FINLAND. National Integrated Border Management Strategy

Transcription

1 FINLAND National Integrated Border Management Strategy

2 EXECUTIVE SUMMARY The purpose of this National Integrated Border Management Strategy is to establish a clear understanding on the implementation and further development of the Integrated Border Management in Finland. The IBM Strategy is developed to fulfil the national obligation defined in the Regulation on European Border and Coast Guard, and it takes into account the main elements for developing the European Integrated Border Management Strategy defined by the Commission (Communication COM(2018) 250 final) and the results of the strategy process established by the Commission. The border situation is relatively calm at the external borders, but several non-foreseeable developments may occur. The national integrated border management is well-defined; however, there is a constant need for development. Additionally, the strategy will be updated as the technical and operational integrated border management strategy becomes available. The most important challenge in Finland is to maintain the high performance of the border management system during austerity in public finance and diminished international predictability of the flow of illegal immigration. The main development areas of Finland s IBM are 1) ensuring credible border surveillance at the eastern border, 2) facilitating secure and fluent border traffic at the major border crossing points, including Helsinki Airport while preventing illegal immigration and effectively preventing cross-border crime, 3) boosting the return process, and 4) maintaining readiness to manage large-scale multipurpose missions at the Baltic Sea. VISION: Finland has the most secure external borders in Europe. Finland is a cooperative and internationally recognised actor in the field of border management, contributing effectively to the security of the European Union. Reliable and professional personnel, effective organisations and distribution of tasks, and state-of-the-art technology ensure high performance. MISSION: The Finnish IBM system is robust, and it will be developed further. Finnish border control and return system supports internal security and effectively prevents cross-border crime. Finland contributes to the common European border management and builds European best practices together with other Member States. The implementation of IBM in Finland takes into consideration state-of-the art technology, and the latest analytical tools and operational concepts such as intelligence-led policing. The aim is to further develop a costeffective and high-performing harmonised national IBM system. 2 FINLAND

3 CONTENTS 1. CONTEXT INTRODUCTION BORDER CONTROL BORDER SURVEILLANCE BORDER CHECKS CRIME PREVENTION INTERNATIONAL PROTECTION MARITIME SEARCH AND RESCUE RISK ANALYSIS MEMBER STATES COOPERATION SUPPORTED AND COORDINATED BY THE EUROPEAN BORDER AND COAST GUARD AGENCY INTER-AGENCY COOPERATION COOPERATION WITH THIRD COUNTRIES MEASURES WITHIN THE SCHENGEN AREA RETURN QUALITY CONTROL SOLIDARITY MECHANISMS TRAINING AND RESEARCH & INNOVATION FUNDAMENTAL RIGHTS BUDGET AND HUMAN RESOURCES...19 ANNEX ANNEX ANNEX National Integrated Border Management Strategy

4 1. CONTEXT The Regulation on European Border and Coast Guard entered into force on 6 October In the regulation, the concept of Integrated Border Management (IBM) is defined for the first time at the level of binding European legislation. The EU institutions are responsible for the development of the IBM strategy of the EU. The main elements for developing the European Integrated Border Management Strategy defined by the Commission (Communication COM(2018) 250 final) is the current guideline for national strategies. The guidelines will be updated as the next products of the strategy process are published. The most central instrument in implementation of the EU IBM is the European Border and Coast Guard, which is composed of the European Border and Coast Guard Agency (Frontex) and relevant authorities of the Member States. Frontex is in charge of delivering the technical and operational strategy for the IBM. According to the regulation, it is mandatory for the Member States to draft National IBM strategies. National strategies shall be aligned with those delivered by Frontex, taking into account the eleven (11) strategic components mentioned in Article 4 of the regulation. Thus, the comprehensive strategy of the European Border and Coast Guard will be composed of the strategies of Frontex and the strategies of the Member States. The aim of the National IBM strategy is to establish a clear understanding on the implementation and further development of the Integrated Border Management in Finland. The legal basis and guidelines for the strategy are provided by national legislation as well as national and international agreements. This IBM strategy is in line with other national strategies, such as internal security strategy. The involved authorities produce their strategies based on this strategy to the extent that the strategies concern IBM. Strategies are being implemented by annual and multi-annual plans and other documents. The legal basis, guidelines, agreements and implementing documents are listed in the annex. The strategy will be revised in the beginning of the EU funding programme, or when it is needed. The strategy and its implementation phase are reviewed annually by the IBM-Forum. Integrated Border Management of the EU is based on and implemented by the four-tier access control model (actions in third countries, cooperation with neighbouring countries, border control, and control measures within the area of free movement including return). State of the art technology is a cross-cutting theme that is included in all chapters of the strategy. For example, border control requires investments in modern technology, such as biometrics, ABC-solutions, advanced scanning and inspection systems, mobile sensors, interconnected databases, artificial intelligence and secure connections. This is why the technology is a part of all the chapters of this document and not a separate chapter. The National IBM Strategy of Finland has been drafted in cooperation between the national stakeholders involved in the IBM. The stakeholders are the National Integrated Border Management Forum (IBM Forum). The Border Guard is the responsible body for the drafting process and coordinates the work of the IBM Forum, which consists of representatives from the Border Guard Department, Police Department, Migration Departments and International Affairs Unit of Ministry of the Interior, Ministry for Foreign Affairs, Finnish Immigration Service, Finnish Security Intelligence Service, National Police Board, National Bureau of Investigations, Finnish Customs and Non-Discrimination Ombudsman. The drafters are responsible for the development and updates of the strategy. The strategy has been approved by the ministries and agencies concerned and endorsed by the Ministerial Council on Migration. Helsinki-Vantaa Airport, the largest border crossing point in Finland. 2. INTRODUCTION The blending of security interfaces, as well as the increasing diversity of security threats, challenge the traditional security outlook. Large-scale illegal immigration, terrorism, organised crime, state actors, cyber threats, and the increasing vulnerability of modern society are challenges for the authorities. In this environment, Finland is emphasising its national features and developing the capabilities of border management authorities in order to prevent internal and external threats, both independently and as part of the European Union. Regarding illegal immigration, the main threats in Finland are related to a weakening predictability at the 1,340-kilometre-long eastern land border, large border crossing points at 4 FINLAND

