Current Situation

Following recent Schengen Evaluation Reccommendations (SR) and the strategic framework for European Integrated Border Management (EIBM), the National Integrated Border Management Strategy (NIBMS) Plan aims at achieving situational awareness and early warnings. It is structured in 4 pillars:

• Measures to be implemented in Third Countries
• Cooperation with neighboring Countries
• Border Controls
• Measures in the free movement area

NIBMS is implemented through National Coordination Centre (NCC), namely through:

• Amendments and monitoring of NIBM strategy
• 6-monthly progress reports identifying delays on predefined
• Mid-term assessment and proposals for necessary

Consistency between BMVI and the NIBMS as well as the European Border and Coast Guard (EBCG) capability development planning, in particular the National Capability Development Plan (NCDP) and the future capability roadmap is to be ensured. The NCDP is in place and provides a comprehensive picture of the national capabilities of all competent authorities, aligned with the National and European IBMS.

New External Service Providers (ESPs), BREXIT and Greek tourism, led to an increase in Schengen visa applications. The Multiannual Financial Framework (MFF) 14-20 supported VIS. To maintain a robust and up-to-date system additional workstations, software, infrastructure, operational costs and other costs related to consular authorities are forseen.

Border management

Relevant Data (source: Hellenic Police)

Border Crossing Points (BCPs): 106 (9 land, 59 maritime and 28 air); 6 of them operate during the summer only.

Following the decrease observed in 2017, migratory flows increased significantly in 2018. Arrests of irregular Third Country Nationals (TCNs) rose up to 54,859 (27% higher than 2017). The largest increase was on Evros and Greek (EL)-Bulgarian (BG) borders, and the largest decrease on north Dodecanese islands and Chios. Irregular entries continued to rise in 2019, amounting to 77,522. 97% of all irregular entries occur in EL-Turkish (TK) borders.

In 2020, 16,897 individuals were arrested for illegal entry; 5,296 were arrested during the first semester of 2021.

Inflows of 2015-2016 (over 500,000) led to depletion of resources. The Internal Security Fund for Borders (ISF-B) supported border management with EUR 285.2 mil. During 2018-2019 arrivals increased by 40%, while in 2020 they decreased by 78%. From 2017 to 2021 migrant apprehensions remained relatively high, with 77,522 in 2019 and 16,897 in 2020, mainly due to COVID19. Migrant entries decreased in 2021 (first 7 months) to 5,296, yet there is a 100% increase compared to the same period in 2020.

Lessons learnt

Automated surveillance systems contributed to border protection. However, the primary focus was to reinforce police in BCPs rather than updating technical equipment and transportation means.

Challenges & Needs

• Up-to-date, efficient border surveillance system at sea and land borders
• Upgraded border surveillance equipment and infrastructures
• New technology for border control and situational Upgrade EUROSUR to meet the requirements of Reg 2019/1896 & 2021/581
• Quick and effective passport controls at BCPs
• Maintenance of Multipurpose Reception and Identification Centers (MPRICs) within the remit of BMVI
• Enhance border support through enforcement and administrative staff
• Collection of verifiable data verifiable by national and international Develop/upgrade Schengen Information System (SIS) , European Travel Information and Authorization System (ETIAS), Automated Fingerprint Identification System (AFIS), Visa Information System (VIS) and Automated Biometric Identification System (ABIS).
• Implementation of large-scale IT Systems and its interoperability
• Upgrade of risk analysis methodology and dissemination to all relevant authorities
• Staff engaged in border management training
• Organize, manage, operate, provide security and maintenance to ETIAS National Unit
• Host the National Uniform Interface (NUI), essential component of EES and ETIAS system that allows interoperability within Ministry of Foreign Affairs (MFA) Data Centers
• Connect national border infrastructure, Central Access Points (CAPs) and competent Authorities to the NUI
• The establishment of an Automated Border Surveillance System at the borders with Albania and the Republic of North Macedonia, as well as the majority of surveillance means that will be acquired through BMVI, will enhance the national situational picture already established by NCC in accordance with Art. 25 of Reg. 2019/1896
• Human Resources (HR) strategy is not in place and for that purpose. A study under technical assistance will be conducted in order to define a sustainable strategy. The HR strategy (more details for the study to the annex) is to increase, inter alia, the Hellenic Police’s (HP) capacity via the creation and use of pools of experts in certain areas, such as screeners, debriefers and Advanced Level Document Officers (ALDOs).. The scope is to achieve a standard procedures on staffing or reinforcing front-line police units providing border management tasks at the EU external border, such as BCPs.

National Strategy

• Improve BCPs to ensure efficient controls
• Reinforce authorities at BCPs to enhance the level of control
• Upgrade situational awareness capabilities
• Implementation of EUROSUR in line with Reg. 2019/1896 & 2021/581
• Strengthen surveillance operations and focus on controlling secondary flows
• Enhance staff skills, including those deployed to the Standing Corps (Cat.2, 3);
• Cooperate with other MSs and EBCGA
• Facilitate legitimate border crossing
• Prevent and detect irregular migration and cross-border crime

Main Actions

• Improve border control capacity, deploying border guards to areas whith large migratory flows, materializing lessons learnt during the recent migration crisis
• Increase effectiveness in travel document controls at BCPs resulting in better migration flow
• Preserving Schengen area without controls at internal borders. This requires efficient controls at the external borders and ensuring that border controls at internal borders are reintroduced only as a last resort measure for limited period of time.
• Member States should allow to prioritise border management measures taking into account the likely development of the legislative framework
• Digitalization of travel documents (harmonised standards implemented by all Member States will facilitate the whole travel process and interoperability);
• Equipping BPCs with the technical capacity to check fingerprint biometerics encoded in electronic travel documents against holder of the document. Related training will also be prioritized.
• Enhance existing surveillance system at the EL-TK border in compliance with the Schengen acquis
• Prioritise development of the legislative framework for border management
• Acquire surveillance technology equipment and land and sea vehicles
• Develop an Automated Border Surveillance System (ABSS) at the borders with Albania and the Republic of North Macedonia, similar to the already installed at the EL-TK land and riverine
• Develop a National Integrated Maritime Surveillance System (NIMSS)
• Upgrade of IT infrastructure in the NCC to ensure exchange of classified information up to EU classified level
• Upgrade of the NCC in order to ensure 24/7 operation (including staff training)
• Development of automated reports into EUROSUR to ensure machine-to-machine communication
• Development of necessary technical tool in order to ensure smooth transmission of information from the National Situational Picture (NSP) to the European Situational Picture;
• Enhancement of inter-institutional cooperation at national level in order to ensure effective provision of information from national authorities to the NSP.

