Risks Of Corruption In Montenegrin Sports December 2012 SUMMARY INTRODUCTION Fight against corruption in Montenegrin Harmful effects of corruption in sports are two- sports is underdeveloped and implemen- tation of the existing anti-corruption mea- is the danger of irrational and illegal waste of publicfold. Apart resources, from the emergence financial ofaspect, corruption and that in susceptibility to corruption, especially in sports, given its popularity and public interest sures is inefficient. This results in a greater, con- for its promotion, can have a negative impact struction of sports facilities and potential the sports organizations co-financing on the whole society. match-fixing. from the local budgets is especially un- onlyAt international recently started level, having the issues a more of comprehen integrity in- The sports organizations co-financing sports and fight against corruption in the field, local governments should provide public withtransparent an insight and into worrying. a precise Therefore, amount allof sive treatment. In the European Union1 (EU), the- first step in that direction was the adoption of- sport organizations, and into the criteria rarythe White sports Paper in the on member Sport in states, 2007. among This docuthem money, allocated for the co-financing of ment recognized key threats to the contempo Construction and re-construction of sports upon which that money was allocated. being corruption and money laundering. The facilities is another area susceptible to aimedEU, based at increasing on previously integrity conducted in sports analyses, - the ef- the misuse of public interest, given the undertook the whole range of other activities strategic orientation of the Government to increasingly employ the concept of Public- activityforts of Europeanin a row Council to adopt conclusions Private Partnership (PPP) in important on match-fixing in2 late 2012 being the last such . implementation of this concept in sports, theinfrastructure special Law projects. on PPPs, For thewhich successful would In , however, activities on prevention introduce the obligation of publishing the and fight against corruption in sports are at early- details and the way the PPP contracts were stage. The Government’s strategic documents area,insufficiently despite the recognize certain allegationsthe need for and prevent indica- ing and minimizing the corruption risks in the - realized, needs to be brought. sport clubs and about sports betting-related veloped countries but Montenegro still does tions about irregularities in the work of certain notMatch-fixing have the is system taking pacewhich even would in more detect de the dubious payments to the sport betting aimfrauds. of the Given paper the is internationally thus to pinpoint recognized the means and potential “national” risks in the field, the shops and possibly reveal the influence on of advancing the fight against corruption in authoritiesmatch result. and With their the coordination aim of preventing need Montenegrin sports. White tomatch-fixing, be strengthened, capacities primarily of the through competent the Paper On Sport establishment of the system of the on-line 1 Commission of the European Communities, , July 2007 supervision of payments and pay-outs to 2 See: EU Council busy with sport issues: health, statistics, doping, match-fixing, possible European Week of Sport, na: http://ec.europa.eu/sport/news/20121204-eu- the sport betting shops. council-sport-issues_en.htmAuthor: Milena Milošević, M.A.

