Clooney Report 8 June 2022

Conflict The Need for Prosecuting
Antiquities
Participants in the Illegal
Antiquities Trade
for Complicity in
e d o c k et International Crimes and
th Terrorism Financing
8 June 2022
This document constitutes the Introduction,
Executive Summary, Methodology, and
Recommendations of The Docket’s
Report entitled “Conflict Antiquities:
Prosecuting Participants in the Illegal
Antiquities Trade for Complicity in
International Crimes and Terrorism
Financing”.
The full Report is available online on our web-

site at https://cfj.org/project/the-docket/.
The Docket, an initiative of the Clooney Foundation for

Justice, gathers evidence of international crimes to trig-
ger prosecutions of perpetrators and support victims in
their pursuit of justice.
Table of Contents
Introduction........................................................................................................................................................................................2
Executive Summary......................................................................................................................................................................6
Pillage and other war crimes by armed groups operating in the MENA
region.............................................................................................................................................................................................7
Patterns of trafficking.......................................................................................................................................................8
Antiquities dealers as possible accomplices to war crimes and financiers of
terrorism.....................................................................................................................................................................................13
Need for criminal prosecutions..............................................................................................................................15
Recommendations......................................................................................................................................................................20
To the UN Security Council, UNESCO, UNITAD, and other international
organizations........................................................................................................................................................................20
To INTERPOL, EUROPOL, and law enforcement agencies..................................................................21
To national authorities and governments......................................................................................................22
To civil society actors.....................................................................................................................................................23
To the art and antiquities industry and related private institutions.......................................23
To online sale platforms and social networks...........................................................................................24
Methodology....................................................................................................................................................................................26
I. Pillage by Armed Groups During Conflicts in the MENA Region.....................................................27
1. Syria..........................................................................................................................................................................................29
1.1 Palmyra.................................................................................................................................................................32
1.2 Dura Europos and Mari..........................................................................................................................32
1.3 Museums..............................................................................................................................................................39
1.4 Religious Sites..................................................................................................................................................39
2. Iraq..........................................................................................................................................................................................42
2.1 Nieveh and Nimrud.........................................................................................................................................42
2.2 Hatra..........................................................................................................................................................................48
2.3 Libraries and Museums of Mosul.......................................................................................................48
2.4 Religious Sites.....................................................................................................................................................48
3. Libya........................................................................................................................................................................................56
3.1 Cyrene........................................................................................................................................................................56
3.2 Museums.................................................................................................................................................................56
3.3 Religious Sites......................................................................................................................................................57
3.4 National Commercial Bank of Benghazi......................................................................................57
4. Yemen....................................................................................................................................................................................57
4.1 Museums...................................................................................................................................................................57
4.2 Religious Sites.....................................................................................................................................................60
5. Looted antiquities as a source of funding for terrorists and other armed
actors...........................................................................................................................................................................................60
II. Patterns of Smuggling and Trafficking...................................................................................................................71
1. Routes from Iraq and Syria.....................................................................................................................................71
1.1 Via Turkey...................................................................................................................................................................71
1.2 Via Lebanon...........................................................................................................................................................75
2. Routes from Libya.........................................................................................................................................................77
2.1 Via Egypt...................................................................................................................................................................77
2.2 Via Tunisia..............................................................................................................................................................77
3. Routes from Yemen.....................................................................................................................................................77
3.1 Via Gulf countries through Egypt.........................................................................................................77
3.2 Horn of Africa.....................................................................................................................................................77
4. Additional Transit Countries and Laundering Portals.....................................................................77
5. Freeports..............................................................................................................................................................................78
6. Money Exchange and Hawala Offices.........................................................................................................79
7. Online Trade in Looted Antiquities.................................................................................................................79
III. Investigations in Europe and the United States..........................................................................................83
1. Christophe Kunicki and Richard Semper....................................................................................................83
2. Roben Galel Dib............................................................................................................................................................85
3. Ali Aboutaam, Hicham Aboutaam, Jean-Baptiste Forestier, and Phoenix Ancient
Art...................................................................................................................................................................................................86
4. Jaume Bagot Peix and Oscar Carreras Palomar...............................................................................89
5. Michael H. Steinhardt................................................................................................................................................89
6. Erdal Dere, Faisal Khan, and Fortuna Fine Arts...................................................................................90
7. Mousa Khouli, Salem Alshdaifat, Joseph A. Lewis II, and Ayman Ramadan................92
8. Mohamad Alcharihi....................................................................................................................................................92
IV. Legal Frameworks for Prosecuting Antiquities Dealers as Accomplices to
International Crimes and Financiers of Terrorism............................................................................................95
1. International, regional, and national framework for cultural heritage protection
..........................................................................................................................................................................................................95
1.1. International Instruments............................................................................................................................95
1.2. Regional Instruments.....................................................................................................................................96
1.3. National Legislation.......................................................................................................................................96
2. Prosecuting illicit trade in looted antiquities as complicity in international crimes
and terrorism financing................................................................................................................................................97
2.1. Core international crimes........................................................................................................................97
2.2. Complicity in international crimes...................................................................................................98
2.3. Financing and material support to terrorism.........................................................................99
V. Conclusion...................................................................................................................................................................................101
Introduction
In July 2018, the visitors of the Metropolitan Museum of Art in New York
were awed by the exquisite gilded Egyptian coffin, the center piece of the
Ned- jemankh and His Gilded Coffin exhibition. Dating back to first and sec-
ond century B.C., the coffin was designed for Nedjemankh, a high priest
of the ram headed god Heryshef of Herakleopolis. The Metropolitan Muse-
um paid US $4 million (€ 3.5 million) for the unique, museum-grade artifact.
A few months later, however, the New York District Attorney’s Office executed
a search warrant at the Metropolitan Museum and seized the coffin. It turned
out that the 1.8 meter long coffin was looted from Egypt in 2011 during the Arab
Spring and smuggled through the United Arab Emirates, first to Germany and
then to France, before the Metropolitan Museum purchased it in July 2017.
The seizure and return of the coffin were the result of a transnational investi-
gation. Prominent antiquities expert and dealer Christophe Kunicki and his
associate, Richard Semper, were implicated in first trafficking and then sell-
ing the coffin to the Metropolitan Museum. In 2020, French police charged the
two men with participating in a criminal association, organized money laun-
dering, forgery, and organized gang fraud. The charges also indicate they were
involved in other transactions of looted antiquities smuggled from Syria, Ye-
men, Libya, and Egypt, worth tens of millions of dollars. Kunicki and Semper
were arrested and later released, while the investigation seemingly continues.
In the following months, German federal police arrested Kunicki and Sem-
per’s alleged German associates for their involvement in the trafficking, as they
had helped “launder” the coffin by creating falsified paperwork and documen-
tation. The Metropolitan Museum promised to increase diligence when pur-
chasing items for their collection. The gilded coffin was repatriated to Egypt.
After an investigation by the New York District Attorney’s Office revealed that
it was looted from Egypt in 2011 during the Arab Spring and smuggled to the
United States via an international network, the coffin was seized and repatriat-
ed to Egypt.
© Cyrus Vance Jr., Manhattan District Attorney’s Office (2019).
2
The French and German investigations are seemingly on- these items via transnational networks to galleries, mu-
going. To this day, there is little information as to how seums, and collectors in Europe and the United States.
an item of such size and value could have made its way
through multiple customs inspections without much
scrutiny, and why the transactions raised no red flags with
financial institutions. It is unclear whether any inquiry
These terrorist organizations
has been launched into the money’s final destination. In and armed groups then use
other words, there are currently no investigations into the proceeds—tens of millions
the profit that the “armed gangs” (as the media referred to of dollars, according to the
them) made from the original sale of the looted sarcopha-
gus, which crimes they financed with the money, and how most conservative estimates—to
each intermediary and dealer in the network contribut- further finance crimes against
ed to the crimes as part of the trafficking transaction. civilians and acts of terror.
These questions are not inconsequential. At the repa-
triation ceremony for the Egyptian coffin, New York While international and national laws and regula-
District Attorney Cyrus Roberts Vance Jr. stated that tions contain extensive prohibitions on illegal traf-
the coffin was “just one of hundreds of antiquities ficking of cultural objects, the perpetrators rarely face
stolen by the same multi-national trafficking ring.” real consequences. Law enforcement efforts often fo-
cus on seizure and restitution of the looted objects and
Recently, the same New York District Attorney’s office the dealers, even when caught red-handed, receive
entered a plea deal with billionaire Michael H. Stein- barely a slap on the wrist, facing mere fines for cus-
hardt, under which Steinhardt has surrendered 180 toms or tax violations or low-level criminal charges
stolen antiquities valued at $70 million and been barred for forging provenance and import documents.
for life from acquiring any other antiquities. The mul-
tinational investigation has determined that the items To dismantle these criminal networks and create ac-
“had been looted and smuggled from 11 countries” and countability for antiquities dealers who finance con-
“trafficked by 12 illicit networks”—yet, the plea agree- flict, war, and mass atrocities, The Docket carries out
ment means that Steinhardt will not face further in- investigations aimed at triggering criminal prosecutions
vestigation or prosecution, and it remains unclear against antiquities dealers in Europe and the United
whether any of the illicit networks discovered by the pros- States for complicity in international crimes and ter-
ecutors will be further investigated. For now, it seems rorism financing, where appropriate. We believe this
the trafficking networks will continue undisrupted. is the most effective way to stop the financing of atroc-
ities through the trade in illegal artifacts and to pro-
tect the cultural heritage of the affected communities.
The Docket’s investigation, de-
tailed in this report, points to
the existence of well orga-
nized international smuggling
networks involved in the sales
of looted antiquities from the
Middle East and North Africa
on European and U.S. markets.
Invaluable artifacts—statues, ornaments, jewelry, books,

The gilded coffin of Nedjemankh was
coins, pottery—have been looted from archeological sites
the headlining piece of the Metropol-
and museums. Terrorist organizations—including the Is-
itan Museum’s Nedjemankh and His
lamic State of Iraq and the Levant (ISIL), Jabhat al-Nusra,
Gilded Coffin exhibition in 2018.
Hayat Tahrir al Sham, al Qaeda in the Arabian Peninsula,
and Ansar al Sharia—and other armed groups have sold © AFP via Getty Images
3
“ISIS kidnapped me in 2014 – they found
out I used to work on archeological sites,
and they wanted me to serve as an ex-
pert and guide their excavations. Except
I was an engineer, and thus didn’t really
know where the treasures are. But I had
to pretend, to survive. They took me to site
in Syria, in Deir ez-Zor, for example, but
also to Iraq, to Mosul. They had intermedi-
aries in Turkey, who were connected, of-
ten through family members, to dealers in
Europe.”
~ A Syrian engineer, interviewed in Turkey

August 2021
4
Executive Summary
Conflict antiquities traded in Europe State and non-state armed

and the United States are fueling inter-
national crimes in the Middle East and groups in Syria, Iraq, Libya,
North Africa (MENA). State and non- and Yemen have institutional-
state armed groups in Syria, Iraq, Libya, ized looting of antiquities as a
and Yemen have institutionalized the
weapon of war and a major
looting of antiquities as a weapon of war
and a major source of financing. Loot- source of financing, which fuels
ing fuels ongoing conflicts and enables ongoing conflicts and enables
the commission of grave human rights the commission of grave human
violations and international crimes.
These crimes will continue unabated
rights violations and internation-
and remain profitable so long as there is al crimes.
largely unregulated international mar-
ket for illicit antiquities where the dealers, brokers, and intermediaries operate
with impunity.
The global traffic in looted cultural objects is at times dismissed as a vic-

timless crime since its harmful aspects are not as apparent as those of traf-
ficking in arms, drugs, or persons. Despite the seemingly benign na-
ture of antiquities, the illicit trafficking of looted antiquities is physically,
socially, and culturally destructive. Artifacts are pieces that are often, not only
invaluable forms of cultural heritage but also non-renewable resources that
can generate income for those who loot and traffic these items for generations.
While looting of antiquities is an ancient phenomenon, over the last decade it has
reached a scale not seen since World War II. This escalation is largely due to the
ongoing conflicts in the MENA region. Estimates as to the amount of income that it
generates for armed groups vary, but most researchers agree that looted antiquities
have become a multi-million dollar source of financing for state and non-state actors
alike. This funding enables them to continue to commit atrocities, by allowing them
to purchase weapons, recruit and compensate new members, and otherwise support
their operations in conflict areas and commission of terrorist attacks elsewhere.
Illegal looting continues at archaeological sites to

this day. A team of looters digs at a site in Syria in
2014.
© Clooney Foundation for Justice 5
Satellite images taken in March 2015 of the Temple
of Hatra in Iraq show extensive looting pits sur-
rounding the site.
© Google Earth. Captured by Clooney Foundation for Justice.
So far, policy and regulatory measures, as well as legal The scale of pillage in these conflicts is overwhelming,
proceedings focused on customs violations, tax eva- making it impossible to document every individual inci-
sion, or property crimes, have not deterred the illicit dent. However, The Docket has gathered detailed infor-
trade in looted antiquities. There is a growing consen- mation on more than 300 incidents of pillage in Syria,
sus that only criminal prosecutions of the market-end Iraq, Libya, and Yemen within the last decade. Almost
dealers—which would expose their connection to and two thirds of these incidents involve the pillage of cultur-
role in perpetuating war crimes, crimes against hu- al property. The primary actors who conduct or facilitate
manity, and financing of terrorism—will ultimately pillage are either insurgent groups (including designated
put an end to the illegal business, prevent further loot- terrorist organizations) or government armed forces or af-
ing and destruction of cultural heritage, and bring filiated groups (such as militias). Groups include, among
much-needed redress to the affected communities. others, ISIL, Jabhat al-Nusra/Hayat Tahrir al Sham, al
Qaeda in the Arabian Peninsula, and Ansar al Sharia.
Pillage and other war crimes by
Most incidents of pillage occurred in places containing
armed groups operating in the large amounts of cultural or religious artifacts, such as
MENA region museums, United Nations Educational, Scientific and
Cultural Organization (UNESCO) World Heritage sites,
In Syria, Iraq, Libya, and Yemen, the pillage of cultural ar- archeological sites, and archeological storage warehous-
tifacts is part of a larger pattern of conflict-related viola- es as well as at churches, mosques, shrines, and other im-
tions amounting to war crimes and crimes against human- portant religious sites.
ity, including unlawful killings, enforced disappearances,
torture, sexual violence, and the destruction of property. º In Syria, tens of thousands of items have been pil-
laged from archaeological sites and at least 40,635
items have been looted from museums. These items
Reports indicate that pillage was rampant in Mari,

