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fronterizos.” 107 However, much remains to be done in order to achieve the planned co-
operation between the different border posts with INTERPOL: "A nivel del RE 3. ningún
protocolo o acuerdo de conectividad ha sido adoptado (IOV 1.); ninguno de los 19 puestos
fronterizos está conectado al I/24/7 (IOV 2.); ninguna consulta al I/24/7 de los 19 puestos
fronterizos ha sido realizada (IOV 3.) y ningún intercambio de información se ha realizado a la
fecha  (IOV  4.).” 108

In Asia region:

In Afghanistan “the  main  activities  of  the  BOMBAF  project  were  tackled  in  close  collaboration  
with stakeholders, in Kabul and in Afghan Badakhshan, in a way that attempted to best
address the needs of project Beneficiaries. To ensure standardisation, harmonisation and
sustainability of the equipment, project stakeholders were involved in the preparation,
revision and approval of equipment listings, specifications and procurements. This process
also helped ensure that the equipment supplied was interoperable with other border
projects in Afghanistan and the Central Asia region.”109

ACP region:

In Mauritania,  the  progress  report  of  the  project  “Gestion  de  la  migration  EDF”  highlighted  the  
fact that since the EU funded similar projects in Mali and Mauritania, some exchange of
information have been organised to ensure a certain level of compatibility between the
equipment installed on the two sides of the border: “Dans  le  but  d’éviter   des  doublons  et  de  
travailler   en   synergie,   l’OIM   a   rencontré   [le]   Coordonnateur   du   projet   sur   la gestion des
frontières   au   Mali,   financé   par   l’UE.   Durant   cette   rencontre,   il   était   question   pour   l’OIM   de  
connaître les postes de frontières réalisés et les équipements utilisés pour assurer la
compatibilité   avec   l’installation   future   des   postes   en   Mauritanie. Ce même souci a guidé
l’intérêt  de  l’OIM  pour  les  modules  de  formation.”  However, the field mission showed that this
has not materialised yet.

5.4.4 Ind544 - Existence and delivery of joint training programmes and materials and other
measures for sharing of (good) working practices at borders including staff exchanges

The EU financed a considerable amount of exchange programmes, mainly joint trainings, exchange
workshops with neighbouring counties, international study tours and even a 2-year college course for
border management practitioners (e.g. in Moldova, financed under EUBAM).

The EU interventions seemed to have a substantial positive contribution to the enhancement of joint
activities, as the answers of the EUD survey suggest. Eight respondents either stated that the EU
‘contributed   substantially’   (three   answers)   or   had   a   ‘reasonable   contribution’   in   the   field   of   sharing  
good working practices. This is the topic that is rated as having the highest EU contribution of all
topics asked under JC 53. The statement of the EUD Mauritania sheds light on the added-value of the
EU  support  to  such  joint  training  exercises:  “The EU plays an important role to coordinate actions as
well as dissemination of information to member states as well as towards other international
organisations.”

Only in Afghanistan the objectives of enhanced joint international co-operation through the provision of
joint training activities, could not be reached, due to difficult working relation between the Afghan and
Tajik side. The MTR of EU support to BM in Afghanistan explains: “BOMBAF was unable to set up
meaningful dialogue between the ABP and the Tajik border authorities. The project recruited as a
consultant a respected Tajik Border Force Colonel to act as Liaison Officer in an attempt to maintain
communication and to attempt to make improvements. To date [2009], the situation is only marginally
improved and this is said to be only because of the presence of the Liaison Officer. This is hardly a
promising situation for future working arrangements and the adoption of international cooperation in
line with full IBM.”110

EU seemed to provide training activities in almost all fields of border management, ranging from drug
trafficking, migration management, to customs and law enforcement.

ELARG region:

In Albania, the EU proved very active in contributing to international co-operation in border
management. More precisely, as evident in project documentation the EU contributed to the
establishment of cross-border workshops and international study visits, as well as joint

107 MR-144479.01, p. 2.
108 MR-144479.01, p. 2.
109 2009 Mid-Term Evaluation of the EU support to BM in Afghanistan.
110 EU (2009): Mid-Term Evaluation of the EU support to BM in Afghanistan.