5 the south-eastern border, and flights from the Far East. Concerning secondary movements, the main threats are related to the land border with Sweden (Tornio area) and ferry connections from Germany, Sweden and Estonia. Future challenges for the border management include possible changes in the situation in Russia, the constantly increasing air traffic at Helsinki airport, and a probable increase of passenger flow at land borders and changes in the legal basis (EU regulations). The border situation - including threats, vulnerabilities and impacts - are defined in the annual strategic risk analysis in detail. Finland participates in an active and constructive manner in the deepening and intensifying cooperation in European foreign and defence policy, internal security and migration policy. The Border Guard is the main responsible authority for integrated border management. The Border Guard s main tasks related to border management are border surveillance at land and sea borders and border checks at border crossing points at land, sea and air borders. The Border Guard prevents cross-border crime and is the responsible authority for search and rescue at sea. The Border Guard participates in national defence in case of a military crisis or conflict. The police and the Customs participate in border management in addition to their main tasks. The division of tasks between border management and immigration authorities is clear. The Finnish Immigration Service (Migri) is the agency that processes and decides on matters related to immigration, residence, refugee issues and Finnish nationality. The police are responsible for public order and general security. It is also the overall authority for crime prevention, including investigations. The police are also responsible for migration control and return operations. Customs is responsible for customs security, customs control, and customs-related crime prevention. The Ministry for Foreign Affairs is in charge of issuing visas and supporting cooperation in border control and return operations with third countries. The largest land border crossing point Vaalimaa, in eastern border of Finland. Despite a clearly defined division of tasks, national legislation enables smooth cooperation between the authorities. Furthermore, according to the national law, cooperation is mandatory for the law enforcement agencies. In pre-defined cases, it is also possible to cross administrative boundaries and operate on other authorities areas of responsibilities. The Border Guard, the police and the Finnish Immigration Service are subordinated for the Ministry of Interior, whereas Finnish Customs is subordinated to the Ministry of Finance. Finnish Customs is nevertheless under the guidance of the Ministry of the Interior in IBM-related matters. 3. BORDER CONTROL The goal of the border control is efficient and credible management of external borders as a part of internal and external security of the State. Border management enhances internal security and prevents cross-border crime. In border checks, the balance between fluent traffic and security is maintained. Border Guard activities in remote land border areas and in the Archipelago contribute positively to the security of inhabitants. The headquarters of the Finnish Border Guard coordinates operational planning of the border control. The operational plans are risk-analysis-driven and updated constantly. The plans are regularly tested, and they include contingency plans for extraordinary and unforeseen situations. Tornio, the internal border between Sweden and Finland. National Integrated Border Management Strategy

6 Border surveillance in archipelago area BORDER SURVEILLANCE The Border Guard is responsible for controlling the land and sea borders. There are four border guard and two coast guard districts for carrying out daily operations. The Air Patrol Squadron supports operational activities throughout the country. Situational awareness on border management is being established by a network of regional (border and coast guard districts/rcc) and national command centres (headquarters/ncc). The National Situational Picture (NSP) is established in the NCC and shared with RCCs, as well as with relevant police and Customs Command and Control centres. Other border management authorities have access to ESP, and their information is downloaded to the EUROSUR by the NCC. Situational awareness in the maritime domain is established in close cooperation between the Border Guard, the navy and the transport agency. The system detects, identifies and if necessary intercepts all vessels coming into territorial waters. Reaction capability is ensured by allocating human resources from other functions, appointing recently retired officers to operational duties (based on commitments), and if need be, calling up the reserves of the Border Guard. There are also the Border Guard s Special Intervention Units available. The teams are on standby readiness and are capable of managing extraordinary cases at border crossing points as well as at land and sea borders. The response is based on mobile patrols, which can be transported to the scene by cars, snow mobiles, motorcycles or all-terrain vehicles. Additionally, helicopters and maritime vessels can transport the response patrols. Joint contingency plans and agency-specific contingency plans enable the receiving of European and international support to manage unforeseen large-scale border incidents. There are plans to establish hotspots facilitating Frontex, Easo and Europol support, among others. The plans are under constant development, aiming for high operational readiness for European joint actions in Finland, if required. Border Guard s Special Intervention units are trained to act fast and effective in all circumstances. In the near future, development will focus on the integration of new mobile surveillance technology with the existing surveillance systems. The aim for the longer term is to develop automation, analytics, and management of sensor data. Situational awareness on the land border is the key to the preventive actions and operational response. In the most important areas, the situational picture is built mainly by stationary and mobile technical surveillance equipment. In other areas, sniffer dogs are the main tool. The sea area is covered with cameras and radars. The situational picture is collected, analysed and utilised in centralised command centres (RCC), which are able to share and fuse the information. Border surveillance at the external land and sea borders is based on risk analysis at all levels of the Border Guard organisation. Surveillance is being carried out by patrols with high mobility. Patrols are supported by stationary and mobile technical surveillance systems and aerial and surface assets. In high-risk areas, the reaction capability to prevent and reveal all unauthorised border crossings is immediate. Trained border guard sniffer dogs are very important tools in land border, regardless of high quality technical surveillance equipment. 6 FINLAND

7 A special area of development in border surveillance is detection and identification capabilities in all weather conditions on a 24/7 basis. Furthermore, night vision capability and development of unmanned aerial systems (UAS) are the main areas of development. The Border Guard is developing the use of fixed wing flying sensors for border surveillance. The possibilities for using hovering sensors are being considered. Finland also actively participates in the development of systems for improving situational awareness at the EU level. At the national level, the main focus is to develop IT systems jointly with different authorities and ministries, thereby supporting an exchange of information and cooperation between authorities. The development will take place in line with the development of the Schengen Borders Code and EUROSUR regulation, aiming at enhanced interoperability. 1. Developing the land surveillance system, including drones, mobile sensors, data fusion, data processing analysis and shared situational awareness for inter-agency cooperation. 2. Developing the response capabilities of the patrols, including special intervention capability, anti-terrorist and hybrid response, and ensuring mobility by renewing the helicopters. 3. Developing the national legislation, contingency plans, hotspot readiness, registration capacity and inter-agency cooperation to manage unprecedented large-scale illegal immigration crises at the eastern border. Further developing strategic reserves, by training conscripts, reservists and developing readiness to hire retired border guards back to service. Maintaining readiness to internally redeploy personnel for eastern land border surveillance tasks BORDER CHECKS The facilitation of fluent border traffic is a high priority while ensuring border security. The challenge is to ensure fluent traffic flows especially in the long term, as Finno-Russian land border traffic will be increasing. Fluent traffic is an aspect that has an impact on the fluent flow of goods and on other dimensions beyond the scope of the IBM. In the medium term, the challenge is the constantly increasing passenger flow at Helsinki airport. Regarding border checks, the division of tasks between authorities has been stipulated in a Governmental Decree (901/2006). The Border Guard is the main authority. Customs is in charge at most seaports, while the police take care of the checks at the airports inside the country. The police and customs officers who conduct border checks have received proper training organised by the Border Guard. Passenger flow in Port of Helsinki. Border management and efficiency of border checks at the major border crossing points are being ensured by a functional division of labour between the Border Guard and Customs. At the largest land border crossing points, the Border Guard and Customs operate in each other s areas of responsibility in order to ensure good customer service and the efficient and effective use of human resources. According to procedure, Customs carries out I-line border checks on cargo traffic, whereas the Border Guard carries out I-line customs control on light traffic. Situation awareness is effective with mobile technical systems and co-operation of trained staff. Finland promotes at the European and national level the balance between fluent border crossings and security. National measures include full utilisation of the National Registered Traveller Program and its compatibility with the development of the European Entry/Exit System. Additionally, all the infrastructure development projects of the border crossing points will be ensured to allow full utilisation of the automated border check devices and biometric solutions. In addition to the technical solutions, legislative measures must support operational needs. National Integrated Border Management Strategy