Schengen Evaluation Recommendations (SR)

Based on the 2021 SR from the Council Implementing Decision 8184/22 and the new Action Plan Greece will prioritise addressing the majority of the SR under the BMVI. Namely, the streghthening of the national capacity to control and monitor the borders, the establishment of a coherent and comprehensive basic, continuous and specialised training system for border guards, the development of a coherent and comprehensive risk analysis system and a national methodology based on CIRAM. The procurement of the necessary equipment to perform border surveillance, scanning and detection is also included. Such information is further detailed in the supporting document “Additional Information and clarifications”.

Flagship Activities

All the equipment (see section 2) purchased will comply with technical standards set out by Frontex and large-scale operating equipment for border management will be registered in the Agency’s Technical Equipment Pool. It shall be used at national level and deployed for operations at EU level. It will be complementary to equipment purchased with Custom Control Equipment Instrument. At the same time, several of the actions refer to the acquisition of equipment, with a view to ensure effective border management, prevention and detection of cross-border crime and timely identification persons entering EU borders (including vulnerable persons).

In particular, the equipment of the Hellenic Coast Guard (HCG) may be used for assistance to persons in distress and supporting search and rescue operations in situations which might arise during a border surveillance operation at sea.

National capacity shall be reinforced with training and deployment of staff, such as advisers to fight identity fraud, in line with the national capability development plans for border management (see actions in section 2).

Greece prioritises all the requirements stemming from the most recent legislation of EU Acquis, such as EBCG Regulation, and transform these initiatives into actions.

• The quality control mechanism plan and the updated CIRAM are not in place and this and the enhancement of the collection and exchange of data for the purpose of risks analysis as required in the EBCG 2.0 Regulation will be funded by BMVI (see “Development of a National Quality Control Mechanism ” under section 2) and (“Preparation of a training curriculum related to efficient implementation of CIRAM”Development of national component of EBCG: All national authorities ensure efficient cooperation with EBGC and relevant authorities in other MSs, as well as with the Frontex. Training of national staff being deployed to the Standing Corps Categories 2 and 3, has already received basic and post-training courses focused on border management. This continues to be a priority under BMVI.
• Ensure the comperehensive implementation of Reg 2019/1896, including development of national component of EBCG, comply with technical standards set out by Frontex and register large-scale operating equipment in the Technical Equipment Pool of Frontex; measures related to the updated CIRAM;
• Development of a comprehensive training system for basic, continuous and specialised training of border guards as the current system is not efficient and not sufficient.
• Preserving Schengen area without controls at the internal borders; and measures taking into account the likely development of the legislative framework;
• Digitalisation of travel documents and equipping border crossing points with the technical capacity needed in order to check fingerprint biometrics encoded in electronic travel documents against the holders of the document. Related training will also be prioritised.
• Implementation of EUROSUR in line with the latest developments;
• Measures addressing all, currently and future outstanding shortcomings identified in the Vulnerability Assessment and SR.

Shortcomings to EU Acquis

A detailed list of elements of Regulation (EU) 2019/1896 regarding EUROSUR is already in place and is provided in the supporting document “Additional Information and clarifications”. Greece will prioritise the following elements to be implemeneted during the period 2021-2027:

• information exchange via NCC
• adequate number of staff to ensure 24/7 functionality
• Compliance with technical standards established by Frontex (in cooperation with Member States) machine-to-machine’ communication
• Infrastructure (monitors, IT equipment, competent staff, securitised area) to be operational by the end of 2022
• Full implementation of the NCC functionalities (National Quality Control Mechanism).
• Correct composition of an NSP
• Certified Common Integrated Risk Analysis Model (CIRAM) experts from all national competent authorities will be appointed in a working group, tasked with the drafting of the national methodology for risk analysis.

Visa policy

Relevant Data (source: MFA)

Greece has 129 consular authorities (with 350 officers) which receive Schengen visa applications. Additional personnel are deployed every year from the MFA central services or from the Police, according to needs.

Total arrivals: 11,613,000 (2017), 11,668,000 (2018), 12,795,000 (2019), 2,485,000 (2020). Visa

Applications: 1,029,564 (2017), 855,285 (2018), 880,892 (2019), 111,870 (2020).

Challenges & Needs

• New obligations and opportunities of the new Visa Code and VIS and interoperability rules
• Consulates allocate resources to detect “marriages of convenience” and to identify the actual purpose of a journey in the Schengen area
• Implement smart solutions to achieve resilience and flexibility
• Establish an evaluation system to ensure that EU law and SR are properly implemented
• Achieve mobility to implement new Visa Code provisions, including stricter monitoring of ESPs
• TMI to be addressed together with other Identify its effectiveness and future impact on the health system.
• BREXIT creates needs for additional consulate personnel
• Further explore consular cooperation options
• Digitalization of the Visa Process (pilot Visa On-Line system)
• Achieving sufficient Consular presence and Consular cooperation
• Develop IT tools for risk analysis and training
• Ensure interoperability of VIS with other EU large-scale IT systems

National Strategy

• Develop VIS to fully interoperate with other IT systems
• Modernize consular services, digitalize visa process, training and risk analysis
• Increase consular coverage and cooperation with other MS
• Increase the number of trained consular staff
• Monitor ESPs more efficiently

Main Actions

• Improve application processing & large-scale IT systems – VIS
• Reinforce HR dedicated to examine visa applications, especially in locations where processing time exceed the permitted maxima
• Train consular personnel to ensure streamline with Visa Code, VIS Regulation and other EU legislation
• Modify and upgrade VIS to implement the revised Regulation and relevant EU legislation
• Upgrade consular services and refurbish premises, to align with security and other Visa Code requirements
• Monitor ESPs and visit Consuls and Consulate IT officers regularly

Flagship activities

• All the flagship activities in the area of Common Visa Policy are prioritized within BMVI
• Upgrading of VIS and its interoperability with other EU systems, the uniform application of the EU acquis in relation to visas and the improvement of quality of services for visa applicants are in place and will continue to be prioritized by BMVI
• The digitalization of visa procedure is not in place and will be financed by BMVI based on the requirements of upcoming EU legislation

Justification on SO2 allocation below 10% threshold

The budget allocationfor SO2 is 13,47% of initial BMVI allocation prior to the transfer of other CPR funds. Moreover, it covers all needs to address the Common Visa Policy, incl. Flagship activities.

