Overview of anti-fraud approaches

AuthorMélissa Campagno - Goya Razavi - Brian Kessler - Léna Bonnemains - Olga Mala
Study on the implementation of Article 125(4)(c) of the CPR in the Member States
Arachne is an IT tool developed on behalf of the EC and in close cooperation with MAs from three
different Member States. It aims to support MAs and IBs in their administrative controls and
management checks on ESF and ERDF projects. The tool has three main functions:
1. It establishes a database of ESF and ERDF projects from the informa tion submitted by MAs;
2. It uses publically available data to enrich the data provided by MAs;
3. Using this data, it identifies fraud risks and red flags related to projects, beneficiaries,
contracts and contractors.
In this way, Arachne helps MAs and IBs with additiona l information to prevent, detect errors
and irregularities among projects, beneficiaries, contracts and contrac tors.
2. Overview of anti-fraud approaches
This section provides a n overview of anti-fraud approaches divided into two a spects. First, the
section focuses on how the EU and the designated ESI Funds authorities have changed their
approaches to anti-fraud and corruption in the 2014-2020 progra mming period in comparison to
the previous programming period. Secondly, it focuses on the National Anti-Frau d Strategies
(NAFS), including their content and structure.
2.1 Changes for the 2014-2020 programming period
Article 125(4)(c)18 has led to a changed approach to fighting fraud in ESI Funds in the
selected OPs. In general, MAs’ approach es to anti-fraud are now more articulated and
formalised than during the previous programming period . Even those measures and
procedures that were in place in the previous program ming period are now better documented than
they were in the past, also thanks to the FRA process.
Many (49%) MAs have started, or are planning to use Arachne (for more d etail, see
section 5. Anti-fraud tools below).
A number of MAs among the i nterviewed ones focused more on p revention for the
2014-2020 programming period than in the previous programming period. The EC’s
“Guidance note o n fraud risk assessment and effective and proportionate anti-fraud measures,”
published in 2014, puts great emphasis on fraud prevention.19 It highlights that prevention is
particularly important in the fight against fraud, since the fraudulent activities are difficult to detect
and it is challen ging to prove that suspicious activities indeed are fraudulent. In line with this, a
number of interv iewees indicated that fraud detection becomes a difficult task as fraudulent
schemes become more complex and adapt to the detection practices. Therefore, in the current
programming period, Authorities increased the focus on prevent ion activities in combination with
the existing d etection measures. In a number of the OPs (14%), interviewees mentioned that more
emphasis was placed on prevention for the 2014-2020 programming period compared with 2007-
2013 period. For example, some MAs created “tone from the top” communications .
Interviewees also mentioned, among the changes for the 2014-2020 programming period, an
increased awareness of the staff with respect to th e importance of anti-fraud risk assessment and
improvement of IT systems used to prevent and detect fraud.
In most MS , national funds and European funds are subject to common basic
procedures (e.g. separation of duties), but additional controls are implemented for
European funds. EU funds are more controlled due to EU requirements. Only a small number of
interviewees mentioned that there was in principle no difference, or pointed to small differences
18 Regulation (EU) No 1303/2013 laying down the common provisions on the European Structural and Investment Fund, available at
19 See http://ec.europa.eu/regional_policy/en/information/publications/guidelines/2014/fraud-risk-assessment-and-effective-and-

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