Landmark Agreement Between United States and Egypt Continues to Protect Priceless Antiquities

Tess Davis
Image courtesy of Egypt Today

Increased cooperation between the United States and the Arab Republic of Egypt is leading to major successes in the fight against cultural racketeering, the illicit trade in ancient art and artifacts.

That was the message from the Antiquities Coalition’s Executive Director, Tess Davis, as she spoke on September 23 to a full house of senior Egyptian diplomats, representatives from the business community, and other friends of the country.

Her remarks were part of “U.S.–Egypt Relations: Challenges and Opportunities,” a panel discussion hosted by American Pulse at the New York City Bar Association, on the margins of the United Nations General Assembly Meetings. Other speakers included Ambassador Hisham Al-Naqib, Egyptian Consul General, Sherif Kamel, President of the American Chamber of Commerce in Egypt, and Tony Shaffer, a former senior intelligence officer in the U.S. Department of Defense.

Key Takeaways

  • U.S.-Egyptian partnership is critical to the fight against cultural racketeering: Egypt is home to one of the world’s longest continuous civilizations, and the custodian of a rich cultural heritage, while the United States is home to 43% of the global art market. Therefore, by working together, they have a unique opportunity to make a major difference in the global fight against the illicit trade.
  • The 2016 U.S.–Egypt MOU is facilitating such joint action: In November 2016, then Secretary of State John Kerry and Foreign Minister Sameh Shoukry signed the first cultural property bilateral agreement between the United States and an Arab nation. This Memorandum of Understanding (MOU) provided a legal basis for the United States to close its borders to Egypt’s illicit antiquities, which had been flooding the black market since the January 2011 Revolution. In addition, it encouraged cooperation and exchange—including U.S. support for Egyptian museums, exhibitions, capacity building, and safeguarding Egypt’s cultural heritage—as well as increased loans from Egypt to U.S. museums.
  • This increased cooperation is leading to concrete results: On September 25, the Manhattan District Attorney’s Office, U.S. Homeland Security Investigations, and the Metropolitan Museum of Art in New York would repatriate an ancient gold coffin to Egypt’s Foreign Minister Sameh Shoukry. Criminals had looted the masterpiece during the chaos of the 2011 Egyptian Revolution, and then with forged papers, laundered it onto the heights of the New York art market. Its return was just one example of the type of cultural diplomacy made possible by the landmark 2016 MOU.
  • It is also inspiring Egypt’s neighbors: While Egypt’s MOU was the first between the United States and an Arab nation, it has not been the last. This historical agreement has also inspired several of Egypt’s neighboring countries to follow suit. Libya and Algeria have signed similar agreements and others with key Middle and North Eastern countries are in the process. These agreements will help pave the way for future partnerships, making it easier to protect irreplaceable pieces of history and culture. 

For the latest updates on this historic agreement, follow the Antiquities Coalition on Twitter.

The AC Digs Into: The Destruction of Iraqi Cultural Heritage

Interview with AC Think Tank Author Seán Fobbe, Part II



In the second of a three-part series, we sat down with Seán Fobbe, Chief Legal Officer of RASHID International and author of the AC’s How to protect outstanding cultural heritage from the ravages of war? Utilize the System of Enhanced Protection under the 1999 Second Protocol to the 1954 Hague Convention. Fobbe discusses the unique challenge of cultural heritage preservation in Iraq; the difficulty of prosecuting war crimes, crimes against humanity, and genocide; and broader patterns in cultural crimes worldwide. Read Part I of the interview here.

At United Nations General Assembly Meetings, United States Launches Global Call to Protect Religious Freedom, Sites, and Relics

UN Photo/Manuel Elias
UN Photo/Manuel Elias

As world leaders again converged in New York for the annual meeting of the United Nations General Assembly (UNGA), the United States highlighted threats to the world’s religions and launched an international campaign to fight back, pledging $25 million to safeguard religious freedom, sites, and relics.