This research has been conducted in the framework of the project "Corruption and Organized Crime in Sport", supported by the Commission for Allocation of the Part of the Revenues from Games of Chance. (Un)recognized Risks ing is closely related to the sport betting, and it often appears in the form of bribery of referees - and players with the aim of reaching a certain Contrary to the develop countries of the West theern biggestEurope, footballbudgets club, of sports Buducnost, organizations amounts in result. Some estimation says that the money Montenegro are modest.3 The annual budget of turnover at the global grey market of games7 of accounts of the 19 sport organizations (clubs chances reaches even 1,000 billion euro . andfor 800,000 associations), euro . includingAs of November the most 30, famous 2012, 8, and this phenomenonNot even the oftencountries represents with low an opportunity corruption forindex money are immunelaundering to9 match-fixing duefootball to their clubs, debts Buducnost and inability and toSutjeska, settle certain were obligationsblocked by the Central Bank of Montenegro the services of on-line. Additionalsports betting, challenge whose in 4 tracking the dubious money flows is posed by . allegations already point to doubts about frauds the Montenegrin sports does not minimize the committedlargest illegal by market , is situated which in Asia. included Certain Nonetheless, the small amount of money within risks of corruption and other criminal acts in vulnerability of sports organizations can direct betting on fictive matches of10 Montenegrin clubs themthe field. towards On the dubiouscontrary, waysprecisely and the sources financial of in the Asian betting shops . 5 Montenegrin Sports: Marginal Target of Anti- corruption Policies financing . among the sources of sports organizations Despite the numerous corruption risks in sports, In many countries, state and local budgets are neither are measures for combating these phe- payers is being spent on the activity of sport nomena in Montenegro sufficiently developed clubsfinancing. and Theassociations mere fact increasesthat the money possibility of tax nor is the need for new measures sufficiently for arbitrary allocation of the money and for recognized. favoring certain sport organizations and activi- ties, which do not necessarily lead to the sports Strategy for the fight against corruption and - organized crime for the period 2010 – 2014 and development. pering the integrity in sports also include cor- Innovated action plan for its implementation for ruptionOther, internationally during construction recognized and re-construction risks of ham clubs,the period sports 2010 associations – 2012 envisage and Montenegrin obligation of publishing financial and audit reports of sports of sport facilities and during the public pro- Fraud In Sport – Putting The Pieces Together, Kako regulisati igre na sreću i klađenje u Evropi? the money trail and the way the international Dosadašnja dostignuća I buduće perspektive – 2012Rezime transferscurement of procedures, players are contracteddifficulties andin following realized, 7 debata 6 - , Brisel, Evropski parlament, 27. jun 2012. godine, str. 30 as well as the match-fixing . Danger of match fix- 8 Robert Hoyzer, referee of the German national football 3 Information obtained during the interview of Institute league, was convicted in 2005 after his involvement in Alternative researcher with Momir Djurdjevac, Secre Corruptionthe match-fixing and Sport: fraud Building - all that, Integrity related and to the Preventing work of tary General of Football Association of Montenegro Abusessport betting shops (See: Transparency International, 4 Spisakavailable blokiranih at pravnih lica i preduzetnika koji se Match Foxing And Fraud In Sport – Put- ne nalaze u evidenciji CRPS-a na dan 30.11.2012 god.,- ting The, 2009) Pieces Together, 2012; European Commission, http://www.cb-mn.org/slike_i_fajlovi/ 9 CommunicationSee: Bozkrut, E, From The Commission to the European fajlovi/fajlovi_platni_promet/preduzeca_u_blokaMoney Laundering Through The Football Parliament, the Council, the Economic and Social Com- Sectordi/2012-11-30_blokirani_-_ne_postoje_u_crps.pdf mittee and the Committee of the Regions: Towards a 5 FATF Report, Money Laundering Through The more comprehensive European framework for online Football, 2009, Sector p. 15 - gambling 6 tional,See: FATF Corruption Report, and Sport: Building Integrity and Međunarodna prevara sa crnogorskim pečatom, Vijesti, Preventing Abuses,, 2009, 2009, p. Bozkrut, 24, Transparency E, Match Foxing Interna And , 2012 10 oktobar 2012. godine

2 - formation about sports pension holders11 Olympic Committee, as well as publishing in theGiven remainder the previously of the paperlisted corruptionwill focus on risks those in . sports and idiosincracy of Montenegro’s context, - sivelyIn practice, treat corruptionnot even this in sports, measure, is adequately being the risks which point to the most striking form of only one in the Innovated action plan to exclu- ofthe public corruption funds to- the sport misuse organisations of public andfunds. on implemented. In other words, the 2011 finan theTherefore, construction the paper and re-constructionwill focus on allocation of sport thecial reportsreports onabout people the whowork acquired of sport theclubs rights and onMontenegrin sports pensions, Olympic were Committee, made but asthey well were as prominence at the global level, and due to the facilities. Still, since the match-fixing is gaining not published information about dubious sport betting in 12 Montenegro, the attention will be devoted to . In 2011, Government adopted the National- this issue as well. tionProgram plan for itsSports implementation Development in (hereafter:the period Co-financing Sports Organizations: National Program) and the accompanying ac No Obligations recognised certain threats to the integrity of System of sports financing in Montenegro is between 2012 and 2016. National Program- not transparent enough, and it suffers from the ency in allocation of public funds to the sports weak coordination between the different au- Montenegrin sports, such as the lack of transpar thorities and institutions during the allocation of public funds to the sport organizations. fromorganizations. local budgets It especially were missing highlighted13 that the - Program,clearly defined however, criteria also for neglected allocation some of money of the . The National The co-financing of sport organizations is justi fiedBetween by the 0,2 andfact 0,3 that per centthe ofsport Montenegrin in Montenegro state budget is key challenges. organized crime, war crimes and terrorism in is allocated for sport. The biggest amount of money (70 Since 2008, Special departments for corruption, per cent) is allocated for the programmes of national have not brought a single verdict about the sport associations and Montenegrin Olympic Committee. criminalPodgorica acts and of corruptionBijelo Polje and Superiour organised Courts, crime