8 Development of different EU IT systems, such as the Entry/Exit System (EES), the European Travel Information and Authorisation System (ETIAS), the Schengen Information System (SIS) and other IT-related initiatives at the EU level, are taken into account in a proactive manner at the national level. A national ETIAS unit will be established within the Border Guard, and it will be integrated with other pre-checking activities (API, customs targeting functions, Passenger Name Record (PNR) and other Police Customs Border Guard (PCB) functions for air-, sea- and land-border crossing points). New border check technologies in use. 4. Ensuring a value-adding and operationally effective European and national legislative framework (ETIAS, EES, amendments to the Schengen borders code, SIS, PNR). 5. Developing the border crossing points to ensure effective border checks, fluent passenger flow and full utilisation of technology, including ABC solutions, biometrics and mobile border checks. The main emphasis is at Helsinki airport, Helsinki harbour and at the major border crossing points at the eastern land border. 6. Reviewing the opening hours of the border crossing points at the eastern land border to reflect the passenger traffic development and cost-effectiveness. The focus is on the development of automation for border checks and on the development of mobile control technologies. The framework for the development of border crossing points is developed with the close cooperation of all authorities. The centralised use of databases between the different authorities and ministries is further developed. This is how the efficiency of both border checks and internal security has been improved CRIME PREVENTION The Border Guard, the police, and Customs work together to prevent cross-border crime. According to uniform national legislation, all three authorities are mandated to carry out pre-trial investigations on cross-border crime. In order to reveal and prevent crossborder crime, the three authorities have established certain joint PCB intelligence and analysis units. The units focus on cross-border crime at land, sea, and air borders. The units are being coordinated by the national PCB crime intelligence and analysis centre. All three authorities are also involved in the European Union Policy Cycle on organised crime. Crime prevention priorities are implemented through EMPACT projects. Investigation on proceeding. All the border crossing points have temporary facilities for apprehensions of less than 12 hours. For longer detention or arrest times, detainees are transported to regional police prisons, which are available in all the provinces of Finland. Border checking in moving train. 8 FINLAND

9 3.4. INTERNATIONAL PROTECTION The asylum process requires close cooperation among relevant migration and border management authorities. The police or the Border Guard is responsible for registering asylum applications. Additionally, the screening of persons in need of international protection and of vulnerable groups is conducted in conjunction with the border checks. After registration, cases are transferred to the Finnish Immigration Service for further evaluation and investigation. The Immigration Service decides whether the asylum seeker is justified to receive international protection according to Finnish and European legislation. Applicants who receive negative decisions will then be returned in an effective, humane and fair manner. Asylum seekers in Raja-Jooseppi border crossing point in The Security Intelligence Service is in charge of fighting terrorism, while the National Bureau of Investigation (in cooperation with other security authorities) is responsible for the pre-trial investigation of terrorism-related crime. In order to discover and prevent terrorism, all personnel conducting border checks have been trained in common risk indicators for foreign terrorist fighters. The crime prevention unit of the Finnish Border Guard coordinates the identification measures of suspected terrorists at border crossing points in close cooperation with the other agencies. Detected suspects will be directed to second-line checks or necessary surveillance is organised. In this regard, the exchange of information between the agencies is flawless. Additionally, national databases and information systems allow targeting and creating alerts to ensure the detection of known terrorist suspects. The police and the Border Guard are the responsible authorities in investigations of trafficking in human beings. Victims of trafficking have a legal right to receive assistance and aid from Immigration Service s aid programme. 7. Reviewing and ensuring the national harmonised, centralised and cost-effective approach to crime intelligence and investigations, including the Border Guard, Customs and the police and Security Intelligence Service, taking into consideration EMPACT projects and avoiding overlaps regarding national intelligence and analysis personnel and ICT systems. 8. Studying the expansion and full utilisation of European and bilateral cooperation possibilities, including Interpol, Europol, Eurojust and other relevant EU agencies. 9. Reviewing competences and capabilities for crime investigations in the maritime domain. 10. Upgrade the situational picture of the asylum seekers. 11. Develop contingency plans for reception capacity. 4. MARITIME SEARCH AND RESCUE The goal of maritime search and rescue (SAR) is to maintain a reliable national Maritime Search and Rescue system and to ensure adequately trained personnel and sufficiently equipped aircraft and vessels for Frontex-coordinated operations. The Border Guard is the leading maritime SAR authority. The Border Guard is responsible for planning, developing and supervising all SAR activities as well as coordinating cooperation with other public authorities and volunteers. In addition to the Border Guard, other maritime SAR authorities are the Emergency Response Centre Administration, the Meteorological Institute, relevant local emergency services, the Transport Safety Authority, Finnish Transport Agency, the police, defence forces, social and healthcare services, Customs, and environmental authorities. Moreover, volunteers and other organisations contribute to maritime SAR activities, the Lifeboat Institution being one of the key actors. Maritime SAR situational awareness is maintained in parallel with the border control related situational picture. Maintenance of the situational picture and coordination of the rescue missions are led by a maritime rescue coordination centre (MRCC) and a maritime rescue subcentre (MRSC), which are at the same time the coast guard districts regional coordination centres (RCC). The focus of preparedness is on the coordination of demanding large-scale accidents at sea and on the implementation and development of regional mass rescue operation plans according to the National Mass Rescue Operation Plan ( MoMeVa ). The SAR requirements for units deployed to Frontex-coordinated operations (including other international maritime operations) are defined on a case-by-case basis. Operational models are National Integrated Border Management Strategy

