U.S.- Cambodia Partnership Continues to Yield Results in the Fight Against Cultural Racketeering

Metropolitan Museum Will Repatriate 14 Looted Masterpieces Linked to Douglas Latchford

The Antiquities Coalition (AC) applauds the continuous and collaborative efforts of U.S. Law Enforcement and the Kingdom of Cambodia to recover the Kingdom’s looted heritage. The AC is proud to actively support these efforts, working hand-in-hand with the Cambodian government, law enforcement officials, and journalists. Through our advocacy and awareness campaigns, we strive to expose the crimes of notorious antiquities traffickers such as Douglas Latchford, and contribute to the ongoing pursuit of justice.

Most recently, on December 15, the Southern District of New York U.S. Attorney’s Office, Homeland Security Investigations, and the Metropolitan Museum of Art (the Met) announced the return of a total of 16 antiquities: 14 to Cambodia and to 2 Thailand, all connected to Latchford. This announcement was further covered in a segment on CBS’s 60 Minutes, as part of a story on Cambodia’s efforts to reclaim its heritage which aired on December 17th after a year-long investigative report by the program.

The pieces returning are part of a decade-long investigation into Latchford’s crimes by HSI and the U.S. Attorney’s Office for SDNY, which is still ongoing. Among the many masterpieces being returned is a sculpture of a 10th century female goddess from the ancient royal capital of Koh Ker. The twin sculpture, also looted from Koh Ker, remains on the list of the Antiquities Coalition’s Ten Most Wanted Antiquities

The Met has faced pressure in recent years to review its collections following several high-profile seizures of artworks connected with suspected traffickers, including pieces connected to Latchford. In 2013, the museum repatriated two Khmer sculptures donated by Latchford. While we applaud these efforts, we acknowledge that more must be done to repatriate remaining stolen heritage from within the Met. In their statement, the Cambodian Ministry of Culture noted that they appreciated this return as a “first step in the right direction.”

“The return of these objects from The Met to their rightful homes in Cambodia and Thailand is an encouraging step for the institution. We continue to call on the U.S. government, the Department of Justice, and the Department of Homeland Security, to play a role in treating the illicit trade in cultural objects like the crime that it is.” -Tess Davis, Executive Director, Antiquities Coalition

Damian Williams, Assistant U.S. Attorney also emphasized the ongoing nature of the investigation in his public remarks on the return. He urged anyone or any institution with potentially looted antiquities to come forward: “Come see us, before we come see you.”

While Latchford escaped justice, passing away in 2020 under indictment, the U.S. and Cambodia’s unwavering efforts prove that the pursuit of accountability for cultural crimes transcends individuals, fostering a commitment to safeguarding global heritage and ensuring restitution even if it takes years.

Adding Cultural Racketeering to the Campaign Against Corruption

AC Joins Global Leaders Seeking Solutions at the 10th UNCAC Conference of State Parties

The $67.8 billion dollar art market remains the largest unregulated market in the world. The multi-billion dollar scale, the unique nature of art itself, and opaque business practices make this market susceptible to a wide range of criminal activity, including fraud, forgery, tax evasion, trafficking, money laundering, sanctions evasion, and terrorist financing.

In order to effectively address these crimes, it is crucial to recognize and address the role of corruption. Recent cases have shown the full extent of how corruption undermines laws and their enforcement, ensures the art market stays unregulated, and helps criminals to escape arrest, conviction, and effective punishment.

Despite this, there has been a glaring lack of attention on the international stage regarding the connections between cultural racketeering and corruption, leaving a critical gap in efforts to combat these pervasive criminal activities within the art market.

On December 11-12, 2023, the Antiquities Coalition brought this topic to a global audience at the 10th session of the Conference of the States Parties (CoSP10) to the United Nations Convention Against Corruption (UNCAC), a forum that brings the international community together in the prevention and fight against corruption.

The AC was proud to co-host a session as part of the special events program at CoSP10, “Cultural Racketeering & Corruption—Recommendations for UNCAC,” with the Italian Republic, the United Mexican States, and the United Nations Office on Drugs and Crime (UNODC), which was attended by over 50 participants from the convention.

The session was opened by His Excellency Carlo Nordio, the Minister of Justice of the Italian Republic, a strong signal of his country’s commitment to this issue. Additional participants included: Melanie Chabert, Associate Crime Prevention and Criminal Justice Officer with the Corruption and Economic Crime Branch of UNODC, Ambassador Javier Díaz de León of the Mexican Foreign Service, and Justice Luigi Marini, who serves on the highest court in Italy and dedicates his work to protecting cultural heritage.