Syria, an ancient Mesopotamian city on the right
bank of the Euphrates River, particularly when
ISIL assumed control over the territory around
June 2014. Looting pits visibly show up on satellite
images of Mari from this time, as seen above.
7
include mosaics, relief sculptures, ceramic, stone, º In Yemen, ongoing pillage has targeted major mu-
and alabaster sculptures, ceramic and bronze tab- seums and archeological sites, including an estimat-
lets, steles, jewelry, and coins. ed 12,000 items looted from the Dhamar Museum,
16,000 items from the Military Museum in Sana’a,
º In Iraq, ISIL extensively pillaged the city of Mosul in and 120,000 items from the national museum in Sa-
northern Iraq, including its universities, libraries, na’a.
and museums; the archeological sites of Nineveh and
Nimrud; and religious sites associated with Yazidi, Pillage and destruction of cultural property constitute
Christian, and Muslim communities. war crimes under international law and the domestic
laws of European States. In addition to being a crime on
º In Libya, the pillage of cultural property occurred its own, pillage is often part of a wider pattern of crimi-
predominantly in the eastern and northern regions, nality and a source of income that has enabled ISIL and
including the UNESCO sites of Cyrene and religious other armed groups to commit war crimes, genocide,
sites associated with Sufi communities in Tripoli. and crimes against humanity. These crimes have been
widely documented and are currently subject to prosecu-
tion in a number of domestic jurisdictions.
Patterns of trafficking
Looted antiquities from Syria, Iraq, Libya, and Yemen
arrive in European and U.S. markets via complex inter-
national networks that include smugglers, dealers, in-
termediaries, and brokers across the North Africa, the
Middle East, Gulf countries, Asia, and Eastern Europe.
Understanding these routes, as well as those through

which armed groups access the resulting funds, is crit-
ically important for establishing the complicity of mar-
ket-end art dealers in crimes committed by state and
non-state armed groups on the ground in the source
countries.
Specific routes vary depending on the country of origin

of the looted antiquities. In some cases, they have also
In December 2016, the United States Department of

Justice filed a forfeiture case for various items, including
the above gold ring with carved gemstone and the carved
Neo-Assyrian Stone. These specific items were linked to
ISIL operations after the United States raided the com-
pound of ISIL Commander Abu Sayaff in 2015, which led
U.S. forces to seize documents related to ISIL’s financing
operations. The seized documents indicate that ISIL bu-
reaucratized the looting and trafficking of antiquities in
the geographic areas they control in order to finance their
terror operations.
© Press Release, United States Files Complaint Seeking Forfeiture of Antiquities

Associated with the Islamic State of Iraq and the Levant (ISIL), U.S. Department
of Justice (Dec. 15, 2016).
8
Examples of the types of items
looted and smuggled out of
Syria, Iraq, Libya, and Yemen
As circulated in Red Lists of Cultural Objects at Risk by the International Coun-

cil of Museums.
© Red Lists of Cultural Objects at Risk for Syria, Iraq, Libya, and Yemen, International Council of Museums.
Syria
Iraq
Libya
Yemen
“For items appraised more than 100,000
dollars, a Turkish dealer would cross into
Syria to check the item. Third party would
be holding the case, so that the payment
can be released once the parties agreed.
Sometimes we were contacted by Europe-
ans directly—through an app which allows
you to have a foreign phone number. Eu-
ropeans have their preferences – mainly
looking for items from early Christianity,
but other items, as long as their authentic-
ity can be verified, are in demand.”
~ A Syrian digger and smuggler, interviewed

remotely in Turkey
August 2021
Freeports are tax-free warehouses created to tem-

porarily retain manufactured goods and have been
repeatedly implicated in storing looted antiquities.
© Fred Merz for The New York Times
© Arcis via Art News
11
at minimal expense until they are released to the market.
How are antiquities “laundered” and Freeports, including ones located in Europe and particu-
smuggled through various countries? larly in Switzerland, have been repeatedly implicated in
storing looted antiquities.
A number of methods are used by trafficking intermedi-
aries to avoid customs inspections and conceal the illicit Finally, over the last decade, the trade in illegal antiq-
nature of the artifacts, including: uities has also become prominent online, particularly
º false declaration of the value of a shipment (lower through online auctions and e-commerce websites, as
than market value); well as through social media platforms. Facebook con-
º false declaration of the country of origin of a ship- tains dozens of groups where the trade in questionable
ment (a transit rather than source country); antiquities seemingly occurs, and some of the admin-
º vague and misleading descriptions of a shipment’s istrators are individuals affiliated with designated ter-
contents; rorist groups. Other social platforms allegedly used to
º splitting a single large object into several smaller trade in illicit antiquities include Instagram, Skype, and
pieces for separate deliveries, allowing informal WhatsApp. Hundreds of items are also being sold at on-
entry and reassembly later after receipt; line auctions such as Ebay, Vcoins.com, Trocadero.com,
º addressing a shipment to a third party, falsely stated and others, where annual sales of antiquities far exceed
to be the addressee or purchaser, for subsequent those of offline auction houses.
transfer to the actual purchaser;
º failure to complete appropriate customs paperwork; Antiquities dealers as possible ac-
º concealing antiquities in shipments of similar, legit- complices to war crimes and finan-
imate commercial goods;
º and addressing shipments to several different ad- ciers of terrorism
dresses for receipt by a single purchaser.
The Docket’s research has established that the archeolog-
ical artifacts pillaged in Syria, Iraq, Libya, and Yemen are
trafficked to Europe and the United States via interna-
changed over time because countries change their laws tional networks that have been on the radar of law en-
or enforcement policies to make certain routes harder, forcement agencies for decades. Yet these dealers have
thus forcing the networks to look for alternatives. managed to avoid any significant consequences for their
criminal activity so far.
The two main routes for antiquities originating in Iraq
and Syria are Turkey and Lebanon. The Docket’s research The Docket’s work has focused on collecting information
has shown that both remain active to date. From Libya, that links prominent dealers operating in European and
looted antiquities are mainly smuggled through Egypt U.S. markets to antiquities pillaged in conflict areas in the
and Tunisia. From Yemen, the items are mainly smug- MENA region by designated terrorist and other armed
gled through the United Arab Emirates (UAE), Saudi Ara- groups. Much of this information cannot be shared pub-
bia, and Qatar. Other transit portals are East European
countries, such as Bulgaria and Romania, as well as Thai-
land, Jordan, Kuwait, Israel, and Singapore.
Transit countries are essential for the process of “laun-

dering” the antiquities (i.e., providing customs or export The Docket has sub-
documentation to legitimize their subsequent sale). The mitted initial evidence
UAE, and particularly Dubai, appear to be an import- packages to prosecution
ant transit point through which items originating in the and law enforcement
Middle East and North Africa arrive to Europe and where authorities.
laundering occurs.
© Clooney Foundation for Justice
Freeports—essentially, tax-free warehouses created to

temporarily retain manufactured goods—play an im-
portant role in the international trafficking of looted an-
tiquities. In freeports, antiquities originating from any
13 country can be held for an unlimited period of time and
A conceptual model of the an-
tiquities market.
© Matthew Sargent et al., Tracking and

Disrupting the Illicit Antiquities Trade with
Open Source Data (2020).
The ATHAR Project conducted an in-depth study of

the use of Facebook groups by antiquities dealers
for the sale of illicitly trafficked and often looted
antiquities.
© Amr Al-Azm & Katie A. Paul, Facebook’s Black Market in Antiquities,

Trafficking, Terrorism, and War, Antiquities Trafficking and Heritage
Anthropology Research Project (June 2019).
The World Atlas of Illicit Flows

has mapped the trafficking flows
out of Syria and into neighboring
countries, including Turkey.
© World Atlas of Illicit Flows, INTERPOL

(2018).
14
licly at present for legal reasons, but this report contains sively discussed at the international, European, and
an overview of the available evidence, which points to the national level for years. Multiple policy and regulatory
need and viability of prosecutions. While this report re- initiatives have been implemented, yet they have had lit-
fers to a few illustrative cases, in which specific individ- tle success in curbing either looting and destruction of
uals are named, it is limited to only the cases that have archeological sites or the international trade in conflict
been publicly reported on—in the media or official state- antiquities. This is largely due to insufficient regulatory
ments from law enforcement agencies. focus on the source countries as well as a lack of stan-
dardization of measures across transit and market coun-
The initial evidence packages have been shared with tries, which continue to be easily exploited by antiquities
prosecutors in several European countries and with U.S. trafficking networks.
law enforcement agencies – specifically, in jurisdictions
to which these individuals are connected through their While market demand drives and enables the entire
nationality, residency, or business transactions. Where trafficking chain, the market remains the least regulat-
possible, The Docket continues to gather relevant evi- ed part of that chain. Attempts to regulate it are often
dence to enable the prosecution of antiquities dealers for undermined by the strength of lobbying groups, and an
complicity in war crimes, financing terrorism, and relat- imbalance of power between market-end dealers and ul-
ed charges. timate receivers of the looted antiquities and the com-
munities from which they have been looted.
International enforcement efforts have focused almost

This report contains an overview exclusively, with a few notable exceptions, on the recov-
of the available evidence, which ery and return of stolen objects to the country of origin.
Seizures and civil forfeitures, however, appear to have no
points to the need and viability of deterrent effect on the dealers. Such penalties are large-
prosecutions. ly perceived as the cost of doing business and, at times,
even boost the dealers’ business, since restitutions are
seen by the market as proof that the dealer trades in au-
thentic (rather than fake) antiquities.
The initial evidence packages have been shared with
prosecutors in several European countries and with U.S.
While policy measures, regulation, and restitution are
law enforcement agencies – specifically, in jurisdictions
important, only criminal prosecution—particularly
to which these individuals are connected through their
prosecutions that result in significant financial losses
nationality, residency, or business transactions. Where
and custodial sentences—is likely to have the necessary
possible, The Docket continues to gather relevant evi-
deterrent effect to disrupt the illegal trade of antiquities,
dence to enable the prosecution of antiquities dealers for
prevent further looting, and stem the flow of funds into
complicity in war crimes, financing terrorism, and relat-
the hands of terrorist and other armed groups.
ed charges.
While the legal frameworks differ from jurisdiction to

jurisdiction, the criminal codes of most European coun-
tries as well as the criminal statutes of the United States
contain provisions that allow authorities to prosecute
the dealers as either accomplices to war crimes and other
international crimes or as financers of terrorist activity.
In general, to establish criminal liability in such cases, it
must be established that the antiquities were looted by a
group involved in criminal behavior and that the dealers
knowingly traded in such items, thus providing the funds
that allowed the armed groups to commit atrocities.
Need for criminal prosecutions

The problem of looting and illegal trade in antiquities
from MENA and other conflict regions has been exten-
15
Only criminal prosecution—particularly
prosecutions that result in significant fi-
nancial losses and custodial sentences—is
likely to have the necessary deterrent ef-
fect to disrupt the illegal trade of antiqui-
ties, prevent further looting, and stem the
flow of funds into the hands of terrorist
and other armed groups.
16
The Docket team on field research in Iraq and Syra.
© Clooney Foundation for Justice
18
“Before Daesh came to the area, we hid
the smaller items from the site storage in
our house. But then they found out, sur-
rounded the house, and broke in. The held
me at gunpoint and threatened to kill my
children unless I showed them where the
items were. I had to show them and they
took everything. They said those were idol-
ized and needed to be destroyed, but we
know that instead they sold them to get
more money to buy weapons. They had
smugglers working with them to move the
items across the border and sell to the
dealers”.
~ A curator of an archeological site near

