

•  National 

•  National 

•  National 

•  Updating of the comprehensive guide on security risks 

• 

in Public Procurement  
Training of Contracting Authorities on how to reduce 
security risks in public procurement*  

•  Measures to improve the effectiveness of control and 
audit  –  Smart  IT  tool:  The  Central  e-procurement 
system  offers  a  data  exchange  service  for  public 
procurement  and  contract  data  via  a  secure 
infrastructure  

• 

The Tax and Customs Board has: 
•  Created  tax  risk  management  positions  in  2024 

• 

(VAT, CIT, Labor Taxes, PIT, Excises) 
Planned  to  create  customs  risk  management 
positions in 2025. 
tax 

risk  managers  under  an 

•  Coordinated 

•  Contracting Authorities 

Police Board 
Internal Security Service  

• 
• 
•  National Audit Office 

• 

The  Tax  and  Customs 
Board 

Intelligence department risk manager to: 

Identify tax risks 

• 
•  Develop risk mitigation strategies 
•  Allocate resources effectively 

Table 44: Additional anti-fraud measures taken by Estonia in 2024 

*The presentation and video recording of the training is available at the Ministry of Finance website 
https://fin.ee/riigihanked-riigiabi-osalused/riigihanked/kasulik-teave#koolitused. 

2.9. Finland 

In 2024, Finland introduced two sectoral anti-fraud measures aimed at enhancing the integrity of EU 
programme implementation across fisheries, the Recovery and Resilience Facility (RRF), and cohesion 
policy.  These  administrative  measures  cover  all  stages  of  the  anti-fraud  cycle,  from  prevention  to 
recovery, reinforcing Finland's commitment to protecting EU financial interests. 

2.9.1. Sectoral Anti-Fraud Strategies For EU Programmes 

In 2024, new anti-fraud strategies were developed for the domestic application of the European RRF 
and  the  European  Maritime,  Fisheries  and  Aquaculture  Fund  (EMFAF).  These  programme-specific 
strategies  aim  to  clearly  define  the  roles  and  responsibilities  of  different  authorities  in  handling 
irregularities and fraud. Additionally, the strategies encourage the adoption of best practices and the use 
of  diverse  information  tools  by  public  authorities.  This  approach  ensures  the  timely  exchange  of 
information, as well as effective reporting and follow-up, to safeguard the Union's financial interests 
against fraud and misuse. 

Single / 
Package 

Type 

New / Update  Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Anti-Fraud Measure #1 Taken by Finland in 2024  

e
g
a
k
c
a
P

Administrative 
(Circulaire/circular, 
Instructions, Guidelines, 
Manuals) 

New 
measure 
Update 

Prevention       Detection 

Sectoral: 
•  Expenditure  – 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Fisheries 

•  Antifraud or 

•  Expenditure  – 
Recovery  and 
Resilience 
Facility 

anticorruption 
strategy 

•  Management of 

funds 

•  Monitoring / 
desk checks 
•  On the spot 

checks 

•  Irregularities 
reporting 
•  Recovery  

Reason / Expected 
Result 

• To clarify or 
consolidate 
exiting rules 
• To enhance 
existing 
measure 

Table 45: Anti-fraud measure #1 taken by Finland in 2024 

2.9.2. Anti-Fraud Training For The EU’s Regional And Structural Policy Programme 

In  2024,  as  a  second  measure,  Finland  reported  the  Ministry  of  Economic  Affairs  and  Employment 
initiative of organising an online event as a follow-up to the anti-fraud training sessions for intermediate 
bodies that had started the previous year.  The training reviewed the procedures necessary to identify 

36 

 
 
 
 
 
 
and prevent potential conflicts of interest. During the event, representatives of the intermediate bodies 
shared good practices in combatting fraud. 

This measure  was reported  as  the  training  of  representative  in the intermediate bodies  is  considered 
central in combating fraud effectively. 

Single / 
Package 

Type 

New / Update  Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Anti-Fraud Measure #2 Taken by Finland in 2024  

e
l
g
n
i
S

Administrative 
(Circulaire/circular, 
Instructions, Guidelines, 
Manuals) 

Update 

Prevention       Detection 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Sectoral: 
•  Expenditure  – 
cohesion policy  

•  Conflict of 
interest 
•  Shared 

management and 
control of EU 
funds 

•  Management of 

funds 

Reason / Expected 
Result 

• To clarify or 
consolidate 
exiting rules 
• To enhance 
existing 
measure 

Table 46: Anti-fraud measure #2 taken by Finland in 2024 

2.10. 

France  

The measure reported by France in 2024 focused on strengthening its anti-fraud mechanisms through 
an operational measure targeting the RRF. 

2.10.1. Enhanced EPPO Cooperation: France's Step Towards RRF Fraud Reporting  

In 2024, France implemented a working agreement between MICAF, DG Treasury and the EPPO in 
order to improve the reporting of fraud to the EPPO within the RRF framework.  

The aim of this agreement is to facilitate the detection of fraud involving the FRR as part of the EU's 
€750 billion recovery plan. It establishes a framework for enhanced cooperation between the European 
Public Prosecutor's Office and the French authorities responsible for managing these funds. Working 
guidelines have been drawn up by MICAF, DG Treasury and the European Public Prosecutor's Office 
to  facilitate  the  operational  implementation  of  this  agreement  and  reports  to  the  Public  Prosecutor's 
Office. 

Single / 
Package 

e
l
g
n
i
S

Anti-Fraud Measure #1 Taken by France in 2024  

Type 

New / Update  Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Reason / Expected 
Result 

Operational 
17/01/2024 

New 
measure 

Sectoral: 
•  Expenditure  – 
Recovery  and 
Resilience 
Facility  

•  Other: measure 
related to the 
RRF 

•  Structured 

cooperation 
with judicial 
authorities 

• Enhanced 

cooperation 

• Other* 

Investigation 
and 
prosecution 

Table 47: Anti-fraud measure #1 taken by France in 2024 

*Other:  This  working  arrangement  and  the  guidelines  will  serve  as  a  framework  for  enhanced  cooperation  between  the 
European Public Prosecutor's Office and the administrations in charge of managing FRR funds. The working guidelines on 
the jurisdiction of the European Public Prosecutor's Office in cases of FRR fraud will improve the quality of reports made to 
the Public Prosecutor's Office in this area. This approach is also accompanied by a range of training courses run by both 
MICAF and the European Public Prosecutor's Office. In 2024, 16 training sessions were given. 

37 

 
 
 
 
 
 
 
 
 
 
2.11. 

Germany 

In the case of Germany, being a federal State, anti-fraud measures are often taken at region level. Three 
of such measures were reported all targeting conflict of interest in the cohesion policy sector. 

2.11.1.  Enhancing  Transparency  Through  Conflicts  of  Interest  Declarations  in  Baden-
Württemberg  

The first measure introduced by  Germany  is a single measure coming from the  Baden-Württemberg 
federal  state.  Germany  introduced  a  measure  through  the  ERDF  Baden-Württemberg  Managing 
Authority that mandates the declaration of conflicts of interest as a key step in project selection, project 
management, and the awarding of public contracts. This initiative requires maintaining documentation 
that evidences impartiality and ensures transparency in decision-making processes. By formalising the 
request for declarations, whether through meeting minutes, checklists, or separate forms, this measure 
significantly focuses on the integrity of contract awards and project management. 

Anti-Fraud Measure #1 Taken by Germany in 2024  

Single / 
Package 

Type 

New / 
Update 

Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Reason / Expected 
Result 

e
l
g
n
i
S

Administrative 
Circulaire/Circular, 
Instructions, Guidelines, 
Manuals 

Update 

Prevention      

Sectoral: 
•  Expenditure – 
Cohesion 
policy  

•  Public 

procurement 
•  Corruption  
•  Conflict of 
interest 

•  Monitoring / 
desk checks 

• To enhance or 
consolidate 
existing rules 

Table 48: Anti-fraud measure #1 taken by Germany in 2024 

Public / 
Private sector 

Public sector 

Corruption within public procurement – Germany #1 

Fight against corruption in public procurement 

Comment 

•  Measures to prevent corruption amongst 
personnel, including management 

Table 49: Corruption within public procurement – Measure #1 taken by Germany in 2024 

2.11.2. Enhancing EU Fund Management: Bremen's Anti-Fraud Training initiative 

The second measure introduced by Germany is a package measure from the Bremen federal state. The 
ERDF Bremen Managing Authority has implemented an initiative designed to enhance anti-corruption 
efforts and minimise conflicts of interest through targeted staff training. This programme aims to equip 
personnel  with  essential  skills  and  knowledge  to  effectively  prevent  fraud  and  corruption  in  the 
management  of  EU  funds.  By  offering  comprehensive  information  on  fraud  prevention  and 
incorporating  these  topics  into  regular  meetings,  the  measure  seeks  to  raise  awareness  among 
employees.  

38 

 
 
 
 
  
 
 
 
Single / 
Package  

Type  

Stage in Anti-Fraud Cycle   Horizontal / Sectoral  

Area  

Scope  

New / Update 

Reason / Expected 
Result  

Anti-Fraud Measure #2 Taken by Germany in 2024  

Administrative 
(Circulaire/circular, 
Instructions, Guidelines, 
Manuals ) 

Update 

Prevention       Detection 

e
g
a
k
c
a
P

Organisational 
22/05/2024 

Update  

•  Corruption 
•  Conflict of 
interest 

•  Fraud definition 

Sectoral: 
•  Expenditure – 
Cohesion 
policy 

•  Management of 

funds 

•  Monitoring / 
desk checks 
•  Irregularities 
reporting 

• To clarify or 
consolidate 
existing rules 

• To enhance 
existing 
measure  

• General 

trainings  

• Fraud awareness 

trainings 

• Other* 

•  Neutral on 
resources 

Table 50: Anti-fraud measure #2 taken by Germany in 2024 

*Other: New guidance on preventing conflicts of interest; mandatory submission of a declaration of absence of conflicts of 
interest. In addition, participation of all staff employed in the ERDF (Managing Authority, Certifying Authority/Accounting 
Body, intermediate bodies) in training on preventing corruption. 

Public / 
Private sector 

Public sector 

Corruption within public procurement – Germany #2 

Fight against corruption in public procurement 

Comment 

•  Measures to prevent corruption amongst 
personnel, including management 

Table 51: Corruption within public procurement – Measure #2 taken by Germany in 2024 

2.11.3. Thuringia Strengthen Anti-Fraud Strategies With Risk Assessments 

The third measure introduced by Germany is a package measure from Thuringia federal state. The ERDF 
Thuringia Managing Authority has introduced a key measure aimed at strengthening anti-fraud and anti-
corruption policies. This initiative includes conducting regular fraud risk assessments across all ERDF 
activities and providing guidance from intermediate bodies to combat fraud and corruption effectively. 
By continuously evaluating risk levels, the measure ensures that high-risk operations receive heightened 
scrutiny and targeted interventions. It also targets regular awareness-raising.  

39 

 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
  
 
 
 
Anti-Fraud Measure #3 Taken by Germany in 2024  

Type  

New / Update  Stage in Anti-Fraud Cycle   Horizontal / Sectoral  

Area  

Scope  

Single / 
Package  

e
g
a
k
c
a
P

Administrative 
(Circulaire/circular, 
Instructions, Guidelines, 
Manuals) 

Update 

Operational 
01/01/2024 

Update  

Prevention       Detection 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Sectoral: 
•  Expenditure – 
Cohesion 
policy 

•  Public 

procurement 

•  Corruption 
•  Conflict of 
interest 

•  Whislteblower 
•  Shared 

management and 
control of EU 
funds 

•  Antifraud or 

anticorruption 
strategy  

Reason / Expected 
Result  

• To clarify or 
consolidate 
existing rules 

•  Management of 

funds 

•  Monitoring / 
desk checks 
•  On the spot 

checks 

•  Irregularities 
reporting 

• IT tools (“IT 

data feeding”, 
“Other IT”) 
• Web reporting / 

Hotline 

•  Enhanced 

coordination 

•  Enhanced 

information 
flow 

•  Targeting of 

checks 

Table 52: Anti-fraud measure #3 taken by Germany in 2024 

*Other: New guidance on preventing conflicts of interest; mandatory submission of a declaration of absence of conflicts of 
interest. In addition, participation of all staff employed in the ERDF (Managing Authority, Certifying Authority/Accounting 
Body, intermediate bodies) in training on preventing corruption. 

Public / 
Private sector 

Public sector 

Corruption within public procurement – Germany #3 

Fight against corruption in public procurement 

Comment 

•  Measures addressing transparency in 

public procurement 

•  Measures to prevent corruption amongst 
personnel, including management 
•  Measures to improve the effectiveness of 

control and audit 

Table 53: Corruption within public procurement – Measure #3 taken by Germany in 2024 

2.11.4. Additional measures  

Germany additionally reported a measure from the Saxony federal States, as well as a measure from the 
Federal Ministry of Finance. 

Region  

Measures Implemented in 2024 

Funds or bodies involved  

•  Conduct of ongoing fraud risk self-assessments across 
policy areas, in line with Article 74(1)(c) of Regulation 
(EU) 2021/1060 

• 

ERDF 
Saxony 
Managing 
Authority  

•  Update of the ‘Catalogue of measures to prevent and 
combat  fraud  and  corruption’ 
to  provide  clear 
instructions  and  insights  on  effective  anti-fraud 
the  self-assessment  process, 
practices,  outlining 
highlights  key 
legal 
frameworks  and  mechanisms  for  involving  third 
parties in preventing and addressing fraud 

findings,  and  details 

the 

• 

Saxony 

•  Division 
EA6, 
Federal 
Ministry  of 
Finance 

• 

Presentation  of  the  function,  work  and  role  of  the 
EPPO  in  the  Federal  Government/Länder  Working 
Group  on  financial  control  (audit  authorities  for  the 
Structural  Funds)  by  high-ranking  representatives  of 
the EPPO 

• 

/ 
Federal  Government 
Länder  Working  Group 
on financial control (audit 
authorities 
the 
for 
Structural Funds) 

Table 54: Additional anti-fraud measures taken by Germany in 2024 

2.12. 

Greece 

Greece reported three measures covering all the stages of the anti-fraud circle, demonstrating a holistic 
approach to fighting fraud. These three horizontal initiatives combine organisational, legislative, and 
administrative measures, both single and package aimed at a comprehensive and strategic approach. Key 

40 

 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
areas of focus include inter-agency cooperation, trainings, effective management of frozen assets and 
improved recovery procedures.  