Synergies and complementarities

Based on the Partnership Agreement, 3% of other Common Provisions Regulation (CPR) funds (EUR 620 million) is being transferred to BMVI (from European Regional Development Fund (ERDF), European Social Fund Plus (ESF+), Cohesion Fund (CF) and European Maritime Fisheries and Aquaculture Fund (EMFAF)).

The Asylum, Migration and Integration Fund (AMIF) supports facilities for eligible target group (asylum seekers, refugees, beneficiaries of international protection, returnees). Services provided in islands and in Evros are eligible under BMVI before and/or within 25 days after the asylum application.

ERDF covers the “Establishment of an IT System for event management and pre-trial investigation” and “Establishment of an IT System for internal security and border surveillance” projects.

HORIZON 2020 supports projects that create synergies with BMVI, such as BorderUAS, TRESSPASS, FOLDOUT, NESTOR.

Planned use of financial instruments

The use of financial instruments is not foreseen for any of the activities of this programme.

Administrative Capacity

The new Ministry of Migration and Asylum (MoMA) impacted the structure of competent authorities, in particular the Management and Control Systems (MCS). The Responsible Authority’s (RA) move between Ministries implied changes in the procedures adopted. The authorities gained experience and know-how from the implementation of the MFF 14-20, but still face difficulties in covering the needs, mainly in terms of human resources and technical capacity.

The Managing Authority (MA) and key partners’ capacity will add staff, outsource consulting services, IT systems and improve procedures through technical assistance. MCS will be simplified in cooperation with experienced delegated authorities.

Additional info in ANNEX I

Baseline situation

The total length of the Hellenic land border is approximately 1,200 km.

National border protection needs constant improvement, in order to overcome smugglers adaptions to prevention means regularly used by border authorities. Consequently, border protection authorities need to reinforce their capacities continuously and invest in emerging technology for surveillance to continue responding effectively.

It is difficult to estimate the number of arrivals in the following years. However, climate crisis and war disputes will probably lead to an increased migratory pressure in the future.

Source: HP, Hellenic Coast Guard (HCG), NCC

Entries from BCPs:

• 2017: 28,315,526: 18,252,864 (EU),10,062,662 (TCNs)
• 2018: 26,915,673: 17,521,587 (EU), 9,394,086 (TCNs) ,
• 2019: 29,296,596: 19,960,599 (EU), 9,335,997 (TCNs),
• 2020: 5,808,567: 4,242,676 (EU), 1,565,891 (TCNs),
• 1st half of 2021: 3,140,372: 1,567,420 (EU),1,572,952 (TCNs)

Arrests for illegal entry: 43,211(2017), 54,859 (2018), 77,522 (2019), 16,897 (2020) and 5,296 (2021 1st sem).

Specific Challenges/Needs

• Prevent usage of forged/falsified travel documents
• Prevent border crossings through unauthorized entry points
• Prevent illegal border crossings of stowaways hidden in all possible means of transportation
• Combat trafficking of irregular migrants
• Ensure long term smooth cross-border traffic, despite of any increase
• Facilitate cross-border flows, while ensuring border security
• Use assets and tools from previous Funds to propose new actions, complementary to this NP, through specific actions, or to use the technical specifications material for the ToRs of new procurements
• Potential use of the iProcureNet network for joint cross border procurement

Continuity and changes compared to the current funding period / Lessons Learnt:

During MFF 14-20, Greece invested in personnel recruitment and training, supply of vehicles/vessels, IT systems, border control and surveillance assets and equipment, resulting in:

• Reduction of operating costs
• Reduction of the number of illegally incoming aliens
• Control of secondary migration flows, with the provisions of 1052/2013 (EUROSUR) (Reg. 2019/1896).

Many actions financed in MFF 14-20, either due to necessity or due to effectiveness, are foreseen for funding under MFF 21-27 also. Such actions include:

• Acquiring transportation means and patrol vehicles
• Renewing the fleet used for border surveillance
• CCTV surveillance systems and heartbeat detectors
• CCTV surveillance systems installed at border crossing points to assist the surveillance of its premises and the control of illegal entries
• Acquisition of heartbeat detectors to identify people hidden in modified crypts of vehicles
• Training personnel deployed at the BCPs
• Transition from temporary reinforcement of Border Services to a more permanent scheme (e.g. recruitment of personnel)

Implementation measures - Annex II, par.1, (a)

• Preserving Schengen area without controls at internal borders. Ensuring efficient controls at the external borders and ensuring that border controls at internal borders are reintroduced only as a last resort measure for limited period of time. Prioritise border management measures taking into account the likely development of the legislative framework
• Measures related to the implementation of updated CIRAM and the enhancement of the collection and exchange of data for the purpose of risks analysis as required in the EBCG 2.0 RegulationEquipping border crossing points with the technical capacity needed in order to check fingerprint biometrics encoded in electronic travel documents against the holder of the document
• Upgrading EUROSUR through the acquisition of all the necessary IT infrastructure complying with Frontex technical standards and the necessary equipment to ensure that NCC’s performance of tasks provided for in Reg. 2019/1896 and Reg. 2021/581. In addition, the development of necessary technical tool to ensure smooth transmission of information from the NSP to the ESP.

Indicative Types of Actions (in line with Article 13(14)(b) and technical standards set out by Frontex)

Land Vehicles: [Annex III, (1), (b)]

• Vehicles equipped with integrated thermal imaging cameras and satellite communication
• Supply and maintenance of Unmanned Ground vehicles
• All-terrain vehicles
• SUVs equipped with thermal imaging
• Vans equipped with x-ray identification

Maritime Vehicles: [Annex III, (1), (b)]

• Multi-Purpose Vessels over 70 m, all-weather, with a helipad suitable for a 10-ton helicopter and a launch pad for an emergency intermediate speedboat with emerging technology surveillance equipment (radar, thermal cameras etc)
• High-speed patrol boats up to 13 m, with emerging technology surveillance equipment (radar, thermal camera etc.) that can exceed 50 knot-speed
• Patrol and rescue boats over 5, 18 and 30 m

Aerial Vehicles [Annex III, (1), (b)]