Preventionin sports. Such of Money cases have Laundering, not been on prosecuted the other includesdefined asactivities the activity such asof sportspublic development,interest. The hand,in front stated of these that courts within either. the Administrationsame time period for creatinglegal definition conditions of “the for public construction interest and in sports” main- it dealt with several dubious cases of sports tenance of sport facilities, stimulating the activi- betting activity 14 11 about top athletes etc15 . - allocationties of national of state sports money, organizations, sport organizations taking care The word “sport” is virtually absent from the local do not receive the detailed. Nonetheless, reasoning during about the governments’ programmes for the fight against cor amount of money which was approved for their ruption in Montenegro. - 12 As one of the excuses why the documents were not published, it was stated that the Internet presenta tion of Administration for Youth and Sports was to the Superior Courts in and , under construction (Source:Treći izvještaj Nacionalna o realizaciji komisija mjera za uponand to the the request Administration for free access for Prevention to information, of Money in- izsprovođenje Inoviranog Strategije akcionog planaza borbu za sprovođenjeprotiv organizovanog strategije formedLaundering. us that The it Supremedid not have Court information of Montenegro, about also the zakriminala brobru protivi korupcije, korupcije i organizovanog kriminala, about the criminal acts of corruption and organized 13 Vlada Crne Gore, Nacionalni program za razvoj sporta, crime,number which of final could verdicts, be characterized brought after asJanuary connected 1, 2008, to april 2012. godine)

2011. 15 the organization and financingSl list of sport activities and 14 Information obtained upon the request for free access to the work of sport betting shops. to information, submitted by the Institute Alternative Član 11, Zakon o sportu, („ . CG“ br.36/11)

3 programs16 - scribed legal criteria of public interest in sports of software which would enable following the are not precise. On the enough other tohand, prevent previously arbitrary de National Program envisages implementation-

sports organizations’ financial flows and intro- decisions about the money allocation. duction of unified forms for financing the sports During the 2012, the state, according to the organizations’ programs. In order to define crite ria for allocation of tax payers’ money to the sport Decision on co-financing sport associations and organizations more closely, National Program Decision on the co-financing sport organizations,17 allocated money to 431 sport organizations criteriaenvisaged for adoption allocation of theof funds new Regulation, and control which over should streamline conditions, benchmarks and entities50 sport for associations, that year18 based on the previously submitted plans and work programs of these . It is worrying, however, the sports development programs’ realization. that some clubs, whose accounts were blocked The framework of criteria and conditions to be- included in the Regulation was also scratched. ofby coordinationthe Central Bank between of Montenegro, the different also statereceived au- tion of the way and procedures of control and money. This case points to the virtual absence analysisThe recognized of realization need for of approveda more precise programs defini is thorities and institutions, such as Central Bank implemented, this measure would create basis and Administration for Youth and Sports, what foranother the assessment advantage of of implementation the National Program. of “public If 19 makes eventual abuses more likely. interest in sports“ - - Insufficient capacities of the Administration for ing on sports . Yet, the Regulation will not andYouth allocation and Sports of fundsrepresent to the an sports additional organiza chal- affect the control20 of local governments’ spend lenge in establishing the more efficient control . - tions. The weak capacities of this authority As already noted, the sports clubs’ financing from to efficiently control implementation of legal the local budgets is un-transparent. While the na tional expenditure for sports in 2012 amounted theprovisions chief sports the sports inspector, organizations conducts cofinancing inspection are reflected by the fact that only one person, for 2,8 million euro, the exact ammount of money21 allocated at the local level remains unknown . and comprehensive inspection of all sports or- show the ammount of money allocated for the The final accounts of all municipalities do not ganizationscontrol. This in hampers central, the northern possibility and of southern detailed work of sport clubs or construction of sport regions16 of the country. - Kotorfacilities municipality in an equally precisely transparent lists manner.transfers For to - sprotexample, clubs, the which2011 Decision for that onyear final ammounted account of Information obtained during the interview of re Montenegrosearcher of Institute Alternative with Momir Djurd jevac, Secretary General of Football Association of expenditure for construction of the sport hall country, so far, can only be anticipated, because the for 222,160 euro, and half million euro capital22- 17 The exact number of sport organizations in the- tal Podgorica does not contain precise data on. On the other hand, the final account of the capi establishemtnof Central Register of Sport Organisa tions, envisage by the Law on Sport, is still ongoing. 19 Yet, it is known that during 2011 there were 1,236 the money allocated for sports. By contrast, it 18 sport clubs (Crnogorski zavod za statistiku, MONSTAT,- So far, sport organizations which receive more than Statistički godišnjak za 2011. godinu) - 3,000 euro were obliged to submit financial reports Decisions are available at the website of the Adminis to the Administration for Youth and Sport about the- eurotration was for allocatedYouth and to Sport the (sporthttp://www.upravazam organizations and way the money was spent to the Administration for ladeisport.me/me). According to them, 2.467.500,00 Youth and Sports. Reports, however, were not pub- and organizations also receive funds from the Commis- lished. associations from the state budget. Sport associations 20 chiefInformation sport inspector obtained during the interview of research er of Institute Alternative with Branimir Ivanovic, the sion for the allocation of revenue from gambling. The 2012 Decision of allocation of revenue from gambling, 21 Ibid. allocated 341,600 euro to the various organizations 22 Odluka o završnom računu opštine za 2011. which applied with sport development programmes. godinu (Broj:11-602), str.3