10 5. RISK ANALYSIS The goal of a risk analysis system for border management is to support decision-making at all organisational levels and to ensure a flexible and cost-effective use of resources and allocation of border guards and assets to areas where risks are highest. Maritime cooperation. based on the maritime SAR training and safety system of the Finnish Border Guard. Detailed preparedness and capacity requirements are defined by orders of each operation. At a minimum, units would have the same capacities to operate in international SAR activities as they have when they are operating in Finland. The deployed unit s capacity and preparedness concerning both the equipment and the crew is confirmed before the operation commences. Maritime SAR capabilities are developed by improving personnel professionalism and by replacing old aerial and surface assets. In , the Border Guard will acquire new fast boats for coast guard stations, and the technical systems of coastal patrol boats will be updated. The risk analysis system of the Border Guard produces analysed information and a situational picture to support planning and decision-making at strategic, operational and tactical levels. These analyses drafted by specially trained personnel at different organisational levels interact together and thus provide a comprehensive national risk analysis that is at the same time tailored for different needs. Changes in risk levels are identified with continuous monitoring of risks and regular monitoring products. There is a risk analysis unit at the national level (at Border Guard headquarters), risk analysis sectors at the regional level (at border/coast guard districts headquarters), and trained risk analysis officers at the local level (at border/coast guard stations and BCPs). National level risk analysis on border management is methodologically based on the EU CIRAM model, according to which risk is analysed through its three components at all four tiers of the access control model. Border Guard cooperation in risk analysis with other national authorities, neighbouring countries, Frontex, and other international partners is an essential part of the national risk analysis system. The Border Guard participates in Frontex Risk Analysis Network (FRAN) activities and is responsible for collecting the FRAN data. Frontex risk analysis products are disseminated in Finland to be utilised by relevant end-users. In addition to what has been stated above, for law enforcement purposes more advanced risk analysis methods and analytical tools shall be used. The emphasis in the development of maritime SAR is on command and control systems and prevention of environmental accidents at sea. Moreover, the management of diverse and largescale mass rescue operations is developed (including chemical accidents and Hazardous and Noxious Substances (HNS) incidents). 12. Developing maritime response capabilities, including renewing the fast boats and purchasing high performance patrol boats. 13. Further elaborating the mobile surveillance and response system at sea (closure of three coast guard stations to ensure operational readiness and cost savings). 14. Implementing national and international measures to increase command and response capabilities of multipurpose and mass rescue operations, including Baltic Sea MIRG, ChemSAR, Vessel Triage, Baltic ACO-manual implementation, National MRO plan and SARC. 1 1 MIRG (Maritime Response Incident Group), ChemSAR (Chemical Search and Rescue, Vessel Triage (referring to the sorting of vessels in different distress conditions), ACO (Aircraft coordinator), MRO (Mass Rescue Operation), SARC (Search and rescue in the Artic). Frontex operation situation centre. PCB authorities have a common crime situational picture; and based on that, they draft common 10 FINLAND

11 risk analysis to support strategic, operational and tactical decision-making and operational activities. Possibilities are developing for PCB authorities to pre-check passengers. The authorities have access to advanced passenger information (API) and passenger name records (PNR) in dedicated units. Utilisation of European-wide databases will be further intensified. Operational risk analysis also supports defining targets in crime prevention. The border guards on the ground are provided with constantly updated knowledge of risk indicators, risk profiles and typical modi operandi of cross-border crime. The indicators and profiles are produced by the Border Guard National and Regional HQs and PCB centres. The risk analysis products are locally distributed and trained by dedicated crime-intelligence officers in the units. The indicators are checked and updated daily at the border crossing points in conjunction with the tactical risk analysis. PCB authorities intelligence-led analysis and proactive automated analyst functions form together with the CIRAM model s responsive analysis development base for a genuinely preventive and revealing instrument for combating cross-border criminality and illegal immigration. Customs own national risk analysis covers all Finnish borders, including cargo and passenger traffic. Customs performs risk management and targeting in close cooperation within the PCB structure. Moreover, the Border Guard and Customs have a joint regional risk analysis group Merilinna, which focuses on tactical risk analysis of cargo vessels. At the EU level, the Common Customs Risk Management Framework and its implementation (Customs Risk Management System) constitute a central part in the implementation of the EU Internal Security Strategy, which again supports border management. Integration of the national risk analysis system into the European framework continues in several different domains (i.a. EUROSUR, new obligations from the EBCG regulation, further implementation of CIRAM). The Border Guard develops new technical solutions and European cooperation possibilities for improving the national pre-frontier intelligence picture. 15. Fully implementing NCC 24/7 functions as a hub for the national command and control function of the national and international operations and information exchange. 16. Further improving tailored CIRAM-based risk analysis products and profiles for operational- and tactical-level end-users and to ensure professional skills of the personnel regarding CIRAM to the extent of the requirements of individual job descriptions 17. Fully utilising PCB networks and API and PIU units, the PCB crime intelligence and analysis centre and units, pre-checks, targeting and other joint operations. Offshore patrol vessel Merikarhu operating in Greece Frontex operation. 6. MEMBER STATES COOPERATION SUPPORTED AND COORDINATED BY THE EUROPEAN BORDER AND COAST GUARD AGENCY The goal of active participation in Frontex-coordinated cooperation and operational activities is to develop the high quality and cost-effectiveness of the European integrated border management system, which supports Finland s national border management. Finland participates in Frontex-coordinated cooperation in an active and extensive manner. Finland is represented in the Frontex Management Board by the Finnish Border Guard, which is responsible for the practical cooperation with Frontex and accountable for the fulfilment of the national cooperation obligation with Frontex. The Headquarters (HQ) of the Border Guard is the National Point of Contact with Frontex. The Finnish Border Guard is responsible for the participation in the Frontex working groups, excluding the return-related working groups, which are represented by the police. The Non-Discrimination Ombudsman participates in all activities and meetings related to return-monitoring. The Border Guard HQ hosts Frontex liaison officer to Finland. Finland aims to maintain 3 5 Seconded National Experts (SNE) in Frontex. Retired personnel from law enforcement agencies are especially encouraged to apply for Frontex Temporary Agent (TA/AD) posts. Finland s priority is to have TA positions in the operational units. The goal is to gain up to 10 essential operational or managerial TA positions in Frontex by National Integrated Border Management Strategy