Raqqa, Syria
November 2021
19
Recommendations
The Docket has approached the issue of illicit looting and trafficking of arche-
ological artifacts from the specific angle of conflict financing. Accordingly, the
recommendations contained in this report focus primarily on ensuring suc-
cessful prosecutions of actors involved in the illicit trade on serious criminal
charges, including complicity in international crimes and financing terror-
ism. Respectable international and national civil society organizations and ac-
ademic collectives working on the issues of cultural heritage protection have
previously issued detailed policy recommendations to enhance regulatory,
legislative, and industry-focused measures aimed at preservation, conserva-
tion, and protection of archeological sites and artifacts. The recommenda-
tions below should be considered alongside these valuable contributions from
cultural heritage experts, whose work is referenced throughout this report.
The Docket recommends conducting investigations and pursuing criminal prose-

cution on charges of complicity in war crimes, crimes against humanity, and geno-
cide as well as the financing of terrorism for those who engage in the illicit trade in
looted antiquities to stop the funding of conflict and terrorism throughout MENA.
To the UN Security Council, UNESCO, UNITAD,

and other international organizations
º Reflecting the international nature of these crimes and networks, in-

ternational organizations should collaborate and support information-
and resource-sharing among States to uncover and dismantle these il-
licit networks trafficking in looted antiquities.
º The United Nations Security Council should condemn the looting of

cultural heritage in MENA by armed groups and terrorist organizations
and continue to recognize that such looting fuels and exacerbates con-
flict. The Security Council should call on Member States to request and
provide cooperation in investigations, domestic prosecutions, and judi-
cial proceedings, particularly in accordance with domestic legal frame-
works implementing international crimes, money laundering, and ter-
rorism financing.
20
º United Nations Investigative Team to Promote Accountability for Crimes
Committed by Da’esh/ISIL (UNITAD) should support the investigation
and prosecution of those involved in networks that illicitly traffic looted
antiquities to ensure accountability for acts that may amount to atrocity
crimes committed by ISIL and to ensure that the interests of survivors
are placed at the center of such efforts.
º UNESCO should leverage its expertise on cultural heritage and applica-

ble legal protections to assist international organizations and domestic
authorities in uncovering and dismantling these illicit networks traf-
ficking in looted antiquities. UNESCO should endorse an independent
monitoring team to observe the trade of antiquities and encourage re-
sponsible collecting and trading. UNESCO should continue to explore
and support the development of international protocols and standards
to address emerging threats to cultural heritage.
º The International Criminal Court’s Office of the Prosecutor should ad-

dress alleged crimes against or affecting cultural heritage in all stages
of its work as summarized in its June 2021 Policy on Cultural Heritage.
º International organizations should support the establishment of per-

manent and interdisciplinary research groups to allow for strong, spe-
cific, and coherent academic research to further innovative thinking.
º The European Union should extend the scope of regulation on illegal im-
ports to easily portable and low-value items, which constitute the bulk
of the online trade of looted artifacts.
To INTERPOL, EUROPOL, and law

enforcement agencies
º Law enforcement agencies should allow for effective collaboration be-

tween agencies through the enactment of mutual legal assistance trea-
ties. Where mutual legal assistance treaties exist already, law enforce-
ment should provide efficient responses to foreign assistance requests
to ensure investigations proceed quickly and judiciously.
º Law enforcement agencies should develop and implement trainings be-

tween various agencies, particularly those with specialized war crimes
and cultural heritage units, to share best practices and processes for ini-
tiating and building strong investigation files for international crimes,
money laundering, and terrorism financing related to the illicit trade
in looted antiquities. Encourage collaboration in such trainings with
non-governmental organizations, private institutions, or other stake-
holders whose specialized knowledge could contribute.
º Law enforcement agencies should produce and publish regular and de-
tailed follow-up reporting on arrest and seizure operations to allow the
public access to reliable data.
º Law enforcement agencies should report data on cultural property sei-

21
zure operations to the World Customs Organization for inclusion in its
annual Illicit Trade Report.
To national authorities and governments
º States should actively support and cooperate with the International

Criminal Court in prosecuting international crimes against or affecting
cultural heritage.
º States should hold individuals and corporations accountable for their

involvement in war crimes, crimes against humanity, and genocide, in-
cluding when those crimes involve or affect cultural heritage.
º States should provide funding and resources to ensure law enforcement

authorities are able to properly investigate networks involved in the il-
licit trade of looted antiquities for complicity in international crimes,
money laundering, and terrorism financing.
º States should ensure that relevant departments (for example, the art
crime unit and the international crimes unit) are able to collaborate and
share information effectively and efficiently to properly investigate the
full scale of these crimes.
º States should open and support structural investigations of these net-

works participating in the illicit trade of looted antiquities to collect in-
formation and evidence even when the perpetrators are not yet known.
º Where necessary, States should enact domestic legislative changes to

ensure prosecution of perpetrators for international crimes (war crimes,
crimes against humanity, and genocide), money laundering, and terror-
ism financing.
º States should ensure victims’ voices are centered. They should enact and
effectuate any procedural safeguards, including facilitating non-gov-
ernmental organizations as civil parties and setting the conditions to
allow for universal jurisdiction cases.
º To protect the abuse of international and domestic financial systems

by these perpetrators, States should sanction targeted individuals and
entities involved in the illicit trade of looted antiquities and diligently
enforce any sanctions violations.
º States should recognize how the networks that illicitly traffic looted an-
tiquities use corporate entities, foreign companies, and offshore trusts
to facilitate their transactions and support law enforcement and judicial
authorities in holding such entities accountable for their role in these
crimes.
º States should implement non-self-executing international instruments

such as the 1972 Convention Concerning the Protection of the World
Cultural and Natural Heritage (the UNESCO Convention) and pursue
their rigorous enforcement.
22
To civil society actors
º Civil society actors should develop digital collaboration between aca-

demics and research institutions by funding a regularly maintained and
centralized system of information accessible to researchers across the
world, as well as law enforcement and local governments.
º Civil society actors should enhance transdisciplinary collaboration be-

tween funded academics and scholarly initiatives to monitor the illicit
market of looted artifacts and investigative initiatives able to liaise with
law enforcement agencies with reliable data and in-depth research.
º Civil society actors should develop synergies with responsible partners

belonging to the art industry.
º Civil society actors should focus on the multi-faceted impact of the illicit
trade of looted antiquities to ensure that damage is not only assessed
by the monetary value of the trade but also by the material and human
damage caused by the illicit trade of looted antiquities.
º Civil society actors should enhance collaboration between international

non-governmental organizations and local partners to provide human-
itarian support and reconstruction efforts of damaged or looted arche-
ological sites post-conflict.
º Civil society actors should participate in criminal and judicial processes

as civil parties and experts to seek redress for victims of pillage of antiq-
uities and other international crimes.
To the art and antiquities industry and relat-

ed private institutions
º As persons most likely to be in contact with looted antiquities, private

institutions should support law enforcement in investigating these
crimes and judicial authorities in prosecuting these crimes by reporting
suspicious antiquities or persons who may be involved in the illicit trade
of looted antiquities.
º Private institutions should support and develop self-regulated trade

through the enactment of ethical codes of best practice with effective
enforcement mechanisms for those involved in the trade of antiquities
to ensure that no illicitly looted antiquities enter the market.
º Private institutions should support the strengthening of due diligence

requirements and detailed provenance research to stop the circulation
of illicitly looted antiquities in the market.
º Private institutions should develop and implement trainings to ensure

all staff understands that trading in looted antiquities is a crime that
can finance conflict and terrorism. Trainings should also address the
23
importance of due diligence requirements and allow staff to identify
suspicious transactions or antiquities that were potentially looted and
illicitly trafficked.
º Private institutions and actors should raise awareness among the gen-
eral public and potential new antiquities collectors that the illicit trade
of looted antiquities is not a victimless crime and those who participate
in these networks are complicit in international crimes.
To online sale platforms and social networks
º Sales websites and online platforms should provide detailed and visible
information relating to the definition of an antiquity, clearly indicate
the provenance of the item, and inform about the risk of buying illegally
imported artifacts.
º Social media platforms such as Meta should provide training to civil so-
ciety and investigators to assist in identifying linkages between differ-
ent accounts.
º Social media platforms should accept and respond to preservation or-

ders from NGOs, if the request is targeted to particular accounts of in-
terest and with a defined purpose, and as long as the request falls within
the mandate of the NGO.
24
25
Methodology
This report is based on extensive research and documentation conducted by The

Docket initiative at the Clooney Foundation for Justice.
The Docket team consists of experienced investigators, international lawyers,

forensic archeologists, open-source intelligence (OSINT) analysts, and other ex-
perts. The project is supported pro bono by several international law firms, as well
as global companies specialized in financial and corporate investigations.
Primary Evidence
The Docket’s documentation included hundreds of interviews with witnesses,
informants, forensic archeologists and cultural heritage specialists, journalists,
law enforcement officials, policymakers, representatives of international organi-
zations, and others. Field work has been carried out in multiple locations in Leb-
anon, Turkey, Syria, and Iraq.
Open-Source Research...
...included gathering information on the trafficking chains and networks: inci-
dents of pillage as well as activities and profiles of terrorist and armed groups
operating in the source countries of Syria, Iraq, Libya, and Yemen; market-end
dealers; and transit countries and intermediaries. Part of this research focused
on online and social media platforms involved in the illegal trade in antiquities.
Legal Research...
...included the analysis of international and national legal frameworks related to
antiquities trafficking, war crimes and crimes against humanity, the offence of
financing of terrorism, and relevant modes of liability.
The Docket reviewed hundreds of academic and media articles and books, cover-
ing all aspects of the international trade in illicit antiquities, as well as numerous
videos, photographic materials, and satellite imagery of looted sites and specific
objects, which were then analyzed by the experts to identify the locations of the
looting sites or the origins and authenticity of the items.
26
I. Pillage by Armed Groups
During Conflicts in the
MENA Region
Over the last decade, all parties to armed conflicts in tative UNESCO6 sites, archeological sites, site muse-
the MENA region have been implicated in grave viola- ums,7 and archeological storage warehouses as well as
tions and human rights abuse, some of which amount to at churches, mosques, shrines, and other important re-
crimes against humanity or war crimes. Though numer- ligious sites. Generally, pillaging has been documented
ous war crimes and crimes against humanity by these more extensively in Syria and Iraq than in either Libya
parties have been documented over the years, this chap- or Yemen.8 The massive scale of destruction and pillag-
ter addresses specifically the war crime of pillage.1 ing of cultural property in the region has been well doc-
umented through satellite imagery analysis9 and digital
Under international law, the war crime of pillage consists mapping technology.10
of the appropriation of property by the perpetrator, with-
out the consent of the owner, and with the intent to de- The primary types of actors conducting or facilitating
prive the owner of their property, all in the context of an pillage are designated terrorist organizations,11 govern-
international armed conflict known to the perpetrator.2 ment forces and pro-government militias, and oppo-
Pillage is criminalized in the penal law of most European sition armed groups. Terrorist organizations linked to
jurisdictions and in the United States. pillage incidents include the group calling itself ISIL,12
Jabhat al-Nusra/Hayat Tahrir al-Sham,13 al Qaeda in the
Pillage,3 including pillage of cultural property, became Arabian Peninsula,14 Houthi militias,15 Ansar al Sharia,16
rampant in the context of recent armed conflicts in the Tariq Ibn Zayad Brigade,17 the Benghazi Revolutionary
MENA region, including Syria, Iraq, Libya, and Yemen.4 Shura Council,18 the Islamic Youth Shura Council,19 and
It often preceded or accompanied ruthless destruction of the Abu Abbas Brigade.20
cultural and archeological sites, extensively documented
by the U.N. bodies, international organizations, and ac-
ademics.
Using information from published materials, as well as