• Drones
• Quadcopter UAVs
• UAV Helicopter
• Upgraded AS-365 N3 Helicopters
• Activation of HC-33 helicopter type AS-365 N3
• Acquisition of new medium-range surveillance aircraft
• Acquisition of two (2) super medium helicopters for personnel transport

Provision of Border Surveillance assets and equipment [Annex III, (1), (a) and (b)]

• Automated surveillance system, and interconnection of the Regional Centres for Integrated Border Management and Immigration
• Develop NIMSS
• Supply of an over-the-top surveillance and video system, using a regular balloon
• Improve information analysis data of i2 type
• Portable thermal imaging cameras
• CCTV systems and necessary equipment
• Heartbeat detectors
• Equipping border crossing points with the technical capacity needed in order to check fingerprint biometrics encoded in electronic travel documents against the holder of the document
• Document forgery recognition devices and equipment for border and passport checks
• Automated license plate recognition system for vehicles crossing the country’s official entry-exit points
• Long-range high-accuracy Surveillance Radars
• Specialized means and equipment for improving the electronic system for Management and coordination of surveillance land and sea borders
• Remote long-range high-accuracy Surveillance Radars
• Long Range Electro-Optical Surveillance Systems for NIMSS
• Extension of NIMSS in southwestern Greece, mainly between Zakynthos and Innovative solutions, such as offshore surveillance platforms, will be explored.
• Radar Emissions direction finder Systems for the 2-18 GHz frequency
• Portable Iridium Radios
• Rescue Diver Intercom
• Prioritising investments into the digitalisation of travel documents, which will facilitate the whole travel process and interoperability.
• Training for Pilot Simulator (training for aircraft operators)
• Vest Secular Type, Diver Wetsuits, Baby Rescue Bag, Rescue Harness, First Aid Bags with Equipment and Drugs, Thermal imaging googles, Night vision goggles, Anti-ballistic vests, and equipment
• Modernization, upgrade and acquisition of electronic equipment
• Supply of canine cars and of dogs for HP and HCG
• Construction of aircraft hangars for air fleet maintenance and surveillance
• Achieving a secure and direct communication between the HCG staff working on the ground and the staff working in the Head Quarters (purchase of mobile phones)
• Enhance existing surveillance system at the Hellenic-Turkish border in order to detect illegal crossings, thus protecting the lives of those who are encouraged by traffickers or state-actors to do so. Such system can be composed of technological surveillance border management infrastructure, electronic software and staff.

Ensuring the uniform application of the Union acquis [Annex II, (1), (d)]

• Prioritising measures addressing all currently and in the future outstanding shortcomings identified in Vulnerability Assessment and the Schengen Evaluation.

Identification Facilities [Annex III, (1), (b)]

• Operation of the Reception and Identification Service (RIS) with food provision, cleaning services, security, technical support and maintenance)
• Deployment of interpreters in MPRICs to reduce time needed for identification and acquisition of necessary documents for the Persons of Concern (POCs)
• Develop the necessary workstations at BCPs

Training and capacity development in the field of border management [Annex III, (1), (c)]

• Ensure the comperehensive implementation of Reg 2019/1896, including development of national component of EBCG, comply with technical standards set out by Frontex and register large-scale operating equipment in the Technical Equipment Pool of Frontex; measures related to the application of the updated CIRAM;
• Training of personnel, including EUROSUR operators, as well as those deployed to the Standing Corps (Cat. 2 and 3), as well as staff to carry out checking fingerprint biometrics encoded in electronic travel documents against the holder of the document at the border crossing points (border surveillance, identification of nationality, passport control, fundamental rights, information, risk assessment - strategic analysis, legality control, foreign languages and dedicated training for Immigration Liaison Officers)
• Preparation of a training curriculum related to efficient implementation of CIRAM
• Development of National Quality Control
• Training of HP and MFA personnel on issues related to the implementation of the EES, including GDPR
• Training in large-scale IT systems operators
• Training personnel coming into contact with third country nationals
• Training and capacity building activities to relevant staff on fundamental rights for the The train-the-trainers actions will be covered by eu-LISA.
• The eu-LISA provides training but this training is not a part of a national training programme for the competent personnel for the HP. However, complementarity may be achieved, since HP staff (technical administrators) that will be assigned with the use of Large Scale IT systems (EES, SIS, Eurodac etc) will receive relevant training from eu-LISA during the years 2022 and 2023. And training on interoperability components.
• Personnel training of the Air Media Service HCG
• Training of HCG personnel on Integrated Border Management as part of the development of a comprehensive training system for basic, continuous and specialised training of border

Implementation measures

Annex II, par.1, (e)

Indicative Types of Actions

IT systems [Annex III, (1), (h), (l) ]

• Develop / upgrade large-scale IT Systems and ensure their interteroperability (EES, ETIAS, interoperability components)
• Implementing the EES
• Service used for the interconnection of National Border infrastructure
• Ιnterconnection of National Border infrastructure, CAPs and competent authorities with the NUIs (EES - ETIAS-VIS-Interoperability).
• Developing national interfaces for access and connection to communication infrastructures and integration of the existing national systems
• Establishing an IT System for the HP related to border protection duties (The main characteristics of the system will be the following: Decision making and administration based on information deriving from other IT systems. Development of an integrated risk analysis system. Standardization of the operating mode of all Regional HP Services, by dividing administrative and operational activities.
• Development of IT tools for risk analysis for ETIAS NUI.Specific Action BMVI/2021/SA/1.5.4/009 “Support to comply with the implementation of the relevant interoperability legal framework”

Desired outcomes and expected results

• Facilitate legitimate border crossings
• Reinforce border controls and surveillance across the border (land, sea, air)
• Prevent unauthorized entries through all BCPs with increased efficiency
• Ensure sufficient number of trained staff for border control; ansure a coherent HR strategy and a comprehensive training system for border guards
• Reduce operating costs
• Strengthen the operational capacity of operational personnel in the performance of their duties
• Optimal protection of country’s borders
• Strengthen and renew the fleet and consequently upgrade the response capacity of the HCG
• Increase effectiveness of border surveillance, cross-border surveillance, and the pre-border area, which are objectives of Integrated Border Management Strategy 2018-2020
• Contribute to the prevention and fight against illegal crossings of sea borders
• Ensure high added value in the pursuit of dismantling organized criminal networks
• Reduce migrant population residing in RIS facilities at the border
• Extend technological capabilities
• Provide sufficient processing time required for the conduction of work and collection of information that is processed through outdated or analogue methods
• Minimize the time required to process vehicles and individuals, and prevent illegal crossings
• Establish quality control mechanisms of EU and in particular the Schengen assessment process and the vulnerability assessment methodology
• Ensure effective information provision and exchange in EUROSUR in compliance with the

requirements deriving from Reg. 2019/1896 and 2021/581, as well as with technical standards and data security rules developed by the Agency