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training and joint border controls of different staff involved in border management with their
respective international counterparts. Following training activities have been found; the
effectiveness or sustainability of joint exchange activities, could not be assessed with the
available documentary evidence:

In   relation   to   the   project   on   the   ‘Pre-screening of asylum-seekers   and   migrants’,
several cross-border workshops on best practices with the participation of Greece,
FYRoM and Montenegro took place. In addition, study visits to one EU accession
country and one EU Member State were organised, including several days of training
at the OSCE police training centre.111

For  the  project  ‘Support  to  the  alignment  of  customs procedures with  EU  standards’  
several international study tours have been organised for the purpose of experience
exchange, one to Poland, the other one to Austria.112

The Border & Inland Control chapter of the EU Customs Blueprint report (2011) states
that “Joint  training  has  been  conducted  under  the  IBM  project,  but  on  a  predominantly  
donor-driven basis. [However] a comprehensive IBM Technology Needs Assessment
is lacking, as is an in house training programme to focus on key border control
issues.”  

The IBM  Regional  Assessment  &  Monitoring  Team  report  (2009/10)  records  that  “The
Border Police have undergone joint trainings on border patrolling with their Border
Police counterparts from the former Yugoslav Republic of Macedonia and Montenegro
and also with the Kosovo Border Police on travel documents recognition. In
addition, joint training for Border Police and Customs from Albania and Montenegro
on   EU   ‘best   practice’   procedures   to   be   operated   at   the   joint BCP at Muriqan /
Sukobin, was delivered by international  partners.”

Joint training and facilitation of international study tours were also provided under the CAFAO
programme. For instance in Serbia, joint border control training with neighbouring countries
took place, facilitating increases of co-operation and information exchange. Similar programmes
took place in BiH and Montenegro.113

ENP region:

In Belarus, the EU has provided support to the provision of joint trainings and seminars under
the   BUMAD3   project.   A   regional   seminar   on   “Practical   Aspects   of   Conducting Effective
Controlled Deliveries to Prevent Drug Trafficking”   was   conducted   at   the   International  
Training Center on Migration and Trafficking in Persons of the Academy of the MoI:
“Representatives   from   the   UN   Office   on   Drugs   and   Crime,   law-enforcement bodies,
Prosecutor’s   Office   and   Supreme   Courts   of   Belarus,   Moldova   and   Ukraine,   as   well   as  
Collective Security Treaty Organization, Interpol, Federal Department of Criminal Police of
Germany, Ministry of Interior of Kazakhstan, Counter Narcotic Agency of Kyrgyzstan,
Lithuanian Criminal Police, Russian Federal Counter Narcotics Service and some others took
part   in   the   seminar.” 114 The   Final   Report   states   that   “the provision of training to law
enforcement should continue with focus on exchange of experience with neighboring
countries. “

Furthermore, the State Boarder Committee of the Republic of Belarus is extremely active
within the EU TAIEX programme and has recently received considerable training assistance.
Outside the scope of this evaluation, Belarus has allowed officers to participate in numerous
study visits, workshops and seminars both at home and abroad, within the framework of a bi-
lateral agreement with Germany and other agreements with the UNHCR, UNDP and IOM.115

In Ukraine, joint trainings regularly took place. In particular, this is the case for the ones
organised under HUREMAS I and II. One of the main activities under these interventions
relate to Human Resource Development and the delivery of trainings. Strong evidence for
training at an international level could be found, e.g. several study tours and training courses
with Hungarian National Police and Polish Border Guards. EUBAM also helped to install a
widespread cooperation network with partners in the different parts of Europe. In this context,

111 ROM monitoring report MR- 40117.03, p. 2.
112 ROM monitoring report MR-136441.02, p. 2.
113 ROM monitoring report MR-041018.02 and MR-041018.02.
114 EU (2009): Programme for the Prevention of Drug Abuse and the Fight against Drug Trafficking in Belarus,
Ukraine and Moldova – BUMAD 3, Project Completion Report.

115

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various study and training visits took place to Germany, WCO/Brussels, UK, Latvia,
Netherlands and Poland.