interviews with experts and eyewitnesses,
The Docket has obtained references to

and documentation of over 300 inci-
dents of pillage in Syria, Iraq, Libya, and
Yemen within the last decade. Almost The pillage of cultural property became rampant in
two thirds relate specifically to the pil- the context of recent armed conflicts in the MENA
lage of cultural property. region, including Syria, Iraq, Libya, and Yemen.
The pinned locations include some of the many
The majority of pillage incidents occurred in places con- locations from which armed groups and terrorist
taining large amounts of cultural or religious artifacts, organizations looted antiquities.
such as museums, UNESCO World Heritage5 and ten-
27
1. Syria Regular reports published between 2014 and 2018 by
Heritage for Peace (HFP23) and the American Society for
Oriental Research’s Cultural Heritage Initiatives (ASOR
In Syria, the pillage of cultural property occurred mainly
CHI)24 demonstrated the patterns of destruction and
between 2011 and 2018, with an apparent peak in 2014.
looting in Syria. These reports are further corroborated
The main cultural heritage sites targeted for looting in-
by large-scale satellite image analysis, which shows the
clude the UNESCO and tentative UNESCO sites of Pal-
dramatic increase in the frequency and intensity of loot-
myra, Dura Europos, Apamea, Mari, Bosra, and Ebla as
ing incidents since 2011 compared to pre-conflict data.25
well as museums, archeological sites, and religious sites.
Tens of thousands of items have been pillaged from ar-
The imagery shows that hectares of earth were removed
chaeological sites and, according to one report, at least
with large earthmoving equipment from ISIL controlled
40,635 items have been looted from museums.21 Pillaged
sites and driven off-site, likely to be sorted through later
cultural items include mosaics; relief sculptures; ceramic,
for artifacts.26 Looters consistently targeted sites of Ro-
stone, alabaster sculptures; ceramic and bronze tablets;
man and late Roman periods—including Apamea, Pal-
steles; jewelry; and metal coins.22 The main perpetrators
myra, and Dura Europos, where looters found mosaics,
of pillage in Syria included Syrian armed forces, pro-gov-
funerary statues, glass, and coins—and sites prominent
ernment militias, and terrorist organizations, including
during the Early and Middle Bronze Ages—including
ISIL and Jabhat al-Nusra/Hayat Tahrir al-Sham.
Ebla, Mari, and Tell Bi’a, where looters found cuneiform
tablets, cult statuary, bronze objects, and jewelry.27 These
During its field investigation to Syria in April 2022, The
types of artifacts seem to be of particular interest to Eu-
Docket team visited multiple looted archeological sites,
ropean and U.S. collectors.
museums, religious sites, and storage facilities previ-
ously used by foreign archeological missions. The team
interviewed witnesses who described the looting by ISIL
fighters, other armed groups, and local residents—all © Jesse Casana & Mitra Panahipour, Satellite-Based Monitoring of
taking advantage of the conflict situation to make a prof- Looting and Damage to Archaeological Sites in Syria, Journal of East-
it. The Docket also obtained documents issued by ISIL ern Mediterranean Archaeology & Heritage Studies (2014).
during its control of the territories in Syria, including

receipts for digging equipment and taxes paid to ISIL by
the “licensed” looters, as described further below.
Based on satellite imagery analysis of archaeological looting in Syria between 2011 and
2015, researcher Jesse Casana mapped and compared the frequency of pre-war and
post-war looting.
© Jesse Casana, Satellite Imagery-Based Analysis of Archaeological Looting in Syria, Near Eastern Archaeology (2015).
29
1.1 Palmyra analysis conducted by a team of archeologists and experts
Syrian opposition groups and local residents looted Pal- estimates that the mean value of the items excavated at
myra, a UNESCO World Heritage site, during the early Dura Europos is over US $18 million.39 Researchers not-
years of the conflict.28 Between 2012 and 2015, these looted that the pattern and systematic nature of this looting
ers removed at least 125 valuable artifacts, the majority indicates it may have been conducted “as a business.”40
of which were funerary statues from the tombs.29 The By mid-June 2013, the on site museum was damaged and
Palmyra Museum later recovered some of these items.30 “large-scale items” were taken from the site, leading ex-
The Syrian Directorate-General of Antiquities and Mu- perts to estimate that around 76 percent of the site had
seums (DGAM) reported 22 funerary busts pillaged from been looted.41
the tombs and other illicit excavations at the site in No-
vember 2014 when it was under the control of the Syrian Initially, illegal excavation and pillaging occurred while
Armed Forces. 31 the site was under Free Syrian Army control.42 Later,
around September 2014, ISIL later took control of Dura
ISIL extensively looted and performatively destroyed Pal- Europos and began “large scale systematic looting”; it
myra during its two occupations of the ancient city from reportedly “destroy[ed] the archeological record over an
May 2015 to March 2016 and again from December 2016 enormous area.”43 After a pause in activity around No-
to March 2017. The destruction and looting was covered vember 2014, illegal excavations began again around the
in the media worldwide and shown in ISIL-produced beginning of 2015.44 This time, , the area was under the
propaganda videos.32 ISIL systematically looted and control of Jabhat al-Nusra. The Docket obtained original
trafficked artifacts from the site and site museum,33 de- video footage of looting in progress in Dura Europos,
stroyed many of the site’s ancient monuments and tem- taken between 2013 and 2014 by a journalist known to
ples34 and used the site as a staging ground for some of The Docket and verified by a Syrian archeologist familiar
its worst atrocities.35 Satellite imagery reveals that ISIL with the site. The illegal excavation on the site appears
looted 19 tombs using explosives between June 2015 and systematic: in certain videos, the looters seem to be con-
March 2016, particularly in the Southeast and Southwest sulting a map of Dura Europos as well as a list of key
Necropolis where funerary statues were taken.36 locations at the site to be excavated. Other videos show
looters using metal detectors, dental tools, picks, and
The Docket has sourced information regarding artifacts, brushes to excavate. The videos also show freshly excavat-
including mosaics, stone statues, Christian and Jewish ed items, including books, pottery, and metal artifacts.
items, and coins, looted from Palmyra by ISIL during Syrian DGAM reported that around November 2016, ISIL
their occupation of the site. The Docket has also identi- militants again conducted large scale illegal excavation at
fied ISIL fighters who operated in or around Palmyra, the site, including granting excavation licenses and using
who witnessed and participated in the destruction or Iraqi vehicles to transport items from the site.45
pillage of cultural property in the area, and who were in-
volved in smuggling the artifacts to Turkey and offering Pillage was also rampant in nearby Mari, particularly
them for sale there. Some of them have since relocated to when ISIL had control over the territory starting around
Europe. June 2014.46 Low-level looting between August 2011 and
March 2014 resulted in 165 visible pits; once ISIL assumed
1.2 Dura Europos and Mari control of the area, however, satellite images reveal that
the looting intensified dramatically. Between March 2014
Satellite imagery and estimates by archeologists suggest and November 2014, approximately 1,286 pits were visi-
that around 9,500 looting pits have been dug in Dura ble on the images.47 From satellite image analysis, arche-
Europos, located on the western bank of the Euphrates ologists estimate that there are around 1,500 looting pits
River, over the last decade.37 The looting area covers ap- (many of them more than 5 meters deep and 6 meters
proximately 68 hectares.38 An empirical site level market wide). They also have evidence of vehicle tracks, likely
Satellite image comparison of looting activity at Tell Bi’a in northern Syria between
October 2011 and October 2014 showing the increase in looting during conflict.
© Satellite-based Damage Assessment to Cultural Heritage Sites in Syria, UNITAR & UNOSAT (2014).
32
Satellite imagery of Palmyra, indicating where damage
and looting occurred.
© Satellite-based Damage Assessment to Cultural Heritage Sites in Syria,

UNITAR & UNOSAT (2014).
Satellite imagery analysis between September 2011

and June 2014 showing extensive looting in Dura
Europos.
© Satellite-based Damage Assessment to Cultural Heritage Sites in

Syria, UNITAR & UNOSAT (2014).
33
35
Illegal looting continues at archaeological sites to this
day. A team of looters digs at a site in Syria in 2014.
© Clooney Foundation for Justice.
Satellite imagery analysis by Dr. Michael Danti

showing the progression of looting at Dura Euro-
pos over time, with a peak around 2014. During
this time, ISIL was in control of Dura Europos and
conducted large-scale systematic looting of the
site.
© Dr. Michael D. Danti, The Cultural Heritage Crises in Syria and

Northern Iraq: Recent Developments (2015).
36
The Docket obtained video footage of looting in progress
in Dura Europos between 2013 and 2014 that appears
systematic: in certain videos, the looters seem to be
consulting a map of Dura Europos as well as a list of key
locations at the site to be excavated. The looters use metal
detectors, dental tools, picks, and brushes to excavate the
site.
Satellite image analysis showing the progression of

looting at Mari between September 2012 and Janu-
ary 2017. Researchers estimate that when ISIL took
control of Mari between March 2014 and November
2014, satellite visible looting pits increased from
165 pits to 1,286 pits.
© Jesse Casana, Elise Jakoby Laugier & Peter F. Biehl, Satellite Imag-
ery-based Monitoring of Archaeological Site Damage in the Syrian
Civil War (Nov. 30, 2017).
37
38
left by vehicles carrying items away.48 The items looted National Army moved into the area58 and damaged the
at the site included cuneiform tablets, small figures, and Ain Dara temple in airstrikes.59 According to U.N. re-
bronze objects.49 ports, the Ain Dara temple was later looted by the Syrian
National Army for artifacts and mosaics and bulldozed
Based on satellite image analysis, the surface area af- between 2019 and 2020, based on satellite images. 60
fected by illegal excavation increased drastically again
between April 2015 and May 2017 when ISIL was in con- 1.4 Religious Sites
trol of the site.50 These images show that new looting pits
emerged and existing ones widened.51 Various religious sites have been looted since the begin-
ning of the conflict in 2011. In 2012, the Jobar Synagogue
1.3 Museums (also known as Eliyahu Hanavi Synagogue), one of the
holiest Jewish sites outside of Jerusalem,61 was report-
At least 40,635 items have been looted from Syria’s mu- edly looted by Syrian Armed Forces that entered Jobar
seums.52 17,000 cuneiform tablets were looted from the in 2012 and by opposition groups, including the Harun
Idlib Archeological Museum.53 Ma’arrat al-Numan Mu- Al-Rashid Brigade in 2013 when they took control of the
seum, located in northwestern Idlib Governorate and site.62 News sources state that the synagogue was looted
famous for its mosaics, was looted after the Free Syrian of its religious and cultural items, which were then sold
Army took control of the area around August 2011.54 in Turkey.63
In March 2022, The Docket visited the Raqqa Museum, In December 2013, Jabhat al-Nusra looted all items of
once one of the richest museums in Syria, from which value from the St. George Church in southern Syria, in-
more than 7,000 artifacts had been looted. The vast ma- cluding an icon of the saint, an ancient church bell, and
jority remain missing to date. The museum curator told marble slabs from the church’s floor and altar.64
The Docket that in 2012, museum staff moved some of
the most valuable artifacts to the Central Bank vaults Around February 2015, Jabhat al-Nusra and Syrian “in-
in Raqqa. Ahrar-Al-Sham looted those vaults when the surgents” entered Assyrian Christian churches located
armed group took control over Raqqa. The Free Syrian in Hasakah Governorate in northern Syria and loot-
Army took the remaining items. By the time ISIL got to ed Christian artifacts.65 Shortly after, ISIL destroyed 11
the museum, all movable items had already been looted; churches and villages in the area.66 Witnesses, who were
ISIL blackened faces on the remaining mosaics on the in the area during the destruction of the churches, told
walls. The Docket that ISIL first took down the crosses from the
churches and then stole icons and other valuables from
Museums located at archeological sites, including those the premises before blowing up the entire building.67
that house artifacts discovered at the site, have also been
systematically looted, as have their storehouses. Reports Syrian DGAM reported that in 2014, an “extremist group”
indicate that ISIL looted the Heraqla storehouse (a stor- that controlled the area around Deir Semaan (also known
age facility for the Raqqa Museum) in March 2013.55 Tell as Saint Simeon Monastery or the Church of Simon Styli-
Sabi Abyad storehouse, with artifacts from Tell Sabi Ab- te), was conducting illegal excavations in the area, and
yad archeological site near Raqqa, was looted between preventing anyone from approaching the area.68 Reports
2014 and 2015 at a time when ISIL controlled the area.56 from DGAM and the Association for the Protection of
Syrian Archaeology describe stone quarrying and looting
Original video footage filmed around 2014, and obtained at Deir Semaan and the surrounding churches by “Isla-
and verified by The Docket, shows the Ain Dara arche-
ological site storage and warehouse in northern Aleppo
Governorate, which was under the control of a Free Syr- At archeological site near Raqqa, the site curator
ian Army faction at the time. The footage shows items at and his wife told The Docket that they hid most of
the storage area of the site, including crates and show- the movable items from the site storage warehouse
cases featuring basalt fragments as well as pottery, glass, in their house in anticipation of ISIL advancing
and stone objects. The footage also shows a basalt face into the area. Unfortunately, ISIL stormed into
from the head of a statue, taken from the temple of Ishtar their house few months later and took all of the
at Ain Dara archeological site, which had been deposited hidden items, after holding the site curator at gun
at the site museum.57 The area was under the control of point and threatening to kill his children.
Kurdish People’s Protection Unit militias until January
2018, when Turkish troops and pro-Turkey Free Syrian © Clooney Foundation for Justice.
39
mist fighters.” 69
ISIL was responsible for most of the destruction and pil-
Around 2018, the Free Syrian Army pillaged the Shrine of lage in Iraq. Some reports also mentioning the involve-
Nebi Huri, a Sufi shrine featuring a Roman-period mau- ment of Shia militias. 76
soleum.70 This pillaging was confirmed by satellite im-
ages showing excavation pits.71 During a site visit in July During field investigation in Iraq in November 2021,
2018, the Idlib Antiquities Center determined that there The Docket team visited the sites looted and destroyed
was a large-scale illegal excavation of the sites between by ISIL—including Mosul museums, libraries, and reli-
2012 and 2018, while the area was under the control of gious sites in the Old City, Nimrud, and Hatra—and in-
the Kurdish People’s Protection Unit and Syrian oppo- terviewed multiple witnesses who provided information
sition forces backed by the Turkish army. Looters used about the looting and the efforts to recover stolen items
earthmoving equipment, metal detectors, and shovels after the liberation.
within the city walls, in the church and cemetery, and in
the shrine.72 The Syrian National Army likely conducted 2.1 Nineveh and Nimrud
another illegal excavation in the fall of 2018, based on
video and satellite imagery and corroboration by ground ISIL also targeted archaeological sites near Mosul, in-
sources.73 cluding Nineveh and Nimrud. Nineveh is located on the
outskirts of Mosul and was an ancient Assyrian city, fea-
More recently, in territories under the control of the Syr- turing royal palaces and large reliefs. In 2016, ISIL leveled
ian National Army, Yazidi shrines and graveyards were the monumental ancient city gates surrounding Nineveh
pillaged throughout the Afrin region in April 2020, in- and sources indicate that the group sold the stones of
cluding Qastel Jindo, Qibar, Jindayris, and Sharran. 74 the destroyed gates for profit.77 Nineveh also featured
the Sennacherib Palace Site Museum, which contained
2. Iraq around 100 carved reliefs. The Museum was disman-
tled and pillaged throughout 2016.78 Around 2017, ISIL
In Iraq, the pillage of cultural property occurred main- used bulldozers and large equipment to dig into the site
ly between 2014 and 2018, with a peak of activity around to construct a road and subsequently used vehicles to
2015 when ISIL extensively pillaged the city of Mosul in move antiquities along the new road and out of the ar-
northern Iraq. During this time, the group pillaged its ea.79 Satellite analyses confirm ISIL also dug an extensive
universities, libraries, museums, and the nearby archeo- network of tunnels under the site of Nineveh in order to
logical sites of Nineveh and Nimrud. Pillage also occurred access and excavate artifacts present at the site.80
at religious sites associated with Yazidi, Christian, and
Muslim communities, including the Nebi Yunus shrine, In 2015, ISIL destroyed the ancient site of Nimrud, which
churches, mosques, and cemeteries in Nineveh Gover- is located south of Mosul and was the capital of the Assyr-
norate in northern Iraq. Pillaged cultural items include ian Empire.81 The site featured many royal palaces with
terracotta and stone reliefs; clay and stone sculptures; extensive reliefs and large figurative sculptures. Reports
clay and stone tablets; manuscripts, books, and docu- indicate that ISIL pillaged the site prior to proceeding
ments of religious and scientific texts; stamp seals and with the performative destruction.82 In 2017, a cache of
signet rings, cylinders, jewelry, and coins.75 more than 100 Assyrian artifacts was found in the home
of an ISIL commander in a Mosul neighborhood, which
Video footage filmed around 2014 obtained and verified

