EValuation border manag org crime

47

Figure 17: Results of the survey to EUDs: Main reasons for the delays in
implementation

External factors

EC procurement procedures

Quality of the management

Quality of initial design

Delay in delivery of equipment

0 2 4 6 8 10 12 14 16 18

Very high High Low Very low

Source: EUD Survey (Particip; 2012)

Despite the problems mentioned above, it appears that most EU funded interventions were eventually
successfully completed ensuring a high level of effectiveness. This is greatly explained by the
flexibility of the EU or the implementing organisation in the management of the intervention.
For instance,

In Mauritania, despite some difficulties due to political instability in 2008, the activities carried
out under national and regional programmes enjoyed a relatively high level of efficiency. This
is partly explained by the fact that the implementing partner (Guardia Civil) could rely on its
own resources to overcome several problems faced during the implementation. This is
illustrated by the equipment provided by Spain during the Seahorse training activities. The
Final   Report   of   the   project   indicates:   “Due to the practical nature of the courses some basic
material has to be provided, especially clothes for divers and tools for mechanics. Spain
through bilateral programmes has also provided Mauritania with material on this field.”
In Afghanistan, the final report of the BOMBAF  project  indicates:  “Despite an initial agreement,
the Tajik Border Force eventually comprehensively rejected BOMBAF proposals to train senior
ABP and ACD Officers in Khorog, Tajikistan on several separate occasions. Such an attitude
caused delays in programmed training events and necessitated revisions to the overall project
implementation schedule.”
The relatively high level of efficiency is confirmed by the ROM analysis carried out in this
evaluation (see Annex 7 - Volume III). 91% of ROM reports screened  in  this  evaluation  score  “good”  or  
“very   good”.   None   of   the   monitoring   missions   have   reported   “serious   deficiencies”   in   terms   of  
efficiency.

3.2.3 Ind323 - Evidence that the implementing organisations' capacity and experience were
adequate to achieve the objectives of the support

As depicted by the following figure (see also the results of the inventory of the EU support presented
in Annex 3 - Volume III), EU support to IBM and OC is largely provided via two types of channel: the
‘Private  Sector’  and  ‘Non-EU  Development  Agencies  and  other  international  organisations’.  Contrarily  
to other sectors of co-operation, where a substantial part of EU support has been channelled to
governments, only 9% of IBM support is channelled towards them.25

25 88% of the funds channelled towards Governments have been received by Morocco. This  refers  to  the  “Appui
budgétaire   relatif   au   Programme   d’urgence   d’appui   au   développement  institutionnel   et   à   la   mise   à  niveau   de   la  
stratégie migratoire au Maroc”.

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

48

Figure 18: EU commitments by funding channels (2002-2010)

Undefined Civil Society

1.0% 0.6%

Government Private Sector
8.7% 43.2%

Non-EU
Development
Agencies and

other
international
organisations

26.2%

EU Member
States and EU
MS Institutions

20.3%

Source: CRIS and Particip analysis (2011)

It is important to note that the big share associated to the private sector category mainly correspond to
construction work, the provision of equipment or the contracting of specific technical expertise (e.g.
CAFAO). The EU funded programmes were essentially managed either directly by the EU (usually
involving a Project Management Unit) or by other international organisations such EU MS institutions
or Non-EU Development agencies.

It is also noteworthy that more than 80% of the funds under Non-EU Development Agencies and other
international organisations have been channelled through UN institutions.

The information collected (see also case studies in Volume III), shows that, overall, implementing
organisations' capacity and experience were adequate to achieve the objectives of the support.

As shown in the diagram below, the survey to the EUDs illustrates that most of the funding channels
present some level of suitability for the support to border management. It also highlights that some
clear reservations are expressed as to the suitability of involving NGOs and the civil society and, to a
certain extent, the private sector in border management interventions. This underlines the difficulty of
significantly involving these types of actors in security-related areas of co-operation.

Figure 19: Results of the survey to EUDs: Suitability of funding channels for the EU support to
border management

Partner country government

Non-EU Development Agencies & other
international organisations

EU Member States and EU Member State
institutions

NGO and Civil society

Private Sector 4 6 8 10 12 14 16 18
02 Very low Not used

Very high High Low

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

49

Source: EUD Survey (Particip; 2012)

Channelling through EU Member states, UN agencies or other international organisations

The evidence gathered during desk phase indicates that channelling the aid through EU Member
states, UN agencies or other international organisations (e.g. IOM) presents a number of
advantages

Interestingly, these organisations have represented a positive factor for enhancing the efficiency
and effectiveness of the support. Indeed, in several occasions, partner organisations have drawn on
their own resources to overcome obstacles that arose during the implementation of the interventions
or to complement the activities carried out. For instance,