• Ensure full fuctionality of the NCC

Operating Support [Annex III, (1), (l)]

To assure effective border management, Greece identified the need to add more competent and experienced personnel. Training and recruitment of Border Guards will increase the operational capacity of the competent authorities, which are in charge of the Greek border control, surveillance and the management of migration flows. In addition, recruitment of police personnel will contribute to the reduction of seconded staff temporarily transferred to these Police Directorates, optimizing both human and financial resources. The presence of Police personnel at the near-border Police Directorates will contribute to the reduction of migratory pressure in these regions and will ensure more effective control and optimal surveillance at the country borders. Personnel recruitment and training will enhance the management of the migrant and asylum-seeking population that currently resides in the MPRICs; this will contribute to reducing the time needed for identification and acquisition of necessary documents for the POCs. Specifically, the proposed actions that fall under the eligibility of operating support based on the BMVI regulation are:

Personnel Recruitment and Training

Hellenic Police [Annex III, (1), (c)]

• Increase the existing number of police personnel by 1,600 new recruits, while covering their operating expenses as part of the ongoing operating support
• Coverage of: a) payroll costs for Border Guards and b) daily allowances away from the main base of activity/operations, overnight and travel expenses for the deployment of police personnel
• Support personnel training to enable the use of new large-scale IT-systems, and other border management-related trainings

Hellenic Coast Guard [Annex III, (1), (c)]

• Coverage of expenditure for the transfer of 80 executives per year to Border Port Authorities
• Providing short-term traineeship programmes for the new personel of HCG on border surveillance as part of the development of a comprehensive training system for basic, continuous and specialised training of border guards. Its necessary element should be a training on Fundamental Rights (theory + practice during surveillance, and related possible Search and Rescue (SAR) acitvities)

Management of MPRICs [Annex III, (1), (c)]

• Recruitment of staff for the purpose of guarding, security, and emergency response in the MPRICs, where migrants and refugees entering the Hellenic territory are temporarily hosted
• Deployment of interpreters in MPRICs to reduce the time needed for identification and acquisition of necessary documents for the POCs

The added value of supported Staff to the achievement of the BMVI scope:

• Ensuring a high level of operational readiness and efficiency
• Preventing border crossings at unauthorized entry points in line with the Schengen acquis and with respect for fundamental rights
• Ensuring more efficient management of mixed migration flows
• Continuous and effective monitoring of the situation on the land, river and lake, as well maritime borders of the country
• Provide necessary services to first-comers to EU territory migrants within the remit of BMVI

IT systems [Annex III, (1), (l)]

• Operating costs for supporting and maintaining the information/IT systems (hardware and software) under development
• Maintenance of ETIAS National Units (NUIs) and competent authorities with the NUIs and Central EES, ETIAS and Information Operations

Maintenance of Infrastructure/ Facilities [Annex III, (1), (a)]

In order to increase the quality of services provided, the fund will support upgrading and renovation of certain buildings and infrastructures located at the national border. Specifically, the proposed actions are:

• Developing the necessary workstations at Border Crossing Points and at the Operational Centres to enable the use of the new IT systems and equipment,
• Configuration of buildings / port infrastructures and supply of material and technical equipment for the Repair Base HCG in Elefsina& Thessaloniki
• Maintenance of RIS accommodation facilities in the MPRICs

Goals of the proposed actions:

The operating support is expected to strengthen and develop the country’s reception system at the border areas by improving and maintaining the living conditions for beneficiaries residing in MPRICs temporarily within the timelimites defined above. It is of paramount importance to comply with legal requirements for TCNs as per determined in the EU acquis

Indicative list of Beneficiaries both from actions and operating support, including their statutory responsibilities

• Ministry of Citizen Protection / National Coordination Centre (NCC)
• Hellenic Police (HP) (Surveillance of the land border, BCPs/border control (land, sea, air), enforcement of aliens legislation and the national anticrime policy)
• HCG (Surveillance of sea borders and enforcement of anticrime measures in its area of responsibility)
• Hellenic Armed Forces (HAF) (subsidiary role) - (Surveillance of land, sea and air borders for ensuring country’s national integrity and defence)
• Reception & Identification Service (RIS) (Implementation of identification procedures of illegally entered TCNs or stateless persons)
• Ministry of Foreign Affairs (MFA) ((Implementation of the national foreign policy (EU and third countries cooperation), Visa policy)

Specific actions

BMVI/2021-2022/SA/1.2.1/015 -Project REACTION

BMVI/2023-2024/SA/1.2.2/12 - Equipment for EBCG

BMVI/2023/SA/1.1.4/009

Table 1: Output indicators

Table 2: Result indicators

Table 3: Indicative breakdown

Baseline situation/Relevant data (Ministry of Foreign Affairs)

With the support of the previous funding instrument, Greece increased the rate of Schengen visas issued in 2017 by more than 8.7% in comparison to 2015 (166,559 more visas) and 2016 (57,313 more visas). In order to maintain the steady increase of visa application numbers, Greece with the use of the BMVI funding instrument will address the challenge of fully digitizing the visa process, by providing personnel training to those assigned to complete relevant processes and by ensuring that the data is swiftly and accurately gathered, recorded and disseminated to the relevant authorities through the use of interconnected IT systems and the national Visa Information System (N-VIS). Regarding personnel capacity for the verification of means of subsistence and fraudulent documents, it should be noted that there was an increase in the refusal rate of visa issuance in comparison to 2016, from 2.8% to 3.5%.

Specific challenges/needs

The specific challenges that the Ministry of Foreign Affairs needs to address in the following years are mainly the following:

• Delays in procurement
• Lack of legal expertise
• Upcoming personnel retirement
• Frequent personnel mobility in consular authorities
• Lack of experts (Schengen and IT experts)
• Budgetary restraints that limit the national capacity to address the needs
• Political, health and security situations in third countries and the new visa trends
• Advanced methods in identification or document forgery

Continuity and changes compared to the current funding period (including lessons learnt)

MFF 14-20 allowed optimal response and performance of the VIS system. Applicants were served faster and working conditions were improved. In this context, Greece considers that it is vital to keep a robust and up-to-date system (regarding IT hardware and software needs). Therefore, the continuation of actions such as procurement of additional VIS workstations, upgrades of IT software, infrastructures and line bandwidth, coverage of operational telecommunication costs, as well as the cost of relocating consular authorities premises, where needed, to continue supporting VIS interoperability with other systems.