12 Participation in Frontex operations is prioritised based on the European border situation. In addition to that, regionally significant operations in northern Europe and at air borders are supported by the Border Guard. The Border Guard s contribution to joint operations is maintained at a high level (over 20 FTE). Rapid border interventions are being participated in. Furthermore, return operations will be participated in based on the overarching consideration. Participation in Frontex-coordinated operations and training supports not only European border management; it contributes to national capacity-building. Frontex will be encouraged to act compatibly with other EU agencies, particularly Europol, Easo, EFCA, eu-lisa and EMSA. The Border Guard maintains a pool of European Border and Coast Guard team members, which ensure constant readiness for deploying 30 border guards for rapid interventions according to the European Border and Coast Guard regulation. The human resources in the pool is updated on an annual basis. A fixed wing aircraft, an offshore patrol vessel, a patrol boat and a fast boat have been nominated to the technical pool by the Border Guard. The police and the Non- Discriminatory Ombudsman have nominated representatives for the return pools. Finland is constantly ready to host joint operations and rapid interventions at land, sea and air borders, including contingency plans and readiness to establish hotspots. The main emphasis of the host country capabilities is at the border crossing points (Focal Points) of the eastern land border and at Helsinki airport. Moreover, Frontex participation in the EU cross-sectoral joint control operations is supported, taking into consideration Border Guard Customs guidelines and inter-agency cooperation on the operational level. The most important bilateral partner Member States are Estonia, Sweden and Norway, with which the operational cooperation is organised both bilaterally and multilaterally. The other bilateral cooperation countries are those around the Baltic Sea. The Border Guard supports the development of coast guard cooperation. The Border Guard contributes to this development via active participation within European, Arctic and North Atlantic Coast Guard fora. Bilateral cooperation at the Baltic Sea will be under further development in the near future. The main emphasis of the development will be the exchange of information, border control cooperation and coast guard functions. 18. Studying the possibilities for increased full-time equivalent contributions to Frontex field operations and long-term deployments of maritime assets with renewed operational concepts, including multinational crews. 19. Improving national readiness to participate in rapid border interventions with the HR and TE pool. 20. Increasing hosting capacity with operational plans (especially at the eastern land border). 7. INTER-AGENCY COOPERATION The goal of the inter-agency cooperation between the police, Customs and Border Guard is to improve each authority capability of carrying out its tasks in an appropriate, efficient and cost-efficient way. Inter-agency cooperation between the police, Customs and Border Guard (PCB cooperation) is based on law (687/2009) and governmental degree (1126/2009). These authorities can conduct authoritative actions in a cost-efficient way on behalf of each other and also outside of their own area of responsibility. PCB cooperation enhances the efficiency of border checks, alien monitoring and custom controls, and it ensures the common use and acquisition of technical equipment. Furthermore, the cooperation improves the prevention of cross-border crime, and it enables collaboration in crime intelligence as well as the extensive common use of databases. At border crossing points, competent authorities cooperate in controlling the roadworthiness of vehicles and the condition of drivers. PCB authorities have the readiness to establish the hot-spot concept at internal or external borders. The PCB international affairs working group plays a vital role in coordinating authorities common activities in international cooperation. The group discusses i.a. deployment of liaison officers to third countries. Liaison officers nominated by the police, Customs and the Border Guard to EUROPOL are in intense cooperation. The National SIRENE bureau is under the responsibility of the National Bureau of Investigation. The Ministry for Foreign Affairs cooperates with the Border Guard and the police on the visa issuance process. Finland s participation in the EU Policy Cycle is coordinated between PCB authorities. The Border Guard participates in all of the Policy Cycle s activities where Frontex has a leading role. Combating cross-border crime is based on common threat assessment Inter-agency cooperation between police, border guard in accordance with the European and customs. multidisciplinary platform against criminal threats (EMPACT), as well as on commonly decided and targeted criminalities and operational actions. In Finland, the prevention measures are aimed especially at human smuggling, trafficking in human beings (THB), drug offences and other cross-border crimes that are related to border management, but in several cases they are detected in the area of free movement. An essential factor of success in inter-agency cooperation is the common use of databases (for example the Ulkonet system) and the exchange of information between the authorities. It is also possible to insert information partially. This enables the sharing of crucial border management 12 FINLAND

13 information in real time while fully respecting data protection rules. The police, Customs and Border Guard cooperate closely to prevent and investigate crimes related to organising illegal immigration. The agencies have joint access to several databases, and the agencies data is interlinked to ensure the information flow (i.a. UMA ). Common IT and surveillance systems will be developed. One of the main goals is to share the common situational picture. Inter-agency cooperation at border crossing points will be developed in accordance with the EU Border Guard Customs Guidelines. The aim of inter-agency cooperation between the Border Guard, defence forces, the Finnish Transport Safety Agency and the Transport Agency ( METO cooperation) is to organise maritime surveillance in a cost-efficient manner. Moreover, it facilitates information exchange between maritime, authorities and it develops the cost-effectiveness of other maritime activities. METO cooperation ensures the common use of surveillance sensors in the coast, archipelago and maritime domain. Furthermore, METO cooperation enables maintaining awareness on other counterparts activities and projects. The cooperation is based on the authorities written agreement. Public-private partnerships have an essential role in ensuring fluent border traffic and security. Especially the Border Guard and Customs are cooperating closely with state-owned and private companies such as Finavia (an airport operator) and VR (a railway operator) related to the development of the border infrastructure and border crossing procedures. 21. Reviewing the national PCB cooperation networks and standing organisations to ensure cost-effectiveness, avoidance of overlapping, and joint operational capabilities. 22. Building joint inter-agency processes through utilisation of API and PNR in the framework of PCB cooperation, development of a joint targeting process, and combining these processes into the national integrated crime process information system (VITJA). The main focus of third-country cooperation is on the cooperation with Russia. Cooperation between Finland and Russia on border management is based on international bilateral agreements. The main aim of the border control cooperation between Finland and Russia is to maintain and further improve border management, fighting cross-border crime, and contributing to the fluency of the cross-border traffic. Structured cooperation exists at strategic, operational and tactical levels. Cooperation is regular, and the intensity of the cooperation can be adjusted based on operational needs and the border situation. Border control cooperation between Finland and Russia is managed from the executive level by the chief of the Finnish Border Guard and the chief of the Russian State Border Guard Service. Cooperation between Finland and Russia is planned in the permanent Finnish-Russian border guard working group and its subgroups. Border commissioners nominated from both sides of the border are responsible for the practical implementation of the border control cooperation. Regular cooperation with third countries other than Russia is based on international agreements, memorandum of understanding documents and established practices. In addition to that, Finland participates in capacity-building projects in third countries based on operational needs and case-by-case assessment. Finland actively cooperates at the EU level with efforts to establish new readmission agreements and procedures between the EU and third countries. Relatedly, Finland supports EU partnership programmes with third countries. One important aim is to include the most important countries from the Finnish perspective in return operations under the coverage of EU programmes for return (Iraq, Afghanistan, Somalia). 8. COOPERATION WITH THIRD COUNTRIES The goal of third country cooperation is to prevent illegal immigration and cross-border crime outside of the Finnish and EU borders as well as to facilitate the return of illegally staying third-country nationals. Activities in third countries and cooperation with third countries are important in order to improve the effectiveness of border control activities. The aim is to establish uniform and clear working methods and procedures with third countries in order to facilitate an effective implementation of the EU Integrated Border Management concept. Cooperation with Russian border guards. National Integrated Border Management Strategy

