Antiquities Coalition Partners with FACT Coalition to Combat Corruption

The American art market is the largest unregulated market in the world, making it vulnerable to a wide range of financial crimes. To fight back, the Antiquities Coalition is proud to announce that we have joined the Financial Accountability and Corporate Transparency (FACT) Coalition

Founded in 2011, the Financial Accountability and Corporate Transparency (FACT) Coalition is a non-partisan alliance of more than 100 state, national, and international organizations working toward a fair tax system that addresses the challenges of a global economy and promotes policies to combat the harmful impacts of corrupt financial practices. As experts on financial crimes within the art market, the AC is proud to deepen our partnership with the FACT Coalition.

The AC recognizes that ongoing exemption from standard financial regulatory laws and oversight, which now cover all industries of comparable risk and size, is a documented and growing threat to our national security and integrity, as well as the vast majority of legitimate collectors, dealers, auction houses, and museums. 

Criminals, including blacklisted Russian oligarchs and Hezbollah financiers, are exploiting the art market’s vulnerabilities to commit a wide range of offenses from fraud to forgery, tax evasion, money laundering, and sanctions violations. By joining the FACT Coalition, the AC looks forward to partnering and expanding our work to strengthen, standardize, and enforce anti-money laundering practices and laws. 

“To best protect art, cultural heritage, and responsible market actors, we must strengthen rules surrounding art and anti-money laundering (AML), counter-terrorist financing (CFT), and sanctions. By joining the FACT Coalition, we are committed to combating these challenges head-on and will continue to champion the principles of accountability and integrity.” -Tess Davis, Executive Director

This announcement is the latest in an ongoing partnership between the Antiquities Coalition and the FACT Coalition. In September 2023, the FACT Coalition recognized AC’s Director of Programs, Helena Arose, as an anti-money laundering expert. The AC looks forward to future joint efforts to combat cultural racketeering. 

For additional information, visit the FACT Coalition’s website.

Careers in Cultural Heritage: A Conversation with the AC

In April, the Antiquities Coalition’s Director of Programs Helena Arose, and Legal Consultant Liz Fraccaro shared their career experience and advice in a webinar hosted by the American Society of Overseas Research (ASOR)’s Early Career Scholars Committee. 

In their discussion, both Arose and Fraccaro shared their journey, noting how their backgrounds in archaeology and museums reaffirmed their passion for the cultural heritage field. They also shared key takeaways for those interested in cultural heritage careers:

  • No two careers look alike in this field—each individual must carve out their own unique path. Regardless of your position within an organization, you’ll need to proactively shape your career trajectory and find ways to focus on cultural heritage.
  • When considering job opportunities, it’s crucial to weigh factors like the size of the organization or company and the nature of your day-to-day tasks. Think about what aspects of work you enjoy most—whether it’s being out in the field, engaging in interpersonal interactions, writing, or other activities. Larger organizations may offer more structured roles with specialized tasks, while smaller ones might provide greater flexibility and opportunities to wear multiple hats.
  • In this field, you’ll often encounter positions within nonprofits, whether you find yourself working in a museum, advocacy group, or think tank. Therefore, honing skills such as grant writing, effective communication, and proficient project management will prove invaluable irrespective of your specific career path.

As the AC’s Director of Programs, Arose collaborates with representatives from the U.S. and international governments, law enforcement agencies, international partners, academics, and other key stakeholder groups to develop and implement programs to fight the illicit trade in ancient art and antiquities. Arose is a recognized expert on cultural racketeering, antiquities looting and trafficking, cultural heritage diplomacy and protection, financial crimes, and the art market. 

Fraccaro, as the AC’s Legal Consultant, is a trained archaeologist and attorney, admitted to the Illinois State Bar and New York State Bar and is a Certified Money Laundering Specialist. Utilizing her extensive background in museum collections and field archaeology, Fraccaro strives to preserve and protect cultural heritage worldwide. In her work at the AC, she uses her expertise in the legal dimensions of cultural heritage management and money laundering to develop concrete recommendations for combating money laundering, forgery, fraud, and terrorist financing via art and antiquities. 

While Arose and Fraccaro acknowledged that entering this field can be challenging, they highlighted that new needs and opportunities are developing in areas such as provenance research, art market compliance, and foreign affairs, which all contribute to the fight against cultural racketeering. 

The AC thanks the ASOR’s Early Career Scholars Committee for spotlighting our leaders and giving them a platform to share their work experiences and inspire the next generation of professionals interested in a career in cultural heritage. Watch the discussion here

Want to get more involved with the Antiquities Coalition? Consider supporting our efforts to end cultural racketeering or apply to our internship program to get first-hand experience in the fight against looting. 

