reference from Bulgaria, Atanas Ognyanov,182 regarding a Bulgarian national sentenced by a Danish court to 15 years imprisonment for aggravated robbery and murder. Mr Ognyanov was detained in a Danish prison from January 2012 to October 2013 whereupon he was transferred to the Bulgarian authorities. The issue was whether Mr Ognyanov could benefit from a more generous remission system available in Bulgaria than in Denmark. The Opinion of AG Bot considered firstly the principle of mutual recognition “in accordance with which court decisions are executed directly throughout the Union without the need for any endorsement procedures.”183 Thereafter the Opinion considers the objective of the FD “so as to facilitate the social rehabilitation of the sentenced person […] by giving them a chance to maintain family, linguistic and cultural links.’184 The Opinion sets out the process that must take place including that the issuing state should satisfy itself of the fact that objective of the Framework Decision will be met, and notes that in line with the freedom of movement the transfer of sentenced persons to a Member State of origin or residence, “is meant to improve the prospects of their social rehabilitation by giving them a chance to maintain family, linguistic and cultural links.”185 Information and representation as tools for the prevention of ill-treatment Ensuring good quality information is given to the prisoner in terms of prison conditions, adaption of the sentence, possibility of consent and so forth, as well as the provision of legal advice can serve as a safeguard for the prevention of ill-treatment. True also is that absence of such information, or access to representation can conversely expose an individual to a higher risk of ill-treatment. Research conducted by the FRA in the context of the provision of information regarding the availability of transfer noted that for the majority of the EU Member States, the only information provided is the legislation implementing the Framework Decision.186 To address this, in Sweden, for example, a public counsel is assigned to an individual contesting a transfer, but also in cases where the individual is a juvenile or is mentally impaired.187 The FRA Study on criminal detention and alternatives in the EU notes that the FD does not provide for any special procedures provision of information to concerned individuals which leaves it to Member States to adopt measures accordingly. In this regard their report notes that more than half of the EU Member States have adopted measures, and in each Member State it varies as to the source of the information, whether the information derives from prison authorities, through leaflets, judicial authorities or law enforcement.188 Overcrowding Another aspect that would require further consideration is whether transfer of prisoners would in some cases actually exacerbate overcrowding and lead to the further decline of prison conditions, and the greater risks of a violation of Article 3 ECHR. The Europris expert group on FD TOP commented that prison conditions were a concern and specifically referred to those cases where the ECtHR 182 C-554/14 Atanas Ognyanov. 183 Ibidem at paragraph 13. 184 Ibidem at paragraph 15. 185 Ibidem at paragraph 15. 186 Criminal detention and alternatives in the EU: fundamental rights aspects in pre and post trial cross-border transfer procedures. 10 November 2016 at paragraph 6.1. 187 Email Survey conducted with a representative of the Kriminalvårdens Huvudkontor, Rättsenheten, Sektionenför internationella och andra särskilda klientärenden, Sweden. 26 January 2017. 188 Criminal detention and alternatives in the EU: fundamental rights aspects in pre and post trial cross-border transfer procedures. 10 November 2016. 46