An interesting EU financed intervention under the EUBAM programme, was the 2007 opening
of   the   ‘National   Border   Guards   College’ in Ungheni, Moldova. According to the EUBAM
progress report116, the course covers a two-year long basic training for operational staff.
The training plan and curriculum were developed according to European standards and
comply with the Common Core Curriculum of the European Border Guards training, given by
FRONTEX. The topics covered are: training on information exchange, risk analysis,
research and development, and coordination of joint operational measures. According to
the EUBAM progress report “this   was   a   first   step   to guarantee that developments related to
the  field  of  training  in  EU  border  guard  institutions  are  being  followed  by  the  UASBGS.”

As for Asia:

In Central Asia, BOMCA supported enhanced international co-operation through its training
component. Following the scrutinised project documentation, study tours to FRONTEX for
all Central Asia countries took place. Most of the countries also included study tours to
Germany and Latvia, and for Uzbekistan also to Poland. Most likely, these study tours
enhanced co-operation between the participants. In addition, trans-border workshops haven
taken place for border and customs officers under BOMCA starting in 2008117. Cross-border
workshops were held in Kyrgyzstan/Tajikistan and Kazakhstan/Kyrgyzstan118.

In Afghanistan, despite some efforts to support the development of joint training, very little
could be achieved due to the difficulties in terms of Afghan-Tajik co-operation. The 2009 Mid-
Term Evaluation of the EU support to BM in Afghanistan observes   that:   “Objective 4,
concerning meetings and seminars between Afghan and Tajik officials, has to be marked
down as not fully achieved, for a number of reasons, not least of which was the attitude of
Tajik agencies. The evaluation team was able to witness the remote and distant, not to say
hostile  approach  from  the  Border  Police  at  the  3  Badakhshan  BCPs”.119

ACP & Latin America:

In Mauritania, some joint training has been organised by IOM at regional level but these
activities remained rather limited in terms of scope (and frequency):  “En ce qui concerne les
formations,   il   y   a   eu   trois   formations   de   formateurs   d’envergures   sous   régionale   et   qui   ont  
réuni   à   Bamako   des   représentants   des   Ministères   de   l’Intérieur   d’Algérie,   du   Mali,   du   Maroc,  
de Mauritanie et du Niger.”120

Under the   regional   project   ‘Seahorse’   a   number   of   joint   training   and   joint   patrols   were  
organised. For instance, the final report of the Seahorse project explains that it is expected
that “the   fact   that   migration   managers   from   different   African   countries   will   attend together to
the   courses   […]   will   contribute   to   network   partners   responsible   for   migration   management   of  
the  African  countries  concerned”. However, the field mission showed that co-operation in this
area between the third countries actually remains limited. Moreover, the level of activity
related to the Seahorse programmes has decreased following the halt in irregular migration
flows in recent years.

Although the SEFRO intervention is at the time of this evaluation at its very beginning, the
documents of the programming stage, shed light on the emphasis that the EU puts on
enhancing the sharing of good working practices in the region, the harmonisation of
border management policies and the co-operation of border management agencies with
international bodies involved in the area, such as EUROPOL and FRONTEX. Furthermore,
study visits to EUROPOL and FRONTEX are planned to take place in June 2012.

5.4.5 Ind545 - Existence and operation of joint patrols, actions and teams at borders, with
formalised standard operating procedures and formalised work programmes

Evidence that joint patrols are operating could mainly be found in the ELARG and ENP region. Joint
patrols are used in the area of passenger control as well as customs. The documentary evidence
suggests that those joint patrols have been effective. However, as illustrated by the complementary

116 EU (2011): Progress report 2005-2010, Main achievements in Border Management by the Partner Services in
five years of EUBAM activity, (EUBAM Phase 8 Action Plan Ref #2.8.1),p.12.
117 EU (2008): Border Management in Central Asia, Phase 5, Final Report December 2008.
118 EU (2011): Border Management in Central Asia, Phase 6, Final Report December 2010, p.12.
119 EU (2009): Mid-Term Evaluation of the EU support to BM in Afghanistan.
120 EU (2010): Progress report December 2009 - June 2010.