 

Antiquities Coalition’s Tess Davis Highlights the Illicit Trade of Cambodian Antiquities in Politico

The Kingdom of Cambodia is home to a rich archaeological heritage, but decades of unrest left its ancient sites and antiquities vulnerable to looters and traffickers. One of the most infamous was British expatriate Douglas Latchford. Latchford’s network sourced countless masterpieces (including a Top Ten Most Wanted artifact) from then-wartorn Cambodia, smuggled them across the border, and then laundered them onto the global art market. He then hid his substantial proceeds using a complex network of shell companies and offshore accounts. To this day, the breadth of Latchford’s crimes are still being exposed, while repatriations of his loot have included some of the biggest stolen art recoveries since after the Second World War. 

But the scale of Latchford’s story—which has been extensively reported on in the New York Times, Washington Post, and beyond—has obscured other dealers and collectors of Cambodian art. 

A recent Politico article sought to even this coverage, by exploring István Zelnik, a former Hungarian diplomat with a passion for Asian antiquities. Zelnik ventured into the art market following his retirement from the diplomatic service and, according to Politico, used his connections to sell Cambodian and other Southeast Asian antiquities to private collectors.   

The AC’s Executive Director, Tess Davis, has long worked to expose Latchford’s dealings and draw more attention to the massive scale of the looting in Cambodia. Davis reaffirmed this in Politico, stating “there is no legal supply of ancient Khmer art, that’s like saying it’s legal to sell a gargoyle hacked off of Notre Dame.”

The Antiquities Coalition will continue to fight to safeguard heritage from cultural racketeering and work with our domestic and international partners to support repatriation efforts of stolen artifacts. 

Learn about Zelnik in Politico here and check out the AC’s Top Ten Most Wanted, including Cambodia’s missing Uma, the Consort of Shiva.

AC Gives Key Takeaways from the Art Market Report 2024

This month, Art Basel and UBS released their annual global art market analysis: The Art Market Report 2024. As in years past, the United States remained by far the largest art market in the world in 2023. As a result, U.S. law and policy that affects the American art market has a significant impact on the entire global industry.

In an article for LinkedIn, AC Executive Director Tess Davis and AC Director of Programs Helena Arose give their key takeaways from the report for policy makers and the wider public.

Check out the article below or on LinkedIn, and follow TessHelena, and the AC on LinkedIn for more.

Antiquities Coalition Warns U.S. Art Market Is a “Sanctions Black Hole” in Financial Times Op-Ed

Art and antiquities have financed some of the last century’s worst actors, yet for too long, public policy has treated cultural racketeering as a white collar and victimless crime. Since its founding in 2014, the Antiquities Coalition has worked to correct this false narrative: The art market’s avoidance from what are now standard laws and regulations is allowing a thriving illicit trade, as well as money laundering and sanctions evasion by some of the United States’ top adversaries—including those behind the war in Ukraine.

On February 28, 2024, in an op-ed for the Financial Times, Chair and Founder Deborah Lehr warned that even as President Joe Biden continues to crack down on Russia, “the U.S. art market is a sanctions black hole.” Reports from the Senate and Treasury Department have extensively documented how “key allies of the Russian state,” Arkady and Boris Rotenberg, have utilized the art market to launder tens of millions of dollars in full evasion of the sanctions regime. The reports also emphasized the need for anti-money laundering (AML) and counter-terrorist financing (CTF) protections in the American art market, the largest unregulated market in the world. 

As Lehr states in her op-ed, until these steps are taken, “there is a real likelihood that collectors, dealers, and auction houses in the US may unknowingly continue to help further crime, armed conflict and even terrorism through the apparently legal purchase of art. This is too high a price to pay, even for a masterpiece.” Lehr’s call has been further justified by recent developments in the case of Hezbollah-financier Nazem Ahmad, who was indicted in April 2023 for using art and luxury goods to bypass terrorism-related sanctions, enabling transactions of over $160 million in the U.S.

The art market’s exemption from legal oversight has made it vulnerable to a wide range of financial crimes, threatening not just national security and economic integrity, but the vast majority of legitimate collectors, dealers, auction houses, and museums. Unless and until the U.S. public and private sectors close these loopholes, they will leave the world’s largest economy wide open to oligarchs, money launderers, terrorists, drug smugglers, artifact traffickers, and the many other criminals proven to have exploited the art market’s weaknesses. The Antiquities Coalition has led a charge to fight back with its Financial Task Force, which brings together a diverse group of experts to support law and policymakers. 

Read Lehr’s full op-ed here

Read Lehr’s previous 2020 op-ed on the Rotenberg brothers in the Hill here.