In Afghanistan, BOMBAF management shows a high level of flexibility as illustrated by the
additional training activities carried out during the implementation of the project. The final
report  of  the  project  notes:  “During 2009, BOMBAF organized and conducted on-site training
for ABP officers on the use and maintenance of diesel-electric power generators. Although this
was not part of the initial plan, it became apparent during the project implementation phase,
that training on the use of equipment to beneficiaries is needed to sustain the day-to-day
activities of the ABP in Badakhshan province. During training on the use and maintenance of
generators, twelve officers from the three BCPs, as well as personnel from the Mobile
Interdiction Teams were trained.”

In Mauritania, one of a major implementing partner (the Spanish Guardia Civil) could rely on
its own resources to overcome specific issues faced during the implementation. This is
illustrated by the equipment provided by Spain during the Seahorse training activities. The
Final   Report   of   the   project   indicates:   “Due to the practical nature of the courses some basic
material has to be provided, especially clothes for divers and tools for mechanics. Spain
through bilateral programmes has also provided Mauritania with material on this field.”

As highlighted in the qualitative response provided by the EUD to the online survey, UN agencies as
well as the EU Member States and, more generally, the EU present a significant comparative
advantage in Eastern Europe and Central Asia. They are considered as neutral compared to other
international stakeholders such as the US or Russia.

Moreover, as also highlighted in Indicator 311, working with these organisations allows for reliance on
their geographical experience and specific technical expertise. This advantage was apparent in a
number of cases analysed in this evaluation. For instance,

In Central Asia, from the start, BOMCA strongly relied on the EU MS technical experts to
design and implement the intervention. This was clearly underlined in the interviews carried at
EU HQ during the desk phase and in the field visits.

In Afghanistan, the EU has relied extensively on the experience of UNDP Tajikistan for the
support to border management in the Northern part of the country. The EUD indicates in the
online survey carried out during the desk phase that relying on this organisation allowed for
increased  access  to  local  stakeholders  and  to  benefit  from  “good technical experience”.

In Mauritania, the EU has relied on the IOM and EU MS for the implementation of several
activities related to migration management or more generally border management. In the
online  survey,  the  EUD   highlights  the  “long experience in the field of migration”   of  IOM. The
project documentation analysed also shows that the fact that IOM activities covered well the
region (with a regional office in Senegal) was considered as a significant advantage.

However, as highlighted by one EUD in the survey to the EUDs carried out during the desk phase, the
strengths  of  the  international  organisations  also  very  much  depends  “on the expert on site rather than
on the organization per se”.

Moreover, working with these organisations presents a number of challenges. One major challenge
relates to the complexity of the  organisation’s  internal  procedures that adds up with the one of the
EU hampering the overall efficiency of the implemented intervention. For instance,

In Central Asia, the 2010 evaluation of the BOMCA programme explains: “The other issue is
the apparent difficulty of UNDP in terms of tendering and contracting staff. As a result each of
the phases of BOMCA has been delayed, up to one year in some cases, with recent phases of
BOMCA facing severe delivery problems. UNDP also faced difficulties in contracting
international border experts mostly due to internal regulations of the UN [i.e. large number of
procedures]. As a consequence this aspect was subcontracted to a third party (the
International Centre for Migration Policy Development or ICMPD). In practice this added yet
another implementation layer (and therefore additional costs) to an already complicated
implementation  structure.”

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

50

Another challenge relates to the fact that there is a tendency to fully delegate the oversight of the
activities to the partner organisation. This arrangement poses problems of accountability (the partner
organisation following its own internal reporting system which is not necessarily in line with EU
standards) and does not always allow for the identification of difficulties early enough to make
potential necessary adjustments. For instance,

In Central Asia,   the   2010   evaluation   of   the   BOMCA   programme   notes   that:   “BOMCA is not
implemented by a contractor based on contractual obligations but by an international
organisation (based on a partnership agreement and specific regulations- FAFA) which has its
own aims and objectives. Therefore the issue of oversight is crucial.”