The “Global Call to Protect Religious Freedom” took place Monday, September 23rd at the United Nations headquarters in New York. President Donald J. Trump, Vice President Mike Pence, and Secretary of State Mike Pompeo — joined by UN Secretary-General António Guterres and others — spoke to a packed conference room that included U.S. cabinet leaders, as well as heads of state, foreign ministers, and other diplomats from around the world.  The high-level attendance from the U.N and U.S. government demonstrates the priority that both are placing on this issue. AC Chair and Founder Deborah Lehr and Executive Director Tess Davis were among those in attendance, in recognition of the important role that cultural preservation plays in the broader mission of ensuring religious freedom.

The AC Digs Into: Cultural Heritage and Human Rights

Interview with AC Think Tank Author Seán Fobbe, Part I



In the first of a three-part series, we sat down with Seán Fobbe, Chief Legal Officer of RASHID International and author of the AC’s How to protect outstanding cultural heritage from the ravages of war? Utilize the System of Enhanced Protection under the 1999 Second Protocol to the 1954 Hague Convention. Fobbe comments on the groundbreaking work of RASHID International, a landmark report documenting cultural heritage destruction during the Yazidi genocide, and the intersection of human rights and cultural heritage preservation.

Getting Dirty with Michael Loughnane

Michael Loughnane brings with him a wealth of experience in financial crime investigations. He is a former Director of Special Operations at the EPA Office of the Inspector General, whereas a special agent and senior manager he led complex procurement crime investigations, including fraud, public integrity, cybercrime, and information security investigations. He later joined Booz Allen Hamilton as a cybersecurity expert, and in 2010, became team lead in the development and delivery of CTF training programs for the DOD. Since 2016, he has delivered financial crime investigation training to law enforcement, military, intelligence, and the international AML/CTF community. Most recently, he completed work with George Mason University under a State Department grant concerning antiquities coming out of Iraq and Syria, wherein he led the effort to build a training program for foreign law enforcement. He is also a member of the Antiquities Coalition’s Financial Crimes Task Force, a multi-stakeholder initiative aimed to protect the $26.6 billion U.S. art market from criminals and violent extremists.

EU Parliament Warns Cultural Racketeering Continues to Finance Terrorism

On September 5 in Brussels, Belgium, Members of the European Parliament (MEP), senior European Union (EU) officials, law enforcement, and international experts came together for “Financing Terrorism through Trafficking of Cultural Goods: Closing the Gaps.”

The Antiquities Coalition was honored to participate in this half-day event, which explored legislative and law enforcement solutions to cultural racketeering, and was organized by MEP and former Polish Foreign Minister Anna Fotyga. It was headlined by Colonel (Retired) Matthew Bogdanos, now Assistant District Attorney of New York County, who presented on his team’s work to investigate and prosecute traffickers of ancient art. EU Counter-Terrorism Coordinator Gilles de Kerchove also gave special remarks on the existing terrorist threat and the way forward for the EU.

Executive Director Tess Davis spoke about the need to protect our world heritage—as well as the legitimate art market—from criminals, war profiteers, and violent extremist organizations. She detailed how the global art market is the largest unregulated market in the world and uniquely vulnerable to trafficking, fraud, forgery, tax evasion, money laundering, sanctions violations, and terrorist financing. Thankfully, the United States and EU, making up such a large percentage of worldwide sales, have a unique opportunity to combat these crimes. 

Davis also officially announced the launch of the Antiquities Coalition’s latest interactive resource, “Cultural Piracy: Mapping Antiquities Seizures Around the Globe.” This tool illustrates the illicit trade in artifacts from the Middle East and North Africa by plotting reported seizures over the last five years. So far it includes 231 incidents and 166,246 individual objects, which total an estimated $63,762,255. However, because only 5% of the objects had reported values, the actual amount is likely much higher.