The implementation of a pilot action called “Field Workers” – with the reinforcement of Police Officers and additional specialized MFA employees at Consular Authorities bearing a high workload – increased the visa application rejection rate, while numbers of granted visas remained high (statistics 2019). Such improvement in the quality of control indicated the need to continue this action.

Health precautions for Consular personnel requires expenditure in infrastructure to continue. The new Visa Code commands limited physical presence of visa applicants (once every five years to collect fingerprints). Thus, Greece will fully digitalize the visa process in this programming period.

Finally, relevant experience gained previously by the SR on ESPs operation, will be used to properly implement contracts allowing Consuls and IT officers to perform necessary visits, allowing for constant monitoring and report.

Implementing Measures Annex II, par.(2), (a)

The indicative types of actions: Annex III, par.2, (e)

• Develop IT tools for risk analysis and Relevant tools already used by the Netherlands and Austria were pointed out as a best practice by the Schengen evaluation mechanism. Such tools could be shared by those countries or be developed gradually in cooperation with Frontex and national authorities. A Risk Analysis tool will be incorporated in the VIS system similar to the national risk analysis system and its products to assist Consular staff in decision making for granting visa, or not. A Training IT tool, that includes production of video educational material with Q&A, mobile application etc.
• Monitor ESPs by allowing Consuls and IT officers to conduct regular visits. The New Visa Code requires consular monitoring by conducting on site visits at the ESPs and frequently reporting back to central authorities. This is a demanding task, as it requires IT-competent personnel. For this reason, it is necessary to have additional support from IBMF.

Annex II, par.(2), (c) / Annex III, par.2, (e)

Study on the Impact of TMI (Travel Medical Insurance) to the national health system. This study focuses on third-country nationals, holders of Schengen Visas with a TMI by an insurance company up to the amount of € 30,000. The following issues will be examined:

• How does insurance coverage work in practice from an institutional and administrative point of view?
• Are there distortions in the system (from the activation to the compensation by the insurance company)?
• What are the conclusions and proposals for hospitals and Consulates?
• The study includes the creation of questionnaires, skype interviews with Consular authorities, collection of all statistical data related to the study subject, collection of all relevant studies already

Digitalization of visa files. Greece has high expenditure for archive space, where visa applications files and relevant documents are kept. The new visa code allows digital files. The new applications may be digitally stored mainly by ESPs, however older files need time and adequate funding to be digitized as well.

Procurement of Visa Stickers.

Annex II, par.(2), (e) / Annex III, par.2, (b)

IT systems

• Visa Information System (VIS) IT system modifications and upgrades to implement the revised VIS Regulation and relevant EU legislation, including trainings for authorised personnel (end users etc.) on fundamental rights, such as the prohibition of discrimination, the right to the protection of personal data, including the obligation of authorities to inform third-country nationals about their data subject rights, the respect of human dignity when collecting biometric data, the rights of children, the rights of persons with disability etc.
• Upgrade of NET -VIS for the interconnection of Hellenic Consular authorities in third countries with the Ministry of Foreign Affairs and the NUIs, which includes: monitoring of all SLA indicators, upgrading network management software, network elements and interfaces as well as operation control of services provided over the network. Troubleshooting the network through a fault monitoring system and all repairs and interventions in network equipment.
• Procurement of appropriate software for monitoring the configuration of active equipment per point/node.
• Upgrade N-VIS, including technical support for N-VIS system includes all N-VIS hardware and

software in the Foreign Ministry premises in Athens, Thessaloniki and all Consular Authorities.

• Ensure proper functioning of equipment and systems
• Preventive & Remedial software (rehabilitation problems, shortages, defects, deviations from specifications and applications software malfunctions, upgrades, supply and install updated versions of software).
• Preventive & Remedial Upgrade Material H /W of Foreign Ministry nodes in Athens and Thessaloniki and all Consular Missions (rehabilitation failures and malfunctions, installation parts, accessories and other necessary materials for maintenance, replacement with spare equipment in case of serious damage and also custom duties, custom fees, transportation and other expenses incurred).
• Further development of the Visa On-Line

Desired outcomes and expected results

• More efficient response of Consulates to the increased demands, especially in high-demand seasons, including fast visa processing
• Upgrading Consular service delivery, contributing to proper application of VIS and provision of flexible and innovative Consular services
• Ensuring system integrity and continuity and preventing VIS network failures due to obsolete systems
• Increase in data security (crypto products), improvement of response times for biometric data retrieval and processing
• Increase in network security and access control of the Consular Offices to the VIS and their systems which are interoperable with VIS (EES, etc.)
• Significant reduction of misuse-abuse of visa applications and better protection of the Schengen area from security, public order and epidemiological threats
• Providing on-the-job training to all Consular officials in their country of accreditation and subsequent reduction of personnel needing to move to the MFA HQ for training purposes
• Enhanced capacity of Consular staff, including local staff, related to Schengen visa processing and consular cooperation
• Improving ESPs’ monitoring
• Saving resources by creating AI tools for training and risk analysis
• Decreasing the need for physical presence of visa applicants by developing electronic visa processing tools
• Decreasing budget allocation for renting spaces for archiving visa files and contributing to a more efficient and secure storage mode
• Ensuring and verifying that officers have adequate capacities in the field to address any new challenges regarding Visa application processes
• Preventing irregular migration and helping protect European MS citizens The new systems will allow easier third-country nationals travel while it becomes easier for operational officers to efficiently identify over-stayers as well as document and identity fraud.