In Afghanistan, some serious deficiencies were faced during the implementation of the project
“Regional  cooperation  in  Precursor  Control  between  Afghanistan  and  Neighbouring  Countries”  
by UNODC. The 2009 Mid-Term Evaluation of the EU support to BM in Afghanistan notes
that: “The performance of the UNODC as an implementing partner, especially in the project
was not always to a satisfactory level to allow the [EUD] to fully monitor and manage the
project to their requirement. It is recommended that if further EUD projects, implemented by
the UNODC are considered, then a more formal process of project monitoring be adopted,
with the EUD having access to the UNODC internet based project management system and

the holding of routine and systematic face-to-face briefings following the submission of each
monthly report to the EUD.”  The  report also notes that: “UNODC  is  divided  into  departments  
according to the projects it is implementing and in each department separate project teams
are assigned to each project. The EU funded projects were 2 of the 6 projects being
implemented by the law enforcement department of UNODC and they were managed by 2
separate project teams. When evaluating these two projects, it would be fair to consider them
as  projects  implemented  by  2  independent  and  separate  UNODC  teams.”

Interviews carried at EU HQ also highlighted the fact that working with international organisations (UN
or others) which rely on experts coming from different backgrounds runs the risk of losing the
‘European   dimension’   of the approach. This was illustrated during the field visit to Serbia where,
despite the best efforts of the Italian Customs Agency, the twinning project that they are implementing
with Customs and Tax is widely regarded amongst the beneficiaries as an Italian project and not and
EU one.

Finally, regarding the monitoring of the interventions by the EU, the 2010 evaluation of the BOMCA
programme points out the fact that:

“the  overall  control  by  the  EU  was  mostly  in  the  hands  of  one  task  manager  based  in  Almaty  who  

was responsible for BOMCA oversight in addition to several other EU-funded projects. As a
consequence and despite the dedication of this EU officer, EU oversight of the programme has
been limited. The EU should consider establishing a permanent monitoring capacity with a solid
capability to steer on a daily basis such complex assistance projects. The BOMCA programme is
intrinsically complex due to its implementation in several countries (two in which the Delegation is
not accredited), different objectives and sensitive issues. In addition BOMCA is not implemented
by a contractor based on contractual obligations but by an international organisation (based on a
partnership agreement and specific regulations- FAFA) which has its own aims and objectives.
Therefore  the  issue  of  oversight  is  crucial.”26

3.2.4 Ind324 - Evidence of synergies between the different EU financial instruments used in
the areas of IBM and OC

The table below provides information from the inventory of the EU support to IBM and OC related to
the financial instruments used to funds the interventions in this area during the evaluation period.

Table 4: EU committed amounts by financial instruments (2002-2010)

Budget Lines (Domain) Commitments
(EUR)

Geographic instruments 290,584,434
178,992,183
TACIS (Technical Assistance to the Commonwealth of
Independent States)

CARDS (Community Assistance for Reconstruction, Development
& Stability in the Balkans)

26 EU (2010): Evaluation of the BOMCA Programme, Final Report 2010, p.31.

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



































68

5 EQ  5  on  border  co-operation

Evaluation Question 5: To what extent has EU support to IBM and OC contributed to improving intra-
agency, inter-agency and international co-operation related to border management?

5.1 JC 51 - EU support has contributed to enhance the development of a
conducive environment for co-operation in border management at
national and international level

5.1.1 Ind511 - Existence of a national government structure to co-ordinate, manage and
direct IBM and OC, in-country and cross borders

Evidence on EU contribution to the creation and existence of national government structures to co-
ordinate, manage and direct IBM and OC, in-country and cross borders, has been found in several
cases across regions.
In the ELARG region:

In Albania, following the implementation of a national IBM strategy, a national government
structure, an Inter-Ministerial Committee, to co-ordinate and oversee the implementation of
the IBM Strategy and Action Plan, manage, direct IBM and OC has been created. This is
illustrated in an IOM Assessment and Monitoring Mission Report: “An   Inter-Ministerial
Committee on Integrated Border Management has been established, which is chaired by the
Ministry of the Interior and assisted by a Technical Secretariat; to oversee and to coordinate
the implementation of the IBM Strategy and Action Plan. In addition, a Joint Regional and
Central Commission for the coordination of IBM related activities between the main agencies,
has been established. The Border and Migration Police (BMP) have been assigned to lead the
implementation  of  IBM.”  (p. 15) Field mission interviews showed that this structure was still in
place and in the main functioning effectively.