In addition to Davis, other speakers included representatives from the Polish Ministry of Culture and National Heritage, the Organization for Security and Co-operation in Europe (OSCE), the World Customs Organization (WCO), and the Art Crime Unit of France. Given the solutions-oriented approach of the event, their remarks focused on best practices that can be adopted both at the national and EU levels to close existing legal loopholes. Key takeaways included:

  • The International Community Must Remain Vigilant: In Iraq and Syria, the illicit trade is changing following the welcome collapse of Daesh (ISIS), as cultural racketeers “switch hats” from fighters to gangsters. However, business continues to thrive, even if profits are no long centralized under one false “Caliphate.” Authorities suspect Daesh-looted pieces are being stored in unknown locations until they can be safely laundered onto the legitimate market. Meanwhile, new evidence is coming to light from other conflict antiquities hotspots, such as Libya and Yemen. The criminal and terrorist financing threat remains and likewise the international community must remain vigilant.
  • Political Will Is Growing: There is growing political will to tackle cultural racketeering, as demonstrated by this event, as well as recent legislative developments in the EU. This April 17, the European Parliament passed Regulation 2019/880, which subjects cultural property imports to uniform controls throughout the EU, and moreover, declares that “the introduction of cultural goods[…] which were removed from the territory of the country where they were created or discovered in breach of the laws and regulations of that country shall be prohibited.” This regulation is binding and self-executing, meaning it was automatically and uniformly applied in its entirety by all 28 Member States. Experts expressed concern that these new laws may make the U.S. market more attractive to cultural racketeers unless comparable action is taken.
  • The Importance of Transatlantic Partnership: Cultural racketeering is a global problem and requires a global solution. However, since the U.S. and the EU combined make up around 75% of the global art market, they have a unique opportunity—and responsibility—to make a difference. Events such as this one are crucial to ensure that lawmakers and law enforcement cooperate across the Atlantic and such increased cooperation between our respective governments could make a huge impact.
  • The Legal Trade is Key to Combatting Looting: All speakers stressed that the illicit trade is a major threat to the legitimate trade—and on the other hand—the stronger the legitimate trade, the weaker the illicit trade. It is critical for governments, law enforcement, and art world leaders to join forces to protect both our world heritage and the art market.



Antiquities Coalition Releases “Cultural Piracy: Mapping Antiquities Seizures Around the Globe”

Nearly $65 Million in Illicit Artifacts Seized Since 2014 From the Middle East and North Africa

WASHINGTON, DC (September 5, 2019) — The Antiquities Coalition is proud to launch its latest interactive map, “Cultural Piracy: Mapping Antiquity Seizures Around the Globe.” This tool provides a geographic representation of the illicit antiquities trade stemming from the Middle East and North Africa (MENA) region by plotting reported cultural property seizures since 2014. These news reports are from English, Arabic, and Turkish-language media sources. In total, the map plots 231 individual seizures and 166,246 individual objects.

Key findings of this map include:

  • Total reported value of $63,762,255.
  • Actual value likely much higher given that just 5% of objects had reported values.
  • Highest valued seizure is $13 million worth of manuscripts and statues from Iraq.
  • The United States accounts for the majority of seizures, with France, Germany, and Spain following.

“The Antiquities Coalition hopes that this map will help underline the patterns in the illicit trade and further reinforce international collaborations to curb it,” says Deborah Lehr, Chairman of the Antiquities Coalition. “Clearly, there are locations in which commendable efforts are succeeding in thwarting this trade.” Nevertheless, there is an obvious need for intergovernmental cooperation: illicit trade is a cross-border issue that requires a multinational response.



About the Antiquities Coalition 

The Antiquities Coalition unites a diverse group of experts in the fight against cultural racketeering: the illicit trade in antiquities by organized criminals and terrorist organizations. This plunder for profit funds crime and conflict around the world—erasing our past and threatening our future. The Coalition’s innovative and practical solutions tackle crimes against heritage head on, empowering communities and countries in crisis. Learn more at Follow us on Twitter @CombatLooting.