by The Docket shows the Ain Dara archeological site stor-
age and warehouse in northern Aleppo Governorate. The
site storage and warehouse were later looted by various
armed groups and bulldozed in between 2019 and 2020,
based on satellite images.
42
Churches in the Hasakah area in Syria. Churches
and other religious sides were often targeted for
looting by armed groups and terrorist organiza-
tions before they were destroyed.
43
In an assessment conducted by Dr. Michael Danti
of ISIL’s attacks in Syria and Iraq, he found that
ISIL deliberately targeted religious sites and
monuments as part of their “cultural cleansing”
practices.
© Michael D. Danti, Ground-Based Observations of Cultural Heritage

Incidents in Syria and Iraq, Near Eastern Archaeology (2015).
Satellite image analysis as part of the American Society

of Oriental Research’s regular updates on the destruction
and looting of cultural heritage during in Iraq. The image
depicts the emergence of tunnels used for looting of
underground sites by ISIL between April 1, 2016 and July
17, 2016.
© Digital Globe. American Society of Oriental Research Cultural Heritage

Initiative – Weekly Report 101–102 (July 6–19, 2016).
46
47
experts believe were likely pillaged from Nineveh and Mosul, but that about 300 genuine items remained in the
Nimrud.83 museum.91 Iraqi archeologist Layla Salih, current head
of the Heritage Department at Nineveh Antiquities for
The Docket documented the devastating destruction of Iraq’s State Board of Antiquities and Heritage and a for-
Nimrud during a site visit in November 2021. Witnesses mer curator at the museum the decade before ISIL’s in-
interviewed at the site stated that they believed Nimrud vasion, documented the damage to the Museum imme-
had been subjected to looting prior to the destruction.84 diately after ISIL’s retreat. She noted that the museum’s
Hatra Gallery—previously filled with Greco Roman-in-
2.2 Hatra fluenced marble statues from Hatra—had been cleaned
out.92 The Docket team visited the museum—where
ISIL also looted and significantly damaged the ancient most of the items are still missing—and obtained a list of
city of Hatra, in the Nineveh Governorate. Witnesses 88 objects that are considered looted by ISIL.
on site told The Docket that ISIL used Hatra, a stunning
2.9-square km fortified city dating back 2000 years, The Docket also documented the looting of the ethno-
as a military base for three years. The Docket team ob- graphic museum and the Mar Touma Syriac-Catholic
served bullet holes on the ancient walls and on the few church in Mosul. The vast majority of items, including
remaining statues, which ISIL fighters used for shoot- ancient manuscripts and religious objects, had been tak-
ing practice, according to the witness. Sources told The en by ISIL during its occupation of the church.93
Docket that Hatra’s site storage warehouse, which had
previously contained statues and reliefs, was also looted. In 2017, while clearing houses in recaptured areas of Mo-
Nearby, ISIL began new excavations, although it is un- sul formerly held by ISIL, Iraqi Security Forces recovered
clear whether they discovered any artifacts during these caches of artifacts and books likely taken from the mu-
excavations.85 seum, university, and library of Mosul, including stones,
fossils, and books.94
2.3 Libraries and Museums of Mosul
2.4 Religious Sites
In 2014 and 2015, ISIL pillaged and vandalized the Mosul
Central Library and the Mosul University Library, before As part of its large-scale attacks against Yazidi com-
burning a large number of the libraries’ collections.86 munities, ISIL destroyed their religious sites and other
Local sources alleged that ISIL used Syrian-registered cultural property, as has been extensively documented
trucks to transport the pillaged rare books and ancient by human rights organization RASHID International.95
texts from the Mosul-area libraries to be sold.87 A pro- Based on ISIL’s pattern elsewhere of looting and sell-
fessor at Mosul University told the Associated Press that ing movable property and destroying the remainder, it
ISIL fighters removed the rare books in the middle of the is likely that cultural and religious items belonging to
night and had only burned the more “normal” books to Yazidi communities were pillaged as well. A report by the
“distract from the looting and selling of the rare man- U.N. Independent International Commission of Inquiry
uscripts on the black market.”88 Library workers inter- on the Syrian Arab Republic also discusses the pillage of
viewed by The Docket confirmed these accounts.89 private property as part of ISIL’s crimes against Yazidis.96
The Yazidi witnesses interviewed by The Docket team in
ISIL also pillaged and vandalized the Mosul Museum in Iraq provided accounts of the destruction and looting of
2015.90 Mosul Museum advisers stated that a majority of Yazidi shrines in Sinjar, as well as of massive other crimes
the artifacts housed at the museum were transferred to committed by ISIL against the Yazidi community.97
Baghdad for safekeeping months before ISIL’s arrival in
Satellite image comparison of the Palace of Sennacherib

between April and May 2016, during which time ISIL
systematically dismantled and destroyed the site. Reports
indicate that the site had previously containing around
100 carved reliefs, which were allegedly pillaged through-
out 2016.
48
Satellite images taken in March 2015 of the Temple
of Hatra show extensive looting pits surrounding
the site.
Satellite image analysis conducted by UNESCO and

UNITAR showing the extent of damage to the Palace of
Ashurnasirpal II within the Nimrud Citadel between
March and April 2015.
© Airbus Defense & Space Pléiades Imagery. Published in Satellite-Based

Damage Assessment of Cultural Heritage Sites: 2015 Summary Report of Iraq,
Nepal, Syria & Yemen, UNITAR & UNESCO (June 2016).
50
Bullet holes on apparent on the monument’s walls and
statutes at Hatra. Witnesses told The Docket that ISIL
used the site as shooting practices in addition to looting
the site warehouse and excavating nearby while ISIL used
the fortress as a military base for three years.
Photographs taken during The Docket’s field in-

vestigation in Iraq in November 2021, showing the
damage and looting in the Mosul Museum.
51
55
ISIL occupied, destroyed, and looted churches98 and ble sculptures; mosaics; column capitals and bases; glass
mosques throughout Nineveh Governorate. Between and semi-precious stone vessels; oil and mosque lamps;
2014 and 2017, ISIL pillaged the Nebi Yunus Shrine in jewelry; and coins.106
Mosul, including digging several tunnels underneath the
site to reach the Palace of Esarhaddon, where “artifacts, The main perpetrators of pillage in Libya include Ansar
such as pottery and smaller pieces” were looted, as inal Sharia, Tariq Ibn Zayad Brigade, the Benghazi Revolu-
dicated by the Director of Antiquities for Nineveh Gov- tionary Shura Council, the Islamic Youth Shura Council,
ernorate.99 A witness stated that ISIL collected “lots of and the Libyan National Army.
reliefs including two headless horses, some figures, and
inscriptions in Aramaic” for further sale.100 3.1 Cyrene
In 2014, ISIL temporarily held the village of Telskuf in the A UNESCO World Heritage site since 1982, Cyrene is lo-
Nineveh Governorate in northern Iraq. During this time, cated near present-day Shahhat on the coast of northern
ISIL militants occupied the Mar Kurkees Church (Church Libya and was an important ancient Greek and Roman
of St. George), a Catholic church in the village, for one city.107 French archeologist Morgan Belzic identified 105
week and pillaged all crosses from the church.101 Prior to funerary sculptures looted from Cyrene, particularly be-
2017, ISIL removed crosses from the dome of the Church tween 2015 and 2016, indicating that many of them end-
of Sham’oon al-Safa (Church of Simon Peter) and used ed up in the European market.108 The above-mentioned
the church as a storage site for items looted from homes armed groups controlled Cyrene between 2011 and 2017
around the city of Mosul.102 and likely took advantage of their strategic positions
to pillage and profit from the trafficking of looted an-
ISIL pillaged graves and cemeteries throughout northern tiquities.109 According to experts, 20 percent of Cyrene
Iraq. Between August 2014 and October 2016, ISIL was has been destroyed by bulldozers since 2013, including
pillaging the graves at Christian cemeteries in Bartella, in around 200 shrines, a sarcophagus, a burial cist (cof-
Nineveh Governorate—one of the oldest Christian villag- fin-like box), and a section of the Roman aqueduct dat-
es in the world.103 Around October 2016, ISIL pillaged al- ing to the 2nd century A.D.110 Similar to the performative
most 100 graves using explosive materials and bulldozers and intentional destruction by ISIL, it is possible that the
in Kirkuk Governorate.104 From around 2014 to 2015, ISIL sites were pillaged prior to their destruction.
used prisoners to destroy cemeteries in Mosul, including
four large Muslim cemeteries and three Christian cem- 3.2 Museums
eteries.105 While the reports focus on destruction, it is
likely that ISIL also used the opportunity to pillage the In the aftermath of the 2011 Revolution, a significant
cemeteries, similar to its pillaging of other archeological number of museums were pillaged, as most extensively
sites and museums prior to their destruction. documented in an ASOR report published in December
2020. The Museum of Susa located near the site of Apol-
3. Libya lonia was pillaged in May 2011: looted items included five
distinct red-on-black Attic jars dating to the Hellenistic
In Libya, the pillage of cultural property occurred main- period.111 The Misrata Museum was looted in October
ly between 2011 and 2015, predominantly in the eastern 2011, including the collections of Numidian and Carthag-
and northern regions of the country. The main cultural inian bronze and silver coins.112
heritage sites targeted for looting include the UNESCO
sites of Cyrene and religious sites associated with Sufi The Bani Walid Museum was used as a base by the Lib-
communities in Tripoli. Pillaged cultural items include yan Armed Forces in 2011 and was partly destroyed and
reliefs, steles, and plaques; rock art; limestone and mar- damaged.113 Before October 2011, 315 objects were stolen
© Robert Leutheuser/Beyond Borders Photography. Faris Mishko/