4 lists transfers to both institutions of sports and

23 of Podgorica’s city stadium, partnership was culture as one, unified item . established in 2003 between Hidromol company and Public enterprise “Gradski stadion”. At the document,The special to Regulation a certain extent, streamlines leaves thediscretion way24 of end of the project, private investor had 66,4 per toclassifying local authorities the municipalities’ to decide expenditure the way of listing. This cent of office space at disposal, while Gradski stadion had 34,5 per cent. the sports institutions and to the institutions of of the PPPs implies synchronization of legal, culturecertain costs.into special Yet, the items separation would of contribute transfers to Nevertheless, the successful implementation the greater transparency of the sports organiza- reasons,regulatory PPPs and arepolitical an area frameworks, highly susceptible which is not to the case in Montenegro. Precisely due to these Constructiontions co-financing atand the localReconstruction level. corruption. of Sport Facilities: Blurred Inter- The transparency of the PPPs at the local level twining of Public and Private has been slightly improved. The amendments to- Corruption risks, which might emerge during the mentsthe Law in on terms Local of Self-Administration,enabling the public to adopted have an construction and reconstruction of sports facilities insightin July 2012,into the brought contracts, about concluded certain improvebetween are closely related to the general corruption risks the local governments and legal and physical in PPPs, since this concept is being increasingly entities employed precisely in this field25. publish 26decisions about granting business and - services, as. Municipalities well as other decisions, are now acts obliged and any to contracts concluded in the disposal of property The deficit of financial means in the Montene- gro’s capital budget urged wider implementation consistent implementation of these provisions of the PPPs. The advantages of this concept, re isprocedures missing at their Internet pages. However, the flected in the higher quality of services, increased 27 ability of meeting the society’s general needs and Games Of. (No) Chances employin the rational it more distribution intensively of in financial the upcoming means, According to the available information, there boosted Government’s strategic orientation to are no prosecuted cases of match-fixing in Mon- tenegro. This, however, does not mean that the period. implemented was precisely the reconstruction problem is absent. On the contrary, its difficult One of the first projects in which the PPP was traceability, absence of coordination between the competent authorities and institutions, and of the sport facility. During the reconstruction every day allegations about tipping the match 23 Završni račun budžeta glavnog grada - Podgorice za results, urge the need for adapting institutional 2011. godinu and legal frameworks and their consistent imple- 24 Pravilnik o jedinstvenoj klasifikaciji računa za budžet mentation in order to prevent match-fixing. This republike, budžete vanbudžetskih fondova i budžete problem can be analyzed from two aspects: form betweenopština („Sl. public list RCG“,and private br. 35/05, sectors 37/05, with 81/05) the aim of 25 The Public-Private Partnership implies co-operation Zakon o izmjeni i dopuni zakona o lokalnoj samoupravi infrastructure objects and sector of services, meaning ensuring financing, construction, reconstruction of- 26 presentations(“Sl.list br. 38/2012”) of various municipalities drastically financing projects and services which are tradition 27 Number of the published contracts at the Internet isally being provided implemented by the public during sector. the construction Apart from andthe its website even the contacts about the volunteering reconstruction ofof Podgorica’s other sport city facilities stadium, as thiswell, model such jobs,varies. and For the example, overall Kolasin number municipality of published published contracts at - - as: construction of sport hall in Zabljak, reconstruc at its website since July 2012 exceeds the number of tion of sport hall in Mojovac etc. Revision of the 2012 contracts, published at the website of Niksic munici budget, envisaged 4,883,000 euro of capital expenses pality and Podgorica capital. Also, the visibility and for construction and reconstruction of sport facilities. accessibility of published contracts vary.