In Serbia, an Inter-Ministerial Co-ordination Body was created and IBM Inter-agency Sub-
Working Groups and Regional IBM Centres were established in order to co-ordinate the
implementation of the IBM strategy and guide the co-ordination in border management at the
national level: “In   May   2009,   by   Government   decree   an   Inter-Ministerial Coordination Body
was established, responsible for the implementation of the IBM Strategy and Action Plan. The
Ministry of the Interior plays the lead role in the coordination and implementation process of
the  IBM  Strategy.”43 In addition to this Inter-Ministerial Co-ordination Body, IBM Inter-agency
Sub-Working   Groups   and   Regional   IBM   Centres   were   established:   “The Inter-Ministerial
Coordination Body will be supported by IBM Inter-agency Sub-Working Groups, responsible
for the various tasks including modernisation of BCP infrastructure; joint procurement of IT
and communication equipment; development of IT systems and databases; and joint risk
analysis. Operational Working Groups at regional and local level have been set-up tasked with
conducting gap analyses on border management related procedures and to draft: joint
operational guidelines / instructions regarding joint inter-agency actions; procedures for the
controls on trains, vessels, and vehicles; an effective organizational structure of border control
procedures to avoid duplication and overlapping of controls; and the introduction of the
‘one-stop’  control  concept  with  joint  search  of  vehicles.  “  (p. 89)

As for CAFAO, IBM coordinating bodies and working groups are in place in all beneficiary
countries.
In the ENP region:
In Ukraine, as illustrated in HUREMAS II final progress report44, an Interagency Working
Group on development of National Concept of Integrated Border Management in Ukraine
exist. In this working group, representatives from the Ministry of Justice, Foreign Affairs,
Internal Affairs, State Security Service, State Customs Service, Ministry of Transport and
Communication, Ministry of Health, Ministry of Labour and Social Policy participate.
In addition the CSE Ukraine45 refers to the existence of a coordination system at ministerial
level to support the process towards IBM. However, the CSE critically mentioned that “the  
division of responsibilities between the police and UASBGS is still an issue. In general, the
institutional set is not yet supportive  for  IBM  since  coordination  mechanisms  are  still  lacking.”

43 IOM (2010): Assessment and Monitoring Mission Report, p. 82
44 IOM (2010): Huremas II Final Progress Report, p.1.
45 EU  (2010):  Evaluation  of  the  European  Commission’s  Cooperation  with  Ukraine,  p389.

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

69

In Asia:

In Afghanistan, aspects not directly covered by the EU support to BM in the country. However,
in the 2009 Mid-Term Evaluation of the EU support to BM in Afghanistan a Ministry of Finance
initiative   is   detailed   thus:   “The Joint Coordination and Monitoring Board (JCMB) exists as a

means of maximising donor coordination and the development process in Afghanistan, The

EUD is a full member. It oversees development projects funded both internally and through

donor assistance. The Economic Governance sector covers Customs matters which are

divided into 9 sub-projects including such work areas as public outreach, post clearance audit,
mobile teams, VAT, enforcement and the proposed  Customs  training  academy.”

As for BOMCA, according to the BOMCA evaluation report, during the evaluation period, first
attempts have been undertaken to draft an IBM strategy in Kyrgyzstan. These attempts have
contributed to some extent to enhance the development of a conducive environment for co-
operation. Activities included for example discussions with the Kyrgyz authorities and
establishing a national co-ordination on BOMCA. In addition, very little developments are
evident in Tajikistan, and Uzbekistan due to BOMCA support, mainly related to changes in the
mindset of the authorities. 46

In ACP and LA:

In Mauritania, the EU support has only contributed to the establishment of an interministerial
committee on Migration issues (Comité Interministériel sur la gestion de la Migration – CIM),
which is clearly a first step towards more formal inter-agency co-operation. Although this
committee has been established and represent a great potential for future action in the area of
BM and migration, little was done by the committee during the evaluation period.

Under SEFRO, a focal point and a National Commission for issues of border security have
been created in all beneficiary countries, in order to manage and direct the activities related to
SEFRO in the country. In addition, SEFRO liaised and established links with several relevant
regional co-operation institutions, i.e. the CJDPCAMCA (in relation to the police), OCAM (in
relation to migration) and SIECA (in relation to customs). The organisation of high level
seminars, aiming at harmonising policies related to border management and promoting a
regional and co-ordinated approach, is in progress. The seminars are scheduled to take place
in the second half of the year 2012.47

5.1.2 Ind512 - Legislative reviews related to co-operation in border management have been
conducted and recommendations have been implemented for/by relevant border
institutions

Very little evidence has been found on EU contribution to the conduction of legislative reviews related
to co-operation in border management and implementation of recommendations by relevant border
institutions.

In the ELARG region:

In Albania, field mission interviews and site visits showed that legislative reviews had taken
place in order to establish both the joint border crossing point and IMOC. PAMECA, CAFAO
and TACTA all played a significant role in this process. The current legal framework for IBM
within Albania was regarded as being satisfactory by the beneficiaries interviewed.

In particular, CAFAO missions provided legal advice and input to legal reviews with the
intention of creating an environment of harmony. CAFAO Missions often played the lead role.
CAFAO provided legal and technical assistance support via working groups with Customs and
other beneficiaries. Resultant operational IBM legislation is in place in all beneficiary countries

(need to see legislation for evidence).

