Annual progress report 2015 albanian contribution – input I september 2014 – may 2015 table of contents
Public Internal Financial Control
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Public Internal Financial Control Strategic framework and political steer The first strategic document was the Government Policy Paper for the PIFC and the action plan 2011-2014, approved in June 2009 with DCM 640. The five – year action plan for the implementation of a modern financial management and control system (2011 - 2016), approved with order of the Minister of Finance No 11841 of 10.06.2011, updated the previous action plan 2011-2014. The PFM strategy 2014 – 2020 and respective Action Plan, approved with the DCM No 908 of 17.12.2014. The Public Finance Management Strategy, 2014-2020, approved by DCM No 908 of 12.17.2014, is coordinated with the public administration reforms and also PIFC policies are part of this strategy. The reforms planned in Public Finance Management Strategy, under the Action Plan 2014-2020, are monitored periodically by the Steering Committee, set up by the Prime Minister's Order no. 202, date 08.25.2014. This committee meets every 4 months. Also, PIFC policies stated in the PFM strategy will be monitored and reported as part of the PIFC annual report. The Ministry of Finance, as the responsible public institution for the coordination and harmonization of PIFC, has initiated several legal acts on the framework of the PFM Strategy and monitors its implementation. The annual report “On the public internal financial control system” is presented every year to the Government by the Ministry of Finance, attached to the annual budget implementation report. The public internal financial control board, established by public financial management and control law, meets every four months to discuss, consult and monitor the issues related to the PIFC implementation. Central Harmonisation Unit (CHU) The Central Unit is established at the Ministry of Finance. The mission of the Central Unit is preparation, harmonization and implementation of the internal financial control and internal audit systems and standards in the public sector. It is composed of two sub-units:
The CHU function is regulated by the following legal acts:
In addition, the tasks of the CHU are specified in the internal regulation of the Ministry of Finance. Many other instructions of the Minister of Finance and decisions of the Council of Ministers regulate the activity of the CHU/FMC and CHU/IA. Referring to the internal organic structure of the MF, the CHU is composed of 13 employees, considered sufficient to carry out tasks and responsibilities. CHU/FMC keeps records of operations since 2011, updated regularly every year. They are detailed in the annual reports of the PIFC functioning in the public institutions. In addition, the CHU/FMC keeps updated records of the appointed “Authorising” and “Executing” officers in the public institutions. CHU/IA keeps records of internal audit activity in the public sector since 2005, updated regularly every year. In addition, the CHU/IA has created and updates regularly the National Register of Internal Auditors. The assessment of the internal control management quality is done every year and is reported in the PIFC annual report. The CHU prepares every year “The PIFC in the public institutions” annual report, which is approved by the Minister of Finance. It is presented to the Government together with the annual budget implementation report, within the month of June, every year. One of the tasks of CHU/FMC is the preparation, distribution and updating of strategies and methodological guidelines for financial management and control in accordance with internationally accepted standards on internal control, the applicable regulations and good practices in the European Union. Another task is organization of awareness seminars and training in continuity in the area of financial management and managerial control and accountability in public sector institutions. To carry out this task, the CHU is supported by the Albanian School of Public Administration. Financial Management and Control (FMC) The Law no. 10296, date 08.07.2010 “For the Financial Management and Control” defines the operational framework for FMC. The managerial responsibilities and reporting methodology is specified in the art. 15 on the general delegating rules and in the Chapter II of Law no. 10296 date 08.07.2010 “For the Financial Management and Control”. The MF reports continuously on the compliance with FMC requirements. This is considered of a very high importance. The Public Financial activity is based on the Law no.10294, dated 1.07.2010 “On Public Financial Inspection”. The Public Financial Inspection is based on complaints and clear indication of irregularities. It is focused on potential risks of fraud, corruption or major financial abuse. The Ministry of Finance/The Public Financial Inspection is developing a process to review the legal framework, in order to approximate the Law to the best European standards and realize the Albanian government expectations in improving public finances as well. This law marks the final separation between the internal audit function and financial inspection law. The appointment of the senior financial officers is done in compliance with the art. 12 of the Law