Operating Support - Annex II, par.(2), (e) / Annex III, par.2, (a)

Facilities / Infrastructure

Upgrade Consular services and refurbish premises to align with security and other Visa Code requirements, subject to location-specific requirements. More specifically:

• The Action focuses on renovation-refurbishment (incl. security services) of Consular premises subject to location-specific requirements in order to align with security requirements, in compliance with the Visa Code and VIS Regulation. Indicatively, subject to a per location evaluation approach: improve accessibility for disabled people, install security doors, bullet-proof windows, security cameras, seating area equipment, room separators, air-conditioning, intercom systems, crowd control equipment, shredders Additional infrastructure will be acquired for the protection of personnel from health hazards.
• In-situ training will be customized subject to each Consulate’s identified training needs and will include its entire serving personnel. Apart from generic issues on visa policy, it will also cover specified topics, depending on the identified training needs of each Consular Authority, such as the identification of false / forged travel documents, data protection and their capacity to respond to the needs of the Schengen evaluation mechanism. The training will be carried out by a team consisting of both personnel from the Ministry of Foreign Affairs and Hellenic Police Officers, with expertise in Schengen and visa policy.
• The above-mentioned actions have already received funding by ISF and the Final Beneficiary is the Ministry of Foreign Affairs.

Staff training

Secondment of expert “field workers”, in addition to the national secondments during high season for the support of the visa administrative process, the reduction of misuse/abuse of visa applications, including “visa-shopping” and the detection of false or falsified documents.

To be more specific:

Increase in visa processers is a major challenge for the Hellenic Ministry of Foreign Affairs. For this purpose, an innovative pilot programme of secondment of visa experts (“field workers”) to Consular Authorities is already being implemented successfully during high season, in order to support the visa administrative process, reduce cases of misuse and abuse of visa applications, including “visa-shopping”, detect false or falsified documents, and swiftly issue Visas to bona fide travellers. According to experience gained so far, “field workers” have significantly assisted the Consulates with their work, especially in recognizing false and falsified documents and ensuring a swift and secure visa process.

Staff reinforcement is allocated according to workload, depending on requests submitted by Embassies/Consulates. The length of temporary secondment depends on the specific requests and workload of each Embassy/Consulate. Specially trained officers from the Ministry of Foreign Affairs and the Ministry of Citizen Protection receive additional training and are seconded for a short period of time, in order to support the Consulates during the high season. Additionally, the current visa trends indicate that a significant increase in visa applications is to be expected in certain countries. Furthermore, it should be underlined that the cooperation with External Service Providers and intermediaries has led to an increased number of short stay visas from tourism markets.

The above-mentioned Action has been considered as a good practice to similar actions by EU member states, during Greece’s Schengen assessment, presented under the Romanian Presidency (EU "Visas").

IT systems

• Maintenance and support of VIS system (NET-VIS network and N-VIS system)
• Maintenance and support of the NUIs Data Centers

Indicative list of Beneficiaries

• Ministry of Foreign Affairs

Table 1: Output indicators

Table 2: Result indicators

Table 3: Indicative breakdown

Technical and legal assistance will be provided for the implementation of the new regulations and obligations for Greece derived from them in order the new IT systems and relevant processes to be better implemented, as well as ongoing technical support throughout the programmed actions to be provided.

Additionally, the technical assistance addresses the need to adjust to national legislation in terms of security, data protection and fundamental rights.

Such assistance includes the provision of advice, expertise, research, analysis, training or other assistance in connection with, inter alia:

• Reinforcing systems and processes of management and coordination including anti-fraud actions
• Enhancing human resources, administrative organization and operation of entities involved in the implementation of the interventions and actions
• Upgrading the managerial and delivery capacity of the beneficiaries of the fund
• Completing necessary formal procedures in case and data handling in relation to the actions described above
• Analysing the national legislation and reviewing of national laws aimed at ensuring compliance with international legal obligations or implementing E.U. laws and regulations
• Drafting non-legislative texts (such as arbitration rules) based on the documents and procedures of national and international law.

Current technical assistance programmes are undertaken in accordance with the mandate of each respective department, office, agency, fund or programme and within the existing financial resources allocated for such purposes under their respective programme budgets.

Allocation of Technical Assistance and indicative Actions

Information & Communication (allocation: 10%)

• Information Campaigns
• Communication Action Plans
• Public events and visits
• Information campaigns
• Commemorative plaques
• Press releases
• Leaflets, brochures, newsletters, and magazines
• Web site for Migration & Home Affairs Funds (AMIF, BMVI, ISF)
• Participation of the Managing Authority in exhibitions and other commercial events
• Production and distribution of Magazine for Migration & Home Affairs Funds (AMIF, BMVI, ISF)

Preparation, implementation, monitoring and control (allocation 20%)

• External Consultancy for planning, monitoring, verification and evaluation process
• External Consultancy for the on-the-spot controls
• External Consultancy for Financial planning
• Costs for the meetings of the Monitoring Committee for Migration and Home Affairs Funds
• Costs for the on-spot-controls

Evaluation and studies, data collection (allocation 10%)

• External Consultancy for the collection of relevant data, statistics and indicators
• Studies (eg: impact of programmes, SCOs, impact of various events on migration, best practices, establishment of new tools etc)

Capacity building (allocation 60%)

• Fixed-term staff for the Managing Authority and the Intermediate Bodies
• External Consultancy for the Managing Authority and the Intermediate Bodies
• External Consultancy for final beneficiaries to assist in the field of public procurement, planning and smooth project implementation
• Training for the Management and Control System
• External Consultancy to assist the Managing Authority for the Home Affairs Committee and relevant legal or strategic documents of the Home Funds
• Contracting services (e.g., recording of meetings, translation/interpretation, operating costs of the Managing Authority and the Intermediate Bodies, travel costs etc.)
• Contracting supplies for the operation of the Managing Authority and the Intermediate Bodies

Table 4: Indicative breakdown

Table 5: Financial appropriations per year

Table 6: Total financial allocations by fund and national contribution

Table 7: Transfers between shared management funds¹

¹Cumulative amounts for all transfers during programming period.

Table 8: Transfers to instruments under direct or indirect management¹

¹Cumulative amounts for all transfers during programming period.

Table 9: Horizontal enabling conditions

Table 10: Programme authorities

Preparation

During the development of the NP, the MA identified and consulted with a wide range of programme stakeholders, to increase efficiency of policy-planning and ensure that the proposed main actions sufficiently cover critical and actual needs in the field. In particular, the MA carried out several meetings –both in person and online– with all de jure monopoly stakeholders, i.e. the following: Ministry of Migration and Asylum, Ministry of Citizen Protection, Ministry of Maritime Affairs and Insular Policy, Ministry of National Defense and Ministry of Foreign Affairs. In parallel, the MA carried out many meetings, per SO, with relevant actors to collect all lessons learnt from the programming period 2014-2020, examine all proposed actions and decide which ones should be integrated into the NP 2021-2027.