2.12.1. “Prevent - Detect - Investigate II: Data-driven Protection of the EU Budget” Conference 
Organised With OLAF 

As  first  measure,  Greece  reported  their  initiative  of  organising  a  two-day  high-level  conference  in 
Athens entitled “Prevent - Detect - Investigate II: Data-driven Protection of the EU Budget” with OLAF. 
It  covered  subjects  such  as:  digitalisation  and  new  tools  for  data  analysis  focusing  on  preventing, 
detecting and investigating fraud in EU spending and the remaining shortcomings of these tools. 

This  measure  was  reported  as  it  allowed  anti-fraud  authorities  from  across  the  EU  to  gather  in  a 
conference aimed at protecting the EU budget in the face of constantly developing threats. It highlighted 
the urgency of making the most of advanced digital tools and working together to tackle increasingly 
sophisticated, cross-border fraud schemes 

Single / 
Package 

Type 

New / 
Update 

Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Reason / Expected 
Result 

Anti-Fraud Measure #1 Taken by Greece in 2024  

e
l
  Organisational 
g
n
i
S

06/11/2024 

New 
measure 

Prevention       Detection 

Horizontal  

Investigation 
and 
prosecution 

•  Public 

procurement 
•  Financial crime 

(including money 
laundering) 
•  Conflict of 
interest 

•  Fraud definition  
•  AFCOS 
•  Whislteblower 
•  Shared 

management and 
control of EU 
funds 

•  Antifraud or 

anticorruption 
strategy 

•  Inter-agency 
cooperation 

•  General 
trainings 

•  Fraud awareness 

trainings 

• Neutral on 
resources  

Table 55: Anti-fraud measure #1 taken by Greece in 2024 

2.12.2. New Legal Framework Enhances Management of Criminal Assets 

The second measure reported by Greece involves the establishment of the Integrated Information System 
(IIS) under Law No 5042/2023, designating the Financial Crime Directorate-General (DG SDOE) as 
the Management Body for assets frozen, seized, and confiscated due to criminal activities. In 2024, this 
initiative  established  an  Advisory  Committee  tasked  with  issuing  informed  opinions  on  the  sale  or 
disposal of such assets, including high-value frozen movable property. Furthermore, a Central Register 
of Frozen Assets has been created within the Management Body to improve transparency and ensure 
effective asset management. 

41 

 
 
 
 
 
 
Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Anti-Fraud Measure #2 Taken by Greece in 2024  

Stage in Anti-Fraud Cycle   Horizontal / Sectoral  

Area  

Scope  

Legislative  
(Decision) 
17/06/2024 
Ministerial Decision No 
84692 ΕΞ 2024/ 17-06-
2024 of the Ministry of the 
Economy and Finance. 

Amendment 

•  Competences 
•  Powers 

Reason / Expected 
Result  

•  To clarify or 
consolidate 
existing rules 
•  To enforce the 
rules in line 
with 
development 
in EU law 

e
g
a
k
c
a
P

Administrative 
(Decision, Resolution) 

Update 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Horizontal 

•  Financial crime 

(including money 
laundering)  
•  Organised crime 
•  Other* 

Organisational 
17/06/2024 

New 
measure 

• Other: 

Management of 
frozen, seized 
and confiscated 
criminal assets 

•  To enhance 
existing 
measure 

• Reorganising of 
existing bodies 

•  Increased 
resources 

Table 56: Anti-fraud measure #2 taken by Greece in 2024 

2.12.3. Establishment Of A New System Of Financial Corrections And Recovery Procedures 

The  third  measure  reported  by  Greece  is  the  adoption  of  Ministerial  Decision  No  196019  ΕΞ 
2024/24.12.2024, which establishes a system of financial corrections and recovery procedures for funds 
improperly or illegally disbursed from the state or EU budgets. This decision pertains to the oversight 
of programmes co-financed by the EU during the 2021-2027 Programming Period. 

This measure was highlighted as it concerns the anti-fraud cycle that focuses on the recovery of amounts 
unduly or illegally paid from EU and state budgetary resources. 

Single / 
Package 

Type 

New / 
amendment 

Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Anti-Fraud Measure #3 Taken by Greece in 2024  

e
l
g
n
i
S

Legislative 
(Law/Act) 
24/12/2024  
No 196019 ΕΞ 
2024/24.12.2024 
(Government Gazette, 
Series II, No 
7553/31.12.2024) 

New 
legislation 

Recovery 
and sanction 

Horizontal 

•  Shared 

management and 
control of EU 
funds  

•  Definition of a 
specific topic 

•  Recovery 

Table 57: Anti-fraud measure #3 taken by Greece in 2024 

2.12.4. Additional measures 
Region / Ministry  

Measures Implemented in 2024 

Funds or bodies involved  

Reason / Expected 
Result 

• To enforce the 
rules in line 
with 
developments 
in EU law 

•  NTA 
• 

Single  Public 
Procurement 
Authority  
•  Ministry  of 
Development  

•  Code of Ethics and guidance to enhance integrity for 
professionals working in public procurement units of 
public  bodies,  as  well  as  on  training  for  official 
working in public sector procurement  

• 

Public procurement units 
of public bodies 
•  Officials  working 

in 
sector 

public 
procurement 

Table 58: Additional anti-fraud measure taken by Greece in 2024 

42 

 
 
 
 
 
  
 
 
 
 
 
 
 
 
  
 
 
 
 
  
2.13. 

Hungary  

In 2024, Hungary launched a comprehensive strategy1 to protect EU financial interests by tackling fraud 
and improving transparency. The first measure increased the checks in public procurement to encourage 
fair competition and reduce single-bid scenarios. The second measure involved changes to the Criminal 
Procedure  Act, making it easier  to  address  online  fraud  and  recover assets from  cross-border  crime. 
Lastly, the National Anti-Corruption Strategy for 2024–2025 brings in international recommendations 
and identifies new areas for intervention, strengthening efforts to fight corruption across various sectors. 
These measures put a focus on Hungary's engagement for integrity and accountability. 

2.13.1. Increasing The Transparency Of Public Procurement 

The first measure reported by Hungary is a package measure implemented to enhance the control activity 
of contract notices in public procurement conducted by the Public Procurement Authority. With a focus 
on increasing the transparency of public procurements, the Authority has intensified its control regarding 
the  examination  of  the  contracting  authorities'  obligation  to  provide  reasons  in  connection  with  lot 
division of the tenders/contracts, as well as the illicit application of specific product markings, over-
specified suitability requirements, and evaluation criteria. Additionally, in order to reduce the number 
of  single-bid  public  procurements,  the  Authority monitors the  proper  conduct  of  preliminary market 
consultations  in  cases  where  their  application  is  mandatory.  The  Authority  has  issued  presidential 
briefings on the aspects of the two types of audits. 

This measure was reported as the Public Procurement Authority’s control activities play a key role in 
increasing  the  transparency  of  public  procurements:  scrutiny  on  notices,  on  the  performance  and 
amendment of public procurement contracts, and on negotiated procedures without prior publication, all 
contribute to the transparent use of public money, including EU funds. 

Single / 
Package  

Type  

New / Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / Sectoral  

Area  

Scope  

Reason / Expected 
Result  

Anti-Fraud Measure #1 Taken by Hungary in 2024  

Legislative  
(Decree) 
15/07/2024 
Section 9(6) of Decree No 
44/2015 of 2 November 
2015 of the Minster 
heading the Prime 
Minister’s Office 

Amendment 

e
g
a
k
c
a
P

Operational 
(presidential briefings) 
22/02/2024 and 07/10/2024 

New 
measure 
Update  

Prevention       Detection 

Horizontal  

•  Public 

procurement 

•  Corruption 
•  Antifraud or 

anticorruption 
strategy  

•   Competences 
•  Powers 

• Intensified and 

increased 
number of 
controls 
• Other* 

• Other: to 

reduce single-
bid 
procurements 
and enhance 
competition 

•  Enhanced 

information 
flow 

•  Targeting of 

investigations 
•  Enhanced ex-
ante controls 

Table 59: Anti-fraud measure #1 taken by Hungary in 2024 

1 The strategy is formally new, but not without precedent, as it was created through a review of the 2022 
strategy, as its continuation and further development. 

43 

 
 
 
 
  
 
 
 
 
 
 
 
 
 
  
 
 
 
*Other: The Public Procurement  Authority  issued a presidential briefing on  22  February  2024  on  the  strengthening of  its 
notice  control  activity  and  on  the  examination  criteria.  The  authority  is  required  to  submit  on  a  quarterly  basis  to  the 
Monitoring Committee – which operates within the Ministry of the Interior and is responsible for monitoring implementation 
of  the  National  Anti-Corruption  Strategy  (adopted  under  Government  Decision  No  1025/2024  of  14  February  2024)  – 
information on the number of calls for competition (contract notices) where it enforces the monitoring criteria specified in the 
NACS and listed in the briefing issued by the president of the authority. A presidential briefing was also published on 7 October 
2024 on the most important information and aspects of scrutiny related to the monitoring of preliminary market consultations.  

Public / 
Private sector 

Public sector 
Private sector 

Corruption within public procurement – Hungary #1 

Fight against corruption in public procurement 

Comment 

•  Measures addressing transparency in 

public procurement 

•  Measures to improve the effectiveness of 
management of the public procurement  
•  Measures to prevent corruption amongst 
personnel, including management 
•  Measures addressing transparency of 
companies participating in public 
procurement 

•  Measures to improve the effectiveness of 

control and audit 

Table 60: Corruption within public procurement – Measure #1 taken by Hungary in 2024 

2.13.2. Strengthening the Fight Against Online Fraud 

The second measure reported by Hungary in 2024 involves the introduction of new provisions under 
Act LXIV of 2024, amending the Criminal Procedure Act to enhance effectiveness in combating online 
fraud. The key amendments include Section 262/A and Section 317/A, which will become effective in 
2025. Section 262/A facilitates streamlined data requests, aiding both domestic law enforcement and the 
protection of EU financial interests, especially against fraud linked to international crime. Section 317/A 
introduces  obligations  to  preserve  and  potentially  seize  book  or  electronic  money,  supporting  the 
recovery of assets from cross-border criminal activities. 

This measure was highlighted as it strengthens the protection of EU financial interests by enabling more 
efficient domestic law enforcement operations and improving asset recovery strategies against cross-
border fraud. 

Anti-Fraud Measure #2 Taken by Hungary in 2024  

Single / 
Package  

Type  

New / Update/ 
Amendment 

Stage in Anti-Fraud Cycle   Horizontal / Sectoral  

Area  

Scope  

Reason / Expected 
Result  

e
g
a
k
c
a
P

Legislative  
(Law/Act) 
01/03/2025 
Act LXIV of 2024 amending 
acts required to ensure further 
effective action against online 
fraud and amending other acts – 
Section 262/A of the Criminal 
Procedure Act enters into force 
on 1 March 2025, Section 
317/A on 1 July 2025. 

Amendment 

Detection 

Horizontal 

Recovery 
and sanction 

Investigation 
and 
prosecution 

•  Financial crime 

(including money 
laundering) 

•  Organised crime  
•  Other: Online 

fraud 

•  Competences 
•  Powers 
•  Other* 

• To clarify or 
consolidate 
existing rules  

• Other** 

Table 61: Anti-fraud measure #2 taken by Hungary in 2024 

*Other: Act LXIV of 2024 marks a significant advance in the fight against online fraud and financial crime by providing faster 
and more effective access to payment and communication data. The act has introduced an obligation to preserve book money 
and electronic money, increasing the effectiveness of asset recovery. The measure makes it possible for the first time to freeze 
funds even if they are not yet available on the bank account or other payment account, providing coverage for later seizures. 

**Other: Section 262/A of the Criminal Procedure Act: The previous legislation required separate prosecutor authorisation 
for  each  data  request,  which  slowed  down  investigations.  The  new  act  allows  the  prosecutor’s  office  to  issue  a  general 
authorisation for specific types of case, preserving data protection safeguards and introducing additional safeguards in this 
area. Section 317/A of the Criminal Procedure Act: Act LXIV of 2024 has introduced an obligation to preserve book money 

44 

 
 
 
 
 
 
  
 
 
and electronic money, increasing the effectiveness of asset recovery. The new legislation seeks to prevent criminal assets from 
being concealed or laundered. 

2.13.3. Hungary’s 2024–2025 Anti-Corruption Strategy 

The  third measure  reported  by  Hungary  in  2024  is  the  adoption  of the medium-term  National  Anti-
Corruption  Strategy  for  2024–2025,  along  with  its  action  plan,  through  Government  Decision  No 
1025/2024 on  14  February  2024.  This initiative  aims  to  build  upon the  progress made  over  the  past 
decade by integrating recommendations from international organisations and national stakeholders. The 
strategy  also  aligns  with  commitments  under  the  conditionality  procedure  and  the  Recovery  and 
Resilience Plan, while incorporating consensus proposals from the Anti-Corruption Task Force. It seeks 
to identify new areas for intervention that were not addressed in previous strategies. 

This measure was highlighted because it plays a crucial role in safeguarding EU financial interests and 
enhancing the fight against fraud. By maintaining past achievements and incorporating a broad spectrum 
of expert recommendations, the strategy ensures a comprehensive approach to tackling corruption. 

Single / 
Package  

e
g
a
k
c
a
P

Anti-Fraud Measure #3 Taken by Hungary in 2024  

Type  

New / Update  Stage in Anti-Fraud Cycle   Horizontal / Sectoral  

Area  

Scope  

Administrative  
(Decision, Resolution) 

New measure 

Prevention       Detection 

Horizontal  

•  Public 

procurement 
•  Corruption  
•  Antifraud or 

anticorruption 
strategy  

•  Other* 

Reason / Expected 
Result  

• Cross-cutting 

measure, 
multi-agency 
measure / 
measure with 
impact on 
various 
bodies** 

Table 62: Anti-fraud measure #3 taken by Hungary in 2024 

*Other: The National Anti-Corruption Strategy sets anti-corruption objectives in seven areas of intervention: transparency, 
legislative integrity, judicial integrity, pubic-sector integrity, public-procurement transparency, social integrity, and combating 
foreign bribery. In almost all areas, there is a balance between the creation of legislation or other methodological guidelines 
and recommendations aimed at reducing corruption risks on the one hand, and raising awareness among pubic-sector workers, 
the public and the business community through different means and ways, on the other. 