At Council on Foreign Relations Meeting on Sanctions Strategy, Antiquities Coalition Calls on U.S. Treasury to Close Art Market Loopholes

February 2024 marked two years since Russian forces invaded Ukraine, destroying lives, communities, and cultural heritage. During that time, we have also seen the exploitation of heritage and historical propaganda become one of the Kremlin’s most effective weapons for its information warfare program targeting the West, a scenario the AC’s Think Tank warned would happen, as well as the organized plunder of Ukraine’s art and antiquities by invading forces. While priceless to the Ukrainian people, these treasures have the potential to be a valuable commodity to the cash-strapped Russian state, and thus may greatly undermine the U.S.-led sanctions regime. The lack of regulation of the American art market is additionally providing another—now well documented—route for Russia to evade sanctions.

At a recent meeting held by the Council on Foreign Relations (CFR) on February 23, 2024, the U.S. Deputy Treasury Secretary Wally Adeyemo spoke on challenges facing the U.S. sanctions strategy. Tess Davis, Executive Director of the Antiquities Coalition and Term Member of the CFR, had the opportunity to ask the Secretary about a sanctions black hole: the American art market.

“Russia is isolated from the global economy, but there remains an easy backdoor through the $30 billion American art market, which is arguably the largest unregulated market in the world, period. And the U.S. government has proven in great detail how art’s providing a lucrative, and unfortunately untraceable, funding source for blacklisted individuals and entities. We’re talking tens of millions to Putin’s top enablers, the Rotenberg brothers, but also 160 million (dollars) to Hezbollah,” Davis noted. She then asked what Treasury is doing to fight back against these risks.

Adeyemo disclosed how his colleagues at the Office of Foreign Asset Control are focused on the art market and pursuing both wealthy Russian oligarchs and those close to the Kremlin. He also shared details on how the Russian Elites, Proxies, and Oligarchs (REPO) Task Force, which was founded in March of 2022 and is made up of the G7 and other allies, is working to ensure the U.S. and allies can track assets, including art, that may be used to move money around the world. 

“Ultimately, the thing that we know is that wealthy Russians have spent decades learning to evade not only our sanctions, but Russian taxes, frankly. So they are very good at this. But what we—by setting up the task force—the Repo Task Force, it’s put us in a position where we’re able to share more information not only in the United States, not only with the U.K., but with a number of our allies and partners to be able to go after their ability to move wealth in ways like this,” he added.

The Antiquities Coalition thanks the CFR and U.S. Deputy Treasury Secretary Wally Adeyemo for facilitating this important conversation. While there is much more to be done, open collaboration and consideration of all markets will ensure maximum effectiveness of the U.S. sanctions strategy.

Watch the full session here and learn more about how the Antiquities Coalition is encouraging responsible art markets and trade practices.

AC’s Tess Davis Joins AIA to Discuss the Fight Against Cultural Racketeering

Cultural racketeering isn’t just a threat to our past. It’s a threat to our future, to human rights, national economies, and global security. It is also a threat to the legitimate art market, to good faith collectors, dealers, galleries, and museums, who themselves can also be victims of looters and traffickers. To fight back, governments, law enforcement, and citizens should join forces to hold criminals accountable and close loopholes that leave our collective history vulnerable to this illicit trade.

On February 25, Antiquities Coalition Executive Director, Tess Davis, joined the Archeological Institute of America to discuss “Blood Antiquities: Tomb Raiders, Art Smugglers And The Black Market In Cultural Treasures.” These conversations help raise awareness of the scale of the illicit antiquities market, an important step in incentivizing action from leaders and policymakers. 

The AIA, the world’s oldest and largest archaeological organization, is a valuable champion in the fight to increase public knowledge of the cultural racketeering crisis through efforts like International Archaeology Day, a Site Preservation Grant program, Archaeology Magazine, their lecture program, and more. The AC is a proud supporter of these efforts, and Davis has previously participated in the AIA Archaeology Hour as the Virtual Lecturer of the Month. These collaborations strengthen our joint efforts. 

The AC has long worked closely with the AIA. AC Chair and Founder Deborah Lehr served as an AIA General Trustee from 2013-19, while co-founder Peter Herdrich was a Board Member and later CEO of the organization. Executive Director, Tess Davis, also started her career there as a program assistant in 2001.

The AC thanks the AIA for their continued partnership and looks forward to future collaborative efforts to ensure cultural relics are kept out of the hands of bad actors.

Learn more about Davis’ recent lecture here.

AC’s Tess Davis and Helena Arose: Museum transparency and ethical conduct regarding stolen cultural property necessary in maintaining public trust

In an article for LinkedIn, AC Executive Director Tess Davis and AC Director of Programs Helena Arose consider the question: Is the Rubin Museum’s closure in 2024 connected to its past involvement with the illicit trade in antiquities? 

Despite the museum’s answer that it is not, Davis and Arose examine the institution’s track record of collecting and transparency, and conclude that “Whether directly related or not, this situation underscores the power of public perception in shaping the actions of cultural institutions in the United States. In any case, it serves as a cautionary tale, highlighting the importance of transparency and ethical conduct in maintaining public trust.”

