Approach

• Author: Mélissa Campagno - Goya Razavi - Brian Kessler - Léna Bonnemains - Olga Mala
• Pages: 7-7

7

DG REGIO

Compendium of anti-fraud practices for preventing and detecting fraud and corruption

in ESI Funds

4. Approach

A good practice is commonly understood as a solution or approach that can be assessed as having a positive

verified impact on a specific issue. However, when it comes to the fight against fraud and corruption,

establishing a clear link between the effects of a practice implemented and the reduction of fraud and

corruption is not straightforward as evidence of the impact on fraud and corruption of any measure is

particularly difficult to gather. For instance, a reduction of fraud cases detected does not necessa rily mean

that fraud has decreased, but can also mean that the sys tem is less efficient in detecting fraud.

Furthermore, a s a large part of the anti-fraud practices featured in this Compendium have been

implemented in response to the new requirements brought by the 2014-2020 programming period, it is too

soon at this stage to call those practices good practices. Indeed, authoriti es who have implemented them

have not yet collecte d sufficient ins ights to assess the results of the practice on their anti-fraud system.

Therefore, this Compendium focus on examples of identified anti-fraud practices, which display a strong

potential to be considered good practices at a time when, and if, their impact on fraud and corruption can

be assessed.

Anti-fraud practices presented in this Compendium were primarily identified when discussing with MAs,

AAs, AFCOS, and CAs where relevant, during more than 140 interviews conduc ted. Interviews were

complemented by desk research work and insights collected from speakers who presented their anti-fraud

practice on this occasion of the 13 September workshop o n preventing fraud and corruption in ESI Funds.

An initial list of 104 practices examples were identified and further refined to obtain a sample of 65 practice

examples. In order to select the best examples from this sample a nd to feature them in this Compendium,

we relied on opinions of stakeholders interviewed, and on PwC experts’ qualitative assessment based on the

following two criteria:

1. Potential impact: whether the practice has the potential to positively impact the anti-fraud

system of the MS;

2. Transferability and applicability: whether the practice is seen as easily transferable and

applicable to other contexts (e.g. other OPs or MS). This criterion ensures that the selected anti-

fraud practices are relevant for a maximum of OPs and MS.

In very few cases, and for the reasons abovementioned, the innovative and unique character of the

anti-fraud prac tice was c onsidered i.e. whether the practice display innovative characteristics that

differentiate it from what is usually done.

As a result, this Compendium encom passes two types of anti-fraud practices. Fo r the main part, practice

examples presented consist of good implementations of suggestions , guidelines, and requirements of the

EC (e.g. designation criteria). For a small part, practice examples highlight unique and innovative features

of certain examples. These were usually put in plac e on the sole initiative of practitioners or authorities, or

as part of other initiatives.

Following this assessment , we grouped the shortlisted practice examples into 8 categories of practices

featuring 25 examples and case studies. Hence, a fiche in the Compendium cor responds to a category of

anti-fraud practices, e.g. “Practical anti-fraud trainings”. The anti-fraud practice fiches further include

descriptions of some of the identified examples in order to illustrate the various practical ways to implement

the anti-fraud practice.