** Cross-cutting measure: The Hungarian Government adopted the medium-term National Anti-Corruption Strategy for the 
2024–2025 period and the action plan implementing the strategy in February 2024 by Government Decision No 1025/2024 of 
14 February 2024. 

Public / 
Private sector 

Public sector 

Corruption within public procurement – Hungary #3 

Fight against corruption in public procurement 

Comment 

•  Measures to improve the effectiveness of 
management of the public procurement  
•  Measures to prevent corruption amongst 
personnel, including management 
•  Measures to improve the effectiveness of 

control and audit 

• 

The tasks set out in point 5 of 
Government Decision No 1025/2024 of 
14 February 2024 seek to address 
fairness in public procurement and 
competition. 

Table 63: Corruption within public procurement – Measure #3 taken by Hungary in 2024 

2.14. 

Ireland  

In 2024, Ireland reported that there were no new measures introduced in relation to the protection of EU 
funds.  

2.15. 

Italy 

The  three  measures  reported  by  Italy  target  the  entire  anti-fraud  cycle,  enhancing  institutional 
coordination, expanding strategic mandates, and implementing operational strategies. By restructuring 
key  offices  and  fostering  international  cooperation,  these  initiatives  comprehensively  address  fraud 
prevention,  detection,  and  enforcement.  By  reorganising  the  Office  of  the  Prosecutor  General  and 
expanding the mandate of COLAF, Italy has strengthened its ability to coordinate with both national 
and international bodies to protect EU financial interests. Additionally, new legislative and operational 

45 

 
 
 
  
 
 
 
 
 
 
strategies  were  introduced  to  combat  tax  fraud,  specifically  targeting  VAT  fraud  through  enhanced 
international cooperation and the use of advanced IT tools.  

2.15.1. Establishment of the Committee For Combating Fraud Against The EU 

The first measure reported by Italy involves an internal reorganisation of the Office of the Prosecutor 
General at the Court of Auditors to enhance its capacity in combating fraud against the EU budget. A 
dedicated section for the Committee for Combating Fraud against the European Union (COLAF) has 
been  established  within  the  International  Affairs  Unit,  which  also  includes  the  OLAF  section.  This 
reorganisation aims to improve coordination, ensuring that the Office can effectively collaborate with 
both national and supranational bodies dedicated to protecting EU financial interests. 

Anti-Fraud Measure #1 Taken by Italy in 2024  

Single / 
Package 

Type 

New / 
Update 

Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Reason / Expected 
Result 

e
l
  Organisational 
g
n
i
S

31/01/2025 

New 
measure 

Prevention       Detection 

Recovery 
and sanction 

Horizontal  

•  Public 

procurement 

•  Conflict of 
interest 

•  Fraud definition  
•  AFCOS 
•  Shared 

management and 
control of EU 
funds 

•  Reorganisation 
of existing 
bodies  
•  General 
trainings 

•  Other* 

• Neutral on 
resources  

Table 64: Anti-fraud measure #1 taken by Italy in 2024 

*Other:  By  means  of  a  specific  organisational  directive,  the  Prosecutor  General  at  the  Court  of  Auditors  assigned  three 
prosecutors/judges to the Unit for international affairs and interinstitutional relations in the fight against the unlawful use of 
EU funds. By means of a subsequent organisational decision, five officials and two inspectors from the Guardia di Finanza 
were assigned to the Unit, with seven specific areas of focus being identified (1. Monitoring the OLAF agreement; 2. Monitoring 
the EPPO agreement; 3. COLAF; 4. IMS (Irregularity Management System); 5. JuriSAI (the Organisation of Supreme Audit 
Institutions  with  Jurisdictional  Functions);  6.  Jean  Monnet  STEPPO  module;  7.  Fighting  corruption  in  the  public 
administration). 

2.15.2. Broadening the AFCOS Mandate 

The second measure reported by Italy in 2024 involves the implementation of Article 3 of Decree-Law 
No 19 of 2 March 2024, which was converted into law with amendments by Law No 56 of 29 April 
2024. This legislative change broadened the scope and expanded the membership of COLAF (the Italian 
AFCOS) to address requirements related to the implementation of the National Recovery and Resilience 
Plan (NRRP).  

This measure is crucial as it strengthens the overarching strategy of activities to prevent and combat 
fraud and other offences affecting NRRP funding, the cohesion policy for the 2021-2027 programming 
period and national funds linked with those funds. 

Single / 
Package  

Type  

New / 
Amendment 

Anti-Fraud Measure #2 Taken by Italy in 2024  

Stage in Anti-Fraud Cycle  

Horizontal / Sectoral  

Area  

Scope  

Reason / Expected 
Result  

e
l
g
n
i
S

Legislative  
(Law/Act) 
02/03/2024 
Decree-Law No 19 of 2 March 
2024, converted into law, with 
amendments, by Law No 56 of 
29 April 2024. 

New 
legislation 

Prevention       Detection 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Horizontal  

•  Public 

procurement 
•  Financial crime 

(including money 
laundering) 

•  Organised crime 
•  Conflict of 
interest 

•  Fraud definition 
•  AFCOS 
•  Shared 

management and 
control of EU 
funds  

•  Antifraud or 

anticorruption 
strategy  

•  Competences 
•  Powers 
•  Criminal 
sanctions 
(more)* 
•  Other** 

• To clarify or 
consolidate 
existing rules  
• To enforce the 
rules in line 
with 
developments 
in EU law 

46 

 
 
 
 
 
 
 
* Criminal sanctions (more): indicates that sanctions have been increased.  

Table 65: Anti-fraud measure #2 taken by Italy in 2024 

**Other: Article 3(9) of Decree-Law No 19/2024 amends Article 512-bis of the Criminal Code with regard to the fraudulent 
transfer of assets to make it more applicable to public contracts. In order to tighten up measures to protect against 
infiltration by organised crime, including in areas related to the NRRP, paragraph 10 amends the Code of Anti-Mafia Laws 
to add a number of income tax- and VAT-related offences to the list of offences that could trigger the issuing of an anti-mafia 
information notice barring access to certain activities. 

2.15.3. Enhanced Collaboration To Fight Against Cross-Border VAT Fraud 

The third measure reported by Italy is a comprehensive package combining legislative and operational 
initiatives to combat tax fraud, focusing particularly on VAT fraud and the protection of EU funds. The 
"FRODI IVA" (VAT fraud) operational plan, led by the Guardia di Finanza, addresses tax fraud both 
nationally  and  cross-border,  enhancing  international  cooperation  through  the  EMPACT  initiative. 
Meanwhile,  the  Carabinieri  Agri-Food  Protection  Unit  has  strengthened  its  capacity  by  adding 
personnel, expanding offices across Italy, and improving collaboration with key entities, such as the 
EPPO, the Agricultural Payments Agency (AGEA), and the Institute for Agri-Food Market Services 
(ISMEA). Additionally, the initiative includes developing IT tools to better identify unlawful activities. 
Furthermore, legislative amendments under Article 4 of Legislative Decree No 13/2024 are set to tighten 
regulations  against  VAT  fraud  and  evasion  by  non-residents,  ensuring  heightened  precautionary 
measures.  

Single / 
Package  

Type  

New / Update/ 
Amendment 

Stage in Anti-Fraud Cycle   Horizontal / Sectoral  

Area  

Scope  

Reason / Expected 
Result  

Anti-Fraud Measure #3 Taken by Italy in 2024  

Legislative  
(Law/Act) 
12/02/2024 
Decreto Legislativo n. 13 
del 12/02/2024, art. 4 

Amendment 

e
g
a
k
c
a
P

Operational 
12/02/2024 

New 
measure 
Update  

Prevention       Detection 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Sectoral: 
•  Revenue – Tax 
fraud 
•  Expenditure – 
Agriculture  

•  Financial crime 

(including money 
laundering) 

•  Organised crime 
•  Shared 

management and 
control of EU 
funds 

•  Antifraud or 

anticorruption 
strategy 

•  Definition of a 
specific topic 

•  Financial 
penalties 

• To clarify or 
consolidate 
existing rules 

•  Enhanced 

• IT tools (“IT data 
feeding”, “Other 
IT”) 

coordination 

•  Enhanced 

cooperation  

• Risk indicators  
• Increased 
number of 
checks 
• Structured 

cooperation with 
law enforcement 

• Structured 

cooperation with 
judicial 
authorities  

•  Enhanced 

information 
flow 

•  Targeting of 

checks 

•  Targeting of 

investigations 
•  Enhanced ex-
ante controls 
•  Enhanced ex-

post  

Table 66: Anti-fraud measure #3 taken by Italy in 2024 

*Other: The Public Procurement Authority issued a presidential notice on 22 February 2024 on the strengthening of audit 
activities 

47 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
2.15.4. Additional measures  

Italy additionally reported 3 legislative measures taken at national level.  

Region  

Measures Implemented in 2024 

Funds or bodies involved  

•  National   

• 

Law  No  90/2024  on  cybersecurity  and  cybercrime, 
enhancing  penalties  and 
introducing  aggravated 
circumstances for cyber offenses 

•  National Anti-Mafia, and 

Anti-Terrorism 
Prosecutor 

•  National 

•  National 

• 

Law  No  112/2024:  Establishes 
the  offense  of 
'Improper Allocation of Money or Movable Property' 
for  public  officials  or  those  in  public  service  who 
misuse money or property they control, deviating from 
legal purposes to gain financially or cause harm. 
•  Aggravating  Circumstances:  Offenses  that  harm  the 
EU’s  financial  interests  or involve  financial  gains  or 
harm  exceeding  EUR  100,000  are  subject  to  stricter 
penalties 

•  Ministerial  Decree  of  15  March  2024  establishing  a 
national register for wiretap records in cases involving 
the EPPO 

Table 67: Additional anti-fraud measures taken by Italy in 2024 

2.16. 

Latvia 

Latvia reported two key measures to prevent and detect fraud in public procurement and to enhance 
transparency and accountability in EU fund management. These measures aim to strengthen Latvia's 
regulatory framework and enhance cooperation between anti-fraud authorities. 

2.16.1. Improvements to the National Regulatory Framework for Public Procurement 

The first measure adopted by Latvia was the implementation of improvements to the national regulatory 
framework governing public procurement processes by the Rural Support Service and the Ministry of 
Agriculture. 

These  amendments,  made  to  Cabinet  Regulations  No.  113,  aim  to  enhance  transparency  and 
accountability in public procurement. Specifically, the changes include reducing the required number of 
offers  in  procurements,  introducing  liability  for  all  beneficiaries,  implementing  liability  for  false 
declaration, and requiring applicants to declare that they do not perform construction work themselves.  

This measure was highlighted as an initiative contributing to a more transparent, accountable, and fair 
public procurement process, by reducing the risk of coordinated offers and more precisely identifying 
conflicts  of  interest  in  construction  projects,  thereby  protecting  the  EU's  financial  interests  and 
preventing fraud. 

48 

 
 
 
 
 
Single / 
Package 

Type 

New / 
Amendment 

Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Reason / Expected 
Result 

Anti-Fraud Measure #1 Taken by Latvia in 2024  

e
g
a
k
c
a
P

Legislative 
(Decree) 
16/07/2024 
Cabinet Regulations No. 
113 

Amendment 

Prevention      

Sectoral: 
•  Expenditure – 
Agriculture  
•  Expenditure – 

Fisheries   

•  Shared 

management and 
control of EU 
funds 

•  Other:  

Conditions for 
receiving 
support, 
obligations of 
the support 
applicant 

• To remedy 

flaws  

2.16.2. AFCOS Job Shadowing 

Table 68: Anti-fraud measure #1 taken by Latvia in 2024 

As a second anti-fraud measure, Latvia reported the initiative called “AFCOS job shadowing” allowing 
employees from the AFCOS network institutions to visit, observe daily work and build relationships 
with colleagues from other institutions. The goal was set to introduce employees to the functions of 
various AFCOS network institutions in order to facilitate understanding of responsibilities of different 
institutions and improve cooperation between them. 

This measure was crucial as it was very successful and allowed participants to better understand the 
importance  of  each  anti-fraud  cycle  steps  and  to  understand  how  the  cooperation  between  different 
authorities can be improved. 

Anti-Fraud Measure #2 Taken by Latvia in 2024  

Single / 
Package 

Type 

New / 
Update 

Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Reason / Expected 
Result 

e
l
  Organisational 
g
n
i
S

26/06/2024 

New 
measure 

Prevention      

Horizontal 

•  AFCOS 

•  Other: job 
shadowing  

• Neutral on 
resources 

Table 69: Anti-fraud measure #2 taken by Latvia in 2024 

2.17. 

Lithuania  

Lithuania  reported  three  single measures  covering the  whole  anti-fraud  cycle. The  measures include 
trainings on transparency and the fight against corruption and fraud, a new sanction framework to secure 
EU agricultural and fisheries funds, and a competitive procurement enhancement plan to promote greater 
competition in procurement and encourage participation by small and medium-sized enterprises.  

2.17.1. Transparency And Fight Against Corruption And Fraud Trainings  

The first measure adopted by Lithuania involves the organisation by the Managing Authority of trainings 
aiming to strengthen the competences of the institutions managing the European Union Structural Funds 
in the area of transparency and the fight against corruption and fraud and the evaluation of its training 
needs.  

This measure was highlighted as capacity building is crucial in order to protect EU financial interests 
and improve measures of fight against fraud. 

49 

 
 
 
 
 
 
 
 
 
 
Single / 
Package 

Type 

New / 
Update 

Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Reason / Expected 
Result 

Anti-Fraud Measure #1 Taken by Lithuania in 2024  

e
l
  Organisational 
g
n
i
S

01/01/2024 

Prevention       Detection 

Update 

Horizontal  

•  Corruption 
•  Conflict of 
interest 

•  Competence 
•  General 
trainings 

•  Fraud awareness 

trainings 

• Neutral on 
resources  

Public / 
Private sector 

Public sector 

Table 70: Anti-fraud measure #1 taken by Lithuania in 2024 

Corruption within public procurement – Lithuania #1 

Fight against corruption in public procurement 

Comment 

•  Measures addressing transparency in 

public procurement 

•  Measures to improve the effectiveness of 

control and audit 

Table 71: Corruption within public procurement – Measure #1 taken by Lithuania in 2024 

2.17.2. New Sanction Framework to Secure EU Agricultural and Fisheries Funds 

The second measure adopted by Lithuania involves the issuance of orders by the Minister of Agriculture 
to  establish  methodologies  for  applying  sanctions  for  infringements  related  to  agricultural  and  rural 
development  projects.  These  orders  target  compliance  within  the  Strategic  Plan  of  Agricultural  and 
Rural Development 2023-2027, as well as management rules for the European Agricultural and Fisheries 
Funds. 