In the ENP region:

In Ukraine, EU support has contributed to enhance the development of a conducive
environment for co-operation in border management at national and international level, mainly
by supporting the development and approval of the national IBM concept under the
HUREMAS interventions. More precisely, the support included establishing an Interagency
Working Group with participants from several ministries, conducting legislative reviews, and
supporting agreements regarding co-ordination principles.

46 EU (2010): Evaluation of the BOMCA Programme, Final Report 2010, p.19.
47 Ayuda de Memoria, II Reunión de Puntos Focales, Tegucigalpa, Honduras, 8 y 9 de mayo 2012

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

70

Legislative reviews related to co-operation in border management have been an activity under
HUREMAS I and II. This basically refers to the approval of the Concept of Integrated Border
Management in October 2010.
As illustrated in the HUREMAS II final progress report48 the IBM concept and the
Implementation   plan   serve   as   a   “road map for multi-actor activities to be carried out to align
Ukraine’s  border  management  system  with  that  of  its  partners  in  the  EU.  This  capacity  building  
exercise in project development and management adds clarity for partners and policy makers
in the domestic, regional and international context. Additionally, related documents should
spell out needs and opportunities for measured assistance, in part through sector budget
support  in  border  management  and  Eastern  Partnership  border.”

As for EUBAM, the evidence available emphasizes the role recommendations made by
EUBAM have played in order to stimulate cross border co-operation. By drawing on the CSE
Ukraine, “EUBAM  has  made  recommendations  for  better  cooperation  within  the  framework  of  
integrated border management, and these are now step by step being implemented at the
central  level.”49
In Afghanistan, aspects related to this indicator have not been covered by the EU support to BM.

5.1.3 Ind513 - Formal agreements and operational measures regulate and encourage border
agency collaboration at national and international level

Evidence on EU contribution to formal agreements, in particular MoU, and operational measures
regulating and encouraging border agency collaboration at national and international level, has been
found in several countries across regions. In the ELARG region:

On an international level Albania has signed formal agreements with some countries, i.e.
Kosovo and FYROM regarding the establishment of joint and synchronised border patrols.
Albania has signed formal agreements with Kosovo and fYRoM regarding joint border patrols.
This is confirmed by the Albania 2011 Progress Report: "Agreements, which enable joint
and synchronised patrols of borders by the police, have been signed between Kosovo
and Albania and the former Yugoslav Republic of Macedonia." (p. 57)
The Regulation on Collaboration between Customs Service& State Police states that it was
brought into force in June 2008, “With   the   purpose   of   creating   a   real   and   prolific   spirit   of  
collaboration  between  structures  of  State  Police  and  Customs  Service.”
The Border & Inland Control chapter of the EU Customs Blueprint report 2011 states that “an  
MoU with the Border and Migration Police has been signed. Roles and responsibilities at the
border have been formally agreed and are in general understood, although further clarification
will  be  made  in  the  next  revision  of  the  IBM  strategy/action  plan”.  However, it then goes on to
state   that   “Despite the IBM national strategy, at operational level, cooperation with national
and neighbouring border control agencies does take place but it is inconsistent and not
uniformly implemented. With Kosovo and FYROM, for instance, relations are good, whereas
with Greek authorities things are much more difficult. A limited number of MoUs have been
signed with relevant agencies and international Customs Administrations and implementation
is  inconsistent.”  Field interviews showed that border agency collaboration takes place with all
Albania’s   neighbours   and   is   regulated   by   MoUs   and   SOPs.   Through   PAMECA   and   CAFAO  
and direct MS assistance, these agreements are generally regarded as being satisfactory and
in certain circumstances (particularly cooperation with Italy, Kosovo and Montenegro) very
productive.

In Serbia, the IBM Strategy and Action Plan created an important basis for the co-operation of
border management agencies. An Inter-agency Co-operation Agreement defining areas and
forms of co-operation at central, regional and local levels, was signed between various
Ministries in Serbia. This is highlighted in the IOM Assessment and Monitoring Mission Report:
“In   February   2009,   an   ‘Interagency   Cooperation   Agreement’   was   signed   between   the   Ministry  
of the Interior, Ministry of Finance, Ministry of Agriculture, Forestry and Water Management
and Ministry of Capital Investments. The agreement defines the areas and forms of
cooperation  at  central,  regional  and  local  levels.” (p. 82)

48 IOM (2010): Huremas II Final Progress Report, p.1.
49 EU (2010):   Evaluation   of   the   European   Commission’s   Cooperation   with   Ukraine, Final Report, volume 2
Annexes, p.411.

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