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and have a national Interpol bureau. Resulting from the limitations of third countries to access EU
data, one objective of the interventions is to support those countries in developing useful own
databases (as now in Serbia the data base for foreigners will be developed).

6.4.2 Ind642 - Evidence and results of periodic joint control operations at international level
(recurring on joint teams, liaison officers and focal points)

Joint control operations still appear to be the exception. In Ukraine, they were practised at the
occasion of the Euro 2012 Championship at the UA-PL border but discontinued afterwards140. Regular
joint patrols have been initiated by EUBAM as a permanent feature at the UA-MD border on
1/1/2012.141
In Mauritania, the EU has funded some training of Mauritanian maritime border guards and supported
joint control operations between Mauritanian border staff and the Spanish Guardia Civil at blue and
green borders. However, the aim of the activities seems to have been the development of the
capacities of border staff through practical training rather than the establishment of periodic joint
control operations over the long term.
No further evidence of EU supported periodic joint control operations at international level has been
found.

6.4.3 Ind643 - Existence and appropriate use of networking platforms at regional or
international levels according to initial plans

Evidence of the EU supporting the use of networking platforms at regional or international levels has
been found in the ELARG and ENP regions.
In the ELARG region:

Albania is a member of the South East Europe Law Enforcement Centre (SELEC) with a
permanent representative from Border and from Customs. The Albanian police is member of
Interpol. Albanian Customs is also member of the EU SEMS/SEED platform for regional
information exchange and the Venice Initiative lead by the Italian Custom Agency – a regional
platform for tackling serious organised crime and serious fraud.
As for Serbia, the EU provides support in terms of technical assistance to SECI/SELEC, which
is the main networking platform in the region in relation to anti-organised crime. Customs and
Police are both members of this networking platform, supply permanent representatives and
have the related national information path ways and networks in place.
In addition, CAFAO has contributed to enhancing international co-operation of border
management agencies related to the detection of organised crime. CAFAO Missions were
instrumental in the application for WCO membership of many beneficiary Customs
Administrations. Additionally, CAFAO Missions acted to assist in membership of other
networking platforms such as SECI/SELEC.
In the ENP region, evidence has been found in Ukraine, where the adoption of a national framework
document on IBM has been advised by an EU expert under HUREMAS II:
“The IBM Concept and the subsequent IBM Concept Implementation Plan provide a roadmap
for multi-actor   activities   to   be   carried   out   to   align   Ukraine’s   border   management   system   with  
that of its partners in the EU. It also envisages cooperation with FRONTEX in common actions
and trainings and assigns state organs of Ukraine to cooperate with Interpol, Europol and
other international law enforcement organizations for the benefit of border management. The
Concept facilitates the internal information exchange between the Ukrainian state authorities
and formulation of national migration policy in line with EU standards. An action plan was
adopted on 5 January to implement the Concept.”142
In Belarus, interviews carried out during the field visits highlighted that positive developments have
taken place after the evaluation period. Under BOMBEL 3 a modern network has been installed
between the different Border Crossings in order to enhance exchange between the SBC.

140 Interview with UASBGS
141 Interview with EUBAM
142 IOM (2010): HUREMAS II, Final Progress Report, p.8.

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7 EQ  7  on  flow  of  persons  and  management  of  migration

Evaluation Question 7: To what extent and how has EU support to IBM and OC contributed to
improving the flow of persons and management of migration at borders?

7.1 JC 71 - EU support to IBM and OC has contributed to enhancing client-
oriented services (including application of human rights) and procedures
being provided by border management agencies

7.1.1 Ind711 - Improvements in the physical layout of border crossing

From the evidence it appears that the EU has provided at least a minimum of support to infrastructure
and equipment of border crossing posts and this in almost all case study countries (exception being
the regional interventions SEFRO where it is still too early to assess the EU support and CAFAO).

The EU has provided on the one hand support to the construction of new posts (Albania, Ukraine,
Belarus, BOMCA and Mauritania) as well as to the renovation/upgrade of existing posts. While in
Ukraine, Belarus and Mauritania several new posts were constructed, the EU support to Albania
focused on the construction of a joint border crossing post. Support provided under BOMCA was
specifically targeted to border posts in remote areas. However these newly constructed border posts
under BOMCA rather serve issues of security in a region with ethnic troubles than to facilitate the
transit of passengers.