This measure was highlighted as it underscores the importance of strict compliance with legal provisions 
to protect EU financial interests. 

Single / 
Package  

Type  

New / 
Amendment 

Anti-Fraud Measure #2 Taken by Lithuania in 2024  

Stage in Anti-Fraud Cycle  

Horizontal / Sectoral  

Area  

Scope  

Reason / Expected 
Result  

e
l
g
n
i
S

Legislative  
(Regional law/ decree/ 
order) 
16/09/2024 
Order of the Minister of 
Agriculture of the Republic of 
Lithuania No 3D-80 of 5 
February 2010* 

New 
legislation 
Amendment 

Prevention       Detection 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Sectoral: 
•  Expenditure – 
Agriculture  
•  Expenditure - 
Fisheries 

•  Other: carrying 

out 
investigations 
into 
irregularities 
(relating to 
projects 
administered by 
the EU), 
preventing 
irregularities 
and fraud 

•  Definition of a 
specific topic 

•  Recovery 
•  Other: 

conducting 
investigations 
into 
infringements  

• To enforce the 
rules in line 
with 
developments 
in EU law 

• Other** 

Table 72: Anti-fraud measure #2 taken by Lithuania in 2024 

*Order of the Minister of Agriculture of the Republic of Lithuania No 3D-80 of 5 February 2010 "On the Approval of the Rules 
for  the  Administration  of  Infringements  of  Legal  Provisions  in  Connection  with  the  Implementation  of  Measures  of  the 
European Agricultural Guarantee Fund, the European Agricultural Fund for Rural Development and the European Fisheries 
Fund “ 

**Other:  Conducting  investigations  into  irregularities,  protecting  the  financial  interests  of  the  EU  and  the  Republic  of 
Lithuania 

50 

 
 
 
 
 
 
 
 
 
  
 
2.17.3. Competitive Procurement Enhancement Plan 

In  2024, the  Public  Procurement  Office  in  Lithuania approved the  2024–2026  Supplier  Engagement 
Action  Plan  and  outlined  measures  for  its  implementation.  This  measure  aims  at  promoting  greater 
competition  in  procurement  and  encouraging  participation  by  small  and  medium-sized  enterprises 
(SMEs) in public procurement processes. This plan is crucial for the protection of EU financial interests 
and  the  fight  against  fraud,  as  it  seeks  to  increase  transparency  and  awareness  in  the  procurement 
process, identify opportunities for digitisation of the procurement process. By achieving the goals set by 
this  plan,  this  initiative  targets  promoting  competition,  reducing  the  risk  of  fraud,  and  ensuring  that 
public procurement processes are fair, transparent, and effective. 

Anti-Fraud Measure #3 Taken by Lithuania in 2024  

Single / 
Package 

Type 

New / 
Update 

Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Reason / Expected 
Result 

e
l
  Organisational 
g
n
i
S

26/06/2024 

New 
measure 

Prevention      

Sectoral: 
•  Expenditure – 
Fund for the 
most deprived 

•  Competence 
•  General 
trainings 

•  Public 

•  Fraud awareness 

procurement  

trainings 

• Neutral on 
resources  

•  Simplification of 

procedures 

•  Other* 

Table 73: Anti-fraud measure #3 taken by Lithuania in 2024 

*Other: To increase transparency and awareness regarding the execution of purchases and the situation in the procurement 
field; to identify the opportunities for the digitisation of the procurement process and to create effective tools for the digitisation 
of the procurement process. 

2.18. 

Luxembourg  

In 2024, Luxembourg reported one operational measure focused on the RRF. 

2.18.1. Control And Monitoring System For The National Implementation Of The Recovery 
And Resilience Facility 

This  first  measure  reported  by  Luxembourg  focuses  on  the  control  and  monitoring  system  for  the 
national  implementation  of  the  Recovery  and  Resilience  Facility.  It  is  crucial  as  Member  States  are 
responsible for the successful implementation of their national Recovery and Resilience Plan. 

Single / 
Package  

e
g
a
k
c
a
P

Anti-Fraud Measure #1 Taken by Luxembourg 2024  

Type  

New / Update  Stage in Anti-Fraud Cycle   Horizontal / Sectoral  

Area  

Scope  

Prevention       Detection 

Operational 
29/11/2024 

Update 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Sectoral: 
•  Expenditure – 
Recovery and 
Resilience 
Facility  

•  Shared 

management and 
control of EU 
funds 

• IT tools ("IT 

data feeding", 
"Other IT") 

• Web reporting / 

Hotline 
• Flagging 
practice 

• Risk indicators 
• Increased 
number of 
checks 
• Structured 

cooperation with 
judicial 
authorities 

Reason / Expected 
Result  

•  Enhanced 

coordination 

•  Enhanced 

cooperation  

•  Enhanced 

information 
flow 

•  Targeting of 

checks 

•  Enhanced ex-
ante controls 
• Enhanced ex-
post controls 

Table 74: Anti-fraud measure #1 taken by Luxembourg in 2024 

2.19. 

Malta  

In 2024 Malta reported two key measures, one aimed at facilitating exchanges of information and the 
other one updating the national risk assessment on fraud and corruption. 

51 

 
 
 
 
 
 
 
 
2.19.1. Creation Of A Central Document Repository System (CDRS) 

The first measure reported by Malta involves the establishment of the CDRS as part of the nation’s 
institutional capacity to fight corruption. Aligned with the National Anti-Fraud and Corruption Strategy 
and  Malta's  Recovery  and  Resilience  Plan,  the  CDRS  enhances  coordination  and  facilitation  of  the 
exchange of information, among and between entities tasked with the protection and safeguarding of 
public funds. This secure digital platform not only stores and centralises access to crucial documents but 
also  facilitates  real-time  communication  and  information  sharing  among  Co-ordinating  Committee 
members. The CDRS was reported as an essential measure in Malta's anti-fraud and corruption efforts 
because  it  facilitates  real-time  communication  among  the  Co-ordinating  Committee  members.  The 
system  ensures  prompt  distribution  of  information,  direct  access  for  appropriate  authorities,  and 
enhances  awareness  of  each  authority’s  initiatives  against  fraud  and  corruption.  This  efficient 
communication and centralised information access help in the early identification of red flags, bolstering 
efforts to protect EU financial interests. 

Single / 
Package 

e
l
g
n
i
S

Anti-Fraud Measure #1 Taken by Malta in 2024  

Type 

New / Update  Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Administrative 
(Action plan) 

New 
measure 

Prevention       Detection 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Horizontal  

•  Other: Generic 
information 
sharing, and 
bilateral 
communications 
related to fraud 
and corruption, as 
well as joint 
initiatives 

•  Other* 

Reason / Expected 
Result 

•  Other: To 

assist in the 
co-ordination 
of the nation-
wide effort in 
the fight 
against fraud 
and corruption 

Table 75: Anti-fraud measure #1 taken by Malta in 2024 

* Other: The CDRS brings together in a digital environment all the members of the Co-ordinating Committee, entrusted with 
coordinating the activities related to the fight against fraud and corruption. The CDRS provides a platform for sharing of 
documents and information in three sub-sites, namely; - Generic Sub-site, accessible to all the members of the Co-ordinating 
Committee; - Bilateral Communications Sub-site, where the exchange of information is between only two members;  - Joint 
Initiatives Sub-site, where more than two members are involved. 

2.19.2. Update Of The National Risk Assessment On Fraud And Corruption 

Malta  has  introduced  a  second  significant  administrative  measure  with  its  Internal  Audit  and 
Investigations  Department  (IAID)  updating  the  National  Risk  Assessment  (NRA)  on  Fraud  and 
Corruption  for  2024.  This  update  involves  re-evaluating  risk  registers,  incorporating  new  risks,  and 
eliminating obsolete ones, thereby enhancing existing control measures.  

This measure was reported for its focus on reassessing exposure, strengthening controls, and raising 
national  awareness  of  fraud  and  corruption  risks,  ensuring  an  effective,  risk-based  approach  to 
combating financial fraud. 

Single / 
Package 

e
l
g
n
i
S

Anti-Fraud Measure #2 Taken by Malta in 2024  

Type 

New / Update  Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Reason / Expected 
Result 

Administrative 
(Action plan) 

Update 

Prevention       Detection 

Horizontal  

•  Other: Fraud and 
Corruption risk 
assessment and 
risk management 

•  Other* 

•  Other** 

Table 76: Anti-fraud measure #2 taken by Malta in 2024 

52 

 
 
 
 
 
 
 
* Other: Risk Assessment is an essential element of the Risk Management cycle. It essentially involves the identification of 
threats and vulnerabilities of an organisation, classified as both internal and external risks. The Risk Register and the resultant 
Risk  Assessment,  besides  categorising  and  ranking  risks,  establishes  existing  controls  and  any  other  additional  mitigating 
actions to reduce the risks. The NRA amalgamates the individual Risk Registers/Assessments composed by each member of the 
Coordinating Committee into one high level NRA. 

**Other: To strengthen and co-ordinate the fight against fraud and corruption and also to implement Action Point 3 of the 
National Ant-Fraud and Corruption Strategy (NAFCS), which is an ongoing Action Point since the NRA shall be reviewed and 
updated on a biennial basis. 

2.20. 

Netherlands  

The Netherlands reported three key measures addressing prevention, detection and investigations. Two 
organisational  measures  put  a  strong  focus  on  cooperation,  at  national  and  international  level.  The 
measures include the designation of a coordinator within the Anti-Fraud Coordination Service (AFCOS) 
to oversee EU funds, network meetings among national partners to exchange best practices and learn 
from each other's experiences, and a new measure focusing on conducting risk analyses for new national 
subsidy regulations related to the European Maritime, Fisheries and Aquaculture Fund (EMFAF). 

2.20.1. Coordination Of Antifraud EU Funds As Part Of AFCOS 

The  Netherlands  designated  a  coordinator  within  the  Anti-Fraud  Coordination  Service  (AFCOS)  to 
oversee EU funds. With various departments handling these funds, the coordinator's role is crucial in 
prioritising  anti-fraud  efforts  on  the  agenda  and  enhancing  communication  with  the  European  Anti-
Fraud Office (OLAF). This measure aims to streamline processes, ensuring more efficient collaboration 
and stronger fraud prevention measures across all departments involved. 

Single / 
Package 

Type 

New / 
Update 

Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Reason / Expected 
Result 

Anti-Fraud Measure #1 Taken by the Netherlands in 2024  

e
g
a
  Organisational 
k
c
a
P

01/09/2024 

New 
measure 

Prevention       Detection 

Investigation 
and 
prosecution 

Horizontal  

•  AFCOS 
•  Antifraud or 

anticorruption 
strategy 

•  Reorganisation 
of existing 
bodies  

•  Inter-agency 
cooperation 

• Increased 
resources  

Table 77: Anti-fraud measure #1 taken by Netherlands in 2024 

2.20.2. Network Meeting With National EU Fund Partners 
As second measure, the Netherlands introduced network meetings among national partners responsible 
for executing EU funds. This initiative fosters collaboration, allowing different partners to exchange 
best practices and learn from each other's experiences. It is planned to hold these meetings twice a year. 

Anti-Fraud Measure #2 Taken by the Netherlands in 2024  

Single / 
Package 

Type 

New / 
Update 

Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Reason / Expected 
Result 

e
g
a
  Organisational 
k
c
a
P

07/05/2024 

New 
measure 

Prevention       Detection 

Investigation 
and 
prosecution 

Horizontal  

•  AFCOS 
•  Antifraud or 

anticorruption 
strategy 

•  Inter-agency 
cooperation 

• Increased 
resources  

Table 78: Anti-fraud measure #2 taken by Netherlands in 2024 

53 

 
 
 
 
 
 
 
2.20.3. EMFAF Subsidy Risk Evaluation 

The Netherlands implemented a new measure focusing on conducting risk analyses for new national 
subsidy regulations related to the European Maritime, Fisheries and Aquaculture Fund (EMFAF). This 
includes  a  new  test assessing  the  controllability and enforceability  of  these  subsidies.  This  initiative 
aligns with Article 74 of the Common Provisions Regulation (CPR 2021/1060), which mandates such 
measures for effective management and oversight by the responsible authorities.  

Single / 
Package 

e
l
g
n
i
S

Type 

New / Update  Stage in Anti-Fraud Cycle 

Area 

Scope 

Anti-Fraud Measure #3 Taken by the Netherlands in 2024  

Horizontal / Sectoral 

Reason / Expected 
Result 

Prevention      

Operational 
01/01/2024 

Update 

Sectoral: 
•  Expenditure  – 

Fisheries 

•  Shared 

management and 
control of EU 
funds 

•  Risk indicators 

• Targeting of 

checks 

• Enhanced ex-
ante controls 

Table 79: Anti-fraud measure #3 taken by Netherlands in 2024 

2.21. 

Poland  

Poland  reported  three  measures  including  competitive  procurement  enhancement  plan  to  ensure 
impartiality and transparency in the processing of aid applications, an anti-fraud policy in agriculture 
and rural development to tackle fraud, corruption, and conflicts of interest within the framework of the 
Recovery and Resilience Plan, and the implementation of the SAMPLER tool to support the verification 
of conflicts of interest by identifying personal and capital links. 

2.21.1. Competitive Procurement Enhancement Plan 

In 2024, Poland's Paying Agency introduced a 'rotation' mechanism to enhance the processing of aid 
applications. This system ensures applications are not processed by agency units in the same area as the 
applicant's  residence  or  registered  office.  The  measure  aims  to  boost  impartiality  and  transparency, 
addressing conflict of interest prevention and resolution from the application checking stage.  