Media Contact

Albert Fujii,

The Art of Money Laundering

The loosely regulated art market is rife with opportunities for washing illicit cash

By Tom Mashberg

Matthew Green was raised in the heady world of fine arts, surrounded from boyhood by the works of Old Masters and Impressionists. His father, Richard, the owner of two of London’s most illustrious galleries, dealt in legendary names like Picasso, Constable, Chagall, and Brueghel. Matthew Green, 51, was preparing to take over the family business so his father could pursue new passions.

But in late 2017, US prosecutors say, Green fell in with the owners of a Mauritius-based investment company, Beaufort Securities, that engaged in fraud, stock manipulation, and money laundering. For Beaufort’s owners, duping investors into buying worthless securities was the easy part. The hard part was making the ill-gotten profit appear legitimate to regulators. Beaufort had done so in the past by depositing money under false names in offshore banks, then slipping it into the global banking system little by little. The company had also used the time-tested trick of buying real estate and quickly selling it off, often at a loss, to convert illegal proceeds into assets that could be accounted for as the fruit of a property deal.

Now, money launderers like Beaufort were searching for less obvious ways to scrub their cash, and Matthew Green knew how to trade in multimillion-dollar works of art. Approached in late 2017 by the Beaufort conspirators—one of whom was in fact an undercover US federal agent who had infiltrated Beaufort—Green allegedly said he would accept £6.7 million (about $9 million at the time) in what he knew to be the yield of securities fraud in exchange for a 1965 Picasso, Personnages. Green would draw up phony ownership papers saying the work had been sold, all the while keeping the Picasso stored away. Down the road he would pretend to buy it back from his coconspirators at a lower price, keeping 5 to 10 percent of the laundered cash for himself.

“Art is a very attractive vehicle to launder money,” says Peter B. Hardy, a former US prosecutor who now advises corporations and industries on compliance with anti-money-laundering requirements. “It can be hidden or smuggled, transactions often are private, and prices can be subjective and manipulated—and extremely high.”

After a slew of recent cases in the United States and Europe, the momentum toward a crackdown on illicit art and antiquities deals is growing. The legitimate art market is itself enormous—estimated at $67.4 billion worldwide at the end of 2018. According to the United Nations Office on Drugs and Crime, the underground art market, which includes thefts, fakes, illegal imports, and organized looting, may bring in as much as $6 billion annually. The portion attributed to money laundering and other financial crimes is in the $3 billion range.

For Green, dabbling in the dark art of money laundering has ended poorly. He has been indicted in the United States on six counts of attempted money laundering, and his gallery in the Mayfair district of London has been declared insolvent by British regulators. Although Green has not been identified as a fugitive, court records indicate that US prosecutors have disclosed his indictment and arrest warrant to law enforcement agencies in the United Kingdom, Hungary, Saint Vincent and the Grenadines, and Mauritius. He has also been ordered to surrender the Picasso.

The tactics used by Green and the others charged in the Picasso scheme remain easy to replicate, at least for now. Green was taking advantage of a regulatory loophole that US and European legislators are working hard to close. Unlike banks, life insurance companies, casinos, currency exchangers, and even precious-metals dealers, auction houses, and art sellers have no obligation to report large cash transactions to a governing authority. In fact, dealers can keep the names of buyers and sellers anonymous. And unlike US businesses that deal in large sums of money, they do not have to file so-called suspicious activity reports with the US Treasury Department if they have doubts about the origins of the money they are being paid.

Bill in Congress

Under the Illicit Art and Antiquities Trafficking Prevention Act under consideration in Congress, the US government would require “dealers in art and antiquities” to establish anti-money-laundering programs, keep records of cash purchases, and report suspicious activity and transactions exceeding $10,000 to federal regulators. In addition, the art industry would be required to look into a client’s background and examine purchases and sales for evidence that the money might be tainted.

In the European Union, under its Fifth Anti-Money Laundering Directive, art businesses would be obliged to augment efforts to vet customers and to discern “as far as reasonably possible” the purpose of all large, unusually complex, or secretive transactions.