EU support to the renovation of existing BCP has been provided in almost all countries
investigated. Especially in the ELARG and ENP region, but also in Mauritania, the EU seemed to have
put an emphasis to refurbishing border crossing posts, which has a positive impact on the physical
layout of border crossing. However, some problems (e.g. maintenance of BCPs) remain evident.

Box 19: Examples of EU support to border crossing infrastructure in case study countries

In Serbia,   according   to   the   Standard   Summary   Project   Fiche,   2007   “there have been many EU

projects oriented to restructuring and upgrading of border crossing points. In 2001, 2002 and 2004
the EU launched projects for the border   crossing   points   at   Horgoš,   Batrovci   and   Preševo143 which
have contributed to the restructuring and upgrading of various border crossings.”  

Moreover, a nine-border-crossing project in 2006/2007 build nine border crossings at the new borders
on Serbian side to Croatia , Bosnia and Montenegro funded by the former EAR.

In Albania the   IBM   Action   Plan   states   the   following   objective   “In most cases, Customs and Border

Police are located at the BCP. Depending on the importance of the BCP, other agencies should also

be located there. The infrastructure should be adapted to allow integrated control in one building

(goods and passengers, except goods on trucks) in order to avoid duplication of controls by different
agencies.”  In  accordance,  various  projects  have  been financed by the EU and have contributed to the
improvement of the physical layout of border crossing. Especially the JBCP (opened in 2009)
between Albania and Montenegro, replacing former portakabins, constitutes a notable step in terms
of improving the physical layout of border crossings. However, it seems that, with exception of the
newly build JBCP and a few other BCPs, most of Albanian Custom Services premises are still
outdated and do not fulfil the needs and aims of a modern Customs Service, especially in the areas of
IBM and risk analysis.

In Ukraine, the EU has provided substantial support for the construction and rehabilitation of border
infrastructure (Construction and equipment supply interventions in Jagodyn, Rava-Russka, and
Uzhgorod. As illustrated in the CSE Ukraine144 “[t]he   refurbished   border   crossings   at   the   borders  
between [UA-Poland and UA-Hungary] are state-of-the-art.(…)   all   construction   projects   were  

completed to a high standard. The improved infrastructure has resulted in less waiting time at the
borders and more effective control, especially through the use of x-ray  scanners.”  This  statement  also  
gets confirmed in the Monitoring Report145 of  the  intervention  ‘Implementation  of  the  Border  Crossing  
Projects’.  As  illustrated  in  the  ROM  report,  “the  quality  of  the  design  and  works  done  is  very  high.  The  
comfortable  facilities  create  conditions  for  effective  work  and  are  operational.”

Also in Belarus, the EU has contributed to improvements and correct usage of the physical layout.
This specifically refers to the activities carried out under BOMBEL1 and 2 and to the construction of
several border crossing points such as Kozlovichi Border Crossing Point under the CBC APs.

143 Standard Summary Project Fiche, Improving Border Control Standards, IPA/2007/019-322.
144 EU  (2010):  Evaluation  of  the  European  Commission’s  Cooperation  with  Ukraine,  vol1,  p.  97.
145 EU (2005): Monitoring Report - Reform and Modernisation of the Ukraine Customs Administration, p3.

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However, support to improvements in the physical layout has mostly been provided to BCPs at the
border between Belarus and EU MS. A large part of the CBC Action Programme was allocated to
border crossing infrastructure to enhance trade facilitation, rapid movement of goods and persons.

The equipment supply which has been carried out under component five of BOMBEL1 (equipping the
border control automated system of highway, railway and simplified control check-points with
automation complex and equipping of airport checkpoints) have contributed to minimised level of
interventions. According to the final report146,  “the  activities  carried  out  (…)  specifically  supported:  a)  
Design construction equipment and integration of automation complexes; b) Delivery of terminal
devices for BCAS AC. Consequently, the citizens of Belarus, who previously had to purchase permits
at  the  Mol  to  travel  abroad,  “are  now  able  to  freely  cross  the  border,  while  control  over  criminals  has  
been   enhanced.”   The   BOMBEL2   Final   Report147 highlights as one of the main efforts made under
BOMBEL1 the reduced time for border control at airport check-points,   “with   no   infringement   upon  
security.”