Used With Permission. Published in Destroying the Soul of the
Yazidis: Cultural Heritage Destruction During the Islamic State’s
Genocide Against the Yazidis, Rashid Int’l (Aug. 2, 2019).
56
Photographs documenting the destruction of the Shrine of Sheikh Abdul Qader and
the Shrine of Mahma Rashan. ISIL conducted large-scale attacks against the Yazidi
community, including destroying religious sites and other cultural heritage property.
© Robert Leutheuser/Beyond Borders Photography and Jérémy André/All Rights Reserved. Published in Destroy-
ing the Soul of the Yazidis: Cultural Heritage Destruction During the Islamic State’s Genocide Against the Yazidis,
Rashid Int’l (Aug. 2, 2019).
from the Bani Walid Museum, including a large collec- The National Commercial Bank in Benghazi was looted
tion of Roman period oil lamps. 114 Bani Walid’s director in May 2011.124 The looters specifically targeted the antiq-
of heritage sites, Sufian Adbeeb, stated that the museum uities held in the bank and took only the most valuable
was vandalized and looted when Misrata-based pro-gov- items,125 even ignoring the cash in the vault.126 An esti-
ernment militias invaded the city in October 2011.115 Ad- mated 9,800 objects, originating from diverse sites, “in-
ditionally, in 2016, three funerary urns, an amphora and cluding the Temple of Artemis in Cyrene and the Helle-
an additional 149 objects were stolen; the identity of the nistic Palace of the Columns in Ptolemais,” were stolen.127
perpetrators is unclear.116
4. Yemen
3.3 Religious Sites
In Yemen, pillaging of cultural property has occurred
Sufi shrines and mosques have been targeted for their since 2011 and continues to date. Tens of thousands of
“perceived deviance from Sunni orthodoxy” by Salafist items have been pillaged from major museums:128 There
militias.117 Since 2010, over 500 Sufi cultural sites across have also been reports of the targeting of religious sites.
Libya have been targeted and destroyed, some by al-Qae- 129
Pillaged cultural items include marble statues; bronze
da-affiliated terrorist groups.118 Some incidents were figures; funerary stelae; architectural reliefs; manu-
documented right after the revolution: the destruction scripts; jewelry; and coins.130 Conflict involving al Qae-
of the Shrine of Cheikh Ahmed al-Zarrouk in Mistrata,119 da in the Arabian Peninsula131 and Houthi militias132 has
the explosion of the Shrine of Cheikh Abdessalem Al-As- contributed substantially to the looting of antiquities.133
mar and the looting of the eponym library and university These groups appear to be copying ISIL’s practices of fi-
in Zliten in eastern Libya,120 and the destruction of the nancing their cause via the sale of looted antiquities. ISIL
Shrine of Al-Chaab Al-Dahmani near Tripoli.121 may also be directly benefitting from the looting.134 An-
sar al Sharia has also been linked to pillage incidents.135
In October 2014, armed groups pillaged tiles and marble
from Tripoli’s Karamanli Mosque,122 and unidentified 4.1 Museums
armed groups looted items from the historical madra-
sa Othman Pacha widely used by the Sufi community of Yemen’s museums were consistently and extensively tar-
Tripoli. 123 geted by armed groups, including Houthi militias oper-
ating during the ongoing armed conflict starting in 2011.
3.4 National Commercial Bank of Nonprofit organizations, researchers, and archeologists
Benghazi have documented the items pillaged from Yemen’s mu-
57
ISIL used this church in Mosul as headquarters. There are
reported incidents of ISIL pillaging churches, mosques,
and synagogues.
59
seums, including from museums in Aden, Taiz, Zinjibar, Reports of pillaging at religious sites, including a Hin-
Dhamar, Sana’a, Zabid, and the Military Museum in Sa- du temple and a Christian church, have been linked to
na’a.136 Experts released detailed records of 1,631 items Houthi militias and al-Qaeda. In July 2015, a group of
missing from the museums of Aden, Taiz, and Zinjibar.137 masked gunmen belonging to the Ansar al-Sharia group,
An official associated with the Yemeni antiquities author- stormed the Hindu Al Baynyan Temple in Aden, destroy-
ity estimates that 12,000 items have been looted from the ing the temple and its contents. The group also allowed
Dhamar Museum, 16,000 from the Military Museum in others to loot the temple.143 In the summer of 2015, var-
Sana’a, and 120,000 items from the national museum in ious armed groups, including Houthi militias, al-Qaeda
Sana’a.138 Eyewitness reports collected by Mwatana for fighters, and others, entered and destroyed the Saint Jo-
Human Rights—a leading Yemeni nonprofit organiza- seph Church in Aden, including pillaging movable items
tion—largely link looting to terrorist organizations and in the church like wooden items and icons. 144
armed resistance groups, particularly since 2015, when
fighting broke out between the Houthi militias and the 5. Looted atiquities as a source of
“Popular Resistance” supporting President Hadi.139
funding for terrorists and other
According to Mwatana’s witnesses, in 2015, Houthi fight- armed groups
ers broke into the Military Museum in Sana’a and stayed
for several months, during which time they looted the The looting and trafficking of antiquities have become a
contents of the museum.140 In 2015, fighters belonging significant source of funding for at least some of the key
to the Abu Abbas Brigade took “three medium-sized bags actors involved in conflicts in the MENA region. While
containing silver coins and antiquities, and three bags estimates of the true scale of the income generated by the
containing antique bronze items” from the National Mu- armed groups vary, most researchers agree that looted
seum of Archeology in al Oradi castle. 141 The Docket in- antiquities are a multi-million-dollar source of financing
terviewed a Yemeni activist who described the looting, for state and non-state actors, and one that has enabled
first by the Houthi militias and later by the fighters asso- them to commit further atrocities. Funds generated from
ciated with the Saudi Arabian coalition.142 the antiquities trade have been used by the armed groups
to purchase weapons, recruit and compensate members,
4.2 Religious Sites and otherwise support their operations in conflict areas
and in the commission of terrorist attacks abroad.145
Satellite image captured in September 2020 showing urban expansion around the
city of Shahhat, present-day Cyrene. Looting often accompanies urban expansion.
60
The Military Museum in Aden after being struck by at-
tacks.
© The Degradation of History: Violations Committed by the Warring Parties

against Yemen’s Cultural Property, Mwatana for Human Rights (Nov. 2018).
Terrorist organizations operating in the MENA region Like many other aspects of ISIL’s operations, the loot-
established financial and bureaucratic systems to prof- ing and trafficking of antiquities was well organized and
it from the looted antiquities originating from territory strictly controlled by the organization’s hierarchy.152
under their control. The Docket has gathered informa-
tion on the systems established by ISIL, Hayat Tahrir al The administration of all pillaged resources within ISIL
Sham, Jabhat al Nusra, and Hezbollah. was handled by the so-called the Diwan Al Rikaz (the
Department of Precious Resources that Come Out of
ISIL used a variety of revenue streams to sustain its the Ground). This entity had been in operation since
large-scale military operations and heavy administra- the announcement of the Caliphate on June 29, 2014.153
tion, including proceeds generated from the sales of oil It included an Antiquities Division in charge of issuing
extracted on ISIL-controlled territories and ransom pay- permits and levying taxes on looted antiquities in ISIL
ments.146 The trade in looted antiquities has been iden- controlled areas. 154 “Al Rikaz” refers to anything that can
tified as the third-largest revenue stream for the terror- be extracted from the ground, which includes—accord-
ist group147, although it is difficult to quantify precisely.
Some estimates suggest that in 2014 alone, ISIL raised
US $1 billion, 148 with an estimated profit of US $200 mil- ISIL’s revenue stream from the looting and traffick-
lion from looting of cultural artifacts alone,149 though ing of antiquities was well organized and strictly
some researchers have contested these findings. Other controlled by the organization’s hierarchy. The Di-
estimates vary and suggest that antiquities trafficking wan Al Rikaz (the Department of Precious Resources
generated between US $6 and US $8 million,150 and that it that Come Out of the Ground) included an Antiq-
represented “up to 15 to 20% of [ISIL]’s resources,” mak- uities Division in charge of issuing permits and
ing it the second biggest source of financing after oil re- levying taxes on looted antiquities in ISIL controlled
sources.151 What is certain, however, is that looted antiq- areas.
uities continued to generate income for the organization
© U.S. Department of State: Documenting ISIL Antiquities Trafficking,
long after it lost territorial control in Syria and Iraq and Remarks by Andrew Keller, Deputy Assistant Secretary for Counter
likely continue to do so to date. Threat Finance and Sanctions with the Bureau of Economic and Busi-
ness Affairs at the U.S. Department of State (Sep. 29, 2015).
61
62
ing to ISIL—classified antiquities, as well as oil and min- former employee of the Syrian Department of Antiqui-
erals. 155 The Antiquities Division was comprised of five ties, who stated that ISIL kidnapped him and used him
offices, namely: Marketing (al-Taswiq), Excavation (al- around 2014 to identify various archeological sites in Syr-
Istekhraj), Exploration and Identification of New Sites ia and Iraq where valuable items were likely to be found.
(al-Istekshaf wal Tahdid), Research and Investigation of 162
Other Docket sources stated that ISIL was estimated
Known Sites (al-Bahth wal Taftish) and Administration to have controlled and exploited approximately 4,500 to
(al-Idara). 156 5,000 ancient archaeological sites across Syria and Iraq
in 2015. ISIL would then issue licenses to looters who
In the fall of 2014, the Diwan al-Rikaz established the were willing to extract the items from the ground.163 The
Manbij Archaeological Administration (MAA) in Syria on group profited from the sale of licenses, even if nothing
the border with Turkey in order to better manage and co- was found at the site.
ordinate the export of items out of Syria via its transit
points. 157 If an item was found, ISIL levied a 20 percent “khums” tax
against the estimated value of the found artifact, which
The Diwan al-Rikaz centralized the process of the illicit was collected by Diwan al-Rikaz administrators locally.164
looting and trade in antiquities, and all those participat-
ing in the process were under ISIL’s control. As is the case Witnesses in northern Al-Hasakah Governorate de-
for other income sources exploited by ISIL, revenue from scribed to The Docket the looting of archeological sites in
the antiquities trade extended beyond immediate profit the area, including Tell Brak. They stated that the digging
from sales of the given item and exploited different as- was initially done largely by local residents, whom ISIL
pects of the trade via fees and taxes at each stage of the had “licensed” by ISIL to dig. However, around 2014 and
procurement, logistics, and end-sale processes.158 2015, ISIL brought in professional equipment, includ-
ing hydraulic pumps, and employed dozens of people to
The Diwan al-Rikaz issued permits for the excavation of participate in the digging. They also forced experts, in-
historical sites and collected a tax from diggers and deal- cluding site curators and those who previously worked
ers on the sale of the artifacts.159 The permit essentially al- with foreign archeological missions, to help identify ar-
lowed the bearer to loot antiquities from ISIL-controlled cheological sites and evaluate the items once they were
territories and sell them to local or international dealers excavated.
under a strict framework. Later, ISIL’s approach to gen-
erating income from looted antiquities evolved from the At an archeological site near Raqqa, the site curator and
permit and licensing system to an excavation system in his wife told The Docket that they hid most of the mov-
which ISIL organized and undertook their own excava- able items from the site storage warehouse in their house
tions and conducted their own trade deals.160 in anticipation of ISIL advancing into the area. Unfortu-
nately, ISIL stormed into their house a few months later,
As part of its field investigation to Syria in April 2022, held the curator at gunpoint, threatened to kill their chil-
The Docket obtained documents issued by ISIL during dren, and took all of the hidden items.
its control of the territories in Syria, including receipt
for digging equipment and taxes paid to ISIL by the “li- The Diwan al-Rikaz was led by ISIL leader Abu Sayyaf,
censed” looters. the head of Oil and Gas Division in al Hasakah Gover-
norate and leader of the Antiquities Division of Al Sham
Under the authority of the Diwan al-Rikaz, exploration Wilayat [al-Barakah and al-Khayr].165 Abu Sayyaf was
teams travelled around the country to identify the ar- killed in May 2015 during a coalition forces raid on his
chaeological and cultural sites likely to contain historical residence.166 Documents seized during the raid includ-
items, indicating a systematic effort and intent to loot ed receipts for US $265,000 in khums tax, which would
and smuggle antiquities.161 The Docket interviewed a represent approximately US $1.25 million worth of loot-
Further receipts and memoranda regarding ISIL man-

aging the looted antiquities trade within the areas they
controlled.
© Aymenn Jawad Al-Tamimi, Unseen Documents from the Islamic State’s