In the view of many art dealers, the legal changes in both the United States and the European Union would strip the vendors of a major selling point—the ability to offer anonymity to clients and preserve the opacity of the art market. In years past, when the fine arts market was seen as a more genteel pursuit, there was no real inclination by the authorities to police it as strenuously as the banking or brokerage trades. All that has changed in the past decade or so because of the enormous amounts of money pouring into art collecting and the growing focus on stymieing the clandestine trafficking in looted and smuggled artifacts from war-torn nations.

Law enforcement officials and even some art merchants now say that excessive secrecy has become a drawback because more and more money launderers have discovered that the art market can be used as an easy conduit. As noted by the FBI and Interpol, “in comparison with other trade sectors, the art market faces a higher risk of exposure to dubious financial practices” because “the volume of legally questionable transactions is noticeably higher than in other global markets.”

The indictment filed against Matthew Green and his confederates even recounts a conversation, tape-recorded by an undercover agent, in which Green allegedly crows that “the art trade is the only market that is this unregulated.” A client “could even buy the art under a false name with no repercussions,” Green is quoted as saying.

“More cases involving artwork and money laundering undoubtedly would be uncovered by law enforcement if art and antiquities dealers were added to the list of businesses legally liable for reporting suspect payments,” says Rick St. Hilaire, a former US prosecutor and an expert on art and antiquities law. “For now, it’s wide open.”

Supporters of expanded regulation say all they want is for the trade in fine art, cultural property, and ancient artifacts to be subjected to the same financial regulations that banks and other industries face.

“The art market is an ideal playing ground for money laundering,” says Thomas Christ, a board member of the Basel Institute on Governance, a Swiss nonprofit that has proposed anti-money-laundering standards for art market operators. He added, “We have to ask for clear transparency, where you got the money from and where it is going.”

The industry objects

Not surprisingly, the art industry is fighting the regulations. Some sectors are asserting that examples of actual money laundering via the art trade are rare or exaggerated by law enforcement agencies eager to generate sensational headlines. Others, like the International Confederation of Art and Antique Dealers Associations, say the reporting requirements are too burdensome for smaller players in the art market.

At a conference on money laundering last year, James McAndrew, a former Department of Homeland Security special agent who now lobbies on behalf of dealers and collectors, said that “there has not been an art dealer or collector convicted for laundering money through art. The idea that auctions are nefarious or evil is outrageous because it hasn’t been proven.” Peter Tompa, director of the Global Heritage Alliance, which supports coin dealers and the bullion industry, warned that many in the trade would exit the market because the new standards would be too costly to adopt.

And the Committee for Cultural Policy, which represents large and small art dealers and buyers in the United States, said that “it is not practical to use art to launder money, especially antiques and antiquities, because art sells slowly, and buyers are usually collectors,” not criminals seeking a quick deal to “legitimize” dubious money.

But advocates say the stratospheric valuations placed on artworks by even second-tier artists leave them no choice but to impose constraints on a vulnerable industry at a time when drug kingpins, oil oligarchs, and assorted kleptocrats are desperate to turn their dirty money into a clean or fungible asset. For now, the momentum is with them, and there are enough money laundering prosecutions to justify those concerns.

A 2014 case known as U.S. v. Ronald Belciano et al., for example, involved both the distribution of marijuana and a conspiracy to launder the profits using artwork. Police seized over $4 million in cash and confiscated approximately 125 pounds of marijuana and 33 paintings worth more than $619,000 from a storage warehouse in Pennsylvania. Prosecutors said the drug dealers had accepted the artworks in lieu of cash after being promised that they could sell them back for laundered money once the art dealers had buried the transactions in their books. In 2015, Belciano was sentenced to five years in prison.

In another high-profile case, a Brazilian financier was accused of embezzling millions from his bank and trying to launder the money by acquiring expensive art, including Jean-Michel Basquiat’s Hannibal (1981). According to federal prosecutors in New York, the financier, Edemar Cid Ferreira, tried to smuggle the Basquiat and about 90 other high-value works of art into the United States using papers that declared the value of each object at $100. Even though he was convicted and sentenced to 21 years in 2006, appeals and complexities in the legal system meant the United States could not repatriate the works to Brazil until 2017.

