[{"bbox": [85, 151, 424, 180], "category": "Section-header", "text": "## 3.4 Risks and Lessons Learnt"}, {"bbox": [81, 193, 1157, 1626], "category": "Table", "text": "<table><thead><tr><td>Category</td><td>Risks</td><td>Likelihood</td><td>Impact</td><td>Mitigating measures</td></tr></thead><tbody><tr><td>External environment</td><td>Risk 1. There is a risk that Government may resist anti-corruption efforts and attempts to enhance accountability and rule of law, or that Government may no longer prioritise the implementation of reforms in the field of accountability and fighting corruption.</td><td>Medium</td><td>High</td><td>Given the approaching elections in 2024 and the fact that the current government came to power on an anti-corruption platform, the risk is assessed as medium. To mitigate the risk, the EU, together with other development partners and UN Agencies, will continue to engage in political dialogue to ensure corruption and accountability remain on the national agenda. The programme also deliberately includes support to both the supply and demand sides of accountability to ensure that citizens, civil society and the media are able to hold government to account and tackle corruption together.</td></tr><tr><td>External environment</td><td>Risk 2. Limited political will to prosecute high ranking officials could mean high levels of impunity and low prosecution and conviction rates of high-level offenders will persist.</td><td>High</td><td>High</td><td>While some level of impunity for high-ranking officials exists in all countries and is notoriously difficult to address without strong political will, and while such cases are difficult to prove especially since such officials can afford the best lawyers, the Action specifically includes support to the specialised Office of the Special Prosecutor, which is designed to investigate all cases, including those involving high ranking officials. The Office is already investigating and launching prosecutions against relatively high-ranking officials (such as the former head of the Public Procurement Authority) and is fiercely maintaining its independence. The Action also targets all other major anti-corruption institutions and provides support for CSO- and media-led advocacy. The mere fact that Government has agreed to a programme focused on corruption provides an excellent opportunity for strengthening political dialogue between the EU and Government on corruption issues as well as creating an issue around which advocacy and lobbying by civil society and the media can be built.</td></tr><tr><td>People and organisations</td><td>Risk 3. Institutions such as the OSP and Independent Constitutional Bodies (ICBs) remain underfunded to exercise their mandates and, in the case of the OSP, have</td><td>High</td><td>Medium</td><td>The legislation creating the OSP was passed in 2017, yet the Office is still to be fully established (although it is already bringing cases of corruption before the courts whilst still negotiating salary structures and planning to employ its full staff complement of 250 employees). While this creates a risk that the Office will not be fully operational at the start of the Action, the new Special Prosecutor (appointed in 2021) is driving the process and hoping to have staff employed during 2022. The</td></tr></tbody></table>"}, {"bbox": [1026, 1680, 1142, 1704], "category": "Page-footer", "text": "Page 14 of 28"}]