In Afghanistan, the EU improved physical infrastructure in three BCPs located in different parts of the
country  through  the  ‘Custom  Modernisation  Project’  as  well  as  though  the  projects BOMBAF and NA-
IBM. Latter once financed the renovation and construction of accommodation buildings for border
staff at the Afghan-Tajik border. For example, the   BCPs   constructed   by   BOMBAF   “have   been  
designed as 2-storey (N4, Sh2), where the top floor includes working offices for passport control,
personal & baggage search, customs declaration, duty payment and animal & plant health controls.
The layout allows the travelling public to move from one control to the next in a smooth and simple
progression. The arrangement should facilitate closer working together of all border agencies and in
time  assist  in  the  adoption  of  many  of  the  inter  agency  aspects  of  IBM.”148

In Mauritania, in total, 8 BCPs were built and more than 26 equipped (incl. 19 with energy supply)
with  the  EU  support.  The  case  study  noted  “Les oeuvres physiques programmes de construction et
équipement  des  postes  frontaliers  (M’Bagne,  Dar  el  Barka  et  Aere  MBar)  ont  été  achevées,  ainsi  que  
l’installation   de   l’équipement.”   Interviews with travellers during the field visit highlighted a general
feeling that BCPs were undergoing major evolutions, in particular with the modernisation of the
equipment used.

From the case studies it appears that an improved layout of the physical infrastructure is a first step
towards faster and safer traveller clearance (Afghanistan, Belarus, Ukraine, see box above) and
IBM, especially the closer working together of all border agencies (Afghanistan). Through which other
means the EU supported improved traveller clearance procedures, is discussed in the next indicators
of this JC.

The non-calculation or underestimation of maintenance costs for donor-financed equipment and
infrastructure highlights the problem of sustainability as well as to some points a lack of
ownership of the national authorities for the new constructions. This is illustrated in reports of EU
funded interventions in Ukraine and Afghanistan:

The Afghan mid-term evaluation (2009) of EU support to BM149 points  out  that  “following the
final hand-over of the BCPs, the GoA has not fully taken on the funding and responsibilities for
the maintenance and operation of the facilities as required.”  

The   ROM   report   (2005)   of   the   project   ‘Reform   and   Modernisation of the Ukraine Customs
Administration’  stated  that  “Ukraine underestimated the cost of maintaining infrastructure and
of operating high-technology equipment; insufficient resources are available for that purpose.
This means that the sustainability of EU support in this field is currently not secure. Indeed
part of the equipment had to be taken out of use for lack of financial means for their operation.

Another related problem is that the mobile x-ray scanners that were supplied by the EU cannot
be moved to other border crossings which lack the required infrastructure for their use. Moving
these scanners is also costly and, in view of the limited resources, UASCS and UASBGS
decided against this, despite the fact that such a system would greatly increase effective
controls  along  the  entire  border”.150

Moreover, for some projects in Albania and Serbia, the field visits highlighted shortcomings in terms of
accessibility, maintenance and equipment:

146 EU (2007): Enhancing Border Management in the Republic of Belarus – BOMBEL 2, Final Report, p.12.
147 EU (2007): Enhancing Border Management in the Republic of Belarus – BOMBEL 2, Final Report, p.7.
148 EU, 2009: Mid-Term Evaluation of the EC support to BM in Afghanistan.
149 EU, 2009: Mid-Term Evaluation of the EC support to BM in Afghanistan.
150 EU (2005): Monitoring Report - Reform and Modernisation of the Ukraine Customs Administration, p3

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Customs facility were included in the final design, there appeared to be a neglect of some of the
expected aspects of Customs enforcement requirements. In particular, whilst scanner and
weighbridge equipment was provided none of the 3 BCPs was supplied with comprehensive, secure
and   dedicated   examination   facilities…whilst   it   is   true   that   warehouses do exist they are wholly
unsuitable for the task, due to their size, construction and position. The scanners, sophisticated
though   they   are,   can   only   acted   like   very   large   ‘flash   lamps’,   to   highlight   something   that   appears  
suspicious or does not fit with  a  normal  and  expected  pattern.  Once  such  a  ‘negative’  scanner  image  
has been obtained, the vehicle and cargo must be examined in depth to determine the true nature of
the  perceived  discrepancy.”