As institutions that serve the public, museums must begin to face the reality of reputational and financial risks associated with unlawful or unethical behavior. The AC is committed to holding all those involved in the illicit trade of antiquities accountable for their role in cultural racketeering.

Check out the article below or on LinkedIn, and follow Tess, Helena, and the AC on LinkedIn for more.

The AC Joins U.S. and Yemeni Leaders to Highlight Successes in the Fight to Safeguard Culture Under Threat

For years, blood antiquities have enabled armed conflicts and terrorism across the globe. While no corner of the world is spared by tomb raiders and art smugglers, Yemen and the broader Middle East are under particular attack. The world’s museums have a unique opportunity—and responsibility—to fight back. 

On January 27, Tess Davis, the AC’s Executive Director, participated in “Museums and Cultural Heritage Protection: A Case Study of Repatriations to Yemen.” This event, hosted by the Smithsonian National Museum of Asian Art (NMAA), featured Davis alongside political leaders who are diligently working to resolve both the armed conflict and humanitarian crisis in Yemen. These included Steven Fagin, the U.S. Ambassador to Yemen, Timothy A. Lenderking, U.S. Special Envoy for Yemen and His Excellency Mohammed Al-Hadhrami, Ambassador of the Republic of Yemen to the United States. 

Davis joined a panel with Ambassador Al-Hadharami and Chase Robinson, Director of the NMAA, titled “A Collective Effort: Preserving Yemen’s Cultural Heritage.” His Excellency the Ambassador detailed Yemen’s example and approach to protecting its culture during conflict, and spoke about the effectiveness of collaborating with the AC.  “The first approach [is] just appreciating what are your priorities. For us, we focused with the help of the Antiquities Coalition… on the market. The US by far is the biggest market for arts, so we started to work here… I remember meeting Tess back in 2018 when I was a Deputy Chief of Mission at the Embassy [and] the coalition’s been there [at] my desk wherever I go…The second [approach] is really finding someone that could help you, someone who helped others before. In our case it was the Antiquities Coalition.” 

Yemen’s case of using close engagement with the U.S. government to fight antiquities trafficking is a powerful one. Davis expanded on the importance of this cooperation. “Cultural racketeering is not a preservation failure, but a failure of governance, law, diplomacy, civil society, and markets. It cannot be solved by better archaeology—and I say this as a trained archaeologist. It can only be solved by strengthening law enforcement, international cooperation, and market integrity,” Davis shared. To better safeguard cultural heritage as a partner to these governmental organizations, Davis also outlined the steps that museums can take to help stem the tide in Yemen and beyond:

  • Understanding that the problem is critical and that museums play a unique role.
  • Launching an awareness campaign to help policymakers, the private sector, and the general public better understand the threats from cultural racketeering and how we can fight back. 
  • Strengthen best practices. It is time to upgrade our strategies, just as criminals have updated theirs, to protect both our cultural heritage and the legitimate art market.
  • Capacity building. Training in provenance research and authentication, as well as having dedicated museum staff to research acquisitions and object history, can make a significant difference. 
  • Treat the issue of cultural racketeering and repatriation as stepping stones, not obstacles.

While these conversations are important, they must be paired with action. Organizations working toward this common goal must continue collaborative efforts to ensure a strong international approach to prevent the looting of antiquities and close loopholes in the art market. 

The Antiquities Coalition commends the Smithsonian, the United States, and Yemen for their leadership in protecting cultural heritage and looks forward to our continued collaboration in efforts to combat looting and cultural racketeering.

Watch the event here.

AC’s Helena Arose, Peter Herdrich, and Abir Chorfa Discuss Digitization as a Tool to Combat Looting

On January 23, Helena Arose, the AC’s Director of Programs, Peter Herdrich, the AC’s Co-Founder, and Abir Chorfa, AC’s Manager of Projects in Algeria, participated in the webinar, The Himaya Project: Addressing Looting Through Digitization. The event was hosted by the Qatar National Library and moderated by Maxim Nasra, the library’s Head of Preservation and Conservation. The AC leaders highlighted the importance of digitization in protecting cultural heritage and combating the illicit trafficking of antiquities. The panelists also discussed the challenges that can occur with digitization.

In recent years, the AC has assisted in digitizing the records of several collections, including that of the Bardo Museum in Algeria and the Syriac Heritage Museum, which have helped preserve prized cultural artifacts. During the conversation, the AC team also spotlighted the Turathi heritage project in Algeria, which is helping law enforcement identify antiquities at risk of being trafficked while also allowing the public to learn more about these pieces.

The Antiquities Coalition thanks the Qatar National Library for organizing this webinar and Maxim Nasra, the library’s Head of Preservation and Conservation, for moderating. We look forward to continuing our work in preserving culture through digitization to help combat cultural racketeering and other threats to heritage.

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.