14 An important area of development in the near future is to establish functional cooperation between the Finnish police and authorities of third countries involved in return activities. A special focus of that work is to improve and strengthen cooperation between officials of relevant consulates. Return charter flights organised by Frontex are being used as effectively as possible. The Border Guard participates in the border management related EU civilian crisis management mission. The focus of participation is on the missions that are most relevant to EU internal security. Finland actively supports including the border management dimension in all missions and operations of the EU and international organisations such as OSCE, NATO and the UN. Regional cooperation and coordination in the Baltic Sea area is pursued by the police, Border Guard and Customs authorities participating in the work of the Baltic Sea Task Force on Organised Crime (BSTF) and the Baltic Sea Region Border Control Cooperation (BSRBCC). Liaison Officers and Visa Issuance The goal of the Border Guard, the police and the Customs liaison officer activities in third countries is to prevent illegal immigration, THB and other cross-border criminality at the outermost tier of the four-tier access control model. Liaison officer activities prevent on an annual basis the arrival of thousands of illegal immigrants to Finland and the Schengen area. The Ministry for Foreign Affairs is the responsible authority for issuing visas abroad. Liaison officer activities contribute to the visa issuance process by detecting potential illegal immigrants, criminals and possible victims of THB. The visa issuance is an important layer controlling access to the whole Schengen area. The visa issuance process can prevent illegal immigration. Finland and the other member states are currently dealing with more than 15 million visa applications annually. of liaison officers under PTN acting in 25 different countries can be used by all authorities involved in the implementation of EU-integrated border management. A specific aim is to further develop liaison officers activities towards more operationally flexible use. So-called roving liaison officers are being rapidly deployed based on operational needs. In addition to that, cooperation with Frontex s liaison officers and European Migration Liaison Officers (EMLO) is constantly being developed. 23. Maintaining and further developing cooperation and information exchange, especially in crime prevention, with the Russian Federation in order to maintain border security at the external border. 24. Further developing liaison officers activities and network towards flexible and effective use. 9. MEASURES WITHIN THE SCHENGEN AREA The goal of measures within the Schengen area is to control migrants condition for entry and stay, to prevent and tackle illegal immigration, to detect illegal labour, and to identify victims of trafficking in human beings. Moreover, checks within the territory prevent vulnerable migrants from being abused by criminals. The police are the main responsible authority for measures within the Schengen area. Related to its main duties, the Border Guard carries out migration control at border crossing points and Deployment of the liaison officers is based on risk analysis. Therefore, they are placed in the countries of origin and transit through which the illegal immigration comes to Finland, but in specific cases, in the EU Member States as well. The main country of deployment is Russia; the Border Guard has four liaison officers there, and this number will be maintained. Liaison officers are regularly in contact with their home organisations and participate in the visa issuance procedure, in crime prevention activities and in investigation of detected incidents related to illegal immigration and THB. Furthermore, the liaison officers support return-related functions. If there is an operational need, document experts (ALDO) can also be deployed to the airports in third countries on short notice. Liaison officers also have an important role cooperating with airline operators and third countries state officials. Training is one of the key functions of the liaison officers. The Nordic Police and Customs cooperation (PTN, Police och Tull i Norden) has an important additional role in further intensifying border control activities. Liaison officers acting under PTN also have jurisdiction to fight against organised cross-border crime. The contacts and knowledge Rush hour in Helsinki airport. 14 FINLAND

