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General observations
The ‘Pericles’ programme is an exchange, assistance and training programme for the protection of the euro against counterfeiting and related fraud. The proposed regulation will replace the legal basis of the ‘Pericles’ programme which will expire at the end of 2013, thus extending it to the end of 2020. The ECB reiterates its view that the ‘Pericles’ programme is a useful contribution to the activities already deployed by the ECB, Europol and national authorities in the fight against euro counterfeiting. The ECB is confident that the ‘Pericles 2020’ programme will continue to contribute to preserving the integrity of euro banknotes, including the second series of euro banknotes.
Specific observations
The programme should be evaluated against all the aspects that influence euro counterfeiting and fraud. Therefore, the ECB recommends full involvement of the ECB and Europol in evaluating the ‘Pericles 2020’ programme as provided for in Article 12(3) and (4) of the proposed regulation. While acknowledging the benefits for euro counterfeit and fraud deterrence worldwide by including third countries in the ‘Pericles 2020’ programme, third country involvement should be sensible and proportionate.
The ECB considers that the only reliable counterfeit detection machines and devices are those listed on its website as having performed satisfactorily in tests involving a batch of topical counterfeit types and genuine banknotes with a range of wear and tear characteristics. Such machines and devices are, however, aimed at the professional cash handling industry and are in general beyond the scope of the specialised anti-counterfeiting authorities defined as the target group in Article 8(2)(c) of the proposed regulation. Therefore, the ECB is of the opinion that it is not appropriate to consider financing the purchase of counterfeit detectors with funds of the ‘Pericles 2020’ programme or using counterfeit detectors by specialised anti-counterfeiting authorities.
It would be beneficial for the Commission, the ECB and Europol to examine initiatives to be funded under the ‘Pericles 2020’ programme jointly, thus avoiding duplication and overlap between the ‘Pericles 2020’ programme and other relevant programmes and activities and ensuring the development of a common strategy against euro counterfeiting and fraud. Therefore, recital 7 and Article 11 of the proposed regulation should be amended to provide for: (a) timely consultation of the principal parties involved by the Commission in relation to the annual work programme; and (b) obtaining the ECB’s and Europol’s agreement on the annual work programme for the purpose of its adoption. In this regard, the ECB and Europol should be given sufficient time to examine the draft annual work programme and to submit their views prior to its discussion within the appropriate advisory committee.