5 the aspect of the oversight over the work of sport the representatives of judiciary and repressive betting shops, and from the aspect of ensuring institutions about mechanisms to be employed the integrity of referees and players, since they are the most often targets of bribery during the match-fixing. in the fight against match-fixing. In October 2012, the EU adopted a Communication, which represents a significant boost to the creation of business in Montenegro - preventioncomprehensive of fraud European and money framework laundering for on-31 Approximately, 400 sport28 betting shops run- line betting. One of its priorities was precisely ments and payouts of the organizers. However, ofit issport ex tremely difficult to trace money flows, pay . moneyThis document laundering recommends to the on-line extension betting ofshops the implementation of32 the EU’s Directive against payoutsgambling. within The Law the on special Games systemof Chances of on-lineobliged and recognizes the need for additional education supervisionthese organizers which to should keep all have the been payments connected and of holders of judiciary posts about the potential to the informatics system of the competent criminal activities with respect to the business authority, all that with the aim of ensuring the permanent and direct oversight - tweenof these betting shops. shops, It places sports special organizations emphasis and on interim and concluding provisions29 envisaged . Although the associations,the need for andmore authorities efficient co-operationregulating games be since the establishment of the on-line system for this obligation to be applied within 60 days of chances.33 by the Administration for Games of Chances, All EU member states incriminated match- the system has not been established yet. This fixing . In Montenegro, there is also an ongoing represents a significant obstacle in revealing theinitiative Criminal of Football Code, whose Association eventual of amendments Montenegro the dubious payments. for match-fixing to be declared a criminal act by Games of Chances cannot be adequate associate are being publically debated at the moment 34 toFor other a concrete authorities example, in revealing Administration the dubious for on online gambling itself, incriminating the sport. However, as noted in the EU’s Communication for Prevention of Money Laundering received frauds did not per se decreased the number of aactivities. tip about To dubious be more transaction precise, Administration in one case, operationaldubious cases. nature, What meaningmore, the that main it deficiency is consisted in the criminal prosecution of match fixing is of an Gamesbut, after of Chances,checking, determined which included that thereasking was an - noopinion criminal and actscontrol of corruption by the Administration and organized for in the insufficient and inadequate implementa crime in the case tion of laws. Hence, although declaring match 30 a good, indirect effect, primarily through rais- . Still, due to the described ingfixing awareness a criminal about act in the Montenegro harmful consequences would have ofdeficiencies Chances cannot of the provide current an supervision adequate opinion system of sports betting, the Administration for Games of31 these frauds, efficientCommunication implementation From The Comand- More developed countries also have a prob- mission to the European Parliament, the Council, the when asked to do so. EconomicEuropean Commission,and Social Committee and the Committee of the Regions: Towards a more comprehensive European framework for online gambling, lem of insufficient co-operation of competent Directive 2005/60/EC on the prevention of the use of the authorities and insufficient knowledge among financial system for the purpose 2012of money laundering 32 and terrorist financing 28 Information obtained during an interview of Institute Alternative researcher with Marko Culafic, acting 33 ,Match Official Fixing Journal In Sport: of European A Map- director of Administration for Games of Chances pingUnion, of 2005.Criminal Law Provisions In EU 27, 29 Član 55, Zakon o igrama na sreću („Sl. list RCG“ br. KEA European Affairs, 52/04 od 02.08.2004. i „Sl. list Crne Gore“, br. 13/07 March 2012- od 18.12.2007, 73/10 od 10.12.2010, 40/11 od 34 Information obtained during the interview of Institute 08.08.2011) Alternative researcher with Momir Djurdjevac, Secre 30 Answer to the freedom of information request tary General of Football Association of Montenegro