The event outlined the close connection between illicit trade and the forces that facilitate it. Tess Davis, Antiquities Coalition Executive Director, elaborated on this dynamic: “Cultural racketeering would not be possible without corruption. Tackling the linked issues of corruption and cultural racketeering requires working across industries, the public and private sectors, and national borders.”  Participants discussed this issue in the broad context of UNCAC, how UNODC is suited to tackle these interlinked problems, and showcased those facing this issue head-on. 

The AC also participated in the Private Sector Forum, “The United Nations Convention Against Corruption at 20: Uniting Leaders for Business Integrity.” Davis joined the session “Between Crime and Compliance: The Ambiguous Role of Gatekeepers in the Global Financial System” where she emphasized how art and antiquities crimes could only succeed with the complicity of those within the art market—like archaeologists, conservators, and dealers – and those who provide ancillary services—like bankers, lawyers, and accountants. 

Despite their strategic position that allows for preventing or interrupting illicit financial flows, these intermediaries often enable the behavior of bad actors, allowing them to thrive and take advantage of this unregulated market. 

Davis also highlighted how corrupt actors can range from soldiers, guards, customs agents, police, and prosecutors to “legal persons”—galleries, auction houses, other corporations, and unfortunately even not-for-profit institutions like museums. Additionally, any framework put in place needs to be on a parallel track with political leaders and elites having the will to resist utilizing organized crimes to their benefit. 


The Antiquities Coalition would like to thank the UNODC and our esteemed partners for highlighting the importance of regulating the art market in the fight against corruption. The AC is committed to working now just with organizations dedicated to preserving culture, but also with organizations like the UNODC to combat looting and better safeguard cultural heritage across the globe.

AC and Other Industry Leaders Urge Secretary Yellen and FinCEN to Prevent Bad Actors from Exploiting the Art Market

The art market continues to be the largest unregulated market in the United States—and arguably the world—leaving it vulnerable to bad actors. Failure to close existing loopholes has allowed criminals to continue evading the law, with serious consequence. 

One glaring example of this is evident in the U.S. Government’s efforts to isolate Russia’s economy following the 2022 invasion of Ukraine. Despite concerted efforts to impose sanctions and tighten economic restrictions, Bloomberg reported in February that federal prosecutors are investigating major auction houses regarding Russian oligarchs, the American art market, and potential sanctions evasion. Concerns by the Department of Justice (DOJ) are valid, as a 2020 Senate report showed that individuals associated with the Kremlin had laundered vast sums through top New York auction houses to bypass U.S. sanctions from Russia’s 2014 aggression towards Ukraine. Unfortunately, these vulnerabilities persist, allowing exploitation by criminals and adversaries. Recent findings from the Pandora Papers and federal probes highlight ongoing issues. For instance, the DOJ indicted Nazem Ahmad, a prominent Lebanese collector linked to Hezbollah, for using art and luxury goods to bypass terrorism-related sanctions, enabling transactions of over $160 million in the U.S.

On August 8th, the Antiquities Coalition along with a coalition of allies dedicated to fighting financial crimes, recommended immediate and concrete actions in a letter addressed to Treasury Secretary Janet Yellen and Andrea Gacki, the incoming director of the Financial Crimes Enforcement Network (FinCEN),  urging them to close the $30 billion American art market to criminals. 

The coalition, which includes organizations such as Transparency International U.S., International Coalition Against Illicit Economies, the Jewelers Vigilance Committee, as well as prominent AML experts like John J. Byrne urges the Treasury, and specifically FinCEN, to prioritize closing the legal and regulatory loopholes that continue to make the art trade and its participants vulnerable to criminal misuse. Steps could include: 

  • Issuing—and then finalizing—rules for antiquities dealers as required by the AML Act of 2020
  • Applying AML/CFT protections to other high-risk American art market participants
  • Working with the private sector to strengthen information sharing
  • Updating guidance and training for law enforcement to include the unique risks and opportunities presented by the American art market
  • Using existing tools, such as targeted recordkeeping and reporting requirements, as well as FinCEN alerts, to better understand and combat threats to the American art market from financial crimes like money laundering, terrorist financing, and sanctions evasion. 

To protect our shared history and responsible market actors, we must strengthen rules surrounding art and anti-money laundering (AML), counter-terrorist financing (CFT), and sanctions. In the past year, global conflicts have made these actions more critical than ever. We urge the leadership of FinCEN and the broader Treasury Department to take action to better safeguard our cultural heritage.

Read the full letter here: Bar Criminals from Exploiting the 30 billion dollar American Art Market