Anti-Fraud Measure #1 Taken by Poland in 2024  

Single / 
Package 

Type 

New / 
Update 

Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Reason / Expected 
Result 

e
l
  Organisational 
g
n
i
S

08/02/2023 

New 
measure 

Prevention      

Sectoral: 
•  Expenditure – 
Agriculture 

•  Conflict of 
interest 
•  Shared 

management and 
control of EU 
funds   

•  Simplification of 

procedures 

• Neutral on 
resources  

Table 80: Anti-fraud measure #1 taken by Poland in 2024 

2.21.2. Anti-Fraud Policy in Agriculture and Rural Development under the RRP 

The second measure reported by Poland involves The Ministry of Agriculture and Rural Development’s 
establishment  of  a  policy  to  lay  down  rules  and  actions  to  tackle  fraud,  corruption,  and  conflicts  of 
interest within the framework of the Recovery and Resilience Plan (RRP). The policy outlines specific 
rules and procedures aimed at managing fraud risks.  

54 

 
 
 
 
 
 
 
 
 
 
 
Single / 
Package 

Type 

New / Update  Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Anti-Fraud Measure #2 Taken by Poland in 2024  

e
l
g
n
i
S

Administrative 
(Circulaire/circular, 
Instructions, Guidelines, 
Manuals) 

New 
measure 

Prevention       Detection 

Recovery 
and sanction 

Sectoral: 
•  Expenditure – 
Recovery and 
Resilience 
Facility  

•  Conflict of 
interest 
•  Shared 

management and 
control of EU 
funds 

•  Management of 

funds 
•  Other* 

Reason / Expected 
Result 

•  To clarify or 
consolidate 
existing rules 

•  To enhance 
existing 
measure  

Table 81: Anti-fraud measure #2 taken by Poland in 2024 

* Other: Combating fraud, corruption and conflict of interest in connection with those RRP investments or parts of investments, 
the implementation of which was not entrusted to the supporting bodies.  

2.21.3. SAMPLER Tool for Conflict of Interests Verification 

The third measure reported by Poland focused on the implementation of the SAMPLER tool designed 
to support the verification of conflicts of interest by identifying personal and capital links in various 
programmes. Utilising data from the National Court Register and Central Register of Beneficial Owners 
via the SKANER application, SAMPLER checks connections up to the third level between two sets of 
identifiers, such as NIP (Tax ID) and PESEL (Personal ID) numbers. While currently focused on project 
selection  for  co-financing,  its  comprehensive  design  ensures  broad  applicability  and  significant 
development potential for use in other areas.  

Poland reported this measure because the SAMPLER tool significantly strengthens the protection of the 
EU's financial interests by improving the verification of connections between entities and individuals. 
It  enhances  the  ability  to  detect  and  address  conflicts  of  interest,  increasing  the  effectiveness  of 
identifying irregularities. By efficiently analysing personal and capital links, the tool is a crucial asset 
in the fight against fraud. 

Single / 
Package 

e
l
g
n
i
S

Type 

New / Update  Stage in Anti-Fraud Cycle 

Area 

Scope 

Anti-Fraud Measure #3 Taken by Poland in 2024  

Horizontal / Sectoral 

Operational 
10/07/2024 

New 
measure 

Prevention       Detection

Recovery 
and sanction 

Investigation 
and 
prosecution 

Sectoral: 
•  Expenditure  – 

Cohesion 
policy 

•  Conflict of 
interest 
•  Shared 

management and 
control of EU 
funds 

•  IT tools ‘”IT 

data feeding”, 
“Other IT”) 
•  Risk indicators 

Reason / Expected 
Result 

• Enhanced 

coordination 

• Enhanced 

information 
flow 

• Targeting of 

checks 

Table 82: Anti-fraud measure #3 taken by Poland in 2024 

2.22. 

Portugal  

In 2024, Portugal reported three measures including the comprehensive monitoring and evaluation of 
the National Anti-Fraud Strategy (NAFS) through a seminar on fraud risk assessment for EU Funds, the 
development of a fraud-flagging system and risk indicators for cohesion policy funds to enhance the 
suitability  and  reliability  of  debt  information  systems,  and  the  implementation  of  an  enhanced  risk 
management system for customs under Union Customs Code provisions to align with new data models 
and risk management procedures. 

2.22.1. Monitoring and Evaluating the National Anti-Fraud Strategy (NAFS) 

The first measure reported by Portugal was led by the Inspectorate-General for Finance (IGF) and the 
Anti-Fraud Coordination Service (AFCOS). It focuses on the comprehensive monitoring, evaluation, 

55 

 
 
 
 
 
 
 
 
 
and dissemination of the National Anti-Fraud Strategy (NAFS). A key component is a seminar on fraud 
risk assessment for EU Funds, involving national authorities, the European Commission, and OLAF. 
This seminar is part of a broader training program under the IGF project 'Prevention and Combating of 
Fraud and Corruption involving EU Funds – 2024.' The initiative was highlighted because it aims to 
enhance  the  training  of  managing  authorities  and  intermediary  bodies,  strengthening  their  role  in 
implementing  the  NAFS.  Portugal's  approach  to  NAFS  implementation  and  monitoring  has  been 
recognised as a best practice and shared with other EU Member States at OLAF events.  

Single / 
Package 

Type 

New / Update  Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Reason / Expected 
Result 

Anti-Fraud Measure #1 Taken by Portugal in 2024  

e
l
g
n
i
S

Operational 
01/01/2024 

New 
measure 

Prevention       Detection

Sectoral: 
•  Expenditure  – 
Agriculture 
•  Expenditure  – 

Fisheries  

•  Expenditure  – 

Cohesion 
policy 

•  Expenditure  – 
Centralised 
direct 
management 
•  Expenditure  – 
the 

Fund 
most deprived 
•  Expenditure  – 
Globalisation 
Fund 

for 

•  Conflict of 
interest 

•  Fraud definition  
•  AFCOS 
•  Shared 

management and 
control of EU 
funds 

•  Antifraud or 

anticorruption 
strategy 

•  IT tools ‘”IT 

data feeding”, 
“Other IT”) 
•  Risk indicators 

• Enhanced 

coordination 

• Enhanced 

cooperation 

• Enhanced 

information 
flow 

• Targeting of 

checks 

•  Expenditure  – 
Migration  and 
asylum 

•  Expenditure  – 
Recovery  and 
Resilience 
Facility 

Table 83: Anti-fraud measure #1 taken by Portugal in 2024 

2.22.2. Fraud-Flagging System and Risk Indicators for Cohesion Policy Funds 

The second measure reported by Portugal involves the development of a fraud-flagging system and risk 
indicators  specifically  for  cohesion  policy  funds.  It  aims  to  enhance  the  suitability,  reliability,  and 
integration  of  debt information  systems and  ensure  close  cooperation among  entities responsible  for 
fraud prevention, detection, and investigation. A key aspect is the automation of data transmission to 
ARACHNE within the Portugal 2030 programs. 

Single / 
Package 

e
g
a
k
c
a
P

Anti-Fraud Measure #2 Taken by Portugal in 2024  

Type 

New / Update  Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Operational 
01/01/2024 

Update 

Prevention       Detection

Sectoral:  
•  Expenditure  – 

Cohesion 
policy 

•  Conflict of 
interest 
•  Shared 

management and 
control of EU 
funds 

•  Antifraud or 

anticorruption 
strategy 

•  IT tools ‘”IT 

data feeding”, 
“Other IT”) 

•  Flagging 
practice 

•  Risk indicators 
•  Structured 

cooperation 
with judicial 
authorities  

Reason / Expected 
Result 

• Enhanced 

cooperation 

• Enhanced 

information 
flow 

• Targeting of 

checks 

• Enhanced ex-
ante controls 

Table 84: Anti-fraud measure #2 taken by Portugal in 2024 

2.22.3. Enhanced Risk Management System For Customs Under UCC Provisions 

The third measure reported by Portugal focuses on the development of an enhanced risk management 
system  for  customs,  following  the  implementation  of  Union  Customs  Code  (UCC)  provisions.  This 
system is designed to align with new data models and risk management procedures. Developed by the 

56 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Customs Anti-Fraud Services, in partnership with the IT department, it improves interoperability with 
control management and national customs information systems. This initiative enhances the quality of 
customs data and risk information, allowing for better monitoring, evaluation, and revision of risk rules, 
thereby strengthening the protection of EU financial interests. 

Single / 
Package 

e
l
g
n
i
S

Anti-Fraud Measure #3 Taken by Portugal in 2024  

Type 

New / Update  Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Operational 
01/01/2024 

Update 

Prevention       Detection

Sectoral:  

•  Revenue 
Customs  

– 

•  Financial crime 

(including money 
laundering) 

•  Organised crime 
•  Customs / TOR / 

illicit trade  

•  IT tools ‘”IT 

data feeding”, 
“Other IT”) 
•  Risk indicators 
•  Increased 
number of 
checks 
•  Structured 

cooperation 
with law 
enforcement   

Reason / Expected 
Result 

• Enhanced 

coordination 

• Enhanced 

cooperation 
• Targeting of 

checks 

• Enhanced ex-
ante controls 

Table 85: Anti-fraud measure #3 taken by Portugal in 2024 

2.22.4. Additional measures  

Portugal additionally reported one legislative measure taken at national level.  

Region  

Measures Implemented in 2024 

Funds or bodies involved  

•  National 

• 

Legal act to provide OLAF with access to the financial 
transactions  register,  in  line  with  Article  7(3a)  of 
Regulation  (EU)  No  883/2013,  currently  in  the  final 
legislative stage 

Table 86: Additional anti-fraud measure taken by Portugal in 2024 

2.23. 

Romania  

Romania reported three measures including a new legislative measure to align national laws with the 
Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, 
the establishment of a national system for monitoring the road transport of goods (RO e-Transport) to 
detect  high-risk  consignments  and  combat  tax  evasion,  and  an  increase  in  staff  at  the  National 
Anticorruption Directorate to enhance its capacity and effectiveness in handling investigative activities 
and legal proceedings. 

2.23.1. Implementation Of Anti-Bribery Measures For Foreign Public Officials In 
International Business  

In 2024, Romania introduced a new legislative measure to align national laws with the Convention on 
Combating Bribery of Foreign Public Officials in International Business Transactions, adopted in Paris 
on 21 November 1997. This measure criminalises corruption offenses involving foreign public officials 
in international business dealings and designates the National Anticorruption Directorate (DNA) as the 
responsible  public  prosecutor’s  office.  It  also  establishes  central  authorities  tasked  with  handling 
requests for legal assistance related to these offenses.  

This measure is crucial as it outlines penalties for individuals and entities involved in such bribery and 
includes preventative seizure measures, aiming to enhance the protection of EU financial interests and 
strengthen international anti-corruption efforts.  

57 

 
 
 
 
 
 
 
 
Single / 
Package 

Type 

New / 
amendment 

Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Reason / Expected 
Result 

Anti-Fraud Measure #1 Taken by Romania in 2024  

e
l
g
n
i
S

Legislative 
(Law/Act) 
20/12/2024 
391 

New 
legislation 

Horizontal 

•  Corruption 

Recovery 
and sanction 

Investigation 
and 
prosecution 

•  Competences 
•  Definition of a 
specific topic 

•  Criminal 
sanctions 
(new)* 

• Other** 

Table 87: Anti-fraud measure #1 taken by Romania in 2024 

* Criminal sanctions (new): indicates that no sanctions were foreseen before 
**Other: Law No 319/2024 aligns national legislation with the provisions of the Convention on Combating Bribery of Foreign 
Public Officials in International Business Transactions. 

Public / 
Private sector 

Public sector 
Private sector 

Corruption within public procurement – Romania #1 

Fight against corruption in public procurement 

Comment 

• 

Other measures preventing corruption in 
public procurement: the regulation of a 
new corruption offence in relation to 
foreign public officials when conducting 
international business transactions, as 
well as the applicable criminal penalties. 

Table 88: Corruption within public procurement – Measure #1 taken by Romania in 2024 

2.23.2. Establishment of RO e-Transport System for Monitoring Goods Transport 

The second reported by Romania focuses on the establishment of the national system for monitoring the 
road  transport  of  goods  (‘RO  e-Transport’).    This  national  initiative  aimed  at  monitoring  the  road 
transport of goods within the EU, mainly in the form of physical checks upon entering Romania. As of 
July 2024, this system requires advance declarations for high tax risk goods and intra-EU supply and 
acquisition. The monitoring includes mandatory checks enforced by cameras and physical inspections 
based on risk assessments, with fines for non-compliance.  

This measure is crucial for detecting high-risk consignments and therefore combatting tax evasion.  

Single / 
Package  

Type  

New / Update/ 
Amendment 

Anti-Fraud Measure #2 Taken by Romania in 2024  

Stage in Anti-Fraud Cycle  

Horizontal / Sectoral  

Area  

Scope  

Reason / Expected 
Result  

Legislative  
(Law/Act) 
11/11/2024* 

New 
legislation 

e
g
a
k
c
a
P

Organisational 
11/11/2024 

Update 

Prevention       Detection 

Sectoral: 
•  Revenue – Tax 
fraud 

•  Financial crime 

(including money 
laundering) 

Operational 
12/02/2024 

Update  

•  Competences 
•  Other 

administrative 
penalties 

• To clarify or 
consolidate 
existing rules 

•  Competence 

• Neutral on 
resources 

• IT tools (“IT data 
feeding”, “Other 
IT”) 

•  Targeting of 

• Web reporting / 

checks  

Hotline 

• Risk indicators  

Table 89: Anti-fraud measure #2 taken by Romania in 2024 

* Emergency Order No 129/2024 amending and supplementing Emergency Order No 41/2022 establishing a national system 
for  monitoring  the  road  transport  of  goods  (‘RO  e-Transport’  System);  Emergency  Order  No  87/2024  amending  certain 
legislative acts in the field of e-Transport, e-VAT and regulating certain tax and budgetary measures; Order of the President 
of the National Agency for Fiscal Administration (ANAF) and the President of the Romanian Customs Authority (AVR) No 

58 

 
 
 
 
 
 
 
 
 
 
 
 
 
  
1.337/1.268/2024 approving the procedure for the use and operation of the national system RO e-Transport to monitor the 
transport of goods. 

2.23.3. Increasing Staff Of The National Anticorruption Directorate  

In 2024 the Romanian National Anticorruption Directorate has increased its maximum number of posts 
to enhance its capacity and effectiveness in handling investigative activities and legal proceedings. This 
expansion  aims  to  strengthen  the  Directorate’s  resources  to  improve  cooperation  with  the  European 
Public Prosecutor's Office (EPPO). 