BOMCA

BOMCA supported the enhancement of client-oriented services and procedures related to the flow of
goods under a specific component that sought to “….demonstrate  the  relevance  of  an  IBM  approach”.
Under this objective the project planned to build and equip BCPs along relevant trading routes, to
carry out surveys and hold seminars on trade and transit, and to implement training for border guards.
“The  survey  took  place  in   all   Central   Asian  countries   (except  Uzbekistan)  and   is  due  to  be   updated  
under the BOMCA 7 phase. In parallel a large amount of infrastructure has been provided by BOMCA
in  the  region  but  it  is  unclear  if  the  provision  of  this  infrastructure  has  facilitated  trade  in  any  way.”

Accordingly. even though there have been some improvements in terms of improving procedures,
equipment and infrastructure, the implementation of trade corridors which was planned under
BOMCA 6 and 7 has not been completed, due to the political situation in Central Asia. It was noted
that the introduction of the trade component   was   “too   ambitious   and   not   fully   endorsed   by   the  
beneficiaries.“

It is noteworthy that in the project documentation scrutinised there is reference to the trade-offs
between trade and security concerns, “The  infrastructure  provided  consists  of  border posts in remote
regions and some border crossing points but apparently not with a primary objective of facilitating
trade. The reason for this is that the issue of security is a much higher priority for all five CA countries
and is demonstrated by the closure of the BCP provided by BOMCA on the border between
Uzbekistan and Kyrgyzstan due to the ethnic troubles The concept of focusing on trade corridors
appears to have been introduced under the BOMCA 6 phase, and the reason is unclear, but some
are of the view  that  the  trade  component  is  too  ambitious  and  not  fully  endorsed  by  the  beneficiaries.“

The BOMCA Evaluation of Trade Facilitation Impact acknowledges that “all  BOMCA  activities  should  
promote recognition of the trade-inhibiting role of border controls, and encourage national authorities
to recognize the trade-offs between justified controls of people and goods and curtailing the benefits
from  trade”.  

The BOMCA Trade & Transit report mentions the need “….improve   the   implementation   and  
sustainability of   several   initiatives,   most   notably   the   projects   that   support   ‘single   window,   trade  
facilitation  committees  and  regional  transit  agreements.”  

A summary of BOMCA initiatives and activities in relation to BCP layout and environment includes the
BOMCA 6 plan to renovate and equip the railway BCP at Nau on the Tajik/Uzbek border. However, in
the course of the project it was decided to reallocate funds to the BCPs a Patar and Fotekhabad. The
construction of the Patar BCP was then delayed. Also under BOMCA 6 there was a plan to build a
BCP at Kunia Urgench in Turkmenistan. However, delays in the contracting of the construction were
so severe that the Turkmen authorities decided to fund the activity themselves, considering the BCP
to be of a high priority. Of BOMCA 7 it can be seen that there was a plan to renovate and equip the
BCP at Andarkham-Avto in Uzbekistan but in the evaluation period nothing more had been done in
this respect. A trade facilitation survey was implemented in November 2010. BOMCA was also
involved in upgrading BCPs on both sides of the Kyrgyz-Uzbek border.

Whilst the EU has provided limited funding support for equipment in relation to that for infrastructure, it
has provided significant support in the use of equipment. This support has come in the form of
training, technical assistance and mentoring as well as in major reorganisations to allow beneficiaries
to establish operation structures that can make more efficient use of the equipment supplied. Often the
training was on the use of equipment which has been supplied by other donors or purchased in house.
This has often been in conjunction with other donors who did not have sufficient capacity in situ to
deliver the training necessary to accompany donations of equipment. This is particularly noticeable in
the CAFAO programme where the practice of equipment supply without training was effectively
countered.