no. 10296 date 08.07.2010 “For the Financial Management and Control”. The CHU/FMC monitors the implementation of hiring and appointing process of the executing officers (senior financial officers). The budget preparation process follows the requirements of the Law no. 9936, date 26.06.2008, “For Management of Budget System in Republic of Albania”, instruction no. 8 date 29.03.2012 “Standard procedures of the midterm budget preparation” and all other instructions/orders issued on purpose by the Minister of Finance. Management information is regularly provided to the appropriate levels of the organisation. CHU/FMC gives a high importance to the risk management process, which is being implemented in the public institutions. The second-level organisations are also obliged to implement the requirements of the FMC Law. State-owned enterprises are subject to robust governance arrangements by their "owner" first-level organisations. State-owned enterprises are subject of FMC law. The internal control procedures are specified in the risk management register of each public institution, they make responsibilities within the organisation clear. These procedures are specified in the internal regulation of each public institution and also in the job description of the employees. The policy proposals are included in the Program Political Declaration, which is prepared and approved as part of the budgeting process. The internal control procedures,
Based on the FMC law/manual, every internal operational procedure in the public institutions should be designed together with its own audit trail. This allows the internal audit and internal control to check and verify key financial decisions. Internal audit The Internal Audit (IA) in the public sector in Albania is regulated by the Law no. 9720 date 23.04.2007 “For the Internal Audit in the Public Sector” amended in 2010, and many other legal acts and sub-acts. Following the art 6 of the Internal Audit Law, the activity of the IA in the public sector is based on the international standards of the internal audit. The law define clearly operational arrangements for internal audit, including the minimum size, independence and reporting arrangements, internal audit standards, manuals, code of ethics and certification. These requirements are defined in, internal audit manual, and other regulations, instructions and orders issued for this purpose. The institutions, which are required by legislation, have established the internal audit units, in line with the size and complexity of the institution based on the DCM no. 212 date 30.3.2012 “For the approval of criteria for the establishment of internal audit units in the public sector”. There are 28 internal audit units that do not have sufficient staff to comply with internal audit legal requirements. In the annual report 2014 “The activity of the internal audit units in the public sector” is reported:
The internal audit has been efficiently regulated and established even for those institutions, which are too small to have their own internal audit. Article 17 of the internal Audit Law provides that the internal audit service can be provided in three ways:
In the public sector, there are 1,802 certified internal auditors, out of which, only 351 are employed in the public institutions. From the information provided by the MF, none of the certified internal auditors has an international audit certification. The internal auditors are trained every year by the CHU/IA, following the requirements of Article 20 of the internal audit law. All national institutions that have an internal audit unit are obliged to have the internal audit charter, which is included in the specific manual of each IA unit. Currently, 21 out of 84 internal audit units have reported that they do not have an approved Internal Audit Charter. At the end of each year, all the IA units prepare the strategic and annual audit plans. After approval from the Head of the institution, a copy of the plan is submitted for information to CHU/IA. All strategic annual plans are prepared based on the risk assessment of the institution, following the specification in Chapter II of the IA Manual. All the draft audit plans are discussed and consulted with the management before being approved. A clear consultation procedure and submission of internal audit report is specified in the Chapter IV of the IA Manual. The chief of IA unit reports directly to the head of the public institution. The findings are discussed and consulted with the senior financial officer and the secretary-general in the moment that the draft audit report is submitted, only if any of these managers has been subject of the audit. The monitoring procedure of implementation of the recommendations is clearly specified in the Chapter III of the IA Manual. External audit With regard to independence of the Supreme Audit Institution (SAI), the Constitution of the Republic of Albania (Articles 162-165) foresees that ALSAI is the highest institution of economic and financial control in the Republic of Albania, which in its operation is subject only to the Constitution and the laws in force. The Law 154/2014 “On the organization and functioning of High State Control” provides for functional, operational and financial independence of the SAI in line with the INTOSAI standards. According to Article 