Single / 
Package 

Type 

New / 
Update 

Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Reason / Expected 
Result 

Anti-Fraud Measure #3 Taken by Romania in 2024  

Sectoral: 
•  Expenditure  – 

Agriculture 

•  Expenditure  – 

Fisheries  

•  Expenditure  – 
Cohesion policy 
•  Expenditure  – 

e
l
  Organisational 
g
n
i
S

22/11/2024 

Update 

Investigation 
and 
prosecution 

Centralised 
direct 
management 
•  Expenditure  – 
the 

Fund 
most deprived 
•  Expenditure  – 
Globalisation 
Fund 

for 

•  Shared 

management and 
control of EU 
funds   

•  Other: the 

strengthening of 
the support 
systems for 
European 
Delegated 
Prosecutors in 
Romania 

• Increased 
resources  

•  Expenditure  – 
Migration  and 
asylum 

•  Expenditure  – 
and 

Recovery 
Resilience 
Facility 

Table 90: Anti-fraud measure #3 taken by Romania in 2024 

2.24. 

Slovakia  

Slovakia reported three measures including guidance on irregularities and financial corrections for the 
2021-2027  programming  period  to  clarify  rules  and  procedures,  the  establishment  of  fraud  risk 
management  working  groups  to  prevent  fraud,  corruption,  and  conflicts  of  interest,  and  the 
implementation  of  a  preventive  control  mechanism  for  sensitive  positions  in  EU-funded  public 
procurements to ensure transparency and accountability. 

2.24.1. Guidance on Irregularities and Financial Corrections for 2021-2027 
The first measure reported by Slovakia involves the issuance of new guidance by the Paying Authority 
on handling irregularities and financial corrections for the 2021-2027 programming period, specifically 
targeting  Cohesion  Policy  and  Fisheries.  This  guidance  provides  comprehensive  instructions  for 
managing information and financial flows associated with irregularities, both at the national level and 
in relation to the EU budget.  

59 

 
 
 
 
 
 
Single / 
Package 

Type 

New / Update  Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Reason / Expected 
Result 

Anti-Fraud Measure #1 Taken by Slovakia in 2024  

e
g
a
k
c
a
P

Administrative 
(Circulaire/circular, 
Instructions, Guidelines, 
Manuals) 

New 
measure 

Detection 

Recovery 
and sanction 

Sectoral: 
•  Expenditure – 
Fisheries 
•  Expenditure – 
Cohesion 
policy  

•  Fraud definition 
•  Shared 

management and 
control of EU 
funds 

•  Irregularities 
reporting 
•  Recovery 

•  To clarify or 
consolidate 
existing rules 

•  Other: irregularity 

reporting 

Table 91: Anti-fraud measure #1 taken by Slovakia in 2024 

2.24.2. Establishment of Fraud Risk Management Working Groups 
As  a  second  reported  measure,  Slovakia  established  dedicated  working  groups  for  fraud  risk 
management across several key programs, including Programme Slovakia, Interreg Slovakia – Czech 
Republic, Interreg Slovakia – Austria, and the Recovery and Resilience Plan (RRF). These groups were 
formed on specific dates in 2024 prior to the full implementation of the associated projects. Their focus 
is  on  preventing  fraud,  corruption,  and  conflicts  of  interest,  in  line  with  the  obligations  outlined  in 
Articles 74 and 22 of Regulations 2021/1060 and 2021/241, respectively. 

These  working  groups  are  a  crucial  measure  for  protecting  EU  financial  interests  by  pre-emptively 
addressing fraud risks. By establishing these groups before project implementation, Slovakia ensures 
effective  prevention,  detection,  and  correction  of  fraudulent  activities,  enhancing  accountability  and 
compliance with EU regulations. 

Single / 
Package 

e
l
g
n
i
S

Type 

New / Update 

Horizontal / Sectoral 

Area 

Scope 

Anti-Fraud Measure #2 Taken by Slovakia in 2024  

Stage in Anti-Fraud Cycle 

Operational 
13/05/2024 

New 
measure 

Prevention       Detection

Sectoral:  
•  Expenditure  – 

Cohesion 
policy 

•  Expenditure  – 
Recovery  and 
Resilience 
Facility 

•  Public 

procurement  
•  Financial crime 

(including money 
laundering) 

•  Organised crime 
•  Corruption  
•  Conflict of 
interest 

•  Antifraud or 

anticorruption 
strategy 
•  Other* 

•  Risk indicators 

Reason / Expected 
Result 

• Enhanced 

coordination 

• Enhanced 

cooperation 

• Enhanced 

information 
flow 
• Other** 

Table 92: Anti-fraud measure #2 taken by Slovakia in 2024 

*Other: Working groups ensure fraud risk analysis at individual implementation levels, therefore they can identify risk on any 
level and from any area related to implementation of projects. 
**Other:  Activities  of the  working  groups  are  expected  to  contribute  to  the prevention  of  fraud,  to  ensure  the adoption  of 
adequate and effective measures to eliminate fraud risks, or measures to minimise the impact of fraud risks. 

60 

 
 
 
 
 
 
 
 
 
 
 
Public / 
Private sector 

Corruption within public procurement –Slovakia #2 

Fight against corruption in public procurement 

Comment 

•  Measures addressing transparency in 

public procurement 

•  Measures to improve the effectiveness of 

management of the public procurement 
•  Measures to prevent corruption amongst 

Public sector 
Private sector 

personnel, including 
Management 

•  Measures addressing transparency of 

companies participating in 
public procurement 

•  Measures to improve the effectiveness of 

control and audit 

• 

Even if the measure is not directly 
aimed at the field of public 
procurement, working groups ensure 
fraud risk analysis at individual 
implementation levels, therefore they 
can identify risk on any level and from 
any area related to implementation of 
projects, including public procurement. 

Table 93: Corruption within public procurement – Measure #2 taken by Slovakia in 2024 

2.24.3. Preventive Control Mechanism for Sensitive Positions in EU Funded Procurements 
As a third measure, Slovakia reported the implementation of a preventive control mechanism targeting 
sensitive positions within the Intermediate Body for Programme Slovakia, specifically focusing on EU 
funded public procurements. The Public Procurement Office has established an independent expert team 
under its Analysis and Reporting Unit to identify and address potential conflicts of interest. This team 
checks  whether  staff  controlling  procurement  contracts  have  any  conflicts  of  interest  with  involved 
parties. Conflict of interest monitoring occurs on a semi-annual basis or as needed, with 10% of unit 
staff and 10% of controlled items undergoing verification. Identified conflicts are resolved in accordance 
with relevant legislation. This mechanism is part of the Audit Trail obligations outlined in the Manual 
of Procedures, ensuring adherence to corruption prevention and transparency in public procurement. 

Anti-Fraud Measure #3 Taken by Slovakia in 2024  

Single / 
Package 

Type 

New / 
Update 

Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Reason / Expected 
Result 

e
l
  Organisational 
g
n
i
S

17/10/2024 

New 
measure 

Prevention       Detection 

Sectoral: 
•  Expenditure – 
Cohesion 
policy 

•  Public 

procurement 
•  Corruption  
•  Conflict of 
interest 

•  Fraud definition  
•  Shared 

management and 
control of EU 
funds 

•  Antifraud or 

anticorruption 
strategy   

•  Competence 

• Neutral on 
resources  

Public / 
Private sector 

Public sector 

Table 94: Anti-fraud measure #3 taken by Slovakia in 2024 

Corruption within public procurement –Slovakia #3 

Fight against corruption in public procurement 

Comment 

•  Measures addressing transparency in 

public procurement 

•  Measures to prevent corruption amongst 

personnel, including 
Management 

•  Measures to improve the effectiveness of 

control and audit 

Table 95: Corruption within public procurement – Measure #3 taken by Slovakia in 2024 

61 

 
 
 
 
 
 
 
 
 
2.25. 

Slovenia  

In 2024, Slovenia reported three measures including support for new participation in quality schemes 
under the CAP Strategic Plan 2023-2027 to enhance market integrity and product standards, an advanced 
tool and contract updates against fraud to detect irregularities and protect the EU financial interests, and 
a strategic plan for inter-institutional cooperation against economic crime and corruption. 

2.25.1. Support for New Participation in Quality Schemes under the CAP Strategic Plan 2023-
2027 

In  2024,  Slovenia's  Agency  for  Agricultural  Markets  and  Rural  Development  launched  Intervention 
IRP11  under  the  CAP  Strategic  Plan  for  2023-2027.  This  initiative  supports  potential  investors  by 
covering costs to join eligible quality schemes, which encourages wider participation. The goal is to 
increase  the  range  of  products  offered  under  quality  schemes  by  incorporating  new  holdings  and 
products  into  these  frameworks,  enhancing  market  integrity  and  product  standards  while  supporting 
rural development. This measure aligns with the prevention phase of the anti-fraud cycle by establishing 
clear  guidelines  and  support  mechanisms  that  decrease  the  risk  of  financial  misuse  and  promote 
compliance with quality standards. A newly integrated eligibility checklist includes questions to detect 
fraud  and  fabricated  conditions.  Examples  of  control  checks  for  detecting  potential  fraud  include 
discrepancies in document formatting and inconsistent stamp and signature placements. These checks 
aim to identify attempted fraud, thus strengthening the management and control of EU funds. 

Single / 
Package  

e
l
g
n
i
S

Anti-Fraud Measure #1 Taken by Slovenia in 2024  

Type  

New / Update  Stage in Anti-Fraud Cycle   Horizontal / Sectoral  

Area  

Scope  

Reason / Expected 
Result  

Administrative  
(Other*) 

New measure 

Detection 

Sectoral: 
•  Expenditure – 
Agriculture 

•  Fraud definition  
•  Shared 

management and 
control of EU 
funds  

•  Eligibility 
criteria 

•  Management of 

funds 

• To enhance 
existing 
measure 

Table 96: Anti-fraud measure #1 taken by Slovenia in 2024 

*Other: The eligibility checklist now includes questions on the detection of fraud and artificially created conditions. These are 
some examples of control statements aimed at detecting attempted fraud:  
- 
document; the text or other content in a document is oddly indented in places; 
- 
of several persons have similarities, etc. 

the stamp and signature are in the same spot across several documents issued by the same instance; the signatures 

The documents do not feature the requisite logos or contain manual corrections; the sharpness varies across the 

2.25.2. Slovenia's Advanced Tools and Contract Updates Against Fraud 

As  a  second  measure,  Slovenia  reported  that  the  Ministry  of  Cohesion  and  Regional  Development 
(MKRR)  update  co-financing  contracts  by  including  provisions  that  require  identification  of  actual 
owners and detail actions to be taken when suspected fraud is detected. As part of this measure as well, 
the Financial Administration of Slovenia (FURS) has introduced a new application within the Qlik Sense 
analytic platform. This tool cross-references data between import records and VAT returns, utilising 
sources  updated  daily.  This  mechanism  identifies  discrepancies  indicative  of  irregularities  or  VAT 
evasion. Combined with data from EUROFISC and Slovenia's own VAT risk system, FURS creates a 
comprehensive view of risk patterns.  

This  measure  was  highlighted  as  it  protects  the  EU  financial  interests  by  immediately  suspending 
payments on suspicious activities until cleared. Also, it allows keeping a record of the actual owners and 
connections between all those involved in an operation in order to prevent price distortion and ensure 
that any expenditure under an operation is subject to market forces, therefore guaranteeing the rational 
use of EU funds. 

62 

 
 
 
  
 
 
 
 
 
  
 
 
 
Anti-Fraud Measure #2 Taken by Slovenia in 2024  

Type  

New / Update  Stage in Anti-Fraud Cycle   Horizontal / Sectoral  

Area  

Scope  

Single / 
Package  

e
g
a
k
c
a
P

Administrative 
(Circulaire/circular, 
Instructions, Guidelines, 
Manuals) 

New 
measure 

Operational 
09/09/2024 

New 
measure 
Update  

Prevention       Detection 

Sectoral: 
•  Revenue – Tax 
fraud 

Investigation 
and 
prosecution 

•  Conflict of 
interest 

•  Fraud definition 
•  Shared 

management and 
control of EU 
funds 
•  Other* 

•  Monitoring / 
desk checks 
•  On the spot 
checks  

•  Irregularities 
reporting 

• IT tools (“IT data 
feeding”, “Other 
IT”) 

• Risk indicators  
• Increased 
number of 
checks 
• Other*** 

Reason / Expected 
Result  

• To clarify or 
consolidate 
existing rules 

• To enhance 
existing 
measure 
• Other¨** 

•  Enhanced 

coordination 

•  Enhanced 

cooperation  

•  Enhanced 

information 
flow 

•  Targeting of 

checks 

•  Enhanced ex-
ante controls 
•  Enhanced ex-

post  

Table 97: Anti-fraud measure #2 taken by Slovenia in 2024 

*Other: Ad. FURS: With this application we can better implement risk management, targeting suspicion patterns, 
transactions and economic operators. 
**Other:   Ad. FURS: Enhance Fraud Management, reporting and better knowledge about possible irregularities. With 
predictive analyses we can better manage Mutual Assistance requests, audits, post audit controls and optimal usage of 
human resources.      
***Other: Re MKRR: Inclusion in the co-financing contract of a clause on the mandatory monitoring of actual owners and 
one stipulating in more detail how to respond to suspected fraud. Re FURS: Training for advance developers, advance 
analysts and other end users and also preparation of sources of information and re-writing the program codes (script). 
Creation of new objects for results visualisation and reports are also needed. Date:02.02.2024 

2.25.3. Strengthening Inter-Institutional Cooperation In The Area Of Economic Crime, 
Corruption And Protection Of The EU’s  

The  third  measure  reported  by  Slovenia  focused  on  adopting  a  strategic  plan  for  inter-institutional 
cooperation against economic crime and corruption. On February 22, 2024, the Slovenian Government 
approved, and on April 26, 2024, the National Assembly enacted, the “2024–2028 National Programme 
for  the  Prevention  and  Combating  of  Crime”.  This  initiative  designates  the  Ministry  of  the  Interior 
(Police)  as  the  lead  for  Exercise  7.4.4.1,  aimed  at  combating  economic  crime  and  corruption. 
Simultaneously, the Ministry of the Interior (European Funds Service) focuses on preventing fraud and 
enhancing the skills of personnel involved in fund management. By providing education and training, 
the program seeks to increase awareness and enhance the detection of offenses. The goal is to foster 
ethical  behaviour,  reduce  risks,  and  elevate  the  number  of  reported  offenses  compared  to  previous 
periods, thereby ensuring robust protection against financial irregularities and fraud. 