The equipment in question generally comes in two forms:

electronic data processing systems to allow for the efficient acceptance and clearance of
Customs declarations,

Thematic global evaluation of the European Union's support to IBM & OC
Final Report Volume II; April 2013; Particip GmbH/EGEVAL II

132

more accurate risk management and greater opportunity for pre-arrival notification and search
equipment to allow for greater levels of detection of non-declared, smuggled and concealed
items (Western Balkans).

Despite the major support given in this area, especially in training of border management skills such
as risk analysis, traffic clearance times are generally still too long and enforcement results not
sufficiently high. Risk analysis as a technique is understood only too well but there are many reasons
(such as limited IT, lack of high level support, corruption, resistance to change) why implementation is
not always satisfactory and effective (ELARG countries, Ukraine, Afghanistan).

Box 24: Main evidence of EU support in the use of equipment

CAFAO

All Western Balkans Customs Administrations have electronic declaration processing systems in
place but many are out-dated or limited in their capability and compatibility. For Montenegro the EU
Customs Blueprints Exercise report points out that a “Computerised   risk   management   system   in  
place  for  import  traffic”. The report of the same exercise for FYRoM says “In  2009  MCA  started  the  
implementation of the new CDPS system, fully aligned with the EU requirements. The project suffers
of  some  delays  and  MCA  should  continue  its  implementation  as  a  matter  of  urgency.”

Albania

The IBM Regional Assessment & Monitoring Team report for Albania (2009/10) states that the
“Customs computerization program continues to make good progress, with the migration to
ASYCUDA World being completed in June 2009. The Risk Analysis Committee sets the risk
parameters for the ASYCUDA system – yellow or red, with the main criteria being origin, type of
goods, past trader history and performance, and also dual-use goods. Customs does not currently
apply the green channel (Customs declarations discharged without physical and documentary
control), which does tend to make the clearance system more complex and certainly slows down the
procedure for the release of goods.”

The EU Customs Blueprints Exercise report for Albania (2011)  records  that  “A   ‘clearway’,  red/green  
channel system is in place at Tirana airport but is not being correctly operated and its purpose as a
facilitation yet control measure is not being properly applied.”

Serbia

The EU Customs Blueprints Exercise report for Serbia (2011) highlights an objective of the
establishment   of   a   ‘single   window’   system   for   customs   declarations.   However,   it   is   not   yet   in   place.
“Customs   has   used   the   national   IBM   strategy   to   begin   the   process   of   the   introduction   of   the   ‘single  
window’  as  a  priority  but  so  far  this  concept  is  not  yet  in  place.” (p. 12)

The same report, “The  CDPS  is  providing  functionalities  that  are  fulfilling the requirements of current
national Customs legislation. However, from the technological point of view it is an obsolete system
(established in 1995). It was developed completely in house using old-fashioned programming
languages. A few years ago, a strategic decision was made to upgrade all software applications.
However,  the  programming  language  selected  is  already  obsolete.”

Ukraine

The Joint Evaluation Report of the EU-Ukraine Action Plan points out that there have been positive
developments in trade facilitation and speeding up of customs procedures, including measures to
implement   the   concept   of   a   ‘single   window’ under the intervention Modernisation of the Customs
Administration at the Borders. Further measures, to modernise customs procedures and fight
corruption, are being envisaged.

BOMCA

BOMCA  supported  a  ‘single  window’ approach and the use of automated systems, however it is not
clear from the project documentation how this has taken place and to what extent this has been
successful.

One major issue that recurs with regularity when evaluating the supply of infrastructure and equipment
is that of sustainability – the ability of the beneficiaries to be able to run, maintain, repair and update
what has been donated, separate to funding or know-how provided. In most cases, it would be

unacceptable for the EU to fund these costs, when it had already funded large amounts for the works
or procurement themselves. In a few, justifiable cases such as the funding provided by EU for the Law
& Order Task Force in Afghanistan, this expenditure is necessary for basic stability, but in general, the
need for beneficiaries to provide sufficient funding themselves is regarded as a sign of ownership of

support or not. In this area, there are many disappointing examples that outweigh the positive (positive
– Belarus; negative - Afghanistan).

Thematic global evaluation of the European Union's support to IBM & OC
Final Report Volume II; April 2013; Particip GmbH/EGEVAL II