To sum up, the MA received and took into consideration all follow-up contributions from the above stakeholders, including their concerns, comments and proposals. In principle, the goal of the above procedure during the preparation phase of the programme was to incorporate the competent national agencies’ strategic planning into the main actions of each specific objective.

Implementation/Execution

The MA focused on presenting the stakeholders with a more active role in the implementation of actions by organizing one-in-one meetings during the implementation period. Potential stakeholders are:

• Ministry of Migration and Asylum
• Ministry of National Defense
• Ministry of Citizen Protection
• Ministry of Maritime Affairs and Insular Policy
• Ministry of Foreign Affairs

Monitoring and evaluation

During the monitoring and evaluation phase of the programme, according to the management and control system, the MA will collaborate closely with all stakeholders. The MA will implement verification and on-the-spot controls of actions and take corrective measures when necessary. Authorities that implement actions under BMVI (Ministry of Migration and Asylum, Ministry of National Defense, Ministry of Citizen Protection, Ministry of Maritime Affairs and Insular Policy, Ministry of Foreign Affairs etc) will participate in the monitoring committee of the Migration and Home Affairs Funds (AMIF, BMVI, ISF) and will therefore contribute to the monitoring and evaluation of the programme. Based on the last updated Ministerial Decision, the members of the monitoring committee are allowed to propose successful practices, while bringing their own experiences and operational expertise during the evaluation phase of the programme.

In addition, the Greek Ombudsman, the Chair of the National Committee for Human Rights, representatives from UNCHR and IOM participate to the Monitoring Committee and are involved in all Programme phases. As far as National Data Protection issues are concerned, all the Ministries have their own independent Data Protection Officer (DPO) responsible for monitoring all actions’ implementation. On the latest updated national legislation, the MA has a DPO focal point with the Ministry of Development and Investment.

MA will repeat periodically every year the meetings with all potential stakeholders other than Monitoring Committee Meeting, to take their feedback related to potential problems into implementation process, and on how to reprogram or re-adjust some projects. The meetings will be conducted either bilaterally or with all stakeholders at the same time. In any case, all beneficiaries will have the opportunity to express their proposals in order to improve the quality of the projects and thus the quality of services provided to migrants.

Communication

Authorities that implement actions under BMVI (Ministry of Migration and Asylum, Ministry of National Defense, Ministry of Citizen Protection, Ministry of Maritime Affairs and Insular Policy, Ministry of Foreign Affairs etc.) will contribute and participate to every communication and visibility action of the programme.

The communication officer is in the Programming and Evaluation Unit of the Managing Authority and will be the link with the central communication officer from the Ministry of Development and Investment.

The communication strategy will ensure that any and all relevant stakeholders that have an active role in the course of the funding period will receive constant and relevant information, in due time. The stakeholders outlined in the actions’ descriptions include but are not limited to national government officials of the relevant Ministries, General Secretariats, the Hellenic Police, the Hellenic Coast Guard and others. Additionally, the stakeholders that will be included in the internal communication of the programme include the relevant E.U., international, member-states, and third-country officials that are relevant to the actions of the funding instrument, which will be outlined in the individual Action Proposal documents. The purposes of the communication plan are:

Objectives

Communication will focus on achievements and impact of the funded actions, not only on administrative or procedural milestones.

In order to maximize the impact of communication efforts, MA will use all the activities such as:

• Display panels (50)
• Banners (50)
• Promotional items (50)
• Photographs (200)
• Audiovisual productions (15)
• Public events and visits (20)
• Information campaigns (15)
• Commemorative plaques (1.000)
• Press releases (200)
• Leaflets (50), brochures (40), newsletters (100), and magazines (14)
• Participation of the Managing Authority in exhibitions (6) and other commercial events (6)
• Web site for the Migration and Home Affairs Funds (AMIF, BMVI, ISF) (1)

The target audience(s) will be:

• Public bodies
• Universities
• Regional and Local communities in the islands and in the mainland
• Asylum Seekers
• Migrants and Refugees
• Irregular migrants

Communication channels (including social media outreach):

• Web site,
• Creating apps
• Other communication channels

The communication and visibility actions are estimated to cost 5,952,220.55 for the programming period 2021-2027.

The communication officer is in the Programming and Evaluation Unit of the Managing Authority and will be the link with the central communication officer from the Ministry of Development and Investment.

Monitoring and Evaluation

The evaluation will be implemented by using output, outcome and impact indicators.

Output indicators: Facebook Target Value (TS) 30,000 followers, Twitter TS 30,000 users, LinkedIn TA 1,000 users, TS Website 100,000 visits, number of TA helpdesk inquiries 50/month

Outcome indicators: 1,500 engagement / post on social media. Recognition rate, audience recall of campaign/activity, degree of satisfaction/usefulness from event, website conversions (downloads, registrations, bouncing rate, connection duration) and degree of user satisfaction, number of participants per event/conference/seminar, social media followers/impressions/views, website visitors, number of Helpdesk enquiries.

Impact Indicators: Disseminating a positive message about the Program and the EU, degree of trust in national/European authorities.

Evaluation will be caried out of the communication strategy and for activities based on the EU toolkit.

(1) This refers to the code in Annex VI of the AMIF, BMVI and ISF Regulations

(2) This refers to the code of a common indicator, if applicable

Appendix 1: Union contribution based on unit costs, lump sums and flat rates

B. Details by type of operation

C. Calculation of the standard scale of unit costs, lump sums or flat rates

1. Source of data used to calculate the standard scale of unit costs, lump sums or flat rates (who produced, collected and recorded the data, where the data is stored, cut-off dates, validation, etc.)

2. Please specify why the proposed method and calculation based on Article 94(2) CPR is relevant to the type of operation.

3. Please specify how the calculations were made, in particular including any assumptions made in terms of quality or quantities. Where relevant, statistical evidence and benchmarks should be used and, if requested, provided in a format that is usable by the Commission.

4. Please explain how you have ensured that only eligible expenditure was included in the calculation of the standard scale of unit cost, lump sum or flat rate.

5. Assessment of the audit authority(ies) of the calculation methodology and amounts and the arrangements to ensure the verification, quality, collection and storage of data.

A. Summary of the main elements

(1) Refers to the code in Annex VI of the AMIF, BMVI and ISF Regulations.

(2) Refers to the code of a common indicator, if applicable.

B. Details by type of operation

DOCUMENTS