6 coordination of the competent authorities are of key significance. toOn prove, the other there hand, is a whilepossibility the bribery for decreasing and the certain level of players’ performance are hard- the risk of referees being bribed by the con havetrol of wide their autonomy work and whenby streamlining it comes to their the overalldelegation. organization, Sports associations control and in appointment Montenegro of referees. Football Association of Montenegro (FSCG) brought the Rulebook about the referees and supervision, which assigned the Referees’ provisionsCommission about duty the of way delegating the delegation referees. is done The35 Rulebook, however, does not contain detailed time period before the start of the match would. decreaseRandom delegationthe possibility of referees of bribing within the referees a short with the aim of match-fixing.

35 , Pravilnik o sudijama i suđenju Fudbalskog saveza Crne Gore Fudbalski savez Crne Gore , 2008.

7 Conclusion and Recommendations  - Key recommendations: tenegrin sports, despite some activities of The awareness about corruption risks in Mon strategicAnti-corruption documents, measures, should be which advanced are Program represents a solid basis for a more already envisaged by the Government’s competent state authorities, is low. National  Capacities of competent state authorities, the state budget should be spent on sport or- and consistently applied. precise definition of the way the money from - tionat first for place Games of theof Chances, Administration should forbe wouldganisations’ enable financing. the enforcement Yet, the of year new after rules thishas Youth and Sport and of the Administra document was adopted, the Regulation which improve the system and transparency of sport strengthened. Their cooperation with- not been brought yet. Activities, which might tionother for institutions Prevention of in Money the fight Laundering, against Construction and reconstruction of sport facili- corruption, namely with the Administra- organizations’ financing, are thus missing. of this concept in Montenegro, and those are Police Directorate, Central Bank of Mon tenegro and Supreme State Prosecutor, ties through the PPPs share general deficiencies  needs improvement. whereprimarily the theneed lack for ofadditional transparency anti-corruption and of an beAwareness raised, by about training the holders necessity of judiciary of the measuresadequate legalis recognized, framework. their Even implementation in the cases fight against corruption in sports should-

Capacities of the competent state authorities, posts about the specificites of the cor is absent. ruption in this field. thesuch successful as the Administration implementation for of Youth anti-corruption and Sport Recommendations with regard to the sports and the Administration for Games of Chances, for  organizations’ financing: funds was the main reason why the on-line should consistently enforce the measure, systemmeasures of supervisionare weak. For of on-lineexample, betting the lack shops of The Administration for Youth and Sports has not been established yet36 reports of sports clubs and Montenegrin which prescribes publishing of financial the absence of the mutual coordination. On the of other com- reports on the people who receive com- hand, capacity-building is not self-sufficient in Olympic Committee, as well as of the single case of corruption and organized crime in  petent authorities. Information that whether a pensation for their sports achievements. not demonstrate the absence of these criminal obligeSpecial local Regulation authorities about to theimplement unified sports has been prosecuted is not known does classification of local budget costs should their expenditures, in a way which would acts. On the contrary, given the deficiencies of enableunified a criteria public insight for demonstration into the precise of the institutional and legal frameworks, difficult the forms of corruption in sports, similar to the ammount of money allocated to sports traceability, and general lack of knowledge about on-line gambling, it is necessary to raise aware-  - nessrecommendations and educate people of the EU’s in police Communication and judiciary on organizations. cise criteria for allocation of money to the sportsLocal administartions and control of its should expenditure define pre by about the way and importance of fight against these phenomena.  36 adoption of special, internal acts. The Administration for Youth and Sports Information obtained during the interview of Institute way and procedures of bringing the Alternative researcher with Marko Culafic, acting should bring the Regulation about the director of Administration of Games of Chances

8 annual sports development programs,  By amending the Criminal Code, match-

allocation of money and for the control  conditions, benchmarks and criteria for fixing should be incriminated. system of random delegation of referees  andSports non-disclosure associations agreement should introduce about the over the programs’ realization. Capacity-building of the Administration sportsfor Youth entities, and Sports their shouldmanagement ensure and the referees’ identities, in order to prevent governanceinspection controlbodies, asover well the as workover the of their bribery which might influence the implementation of other norms and match result. standards in line with the Law, to be conducted by more inspectors instead

of the one – chief sports inspector, as it is the case now. -

Recommendations with regard to the construc  tion and reconstruction of sports facilities: oublishingThe special the Law details on PPPs, and which the way would the PPPsclearly contracts define areobligations being realised, of publish- needs

 - to be brought. tain all past and future PPPs contracts andThe Centralbe accessible register, for which all the should interested con

parties, should be established.