162 of the Constitution, and to Chapter – III, (“The Chairman of the State Supreme Audit Institution), Articles 19-24 of the Law nr.154/2014 “On the organization and functioning of High State Control” the HSC Chairman is elected by the Parliament, on the Proposal of the President of Republic, for a mandate of 7 years and in his/her activity is liable only to the Parliament. According to Chapter – II, (“Powers, Rights and duties”), Articles 10-14 of the Law nr.154/2014 “On the organization and functioning of High State Control”, the audit mandate of the SAI is comprehensive and covers all public financial operations. According to Chapter – II, (“Powers, Rights and duties”), Articles 11-13 of the Law 154/2014 “On the organization and functioning of High State Control” the SAI has the authority to undertake a full range of financial, regularity and performance. According to Chapter – II, (“Powers, Rights and duties”), Articles 15-26 of the Law 154/2014 “On the organization and functioning of High State Control” the external auditors have an unrestricted right to access the premises, records and documents of the audited bodies. Financial independence of SAI According the Chapter – I, (“General Provisions”), article 7 of the Law 154/2014 “On the organization and functioning of High State Control” SAI has financial independence. Institutional capacity of SAI SAI has the sufficient personnel resources to conduct its audits as planned, but the approval of new Law, nr.154/2014 “On the organization and functioning of High State Control”, has given the right to ALSAI to conduct Financial Audit and IT audit and, for this reason, SAI actually doesn’t have sufficient capacities in terms of staff’s number and professional knowledge. The IPA project, commencing in May, 2015, will support ALSAI in building its capacity. ALSAI has adopted its development Strategy for the period 2013-2017 and the action plan on the strategy implementation. ALSAI monitors the implementation of the strategy for the years 2013-2014 and has recently completed its update, referring to concrete objectives and changes occurred, so that the strategy is feasible and consistent with external developments (e.g, adoption of ALSAI’s new law, which entered into force on 6 February 2015). It should be also stressed the fact that IPA 2013 for ALSAI, Component I, is yet uncompleted and this has directly affected the non-implementation of certain strategic objectives. In the past three years, the ALSAI’s training process has shown to be a continuous, sustainable and with concrete achievements process. The systematic proceeding and its consolidation, made possible in general terms for the 2014, that the results achieved in the area of staff professional development, could rank ALSAI at the highest levels as counterpart institutions in more developed countries. Indicators show a high performance of participation in trainings, under which it was possible for each auditor to meet about 26 days of training during 2014, and any new auditor reportedly was trained for more than 30 days. Despite the efforts in this direction, there are shortcomings in terms of the formation of auditors in financial audits and information technology, which are expected to be the output of IPA Project 2013, an EU subsidy which is expected to begin in May 2015. Yes. In every audit program is planned as special trend the assessment of internal control systems and the implementation of the Law on financial management and control requirements. In May 2012 the ALSAI has signed a Memorandum of cooperation with the Ministry of Finance. This Memorandum aims to foster the cooperation with Central Harmonisation Unit in Ministry of Finance and internal audit structures. We have organized with CHU/IC join seminars for presenting the main concept “On Financial Management and Control” for the auditor staff. ALSAI has in its organizational structure the Directorate of Internal Audit and this unit has sufficient staff. Internal unit is subordinated by the chairman of ALSAI. ALSAI has a Financial Audit Manual (in terms of compliance), a draft of Performance Audit Manual and not yet an IT Audit Manual and Attestation Financial Statement Manual. These manuals will be output of IPA Project mentioned above. The annual audit plan of ALSAI is a risk-based plan, but the IPA project will assist ALSAI toward the designation of methodology and practical training for scheming an annual audit plan in accordance with INTOSAI standards. SAI procedures and transparency SAI has in place procedures for quality control and ethics, providing reasonable assurance that the SAI auditors are complying with professional standards, including integrity, independence, objectivity, confidentiality and competence. ALSAI’s auditors are complying with professional standards including integrity, independence, objectivity, confidentiality and competence, referred to ISSAI 40 “Quality Control of SAI’s”. ALSAI has written procedures for ensuring the quality of audit work in accordance with the definitions of ISSAI 40. Furthermore, ALSAI has a Code of Ethics which is being revised and updated, fully in accordance with the latest revisions of ISSAI 30. SAI reports its findings independently on an annual basis to the Parliament. It has a constitutional and legal duty to do so. SAI submits to the Parliament two main reports:
ALSAI publishes on its website, the reports submitted to the Parliament. Furthermore, ALSAI submits to the Parliament the Bulletin on its activity on quarterly basis. There are no fixed Parliamentary procedures for dealing with these reports. The Parliamentary Commission on Economy and Finances scrutinizes SAI annual report of its activities and produces a draft-Parliamentary Resolution on SAI’s annual performance that is discussed and approved in plenary session. Also, it scrutinizes the SAI Report on the implementation of the previous State Budget, before the Government sends to Parliament the draft Law for the upcoming State Budget. The Commission deals with particular audit reports of the SAI on specific requests from members of Parliament or the Prime Minister. The recommendations of ALSAI are useful and professional. With regard the recommendations monitoring procedure, each audit to an entity, refers to the fulfillment of recommendations given by ALSAI during the last audit carried out. Likewise, at the end of the year, it is undertaken a special audit mission in all entities audited during the current year, in order to verify the status of recommendations given previously. ALSAI publishes on the website for each of the audited entities, executive summaries including: findings, conclusions and recommendations, as well as whether the audited entity has accepted or not the recommendations done. Protection of the EU's financial interests Albanian legal framework Regarding the definition of the criminal offense of money laundering, Article 287 of the Penal Code "Cleaning of the proceeds of crime or criminal activity"66 provides: Article 287 Laundering of the proceeds of criminal offence or criminal activity through: a) The conversion or transfer of property, for the purpose of concealing or disguising the illicit origin of the property, knowing that such property is the proceeds of criminal offence or criminal activity; b) The concealment or disguise of the true nature, source, location, disposition, movement or ownership of or the rights with respect to property, knowing that such property is the proceeds of criminal offence or criminal activity; c) The acquisition, possession or use of property, knowing, at the time of receipt, that such property is the proceeds of criminal offence or criminal activity; d) Commission of financial actions or divided transactions to avoid reporting according to the legislation on the prevention of money laundering; e) Investment in economic or financial activities of money or objects, knowing that they are proceeds of criminal offence or criminal activity; f) consultation, assistance, instigation or public call for the commission of each of the offences defined above, shall be punished by five up to ten years of imprisonment. If this offence is committed in the course of the exercise of a professional activity, in complicity or more than once, it shall be punishable by a term from seven up to fifteen years of imprisonment. The same offence, if inflicting serious consequences, shall be punishable by not less than fifteen years of imprisonment. The provisions of this article shall apply even if: a) the criminal offence whose proceeds are laundered, is committed by a person who cannot be taken as a defendant or cannot be sentenced; b) the prosecution for the criminal offence, the proceeds of which are laundered, is prescribed or given amnesty for; c) the person who commits laundering of proceeds is the same with the person who has committed the criminal offence, the proceeds of which are laundered; ç) The criminal offence whose proceeds are laundered, is committed by a person, despite his citizenship, out of the territory of the Republic of Albania and at the same time it is punishable both in the foreign state and in the Republic of Albania; Awareness and purpose according to the first paragraph of this article may be revealed from objective circumstances of the fact; The institution in charge for the prevention of money laundering is the General Directorate for the Prevention of Money Laundering which pursuant to Law no. 9917 dated 19.05.2008 "On the prevention of money laundering and terrorism financing", as amended, exercises the functions of the responsible authority under this law, as an institution under the Ministry of Finance. This directorate, within its scope of activity, is empowered to determine the manner of pursuing and resolving cases related to potential money laundering and financing of potential terrorist activities. Pursuant to this law, the General Directorate for the Prevention of Money Laundering, acts as a specialized financial unit for the prevention and fight against money laundering and terrorism financing. Moreover, this directorate functions as the national centre in charge of the collection, analysis and dissemination of data regarding the potential money laundering and terrorism financing activities, to the law enforcement agencies. The designation of AFCOS represents an institution building measure. By setting up or designating such service, giving in this way a legal mandate for function, Albania has demonstrated its capability to give effective protection to the EU’s financial interests and co-operate effectively in this respect with the Commission (OLAF), as required by Article 325 of the TFEU(ex-Article 280 of the EC Treaty). AFCOS is established in the Ministry of Finance, within the Directorate of Public Financial Inspection. Legal Bases:
A national anti-fraud coordination service (AFCOS) been designated as a single contact point for the Commission. However, it does not have the sufficient staff numbers and administrative capacity. Financial Inspection Department, in which AFCOS is positioned, is in the process of revising the legal basis of “Public Financial Inspection Law”, where there is included the function of AFCOS as well. There are no cooperation arrangements between AFCOS with OLAF. In this way, there is not a solid track record of investigation activities and on the spot checks between component national authorities and the OLAF. Irregularity Management System is established in all DM Structures. It has regulated through Memorandum of Understanding between NAO-AFCOS & NAO –General Prosecutor all mutual relations with regards to Irregularities Management. On the draft Law on “Public Financial Inspection Law”, besides the functions of AFCOS which serves as a contact point for OLAF, in the article nr. 11 “Functions of the Principal Authorizing Officer”, is added the point below: For European Funds only, the functions of the First Authorizing Officer regarding the Public Financial Inspection are performed by the National Authorizing Officer. Albania has prepared the Albanian PFM strategy 2014-2020, including the protection of the EU's financial interests, and a corresponding action plan for its implementation, (AFCOS legal basis). Protection of the euro against counterfeiting Albania has signed but not yet ratified the 1929 Geneva Convention for the suppression of counterfeiting currency. According to Article 40 of the Law no.8269 “On Bank of Albania”, Bank of Albania is the responsible authority for sequestering and confiscation of counterfeited bank notes and coins. Supervisory Council of the Bank of Albania has approved 2 regulations which aim at definition of rules and procedures on treatment of suspected counterfeited money, Albanian and foreign ones. These two regulations are partly in line with Regulation No.1338/2001 dated 28.06.2001 of the Council on necessary measures for the protection of euro from counterfeiting and Regulation No. 45/2009. Banking and non-banking institutions licensed by the Bank of Albania have the obligation to withdraw and to submit at the BoA National Centre of Analysis the banknotes and coins suspected as counterfeited, Albanian and foreign ones including Euro. According to Article 4 point g of the Regulation “On the suspected counterfeit Euro and other foreign banknotes and coins", approved by the Decision no. 49, date 31.07.2013 of the Supervisory Council of BoA, the following definition is provided in Albanian law: “counterfeit banknotes and coins” - are the banknotes and coins having the appearance of authentic banknotes and coins, illegally produced through the counterfeiting methods or various modifications, with the purpose their illegal use and/or fraud; This definition is in line with Council Regulation (EC) No 1338/2001 of 28 June 2001 laying down measures necessary for the protection of the euro against counterfeiting. According to the abovementioned Albanian Regulation (Article 11) the banknotes and coins, which at the end of the technical examination result to be counterfeit, shall be stored for a 15 (fifteen) years period with the Bank of Albania. At the termination of the storing term, the banknotes and coins may be destroyed as per procedural rules set forth by the Bank of Albania. The chosen samples of counterfeit banknotes and coins as integrated part of albums or catalogues will be maintained indefinitely, being part of the collection inventory of the National Analysis Centre Office. It should be added that the National Analysis Centre Office shall hand over the banknotes and coins for storing if they are subject of investigation in penal cases, based on the written request by the competent authorities. According to Article 5 of the Regulation “On the suspected counterfeit Euro and other foreign banknotes and coins" approved by Decision no. 49, date 31.07.2013 of the Supervisory Council of BoA, of BoA point 1: The entities shall ensure that the Euro and other foreign banknotes and metal coins received during the conduction of their activity are checked for the authenticity. According to Article 6 point 1 of the regulation no. 49 of BoA, point 1: The entities shall immediately sequestrate and withdraw from circulation the suspected counterfeit banknotes and/or coins. The banknotes and coins suspected as counterfeit by the entities, and those handed over voluntary, shall be consigned for check and examination at the National Analysis Centre Office, at the Bank of Albania's Issue Department. The consignment shall take place within 20 (twenty) business days from the day of concluding the suspect or their voluntary submission According to regulation no. 49 Article 13 on cooperation with the competent authorities, Bank of Albania has the right to enter into agreement with the European Central Bank and other authorities, in the field of the protection of Euro and other foreign banknotes and coins from counterfeiting. The Bank of Albania shall assure the harmonised implementation of these agreements with the requirements of this Regulation. The Bank of Albania, in compliance with the applicable legal framework, shall cooperate with the relevant national and/or international authorities to share information related to the prevention and protection of Euro and other foreign banknotes and coins from counterfeiting. In compliance with paragraph 2 of this Article, the Bank of Albania shall cooperate with the authorities responsible during the conduction of the respective tasks, in particular for:
According to the Albanian Penal Procedure Code, anyone who comes in contact with counterfeits shall hand over them to the competent authorities. According to Article 9 of the Regulation ”On the Albanian banknotes and coins suspected as courtefeit" approved by the Decision of the Supervisory Council of Bank of Albania No. 41 dated 26.06.2013 the entities shall accept the national banknotes and coins suspected as counterfeit, if handed over voluntary at their counters by either legal or natural persons. With regard to regulation of the medals and tokens similar to euro coins, Bank of Albania has planned to prepare a draft regulation which after the consultation with interested parties is foreseen to be approved by the Supervisory Council of the Bank of Albania within the first quarter of 2016. According to Article 5 of the Regulation “On the suspected counterfeit Euro and other foreign banknotes and coins " approved by the Decision of the Supervisory Council of Bank of Albania No. 49 dated 31.07.2013, entities shall ensure that the Euro and other foreign banknotes and coins received during the conduction of their activity are checked for the authenticity. The check for the authenticity is carried out by the machines for the handling of banknotes or metal coins67, or manually by a trained member of staff. The entities shall ensure that all the suspected counterfeit Euro and other foreign banknotes and coins be detected in a timely manner and not be put back into circulation for the consumers and other users. The National Analysis Centre at the BoA Issue Department was established by the Supervisory Council's Decision No. 57, dated 27.07.2011, changing the approach to counterfeiting, in accordance with best standards and practices of EU Central Banks. Similar to counterpart structures at EU central banks, the National Analysis Centre Office operates as a “Centre” for collecting, carrying out technical analysis and classification of counterfeit money, including euro banknotes and coins; processing technical and statistical information; monitoring and developing the database with data collected from technical analyses of counterfeit currency; and engaging in other activities to prevent and protect against counterfeit currency. To this purpose, the National Analysis Centre Office cooperates with competent authorities at a national and international level. At present, the National Analysis Centre consists of three experts. In September 2013, the forensic cabinet for technical expertise of counterfeit banknotes became fully operational. It is equipped with modern technological devices, such as:
Thanks to the technical and administrative capacities, the technical analysis of banknotes suspected of being counterfeit and detected by the Albanian banking system is fully carried out at the Bank of Albania's National Analysis Centre. The experts also prepare the expertise acts on the relevant expertise, process the technical data deriving from the expertise results and prepare the technical and statistical report on the counterfeit. During 2014 the National Analysis Centre detected and analysed a total of 1722 counterfeit, respectively 1385 and 337 domestic and foreign currency banknotes and coins. For the period covering 1 January 2015 - 15 April 2015, the Centre has detected and analysed 285 domestic and foreign currency banknotes and coins With a view to improving the technical capacities in the examination of coins, the National Analysis Centre has recently installed the expertise (analysis) cabinet for coins in accordance with European Anti-Fraud Office (OLAF) standards and recommendations. This cabinet is equipped with the following devices:
Bank of Albania is in the process of negotiating with national competent authorities (such as Ministry of Interior, State Police and General Prosecutor) aiming at achieving a mutual memorandum of Understanding for the protection of money against counterfeiting; centralization of analysis and elaboration of statistical and technical data on counterfeiting money. In compliance with the Regulation “On the suspected counterfeit Euro and other foreign banknotes and coins " approved by the Decision of the Supervisory Council of Bank of Albania No. 49 dated 31.07.2013, that stipulates the cooperation of the National Analysis Centre with European Central Bank, the Bank of Albania is negotiating a memorandum of understanding with the European Central Bank (actually a draft of agreement from ECB has been sent to BoA for consultation) on issues related to the protection of euro against counterfeiting. National competent authorities (Bank of Albania, State Police and General Prosecutor) participate regularly in the activities organized by the Pericles 2020 Programme such as training seminars, conferences and staff exchange.
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