Diwan al-Rikaz, Middle East Forum (Oct. 12, 2015).
63
64
65
ed antiquities over this six month period.167 Electronic position of “Emir of Archeology” to “handle archeologi-
evidence seized in the Abu Sayyaf raid provided further cal matters.” He refused and fled the area. He stated that
evidence of the sophisticated bureaucratic systems that dealers came from Turkey. Some of them had maps of
regulated the process of looting and trading in antiqui- Ottoman sites in the area and would ask ISIL to excavate
ties in ISIL-controlled territory. The electronic cache also at those sites. The dealers would then purchase from ISIL
contained a broad range of items, including an “assort- any items discovered there. The archeologist confirmed
ment of archaeological artifacts and fragments, histor- that every piece had to be reported to ISIL first before it
ical objects, modern/contemporary items, and replica or was appraised by experts. It was then either sold by ISIL
faked antiquities.”168 Among the items identified were directly or by the locals themselves if the item was of less-
gold jewelry, gold coins, and a neo-Assyrian stone stela.169 er value.
The Docket obtained information directly from wit- While ISIL’s bureaucratic control over antiquities traf-
nesses, including former ISIL operatives, that confirms ficking was “more systematic and organized,”170 other
the above-described mechanisms through which ISIL armed groups have benefited from antiquities looting
engaged in the looting and sales of antiquities. Several and traffic, although their involvement is much less doc-
sources mentioned to The Docket that ISIL actively used umented.
antiquities experts from North Africa and Jordan to assist
in locating and evaluating the items and recruited fight- Hezbollah was likely involved in antiquities trafficking
ers from Europe to facilitate contacts with Europe-based through Lebanon. The group mobilized their existing
antiquities dealers. network for transporting (including drugs and guns)
mobilized for the trafficking of looted antiquities. 171
One witness described to The Docket how he used to buy Hezbollah was already previously involved in the looting
items from ISIL to preserve them. He could only afford of the Baghdad Museum in Iraq in 2003 and levied taxes
the relatively cheap ones; more expensive ones, he said, on this trade.172 More recently, it appears that Hezbollah
cost between US $8,000 and US $90,000. The witness helped the regime transport the looted material into Leb-
stated that Diwan al-Rikaz held antiquities sales in differ- anon.173 The Docket’s sources in Lebanon confirmed that
ent locations in Raqqa: there were usually many antiqui- Hezbollah played a part in controlling and organizing
ties on display, including items recently dug with visible trafficking across both the border areas under its control
dirt still attached and items taken from museums, some and the smuggling of antiquities out of Lebanon by air.
with museum marking. He stated that many of the buy-
ers appeared to be foreigners based on their accents and In Idlib Governorate, all major Islamist armed groups
looks. Having had regular contact with ISIL over several have been involved in the excavation and traffic of cultur-
years, the witness observed that some of the ISIL fighters al artifacts in their respective areas of control. While they
were recruited from foreign countries with the specific may not have carried out the same “iconoclastic cam-
aim of facilitating ISIL’s antiquities trade abroad. These paign” as ISIL, Jabhat al Nusra and Hayat Tahrir al-Sham
fighters had contacts in European countries and helped have been involved in the destructions of museums, ar-
ISIL identify buyers for the most valuable items. cheological sites, mausoleums, and churches.174
A Syrian archeologist from the city of Membij told Hayat Tahrir al-Sham (HTS) was heavily involved in the
The Docket that when ISIL took over the city, an ISIL looting of Syrian cultural assets in northwest Syria.175
high-level commander came to him and offered him the HTS Security Branch monitors excavation and archeo-
The Diwan Al Rikaz (the Department of Precious Resources that Come Out of the Ground)
included an Antiquities Division in charge of issuing permits and levying taxes on loot-
ed antiquities in ISIL controlled areas. This memorandum bans unauthorized looting in
ISIL-controlled areas.
© U.S. Department of State: Documenting ISIL Antiquities Trafficking, Remarks by Andrew Keller, Deputy Assistant Secre-
tary for Counter Threat Finance and Sanctions with the Bureau of Economic and Business Affairs at the U.S. Department of
State (Sep. 29, 2015).
66
Memorandum identifying the ISIL Antiquities Division leadership as Abu Sayyaf.
© U.S. Department of State: Documenting ISIL Antiquities Trafficking, Remarks by Andrew Keller, Deputy Assistant Secre-
tary for Counter Threat Finance and Sanctions with the Bureau of Economic and Business Affairs at the U.S. Department of
State (Sep. 29, 2015).
logical sites, while the Office of Economics manages the The ideology of HTS members affected the conduct of
antiquities trade.176 A source with first-hand knowledge trade. For instance, gold or silver statues were to be “sold
of HTS operations told The Docket that since 2015, sev- according to their intrinsic metallic value, or alterna-
eral specialized HTS structures oversaw the looting and tively disfigured before the sale.”182 On the other hand,
trafficking of antiquities, including the Ministry of Exca- stone idols were to remain whole “since disfiguring them
vation (Hayat al hiraj) and the Ministry of Buried Items would completely nullify their market value.” 183
(Hayat al dafain).177 HTS also had an Office of Antiquities
Restoration (Markaz Tarmeem al-Athar) established in Historian Olivier Moos notes that armed groups that
2018, based in Al Dana, and charged with the “bureau- pledged allegiance to HTS leader Abu Mohammad
cratic side of the trade.” 178 al-Jolani were exempted from the tax.184 They included
two Islamist groups, Jaysh al Islam and Failaq al-Rah-
HTS imposed the zakat al-rikaz (a tax of 20 percent) on man, initially based in the Eastern Ghouta before mov-
the sales value of any items excavated. All sales had to be ing to northwest Syria in March 2018.185 They reportedly
registered with and taxed by the HTS Office of Econom- brought with them illegally excavated ancient books and
ics.179 Telegram conversations reveal that HTS observers parchments, which they sold in Idlib.186
were monitoring chatrooms to “ensure that sales were
recorded and taxed . . . .”180 Where HTS officially hired A witness indicated to The Docket that, as of August 2021,
a digging team or applied for a permit to excavate, one- the digging for artifacts continued actively in areas un-
third of the profits would go to the excavation team and der HTS control, including with extensive use of metal
the remaining two-thirds to HTS. 181 detectors.187 The source also provided The Docket with
information concerning the trafficking routes used by
67
the HTS and their means of communication, which the
Docket shared with relevant law enforcement agencies. Additionally, the Antiquities Trafficking and Heritage
Anthropology Research (ATHAR) Project identified mem-
Jabhat al-Nusra (JAN) adopted a pragmatic approach to bers of elite military units of Gaddafi loyalists and likely
dealing with cultural assets.188 JAN imposed a religious members of the Libyan National Army posting sales in-
tax on the price of archeological items discovered on quiries for Libyan items on social media platforms like
their territory. 189 A similar distribution of income as HTS Facebook.200 Among the anti-ISIL armed groups, Misu-
has been applied by JAN. 190 ratan soldiers in Sirte were accused of looting and seiz-
ing property.201
To a lesser extent, government forces, pro-government
militias, and opposition forces were also involved in the
looting of antiquities.
Early in the Syrian conflict, the Free Syrian Army dug

and sold artifacts in order to purchase weapons.191 In
particular, they oversaw the excavation of Roman tombs
near Damascus in Syria and trained “excavation teams”
to search for “gold, mosaics, statues and other transport-
able artifacts that can be sold easily.”192 However, they did
not appear to have a well-organized or structured system
for generating profit from looted artifacts and were in-
volved in looting at a much lesser scale than ISIL or other
Islamist groups. 193 The Kurdish armed groups have also
likely made profits in areas under their control.194
Although media reports and interviews conducted by The

Docket do not demonstrate direct organization of the ex-
cavations or the trade of antiquities by the Syrian army,
sources interviewed in 2016 confirmed the involvement
of the Syrian Armed Forces in the illicit traffic through
the transportation of looted artifacts or bribes to facili-
tate illegal excavations.195 Studies have revealed a spike
in looting in both Apamea and Ebla when the sites were
controlled by the Syrian Armed Forces.196 In Apamea, the
Syrian Armed Forces systematically looted the site using
heavy machinery and large teams of excavators.197
In Libya, while direct reports of looting attributed to spe-

cific armed groups or terrorist organizations are scarce,
there is information detailing the geographic control
certain armed groups and terrorist organizations had
over areas of Libya that suffered extreme looting. ISIL
has dominated the eastern region of Libya since 2014,198
which includes Cyrene and Tripoli, locations that suf-
fered widespread looting and from which the highly
unique and recognizable Cyrenaican antiquities stem.
Between 2013 and 2015, Cyrene and its surrounding
area were dominated and controlled by al-Qaeda-linked
Ansar al Sharia, the Islamist militias Benghazi Revolu-
tionary Shura Council and Mujahidin Shura Council of
Derna, the Libyan National Army as well as ISIL and the
ISIL-linked Islamic Youth Shura Council, either directly
or through its relationships with local groups and mili-
tias.199
68
Based on analysis conducted by Dr. Michael Danti and
others, virtually all armed groups part of the Syrian con-
flict took part in the looting of cultural heritage.
© Dr Michael D. Danti, The Cultural Heritage Crises in Syria and Northern

Iraq: Recent Developments (2015).
69
Satellite images taken at Tell Jifar in Syria in April
2012 show the presence of Syrian military forces at
the site.
© Google Earth and Digital Globe 2015. Published in Jesse Casana,

Satellite Imagery-Based Analysis of Archaeological Looting in Syria,
Near Eastern Archaeology (2015).
70
II. Patterns of Smuggling
and Trafficking
The trade-in looted antiquities has been characterized by A number of methods are used to avoid customs inspec-
researchers, policymakers, and law enforcement officials tions and conceal the illicit nature of the artifacts, includ-
as an “organized transnational business that is helping ing false declarations of the value of a shipment (lower
fund terror”202 and a “transnational criminal network.”203 than market value); false declarations of the country of
Understanding the complex routes through which looted origin of a shipment (a transit rather than source coun-
antiquities enter European markets, and those through try); vague and misleading descriptions of a shipment’s
which the profits reach armed groups, is critically im- contents; splitting a single large object into several small-
portant for establishing the complicity of the market-end er pieces for separate deliveries, allowing informal entry
dealers in the crimes committed on the ground in the and later reassembly after receipt; addressing a ship-
Middle East and North Africa. ment to a third party, falsely stated to be the addressee or
purchaser, for subsequent transfer to the actual purchas-
Looted antiquities from Syria, Iraq, Libya, and Yemen er; failure to complete appropriate customs paperwork;
arrive at the European markets and the United States via concealing antiquities in shipments of similar, legitimate
complex international networks that include smugglers, commercial goods; and addressing shipments to several
dealers, intermediaries, and brokers across North Africa, different addresses for receipt by a single purchaser.209
the Middle East, Gulf countries, Asia, and Eastern Eu-
rope. 204 1. Routes from Iraq and Syria
Specific routes depend on the country of origin of the The two main routes for antiquities originating in Iraq
looted antiquities. In some cases, they also change over and Syria are Turkey and Lebanon. Their prominence
time due to changes in laws or enforcement policies, has fluctuated over time, depending on which groups
which make certain routes harder to access and forced controlled relevant parts of the border, and to what ex-
the networks to look for alternatives. All means of trans- tent law enforcement and border patrols were active in
port are utilized, including automobiles, buses, cargo attempting to prevent the smuggling. However, as The
trucks, mail and courier services, personal luggage, air Docket’s research has shown, both Turkey and Lebanon
and sea freight. Items are transported both as part of a remain active routes to date.
broader smuggling attempt alongside other commodi-
ties,205 and as a more specialized trade.206 1.1 Via Turkey
An important link in this supply chain are the transit As described above, within ISIL’s administration, the Di-
countries. These countries are essential in the process of wan al-Rikaz oversaw the looting and trading in antiq-
“laundering” the antiquities: they provide customs or ex- uities. The Manbij Archaeological Administration (MAA)
port documentation “which seemingly legitimizes their coordinated the export.. The MAA organized the traffic of
trade and subsequent sale on the destination market.”207 items out of the country via its transit points, such as the
These transit portals are situated in jurisdictions outside one at Tal Abyad (en route to Turkey) or Jabal Qalamun
the source markets, and often in freeports, such as Dubai (en route to Lebanon) or through a network of approved
or Hong Kong.208 intermediaries in Damascus, Amman, and Beirut.210
71
© Matthew Sargent et al., Tracking and Disrupting the Illicit Antiquities Trade
with Open Source Data (2020).
72
Items were smuggled out of Iraq, Syria, and Turkey over- facts.216
land. Smaller items likely hidden in vehicles or transport
trucks mixed with other goods such as bags of flour.211 A witness interviewed by The Docket in Syria, a dealer
Stolen antiquities were also carried out of Syria and Iraq and a smuggler himself, said he took to Turkey the items
by refugees. 212 that he excavated himself as well as the ones he bought,
through the same intermediary, from both the Free Syr-
In Turkey, one of the main smuggling hubs is the district ian Army and ISIL. The individual said he met with deal-
of Akçakale, on the Turkish-Syrian border and direct- ers in several locations in Urfa, who were both Turkish
ly north of Raqqa.213 Another entry point is the Turkish and Europeans, coming mainly from Switzerland and
border town, Kilis, which is located directly north of Italy. According to the witness, floor mosaics were in
Aleppo214. From Akçakale and Kilis, stolen antiquities are particular high demand, and experienced smugglers like
transported to Izmir, Mersin, and Antalya, where orga- himself would first clean them, apply an adhesive layer
nized crime groups then produce falsified documents and linen cloth, before rolling them for transportation.
on the origin of the antiquities.215 The smuggling routes Equally in high demand were cuneiform tablets and cyl-
through Turkey are key as Turkish border towns host inder seals.
many artisan markets where stolen antiquities can be
easily bought and sold with little or no documentation. In addition, public sources indicate that the town of An-
takya was a transit platform for artifacts coming most-
As part of a 2018 study of illegal trade in Syrian cultural ly from Apamea, an archaeological site in Syria’s Hama
objects, a Syrian individual with first-hand knowledge province.217
of the smuggling operations indicated that most of the
antiquities looted by ISIL were “transported out through Another center of antiquities smuggling is Gaziantep in
Turkey, sometimes in fuel trucks,” a transportation facil- southern Turkey, where illegal auctions took place and
itated by bribing border guards and paying off criminal antiquities were sold to dealers who then moved the
gangs operating on the Turkish side of the border and, goods through a trusted network of local antique shops
at times, with the assistance of Syrian army officers who located at the Bakırcılar Çarşısi market on Eski Saray
would facilitate the trade and transportation of arti- Street in the Şekeroğlu District for the sale of looted an-
© Matthew Sargent et al., Tracking and Disrupting the Illicit Antiquities Trade
with Open Source Data (2020)
73
© World Atlas of Illicit Flows, IN-
TERPOL (2018).
© World Atlas of Illicit Flows, IN-