15 border areas. The Border Guard participates in migration control operations inland, based on a request by the police. Actions and controls within the Schengen area are based on good situational awareness, and particularly on efficient information and intelligence exchange as well as on full use of intelligence databases. The Finnish agencies have common and interoperable databases, which are in some cases operated in joint facilities, such as a national PCB centre or PCB intelligence units. In addition to this, essential data is automatically exchanged between information systems. For example, UMA, PATJA and RVT allow automated information about crimes, refusals of entry, asylum applications and asylum decisions between the Finnish Border Guard, police and Immigration Service. The police have intensified its actions according to the Commission s recommendation on proportionate police checks and police cooperation in the Schengen area, dated Migration control inside the country is carried out in daily police duties and by thematic controls based on risk analysis. The police lead migration control operations, which are often carried out with other authorities (i.a. the Border Guard, Customs, tax and labour authorities). The measures are directed based on risk analysis. The police are in charge, and the other agencies (such as border guards) support them. The main emphasis is near border crossing points, internal borders, major cities and places of interest in terms of illegal work, such as restaurants and large construction sites. The operations are planned in the regional police districts, supported by inter-agency analysis and cooperation. 26. Upgrading readiness to reintroduce border controls at internal borders and other unified PCB measures at internal borders, including continuing to implement the Commission s recommendation on proportionate police checks and police cooperation in the Schengen area. 10. RETURN The goal is to effectively return all individuals who have been refused entry at the border or who have an enforceable return decision. Persons who pose a higher security risk are considered a priority in return operations. The police have the overall responsibility for the implementation of return operations, whereas the Finnish Immigration Service is responsible for issuing return decisions and implementing the national system of assisted voluntary return. The Border Guard supports the police based on requests. The Non-Discriminatory Ombudsman is responsible for monitoring return flights. In case of sudden and large illegal immigration, there are contingency plans to reintroduce internal border controls. Before reintroducing internal border control according to the Schengen Borders Code, increasing illegal immigration across the internal border is primarily taken under control by inter-agency cooperation and particularly by intensified migration control measures, such as police controls. The aim in reintroducing internal border controls is to ensure that passengers have the right to enter and stay in Finland, to identify asylum seekers and take them through the asylum process, and to detect possible terrorists and foreign terrorist fighters. The contingency plans and the capability of reintroducing internal border controls are maintained constantly. The main responsibility for that lies with the Border Guard. Reintroduction is executed in cooperation with the police and Customs. Resources for internal border control are reallocated from other tasks and operational areas. Border checks at internal borders are carried out based on risk analysis and crime intelligence. Intensified migration controls are carried out inland on a need basis. 25. Developing legislative and operational measures to reveal and prevent illegal residence in Finland, including reviewing penalties for illegal stays, confiscating travel documents, preventing illegal employment, and exchanging information between social insurance institutions and other authorities and stakeholders. The police is implementing the forced return escorting in Finland. The Immigration Service (MIGRI) maintains the situational picture and the prognosis of the return situation under the guidance of the Ministry of the Interior. The police produce plans of the returns in line with the European Border and Coast Guard Regulation and other relevant legislation. The plans contain national return flights, foreseeable support needs of Frontex and other Member States, and readiness to host return operations, including rapid return interventions in Finland. The police are responsible for documenting and communicating the return situation and implemented return operations by the Frontex Application for Return (FAR) and IRMA (Integrated Return Management Application). National Integrated Border Management Strategy

16 The international cooperation in the field of return depends on the willingness of the receiving countries to accept its citizens who have been issued return decisions. The functional cooperation between the police and the agencies in the return destination country is essential, including civil servant level collaboration with embassies and consulates. Bilateral readmission agreements or return agreements negotiated by the EU or Finland support returns to the challenging countries. The police are responsible for organising the returns at the practical level. The administrative coordination of certain return issues is centralised in two police units. All police units contribute to the practical implementation of return operations. Both scheduled flights and charters are used. Frontex-organised return charter flights will be participated in, if possible. The police have dedicated six policemen to the Frontex pool of return escorts. As the primary option, the returnees are offered the possibility of assisted voluntary return. The support of the International Organisation for Migration (IOM) is used in relation to voluntary return flights. Voluntary return support can be granted, in line with national legislation. Voluntary return support cannot be granted if the returnee has a return decision based on criminal conduct. The goal is to maintain effective returns even during the increased volume of returnees. Cooperation in return matters with third countries and their consulates will be further improved. To ensure that the returnees will not try to avoid the execution of the return, the police may use measures based on the Aliens Act. Detention is the strictest and the last option. In Finland there are two closed detention centres, which have the capacity for 4,000 annual returns. This capacity will be increased up to 10,000 returns. This means increasing the detention capacity from 80 to 110 persons at a time. Additionally, in urgent situations and if detention centres are full, police prisons may be used to ensure that the returnee will not avoid the return operation. 27. Increase the number of voluntary returns and increase bilateral and European return operations. Conclude readmission arrangements with key third-countries (Iraq, Somalia). Developing the situational picture of the returnees, sharing it with stakeholders and upgrading the planning of returns support the process. 28. Increasing the detention and imprisonment capacity of returnees who are suspected of avoiding return operations. 29. Increasing the hosting capacity of the Frontex return operations, including establishing readiness to host rapid return interventions with a European escort, a monitor and specialist support, including pre-return support. 11. QUALITY CONTROL The main goal of border management related quality control is to ensure the adequate implementation of EU IBM and Schengen Acquis in Finland. The secondary aim is to support the development of compatibility between the Schengen evaluation mechanism and Frontex vulnerability assessment methodology. Finland supports the further development of European quality control mechanisms. The Border Guard actively participates in the implementation of the Schengen evaluation mechanism. The Border Guard nominates at least one candidate in each external border evaluation mission. Finland also supports the further development of efficiency and effectiveness of the Schengen evaluation mechanism. Finland supports the developing vulnerability assessment to be an effective and transparent mechanism that would contribute to further development of the border management system in Finland and in the other EU Member States. The Border Guard is responsible, with the support of other authorities, for the implementation of vulnerability assessment at the national level. Vulnerability assessment is a crucial element in ensuring the performance of the border management system. The performance and capacity of the Finnish border management system is under constant monitoring. The use of border control resources is planned in compliance with commonly agreed EU standards. Possible changing threat scenarios are taken into account in advance in order to reveal vulnerabilities in the Finnish border management system. In addition to the Schengen evaluation mechanism and vulnerability assessment, a national quality control mechanism is used for implementation of border controls and return activities in accordance with the principles of the EU integrated border management concept. The National Integrated Border Management Forum (the IBM Forum) is the dedicated national quality-control body to ensure coherence in the IBM development. The Finnish Border Guard is chairing the IBM Forum. It has representatives from the Border Guard Department, police department, migration department and International Affairs Unit of Ministry of the Interior, Ministry for Foreign Affairs (Department for Europe / Consular Services, Visa and Passport Unit), Finnish Immigration Service, Finnish Security Intelligence Service, National Police Board, National Bureau of Investigations, Finnish Customs and Non- Discrimination Ombudsman. The IBM Forum is responsible for the development and updates of the strategy, and it is responsible for the national quality management and cross-sectoral IBM governance. The further monitoring and implementation of the strategy takes place in the existing inter-agency structures, such as the police, Customs and Border Guard Executive Board (heads of the agencies), Ministry of the Interior s department chiefs executive meetings, relevant cooperation meetings among the ministries and in the Security Committee. Schengen evaluations of Finland are prepared by national simulations of the Schengen evaluations. Quality control of border checks is carried out by the Border Guard in close cooperation with the police and Customs, in the national PCB working groups. National 16 FINLAND