Recommendations with regard to the match-  - fixing prevention: es, the sport betting-related payments andIn line payouts with the should Law on Gamesbe stored of Chanc in a special system of on-line supervision, which needs to be connected with the informatic system of the competent authoritiy, in order for the continuous and direct overisght over the sports

 beeting to be established. is established, the information-sharing After this system of on-line supervision of Chances and other authorities and institutions,between the primarilyAdministartion with the for Central Games

for Prevention of Money Laundering Bank of Montenegro and Administartion

should be strengthened.

9 About Institute Alternative

Institute Alternative is a non-governmental organisation, established in September 2007 by a group of citizens, experienced in civil society, public administration and business sectors. The mission of Institute Alternative is to strengthen the democratic processes in Montenegro by identifying and analysing public policy options. policy, contribute to the development of democracy and the rule of law, and to contribute to the The strategic aims of Institute Alternative are to: increase the quality of development of public protection of human rights in Montenegro. The values we adhere to in our work are dedication to our mission, independence, constant learning, networking, cooperation and teamwork. Institute Alternative acts as a think tank, i.e. a research centre, and its activities focus on the parliamentarydomains of good oversight governance, of security transparency and defence and accountability. sectors, oversight Topics role covered of the Parliament by the Institute’s and its research activities, in which it exercises influence by providing its own recommendations are: role in the process of European integration, public administration reform, public procurement, public-private partnerships, state audit and control of the budget of local authorities.

To date, Institute Alternative published the following reports / studies: • Parliament and civil society organisations - partners in budget control • Development of PIFC in Montenegro - From the civil society perspective • Committee for Anticorruption - cure or placebo? • Corruption and Public Procurement in Montenegro • Montenegro and negotiations in Chapter 24 - Justice, Freedom and Security • Montenegro and negotiations in Chapter 23 - Judiciary and Fundamental Rights • Secret Surveillance Measures in Criminal Procedure - Neglected control • National Security Agency and Secret Surveillance Measures - Is there any control? • Parliamentary inquiries in Montenegro - Control mechanism without political support • The in the process of European integration - observer or active - participant? mentation • Law on Parliamentary Oversight in the Security and Defence Sectors - First Year of Imple

• Montenegro under the watchful eye of Đukanović and the EU • Analysis of RIA effects in Montenegro - toward ‘good legislature’ • Control of the local self-government’s budget • State Audit in Montenegro - proposals for strengthening its influence • Think Tank - the role of independent research centres in public policy development • Public Administration Reform - between high ambitions and limited possibilities • Public-Private Partnerships in Montenegro - Accountability, Transparency and Efficiency 10 • Public Procurement in Montenegro - Transparency and Accountability • Assessment of the Legal Framework and Practice in the implementation of certain control mechanisms of the Parliament of Montenegro: Consultative Hearing, Control Hearing and Parliamentary Inquiry • Parliamentary oversight of the defence and security sector: What next? • The Lipci Case 2008: How not to repeat it • The Case of the Prva Bank - Lessons for the supervisor and other decision-makers for professional advancement • Public Administration in Montenegro: salary schemes, reward system and opportunities

Institute Alternative is a member of the NGO self-regulatory body and has disclosed full details of its financial affairs in line with Activity Code for NGOs, to which Institute Alternative is a party. In its hitherto activities, Institute Alternative was supported by: the European Fund for the Balkans, Foundation Open Society Institute - Representation in Montenegro (FOSI ROM), Open Society Institute - Think Tank Fund, Foundation Friedrich Ebert, the Parliamentary Commission for the distribution of resources for NGO projects, European Commission. The Institute cooperates with the European Stability Initiative from Berlin, which carried out a- capacity building programme for IA associates. Institute cooperates with a number of national organisations, numerous institutions and state bodies such as: the State Audit Institution, Pub lic Procurement Agency, the Parliament of Montenegro (especially its Committee for economy, budget and finance as well as the Committee for security and defence), the Ministry of Finance, Concessions Commission, etc.

All publications / research reports are available online:

www.institut-alternativa.org

11 Find out more about the work we do at: www.institut-alternativa.org