And small-scale scams occur every day. Indian officials, for example, say antiquities looted from remote temples and tombs are used as a means of currency exchange. The items are shipped to dealers in Hong Kong SAR or Bangkok—often falsely listed in manifests as replicas worth a few rupees. Collectors and traders are standing by to pay thousands of dollars for the relics, which come with fake documents attesting to their legal purchase. The dealers keep a share of the take and filter the rest of the money back to crime rings in India through unregulated nonbank financial companies.

Deborah Lehr, chairman of the Antiquities Coalition, a Washington, DC–based organization fighting trafficking in artifacts, warns that terrorist groups are already using the art and antiquities industry to raise money by plundering ancient cultural sites and employing intermediaries to sell off the looted goods. “A key priority is shutting the US market to illicit antiquities while encouraging responsible trade practices,” she says.

Given that upward of 70 to 90 percent of auction catalog listings for valuable antiquities provide scant information about the seller, art merchants would be wise to accept the inevitable and move toward greater transparency and more due diligence, says Hardy, the former prosecutor. The proposed regulations, he says, would simply enshrine into law the steps that art dealers ought to be taking in the first place to stave off criminal acts.

“Sometimes,” he says, “the provenance of the funds can be more critical than the provenance of the art.”

Download full article PDF here.

Yemen Gains Ground in Fight Against “Blood Antiquities” Trade

Joins Main International Treaty Combatting Cultural Racketeering 

WASHINGTON, DC (September 3, 2019) — Today, the Republic of Yemen became a State Party to the main international treaty to combat cultural racketeering, the 1970 UNESCO Convention on the Means of Prohibiting and Preventing the Illicit Import, Export and Transport of Ownership of Cultural Property. The Antiquities Coalition applauds Yemen for taking this critical step, which demonstrates the government’s commitment to fighting the illicit trade, even in the midst of a civil war. Yemen’s ratification will do much to strengthen its cooperation with the agreement’s 139 other State Parties, particularly the countries that are providing the market demand for its conflict antiquities, like the United States. 

By joining the UNESCO Convention, Yemen is now eligible for a host of legal protections, including a bilateral agreement with the United States under the U.S. Convention on Cultural Property Implementation Act. Such an agreement could restrict the U.S. import of Yemeni cultural material, absent proof that it left the country legally. The United States now has 19 of these agreements. 

A bilateral agreement between the United States and Yemen would protect unsuspecting American buyers from purchasing conflict antiquities,” says Deborah Lehr, Chairman of the Antiquities Coalition. “It would also increase much-needed law enforcement and counterterrorism cooperation between our two countries. Now that Yemen has taken the important step of joining the UNESCO Convention—even amid the many challenges it now faces—we call on the international community to do its part to help protect the country’s rich heritage for future generations.” 

Yemen’s ratification comes at a critical time. Its government and international experts have long warned that cultural racketeering is financing the Houthi insurgents, Al-Qaeda in the Arabian Peninsula (AQAP), and opportunistic criminals. As reported earlier by the Antiquities Coalition and the New York Times, Yemen still needs the public’s help to recover thousands of priceless artifacts that have been looted amid the ongoing fighting. The Embassy of Yemen has launched a 24-hour hotline for the public to report any of its stolen artifacts, which can be reached at +1 (202) 717-1066 or


To Learn More


About the Antiquities Coalition 

The Antiquities Coalition unites a diverse group of experts in the fight against cultural racketeering: the illicit trade in antiquities by organized criminals and terrorist organizations. This plunder for profit funds crime and conflict around the world—erasing our past and threatening our future. The Coalition’s innovative and practical solutions tackle crimes against heritage head on, empowering communities and countries in crisis. Learn more at Follow us on Twitter @CombatLooting.