17 quality control is based on annual planning. Findings and detected deficiencies together with recommendations are reported to the heads of PCB authorities in the national PCB-executive board. National quality control of border surveillance is implemented through an annually planned control mechanism of the Border Guard. Persons who have successfully participated in the Schengen evaluators basic course organised by Frontex are especially used for the national quality control. The number of trained people has been increased consistently in order to facilitate efficient implementation of the Schengen acquis through the national quality control mechanism. The national quality control mechanism is developed by including an evaluation of returns as part of the national quality control. 30. Conducting the vulnerability assessment pilot projects and supporting Frontex to establish an effective vulnerability assessment system. 31. Maintaining a high level of participation in Schengen evaluations and actively participating in the Schengen evaluation development process to fortify the Schengen evaluation mechanism. 32. Upgrading national quality control systems, including national Schengen evaluations. Ensuring effective enforcement of operational tasks, respecting fundamental and human rights, and deterring misconduct and corruption. 12. SOLIDARITY MECHANISMS The goal is to use solidarity mechanisms in the most useful, effective and cost-efficient way. The Internal Security Fund (ISF) is the most vital element benefitting the solidarity mechanisms. In the EU funding programmes of , the Finnish border management and related development projects have been allocated 16.4 M. The focus of development is on NCC activities and on enhancing the capabilities of technical border surveillance and situational awareness systems. Internal security funds are used systematically for acquiring patrol cars and boats, as well as surveillance and information systems for aerial assets and vessels. Regarding border checks, the fund is used for the continuous development of automated border control. Additionally, ISF-P funding is allocated to the PNR projects. Border crossing points at the Russian border are developed using the Finland-Russia European Neighbourhood Instrument, Cross-Border Cooperation (ENI CBC) programmes ( ). In the near future, the aim is to widen the scope by using different funding instruments for border management. Already partly exploited options are Frontex support for returns, the 2015 Coast guard: Finnish Patrol Boat in Greece operation. Cooperation fund for the Baltic Sea, Barents and Arctic regions (IBA), the Council of the Baltic Sea States (CBSS) project fund, and Interreg funding cooperation for the Baltic Sea region. In addition, Horizon 2020 funding and initiatives are actively used. The funding programs are reviewed annually by the Border Guard and ministerial-level stakeholders to ensure effective implementation. The priorities of the funding of the Internal Security Fund can be adjusted based on the findings of the Schengen evaluations, vulnerability assessment or other operational needs. Planning the utilisation of the funding mechanisms is coordinated by the International Affairs Unit of the Ministry of the Interior. 33. Actively utilising national ISF funds, among others, with the main emphasis on the development of the national databases. 34. Fully utilising specific funding to purchase equipment for the European Border and Coast Guard Agency s operations. The main emphasis is on patrol boats. 13. TRAINING AND RESEARCH & INNOVATION The goal of the training is to ensure adequately trained personnel for border management. The Border and Coast Guard Academy is responsible for border management training in Finland. The Border and Coast Guard Academy is subordinated to the Border Guard. The Border Guard management personnel (border guard officers) are trained in cooperation between the Border and Coast Guard Academy and the National Defence University. Border and coast guards are trained by the Border and Coast Guard Academy. Police and Customs National Integrated Border Management Strategy

18 officials carrying out border checks are trained in courses organised by the Border and Coast Guard Academy. Inter-service and on-the-job training are organised at the national, regional and local levels, including the train the trainers concept. The training and education system of the border guards ensures a skilled staff and high professional standards for border management and maritime rescue missions. It is compatible with European border management training and education (including the Copenhagen principles and the Bologna process). The system is built on basic, advanced and complimentary education of border guard officers and border guards. The curricula fulfil the requirements of the Common Core Curriculum (CCC) of the European Union. The CCC has been assessed and approved by the Frontex Interoperability Assessment Program. The system is based on life-long learning and the Sectorial Qualification Framework. The training is supported by the use of e-learning systems. The Border Guard provides additional training to its personnel and to the members of the other agencies that deal with border management tasks. Joint training for the agencies is facilitated within the framework of PCB cooperation. The PCB executive board agrees on a common training catalogue, and its annual implementation is decided separately. Common training for border checks, document expertise, crime investigations and language training are examples of PCB training cooperation. The PCB training working group coordinates PCB training cooperation. The Border Guard is responsible for all border check training. The Border and Coast Guard Academy is organising specialised PCB border check courses annually for police and customs officers who will be deployed to border checking tasks. Customs trains the other authorities in its fields of competence. The police are training their personnel for the return operations in the advanced training courses of the Police University College. Additionally, the police are actively utilising Frontex support to train escort leaders. The CEPOL-led EU Strategic Training Needs Assessment (EU-STNA ) is an exercise for identifying law enforcement capability challenges and prioritisation of training needs. It aims at more targeted training activities for implementing the EU policy cycle for and is prioritised nationally. The Police University College is the main national body to coordinate the cooperation with CEPOL, but the Border and Coast Guard Academy is also cooperating with it within the scope of border management related training. The main emphasis of the international training cooperation for border management is on the cooperation with Frontex. The Border and Coast Guard Academy is a Frontex partnership academy, and it nominates the National Training Coordinator (NTC). Additionally, bilateral training cooperation with Member States is conducted in the framework of the cooperation agreements. The Border and Coast Guard Academy develops and supervises a border control canine training system. There is close cooperation among law enforcement regarding canine training. The training and education is under constant development in order to reflect the requirements of evolving circumstances and operational needs. The tasks and duties necessitate competencebased training. E-learning will be increasingly utilised. Simulators are already used, and new simulators will be piloted. The results of the pilot projects will define the possibilities to intensify the use of simulators. The high standards of the maritime rescue training and the other maritimerelated training will be maintained. The training environment and training equipment will be developed to reflect evolving requirements. The aim of the research and innovation is to produce information and technology for border management that supports the operational activities, strategic planning and decision-making. The research regarding the foreseeable development of the operational environment is the most important area of interest. Appropriate national and international research cooperation is intensified in order to gain information, which is supporting the development of the strategies and operational activities. The main responsibility for implementing border management related research and innovation lies with the Border and Coast Guard Academy. Practical developing work and the acquisition of state of the art technology is conducted by the Border Guard HQ. Furthermore, there is a dedicated unit for projects in the Border Guard HQ, which is carrying out EU-funded development projects. High professional skills are maintained in the field of core competences, which ensures the business contingency and high standards. Support functions can be outsourced to the governmental of the private service provider, if security, safety and cost-effectiveness can be ensured. Coast guard training. 18 FINLAND