63 

 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
Single / 
Package 

Type 

New / 
Update 

Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Reason / Expected 
Result 

Anti-Fraud Measure #3 Taken by Slovenia in 2024  

e
l
  Organisational 
g
n
i
S

26/04/2024 

New 
measure 
Update 

Prevention       Detection 

Sectoral: 
•  Expenditure – 
Migration and 
asylum 
•  Expenditure – 
Recovery and 
Resilience 
Facility 

•  Public 

procurement 

•  Conflict of 
interest  
•  Shared 

management and 
control of EU 
funds 

•  Reorganisation 
of existing 
bodies 

•  Competence 
•  Inter-agency 
cooperation 

•  General 
trainings 

•  Antifraud or 

•  Fraud awareness 

anticorruption 
strategy   

trainings 

•  Other* 

• Neutral on 
resources  

Table 98: Anti-fraud measure #3 taken by Slovenia in 2024 

*Other:  Police:  setting-up  of  contact  points  with  the  competent  bodies  involved  in  safeguarding  the  financial  interests  of 
Slovenia  and  the  EU.  Participating  bodies:  Supreme  State  Prosecutor’s  Office,  European  Public  Prosecutor's  Office, 
Commission  for  the  Prevention  of  Corruption,  Ministry  of  Justice,  Ministry  of  the  Interior,  Ministry  of  Finance,  Budget 
Supervision Office, Recovery and Resilience Office, Financial Administration of Slovenia, Court of Audit, Ministry of Natural 
Resources and Spatial Planning, Ministry of Infrastructure, Ministry of the Economy, Tourism and Sport, Ministry of Cohesion 
and Regional Development, Government Office for Post-Flood and Landslide Reconstruction. Re European Funds Service: 
Incorporation of fraud red flags by updating the checklists and increased focus on detecting conflicts of interest and risks in 
public procurement procedures and contract implementation (date of measure: 15 April 2024). 

2.26. 

Spain  

Spain reported three measures in 2024, aiming to enhance tax compliance, protect whistleblowers, and 
leverage artificial intelligence in e-commerce fraud detection. The measures include strengthening tax 
compliance  and  combating  VAT  fraud,  establishing  an  independent  authority  for  the  protection  of 
whistleblowers, and using artificial intelligence to detect e-commerce fraud. 

2.26.1. Strengthening Tax Compliance and Combating VAT Fraud 

The  first  measure  reported  by  Spain  was  adopted  to  ensure  fair  taxation  and  enhance  fiscal 
accountability. This legislation introduces a Supplementary Tax for multinational and large domestic 
groups, a Tax on certain financial institutions, and a Tax on liquids for electronic cigarettes and other 
tobacco-related  products.  Furthermore,  it  includes  amendments  to  various  tax  regulations,  notably 
refining the Value Added Tax (VAT) system to fight fraud. 

A  significant  focus  is  the  VAT  fraud  prevalent  in  the  hydrocarbons  sector,  particularly  involving 
‘missing traders’. These entities are set up to extract hydrocarbons, levy VAT without remittance, and 
disappear  before  they  can  be  detected  by  the  Tax  Agency.  To  combat  this,  the  regulation  mandates 
certain VAT taxable persons to provide guarantees or pre-pay the VAT amounts for non-exempt supplies 
following the extraction of hydrocarbons from tax warehouses. It also introduces a monthly settlement 
period for operators of fuel tax warehouses covered under the mineral oils tax, as well as applicable 
businesspeople and professionals. 

64 

 
 
 
 
 
 
 
 
 
 
Single / 
Package  

Type  

New / 
Amendment 

Stage in Anti-Fraud Cycle   Horizontal / Sectoral  

Area  

Scope  

Anti-Fraud Measure #1 Taken by Spain in 2024  

e
l
g
n
i
S

Legislative  
(Law/Act) 
20/12/2024 
Law 7/2024 

New 
legislation 
Amendment 

Prevention       Detection 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Sectoral: 
•  Revenue – Tax 
fraud 

•  Organised crime 
•  Fraud definition 

•  Competence 
•  Powers 
•  Definition of a 
specific topic 

•  Recovery 
•  Financial 
penalties 

•  Other 

administrative 
penalties  

Reason / Expected 
Result  

• To clarify or 
consolidate 
existing rules 

• To remedy 

flaws 

• To enforce the 
rules in line 
with 
developments 
in EU law 

Table 99: Anti-fraud measure #1 taken by Spain in 2024 

2.26.2. Establishment of the Independent Authority for the Protection of Whistleblowers 

Spain introduced its second measure with the enactment of Royal Decree 1101/2024 on 29 October, 
which  approves the  Statute  of  the  Independent  Authority  for the  Protection of Whistleblowers.  This 
decree establishes the organisational framework, operational functions, and essential aspects needed for 
the Authority to effectively execute its responsibilities. The establishment of this independent authority 
is  provided  for  in  Law  2/2023  of  20  February  on  the  protection  of  persons  who  report  regulatory 
violations and the fight against corruption. The purpose of this Independent Authority for the Protection 
of the Informant is to guarantee the protection of the informant, to serve as an institutional pillar in the 
prevention  and  fight  against  fraud  and  corruption,  and  in  guaranteeing  the  integrity  of  the 
administrations and personnel in the service of the public sector. 

Single / 
Package  

Type  

New / 
Amendment 

Stage in Anti-Fraud Cycle   Horizontal / Sectoral  

Area  

Scope  

Anti-Fraud Measure #2 Taken by Spain in 2024  

e
l
g
n
i
S

Legislative  
(Decree) 
29/10/2024 
Royal Decree 1101/2024 

New 
legislation 

Prevention       Detection 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Horizontal 

•  Whistleblower 

•  Competence 
•  Powers 
•  Definition of a 
specific topic 

•  Recovery 
•  Financial 
penalties 

•  Other 

administrative 
penalties  

Reason / Expected 
Result  

• To clarify or 
consolidate 
existing rules 
• To enforce the 
rules in line 
with 
developments 
in EU law 

Table 100: Anti-fraud measure #2 taken by Spain in 2024 

2.26.3. Leveraging Artificial Intelligence in E-commerce Fraud Detection 

The third measure reported by Spain focuses on the integration of artificial intelligence in detecting e-
commerce fraud. This measure is crucial as it addresses challenges posed by the exponential growth in 
imports  linked  to  online  commerce  and  the  impossibility  of  impossibility  of  effective  control  with 
conventional tools in the fight against fraud in the field of the general protection of financial interests, 
in particular traditional own resources accrued on the occasion of this type of imports. Traditional tools 
for  fraud  control  are  increasingly  insufficient  to  manage  this  surge  in  activity.  AI  offers  enhanced 
capabilities  for  monitoring  and  analysing  transactions,  enabling  more  effective  identification  and 
prevention of fraudulent activities.  

65 

 
 
 
 
 
 
 
  
 
 
 
 
 
 
Single / 
Package 

e
l
g
n
i
S

Anti-Fraud Measure #3 Taken by Spain in 2024  

Type 

New / Update  Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Reason / Expected 
Result 

Operational 
15/10/2024 

New 
measure 

Detection

Sectoral:  

•  Revenue 
Customs  

•  Fraud definition 
•  Customs / TOR / 

– 

illicit trade  

•  IT tools ‘”IT 

data feeding”, 
“Other IT”) 
•  Risk indicators 
•  Increased 
number of 
checks  

• Targeting of 

checks 

• Targeting of 

investigations 
• Enhanced ex-
post controls 

Table 101: Anti-fraud measure #3 taken by Spain in 2024 

2.26.4. Additional measures  

Spain additionally reported measures taken at regional and national level.  

Region  

Measures Implemented in 2024 

Funds or bodies involved  

• 

Procedural Manual in relation to the Strategy for the 
prevention, detection and fight against fraud and 
conflict of interest  and  Guide  for  the  elaboration of 
the risk assessment of the Spanish Agricultural 
Guarantee Fund, Paying Agency (FEGA) 

•  Compliance with the criteria for the authorisation of 

paying agencies 

• 

Intensified  training  on  the  prevention  and  fight 
against fraud to the EU's financial interests, both in 
general terms in these matters, and in more specific 
training  in  the  framework  of  the  implementation  of 
the Recovery, Transformation and Resilience Plan 

•  Organisation as coordinator of the “Conference on 

investigation  of  fraud  against  the  EU's  financial 
interests” to provide training to national investigators 
specialised in economic and financial investigations  

•  Reinforcement  of  controls  for  REDEF  to  prevent 
VAT  fraud:  with  the  aim  of  removing  from  the 
Register subjects who presented clear indications of 
tax risk through visits and analysis of documentation 

• 

• 

• 

Establishment  of  the  Observatory  against  Health 
Fraud and Corruption. 
It has the character of a working group and collegiate 
body,  and  will  act  in  the  field  of  prevention,  alert 
system  and  collaboration  with  public  or  private 
entities  or  bodies  with  oversight,  supervision  or 
control functions in the area of public procurement or 
corruption prevention. 

Establishment  of  two  independent  institutions  at 
regional  level  to  address  abuses  of  position  and  to 
protect whistleblowers:  

• 

• 

The  Galician  Whistleblower  Protection 
Authority  
The Independent Authority on Corruption in 
Castilla y León 

•  Continued staffing of IGAE's Support Unit for EPPO 

•  National 
level 

•  National 
level 

•  National 
level 

•  National 
level 

•  National 
level 

•  Galicia 
•  Castilla  y 
León 

•  National 
level 

• 

Spanish  Agricultural 
Guarantee 
Fund 
(FEGA) 

• 
• 

Spanish AFCOS 
FEGA 

•  Civil Guard 

•  Register  of  Extractors 
of 
Deposits 
Tax 
(REDEF) 

•  Ministry 

overseeing 
public procurement and 
corruption prevention 

• 

• 

The Galician 
Whistleblower 
Protection Authority  
The Independent 
Authority on 
Corruption in Castilla y 
León 

•  General Intervention of 

the State 
Administration (IGAE) 
The EPPO 

• 

Table 102: Additional anti-fraud measures taken by Spain in 2024 

66 

 
 
 
 
 
 
 
2.27. 

Sweden  

In  2024,  Sweden  implemented  two  strategic  measures  to  strengthen  the  prevention  and  detection  of 
fraud in relation to the European Union's financial interests. The first measure strengthened financial 
protections  under  the  Recovery  and  Resilience  Facility,  ensuring  robust  oversight  and  management 
across multiple authorities. The second measure focused on enhancing anti-fraud capabilities through 
targeted training for personnel handling EU aid.  

2.27.1. Enhanced protection of the Union’s financial interests when implementing the Recovery 
and Resilience Facility (RRF) 

The first measure reported by Sweden centres on the implementation of the Recovery and Resilience 
Facility (RRF). In Sweden, the deployment of the RRF involves 62 distinct implementing authorities, 
each responsible for managing various aspects of the initiative. To ensure robust protection of EU and 
national  financial  interests,  the  Swedish  National  Financial  Management  Authority  (ESV)  has  been 
designated  to  oversee  and  guide  these  efforts.  The  ESV  has  developed  comprehensive  guidelines, 
disseminated exemplary practices, defined key terminologies, and conducted informative campaigns to 
assist these authorities. Consequently, each of the 62 authorities was mandated to refine and consolidate 
their routines. 

This measure is crucial because the RRF is a relatively new financial instrument with less established 
control  systems  compared  to  more  traditional  mechanisms.  Many  implementing  authorities  lack 
experience in managing EU funds, underscoring the need for a focus on fraud prevention and financial 
integrity.  By  sharing  experiences,  issuing  guidelines,  promoting  best  practices,  and  strengthening 
control systems, Sweden enhances efforts to protect the Union’s financial interests and provides valuable 
lessons for future instruments. 

Single / 
Package  

Type  

New / Update 

Horizontal / Sectoral  

Area  

Scope  

Anti-Fraud Measure #1 Taken by Sweden in 2024  

Stage in Anti-Fraud Cycle  

e
l
g
n
i
S

Administrative  
(Circulaire/Circular, 
Instructions, Guidelines, 
Manuals) 

New measure 
 Update 

Prevention       Detection 

Sectoral: 
•  Expenditure – 
Recovery and 
Resilience 
Facility 

•  Financial crime 

(including money 
laundering)  
•  Corruption  
•  Conflict of 
interest 

•  Fraud definition 

•  Management of 

funds 

•  Monitoring / 
desk checks 
•  On the spot 

checks 

•  Irregularities 
reporting  

Reason / Expected 
Result  

• To clarify or 
consolidate 
existing rules 

• To enhance 
existing 
measure  

• Cross-cutting 

measure, 
multi-agency 
measure / 
measure with 
impact on 
various 
bodies* 

Table 103: Anti-fraud measure #1 taken by Sweden in 2024 

*Cross-cutting measure: The National Financial Management Authority and the SEFI Council have been tasked with 
preparing guidelines, good examples and information campaigns to support the 62 authorities implementing the RFF in the 
prevention, detection and reporting of irregularities. 

Public / 
Private sector 

Public sector 

Corruption within public procurement – Sweden #1 

Fight against corruption in public procurement 

Comment 

•  Measures to prevent corruption amongst 

personnel, including 
Management 

•  Measures to improve the effectiveness of 

control and audit 

Table 104: Corruption within public procurement – Measure #1 taken by Sweden in 2024 

2.27.2. Anti-Fraud Training Initiative For EU Aid Management 

The Swedish Board of Agriculture, along with other relevant handling authorities, has implemented a 
comprehensive training program focused on anti-fraud measures for employees managing EU aid. The 
training featured speakers from the Swedish Economic Crime Authority and the European Anti-Fraud 

67 

 
 
 
 
 
 
 
Office, among others, and was well attended by personnel from the Swedish Board of Agriculture and 
other authorities involved in EU aid management. 

During the current programming period, anti-fraud efforts have become a key focus for the European 
Parliament, Council, and Commission. Recognising this priority, the Swedish Board of Agriculture has 
established an anti-fraud working group to coordinate initiatives against fraud. This training is part of 
their active engagement in aligning with the Commission's guidance on addressing serious deficiencies 
impacting the protection of the Union’s financial interests. By prioritising these efforts, the Swedish 
Board of Agriculture aims to ensure robust management of EU aid. 

Anti-Fraud Measure #2 Taken by Sweden in 2024  

Single / 
Package 

Type 

New / 
Update 

Stage in Anti-Fraud Cycle  Horizontal / Sectoral 

Area 

Scope 

Reason / Expected 
Result 

e
l
  Organisational 
g
n
i
S

01/01/2024 

New 
measure 
Update 

Prevention       Detection 

Sectoral: 
•  Expenditure – 
Agriculture 
•  Expenditure – 
Fisheries 

•  Fraud definition 
•  Shared 

management and 
control of EU 
funds 

•  Competence 

• Neutral on 
resources  

Table 105: Anti-fraud measure #2 taken by Sweden in 2024 

68 

 
 
 
 
 
 
 
3. Case studies 
3.1. Revenue 

Within  the  framework  of  the  PIF  questionnaire  2023,  this  section  presents  a  series  of  case  studies 
reported by Member States, classified under traditional own resources (TOR). The section is divided 
into the two areas most represented by the case studies: smuggling and misclassification/description.  

3.1.1.  Smuggling  

With regard to smuggling, an initial overview shows that Member States reported a variety of illicit 
activities, including trafficking in counterfeit medicines and illegal cigarette smuggling. For instance, a 
Greek  operation  uncovered  networks  involved  in  the  illicit  trafficking  of  legitimate  and  counterfeit 
medicines, highlighting the intricate web of criminal operations present in this trade. Similarly, a case 
from Croatia demonstrated the sophisticated nature of smuggling, as customs officers detected illegal 
cigarette  shipments  disguised  as  refrigerator  transits.  These  cases  underscore  the  importance  of 
transnational  cooperation  between  Member  States  and  international  organisations  in  fighting  illegal 
trafficking. Moreover, they highlight the critical role of customs detection in identifying and intercepting 
smuggling activities. 

Member 
State 

Sector and EU 
funding program 

Type of fraud 

Description 

The goods-undeclared cigarettes were seized due to attempt to illegally bring them into the Republic of Croatia 

a
i
t
a
o
r
C

Revenue - TOR 

• Customs evasion  
• Smuggling 
• Misdescription 

/ 

Misclassification 

On February 4, 2024, customs officers at Border Control Point Tovarnik, Croatia, intercepted 
a truck and semi-trailer under the pretext of transiting refrigerators with a net weight of 3,621 
kg. Upon further x-ray inspection at Border Control Point Bajakovo, discrepancies arose in the 
declared  goods,  revealing  smuggling  activities.  The  investigation  found  cardboard  boxes 
concealed within the  shipment containing 899,800 various brand cigarettes. Subsequently, a 
criminal  complaint  was  filed  against  the  truck  driver,  and  the  authorities  collected  duties 
amounting to EUR 124,826.10. The vehicles and goods involved were seized. 

Participation of the Hellenic Police, as co-leader, in Operation SHIELD V against illicit trafficking of legitimate and 
counterfeit medicines 

e
c
e
e
r
G

 Revenue - TOR  • Illegal 

trafficking  

The Hellenic Police, as co-leader, actively participated in Operation SHIELD V, 
coordinated by EUROPOL, targeting the illicit trafficking of genuine and 
counterfeit pharmaceuticals products, doping substances, and food supplements 
from April to November 2024. Collaborating with OLAF, INTERPOL, 
FRONTEX, the World Customs Organization, the World Anti- Doping Agency, 
and private entities, Operation SHIELD V addressed nine criminal networks 
engaged in national and international illegal activities. The operation led to the 
arrest of 30 individuals and involved 36 more in criminal case files. Criminal 
proceeds amounted to over €6.5 million, with illegal products seized valued at over 
€3.5 million.  

Table 106: Case studies – Smuggling  

3.1.2.  Misclassification / misdescription 

With  regard  to  cases  involving  misclassification/misdescription,  a  case  study  revealed  fraudulent 
practices aimed at bypassing customs duties and tariffs. The Italian case study showcases this issue, 
where a company misclassified imported e-bike components to evade anti-dumping duties and VAT. 
Such fraudulent declarations highlight the necessity for vigilant customs enforcement to protect national 
and EU revenues from significant financial losses. 

69 

 
 
 
 
 
 
 
 
‘NO DUTY’ operation carried out by the Monza Guardia di Finanza 

Member 
State 

Sector and EU 
funding program 

Type of fraud 

Description 

y
l
a
t
I

Revenue - TOR 

• Misclassificatio
n  of 
goods 

imported 

In  2024,  the  Italian  Guardia  di  Finanza  tackled  a  case  of  customs  fraud  involving 
misclassification of imported goods. A company in Italy avoided paying significant anti-
dumping duties  and  the  related VAT  by  importing key  components  for  e-bikes  from 
China and assembling the bikes domestically. Analysis of customs declarations from 
2019  to  2022  indicated  that  the  company  had  falsely  classified  these  components, 
resulting in lower declared production costs compared to competitors and avoiding EUR 
10,124,360.75 in import duties and VAT. Consequently, EPPO’s Milan office ordered 
the  preventive  seizure  of  EUR  5,039,260.08,  leading  to  the  seizure  of  a  commercial 
property valued at EUR 1,500,000.00 and approximately 10,790 bicycles ready for sale. 

Table 107: Case studies - Misclassification / misdescription 

3.2. Expenditure 

This section presents the collection of case studies reported by Member States regarding the budgetary 
area of expenditures. 

These case studies provide a thorough overview of the various cases where financial irregularities and 
fraudulent activities have been detected in projects financed by EU funds. The section is divided into 
the two areas most represented by the case studies: fraud involving misuse or mismanagement of fraud 
and public procurement and subsidy fraud.  

3.2.1.  Fraud Involving Misuse or Mismanagement of Funds 

The mismanagement and misuse of European Union funds present a significant barrier to the effective 
implementation of developmental and infrastructural projects across member states. Case studies from 
Bulgaria, Romania, and Estonia highlight the diverse methods through which funds are misappropriated, 
ranging from the submission of falsified documents to the strategic manipulation of grant requirements. 

Member 
State 

Sector and EU 
funding program 

Type of fraud 

Description 

EMFF (European Maritime and Fisheries Fund) – Misuse of funds 

  Expenditure: 

a
i
r
a
g
l
u
B

Maritime and 
Fisheries 
Programme 
(EMFF) 

• Misuse 

and 
misappropriation 
of funds 

The case concerns information on misused funds awarded as a grant to a beneficiary under the 2014-
2020  Maritime  and  Fisheries  Programme,  and  there  is  sufficient  evidence  of  a  criminal  offence 
under Article 254b of the Criminal Code having been committed. There is evidence of fictitious 
execution  of  a  project  under  the  procedure  ‘Encouraging  new  sustainable  aquaculture  farmers 
practising  sustainable  aquaculture’  and  unlawful  disposal  of  the  assets  financed  under  the 
programme. The assets could not be identified at the specified investment location and there was 
evidence that the investment had never operated in accordance with the approved project proposal. 
The grants had been used by the beneficiary not for their intended purpose, but to pay off other 
liabilities they had. The file was submitted to the European Public Prosecutor’s Office and criminal 
proceedings were initiated. The total cost of the project is in the region of BGN 800 000. The loss 
to the budget is around BGN 380 000. 

Artificial fulfilment of requirements when applying for direct grants to avoid sanctions (EAGF) 

a
i
n
o
t
s
E

Expenditure:  
European 
Agricultural 
Guarantee Fund 
(EAGF) 

• Fraudulent 
practices 
subsidy 
applications  

in 

A legal entity, previously penalised for violating organic agricultural subsidy 
requirements, attempted to avoid ban on applying sanctions by transferring control of 
the fields to other legal entities managed by close relatives. These entities applied for 
subsidies in the following year, but their autonomy was investigated, revealing a 
dependency relationship with the sanctioned entity. As a result, subsidies were denied, 
and the new entities also faced penalties with a ban on applying in the future. 

70 

 
 
 
 
 
 
 
 
EAFRD – Presentation of false documents for EU funding 

a
i
n
a
m
o
R

Expenditure: 
European 
Agricultural Fund 
for Rural 
Development 
(EAFRD) 

• Submission 

of 

false documents 
• Forgery 
documents   

of 

The Anti-Fraud Department (DLAF) in Romania investigated a project funded by the 
EAFRD following a referral from the European Public Prosecutor’s Office (EPPO) about 
potential  fraud.  The  investigation  uncovered  that  an  individual  exercised  significant 
control over both the supposed beneficiary company and the equipment supplier, though 
this person was not officially recognised as the project’s beneficiary. False documents 
were allegedly submitted to manipulate the procurement process for a 3D printer and to 
secure private co-financing. There were serious indications that the project involved the 
submission  of  inaccurate  and  potentially  forged  documents,  suggesting  a  scheme  to 
improperly  secure  EU  funds.  DLAF's  findings,  which  included  possible  forgery  and 
abetting  of  criminal  offenses,  were  forwarded  to  the  European  Public  Prosecutor’s 
Office,  and  compliance  measures  were  initiated  for  related  projects.  The  DLAF  also 
notified the Agency for Financing Rural Investments and OLAF.  

Table 108: Case studies – Fraud Involving Misuse Or Mismanagement Of Funds 

3.2.2.  Fraud Related to Procurement and Tenders 

The integrity of procurement processes is crucial for ensuring fair competition and the efficient use of 
public funds. However, procurement fraud continues to pose significant challenges, often manifesting 
in  forms  such  as  bid  manipulation,  bribery,  and  conflicts  of  interest.  Such  fraudulent  activities 
compromise the fairness and transparency of tender processes. Through case studies from the Czech 
Republic, Poland, and Hungary, we gain insight into how these fraudulent practices can be orchestrated 
and the impact they can have on EU-funded projects.  

Member 
State 

Sector and EU 
funding program 

Type of fraud 

Description 

Procurement fraud in tenders for road cleaning and marketing services 

c
i
l
b
u
p
e
R
h
c
e
z
C

Expenditure: 
Cohesion policy, 
ERDF 

• Public 

procurement 
fraud 
• Bribery 
• Subsidy Fraud 

The  Czech  Police's  National  Centre  Against  Organised  Crime,  under  the  European 
Public  Prosecutor’s  Office  in  Ostrava,  arrested  eight  individuals  following  an 
investigation  into  procurement  fraud,  bribery  and  subsidy  fraud  in  the  Moravian-
Silesian  region.  The  investigation  focuses  on  small-scale  tenders  organised  by  two 
public entities: the Moravian Road Administration and the Moravian Energy Centre in 
2020.  Allegedly,  tendering  procedure  was  manipulated  to  secure  contracts  for  pre-
selected  bidders  via  bribes,  using  EU  funds.  Charges  of  procurement  fraud  are  filed 
against five individuals and a legal entity, with bribery charges also pressed, including 
against the former deputy governor of the region. Conviction could range from up to 
eight  years  to  ten  years  in  prison.  All  suspects  are  considered  innocent  until  proven 
guilty by the competent Czech courts of law. 

Detection of conflicts of interest through sample checks 

y
r
a
g
n
u
H

Expenditure: 
Cohesion policy, 
ERDF 

• Conflict 
interest  

of 

During  routine  sample  checks,  the  Directorate  for  Internal  Audit  and  Integrity 
discovered a conflict of interest involving five projects subjected to on-the-spot checks. 
The managing director of the supplier company was the father-in-law of the individual 
being investigated, who failed to declare any conflict of interest concerning the related 
tenders.  This  failure  compromised  the  impartiality  and  objectivity  of  the  involved 
person  in  the  procedural  acts  assessed  during  on-the-spot  checks.  As  a  result,  the 
Directorate  informed  relevant  development  policy  actors.  Based  on  the  findings,  the 
employer  of  the  investigated  individual  initiated  the  termination  of  the  employment 
relationship. 

71 

 
 
 
 
 
 
 
Corruption, misuse of powers and harm to the public interest 

d
n
a
l
o
P

Expenditure 

• Corruption  and 
misuse 
of 
powers 

Following  press  reports  and  a  Central  Anti-Corruption  Bureau  investigation,  an 
employee of a state agency was detained for alleged misuse of powers and harm to the 
public  interest  related  to  an  EU-funded  project.  The  employee  used  their  position  to 
unlawfully disclose  confidential information  about tenders  to  third  parties,  accepting 
financial benefits in return. This led to a conflict of interest and ultimately constituted 
corruption,  with  the  favoured  company  winning  tenders  for  the  supply  of  certain 
electronic systems deemed eligible under the project. In court, the involved employee 
admitted to passive corruption, misuse of official powers, and breach of professional 
secrecy, resulting in fines and imprisonment. A 100% financial correction was applied 
to the project, with irregular expenditure amounting to almost EUR 3.5 million being 
withdrawn  from  the  declaration  sent  to  the  European  Commission.  The  case  was 
reported  as  established  fraud  to  the  Irregularity  Management  System  (IMS). 

Table 109: Case studies – Fraud Related To Procurement And Tenders 

3.3. Cybercrime case study   

As  an  additional  case  study  reported  by  Estonia,  we  examine  cybercrime  and  the  critical  role  of 
innovative tools in confronting emerging cyber threats. It underscores the necessity for adaptive anti-
fraud measures that evolve in tandem with fraudsters' tactics, ensuring law enforcement remains one 
step ahead in the digital battleground. 

Award for Innovative Technical Solutions 

Member 
State 

Sector and EU 
funding program 

Type of fraud 

Description 

a
i
n
o
t
s
E

Not applicable 

• Cybercrime 

In  a  successful  international  joint  operation  named  OP  PhishOFF,  involving  law 
enforcement  from  several  countries,  with  Estonia  playing  a  key  role,  dismantled  the 
Phishing-as-a-Service  platform  "LabHost."  Estonia  developed  innovative  tools  to 
identify and dismantle the malicious infrastructure, and deterred criminals by creating a 
sense  of  immediate  pursuit.  This  method,  acknowledged  with  Europol  Excellence 
Awards  in  Innovation,  is  transferable  to  other  law  enforcement  agencies  for  future 
cybercrime interventions. 

Table 110: Case studies – Cybercrime 

72