TERPOL (2018).
74
© Matthew Sargent et al., Tracking and Disrupt-
ing the Illicit Antiquities Trade with Open Source
Data (2020).
tiquities.218 Sources indicate other cities receiving looted Qusayr and to the south of Baalbek, in the Tfail salient.222
jewelry and coins included Urfa, Mersin, Kilis, Reyhanli,
and Adana. Journalists, researchers, and sources interviewed by The
Docket in Lebanon also indicated that the smuggling of
In addition to ISIL, other armed groups used Turkey as a antiquities may be facilitated by Hezbollah and the Leb-
smuggling route, including the Kurds, who deal through anese military, who provide “cover” for smugglers to op-
intermediaries in southern Turkey.219 Before the regime erate. 223 Military officials responsible for the border ar-
took control by mid February 2012, Turkey was also used eas are allegedly paid to look the other way. The Docket’s
as a smuggling platform for Free Syrian Army fighters for sources indicated it was not uncommon for military offi-
the looted antiquities, as admitted by former Free Syrian cials posted to the border area to be visited by Hezbollah
Army leader Abu Abd al Tadmuri.220 prior to their posting, to ensure they understand their
role in providing cover. Since the blast that destroyed
According to The Docket’s sources, Turkey-based crimi- Beirut port in August 2020, the airport has been the main
nal networks have been involved in producing false doc- exit point for all goods, including antiquities. Hezbol-
umentation about the origin of the antiquities to facili- lah has long had control of smuggling routes across the
tate their transfer into international markets. Turkey has border between Lebanon and Syria, as well as a “control
regularly run operations to seize looted Syrian items—in structure” within Lebanon’s Rafik Hariri International
2016, for example, around 50,000 objects of Syrian origin Airport,224 and The Docket’s sources indicate that “for
were seized—but countless other items made it to the in- the right price” anything—including large antiquities—
ternational markets.221 can be moved out of Beirut airport and directly into Eu-
rope.225
The Docket collected and handed over to relevant law en-
forcement agencies detailed information regarding ISIL Multiple seizures of smuggled antiquities have been re-
operatives who moved from Syria into Turkey to contin- ported in Lebanon over the years, including objects orig-
ue smuggling operations and offered items looted in Pal- inating from Apamea and Palmyra and zones controlled
myra for sale there. The Docket also obtained and hand- by Islamist groups,226 which highlight the massive scale
ed over to law enforcement agencies evidence of specific of the trafficking from Syria to Lebanon.227
items looted from the Palmyra area which were offered
for sale around December 2015 in Reyhanli, Turkey. The Docket has collected and handed over to relevant law
enforcement agencies detailed information concern-
1.2 Via Lebanon ing several families that control antiquities trafficking
in Lebanon.228 One of such families, based in Baalbek,
In Lebanon, as confirmed by The Docket’s investigation is closely connected to several smugglers who maintain
on the ground, the smuggling is carried out mainly in contacts on the Syrian side of the border. For small arti-
the regions along the Lebanon-Syria border in the east- facts, the smugglers are paid a finders’ fee, while for larg-
ern Bekaa valley: to the north, in the area of Hermel and er items, the dealers provide funds to the smugglers who
75
© Morgan Belzic. Published in Report: The State of Illicit Trade and
Looting of Libyan Antiquities: 2011-2020, American School for Orien-
tal Research (Dec. 31, 2020).
76
pay their Syrian counterparts in cash. These deals are was seized near the Libyan border, in the city of Tatouine
usually done in U.S. dollars. According to The Docket’s by a Tunisian National Guard.240
research, some of the family members travel to Europe
regularly. 3. Routes from Yemen
Once in the Bekaa Valley, the items are inspected by bro-
While the Gulf countries and the Horn of Africa appear to
kers, who take pictures of the items, consult with experts
be preferred routes for the smuggling of Yemeni looted
in Europe, and inspect the items in person. The Docket’s
artifacts,241 the information about these routes remains
sources named one individual, who is Lebanese but has
scarce and requires further investigation.
residency in one of the European countries, as the main
person involved in verification and establishing contacts
with potential buyers in Europe. 3.1 Via Gulf Countries Through Egypt
The Antiquities Coalition has reported the seizure of

2. Routes from Libya looted Yemeni artifacts in Oman and Egypt following
the start of the conflict. In 2014, eight Yemeni artifacts
From Libya, looted antiquities are mainly smuggled via coming from the UAE were seized in Cairo in the port
Egypt and Tunisia. of Sefja.242 In 2015, five valuable Yemeni artifacts from
the pre Islamic era were seized in the Geneva Freeport
2.1 Via Egypt were seized; these items had passed through Qatar and
the UAE.243
Egypt is a common route for items from Cyrenaica, the
eastern coa229stal region of Libya, adjacent to the Egyp- In 2018, the Omani authorities seized 52 antiquities
tian border. The trafficking is facilitated by the criminal smuggled from Yemen at al-Mazyouna crossing point
gangs who smuggle large volumes of antiquities in “tim- between Yemen and Oman244 and another lot of uniden-
ber cars” to the Damietta port.230 tified yet likely Yemeni artifacts were seized in Muscat.245
From Egypt, the items are usually transported by ships, Researchers who analyzed the traffic of antiquities into
toward Dubai and Bangkok, and afterwards by air to Eu- the United States, confirmed the above mentioned smug-
rope.231 In 2011, items were seized in Port Said on a ship gling routes and found that “the smuggling of antiquities
bound for Dubai “in a container loaded with sofas.”232 The from Yemen [passes through] countries such as the UAE
container contained at least ten sculptures from Cyrenai- and Israel before arriving in the United States.”246 Media
ca and various other objects.233 In 2015, items were seized reports indicated that since the escalation of the conflict
in Damietta, Egypt—four wooden boxes transporting in Yemen, the number of Yemeni artifacts and antiqui-
more than a thousand looted archeological artifacts, hid- ties shipped from Saudi Arabia to the United States has
den in a container with toilet paper.234 The ship, which grown exponentially, reaching an estimated value of US
was bound for Bangkok, contained seven Cyrene funer- $5,940,786.247
ary sculptures; researcher indicated that the trafficking
likely involved “a smuggling ring based in Dubai.”235 3.2 Horn of Africa
On May 25, 2017, a Libyan citizen was arrested at Al-Sal- On August 15, 2018, Aden port officials seized a shipment
loum Border Crossing in Egypt for smuggling Libyan an- containing eight early Islamic artifacts coming from
tiquities to Egypt.236 The collection he was transporting Sanaa and going to Djibouti, “a known transit point for
comprised ceramic pieces such as lamps, amphorae, or antiquities coming out of the Arabian Peninsula.”248 The
funerary goods found in the Greek tombs in East Libya.237 seizure confirmed the media reports that suggested that
items looted by Houthi militias are smuggled through
2.2 Via Tunisia the Red Sea by fishing boats to Ethiopia and other coun-
tries in the Horn of Africa as well as by land in military
Other items, particularly Hebrew manuscripts from Lib- vehicles and ambulances.249
ya’s Nafusa Mountains, have been smuggled through Tu-
nisia.238 In November 2017, the Tunisian police arrested
4. Additional Transit Countries and
a group of individuals in the city of Zaghouan in posses-
sion of likely looted antiquities, including Hebrew man- Laundering Portals
uscripts, likely en route to Europe.239 In January 2020, a
leather-bound Hebrew manuscript with precious stones The UAE (and specifically Dubai) appears to be an im-
77
portant transit point where laundering occurs for items Charles de Gaulle Airport in Paris, in transit from Leb-
originating in the Middle East and North Africa and des- anon to Thailand. French customs thought the intended
tined for Europe. final destination was probably the United States.252
The Docket collected and handed over to relevant law en- 5. Freeports
forcement agencies preliminary information on several
UAE-based individuals who have been previously impli-
The picture of antiquities trafficking would be incom-
cated in cases related to trafficking antiquities. Further
plete without the mention of freeports. Freeports are
investigation into the activities and financial transac-
tax-free warehouses created to temporarily retain man-
tions of these individuals and companies affiliated with
ufactured goods, where antiquities originating from any
them is likely to produce additional evidence linking
country can be stored for an unlimited period of time
them to Europe and U.S.-based dealers.
and at minimal expense, until they are released to the
market.253 Freeports, including those located in Europe,
Media reports and The Docket’s own research suggest
have been repeatedly implicated in storing looted an-
that Bulgaria and Romania are prominent transit coun-
tiquities.254 While some, like the Geneva Freeport, have
tries for the smuggling of Middle Eastern antiquities. In
recently introduced stricter regulations to prevent the
March 2015, police seized 9,000 ancient coins, dozens of
reoccurrence of scandals,255 others continue to operate
Roman statues and what looked to be Sumerian relief
without any scrutiny.
from Iraq in the district of Shumen in northeast Bul-
garia.250 The Docket has also identified intermediaries
The dangerous use of freeports to conceal illegal activi-
working out of Romania, facilitating the trafficking of
ty, including the illicit trade in cultural goods, has been
items from Syria to Europe.
highlighted by UNESCO,256 OECD’s Financial Action
Task Force,257 and the International Chamber of Com-
Other transit points include Thailand, Jordan, Kuwait,
merce.258
Israel, and Singapore.251 Thailand is increasingly be-
coming a significant transit country for Middle Eastern
Freeports specializing in the storage of cultural goods
antiquities. In March 2016, two pieces of relief from a
are located in Geneva, Singapore, Monaco, Beijing, Del-
church in the Syrian Euphrates Valley were seized at
aware, Dubai, and Luxemburg. Many of them appear to
Freeports are tax-free warehouses created to temporarily retain manufactured goods and have been
repeatedly implicated in storing looted antiquities.
© FABRICE COFFRINI/AFP/Getty Images.
78
be run by the same tight-knit group of mostly Swiss own- tions with Al-Haram Exchange.272
ers, managers, and contractors.259 Journalistic reports
suggest that the Dubai Freeport in particular has been Since at least 2015, the Al-Khalidi hawala exchange facili-
exploited by criminal networks, due to its location and tated ISIL transactions.273 As reported by OFAC, Al-Khal-
impressive infrastructure.260 idi was the largest financial exchange office that dealt
with ISIL in 2016.274 In 2017, the Al-Khalidi offices in
6. Money Exchange and Hawala Syria and Turkey enabled the transfer of ISIL funds from
Iraq through Syria.275
Offices
The hawala system is used in the context of antiquities 7. Online Trade in Looted
sales,261 which sources in Turkey and Iraq confirmed to Antiquities
The Docket. Other researchers also interviewed smug-
glers operating in Iraq, who stated that for a fee, an inter- Over the last decade, the trade in illegal antiquities has
mediary called a hawaladar, an individual often based in also become prominent online, particularly through
Turkey or the United Arab Emirates with an established online auctions and e-commerce websites as well as
reputation who would receive the money in U.S. dollars through social media platforms.
and then communicate the sum to be paid to the seller of
the artifact to an Iraq-based counterpart hawaladar who Facebook, due to its wide reach and limited internal con-
received the funds in Iraq.262 This process occurs without trols, stands out as one of the key platforms for the digital
any money or data passing through the international fi- black market, where users buy and sell goods, including
nancial channels.263 illicit antiquities. A detailed study by the ATHAR Project
on the trade of conflict antiquities on Facebook, which
Over the past years, the U.S. Office of Foreign Assets analyzed the activity of 95 Arabic-language groups,
Control (OFAC) has designated individuals and entities found that “80% (1,302) of posts offering artifacts for
operating money exchange and hawala offices as belong- sale were listed in countries either in conflict or border-
ing to a network of actors financing terrorism, including ing conflict zones.”276 The research further showed that
ISIL.264 The Docket’s source named the Al Rawi network, the administrators (admins) managing these groups are
the Al Haram Exchange, and the Al Khalidi network as highly interconnected and have a global reach. The study
being involved in the transfer of money associated with identified 488 individual admins managing a groups of
looted antiquities.265 1,947,195 members.277 The admins include a mix of av-
erage citizens, middlemen, and extremists, including
The Al-Rawi or Rawi network has operated since the those associated with Syrian-based armed groups Hay’at
1990s in Iraq and has supported ISIL since at least Tahrir Al Sham, Hurras Al-Din, the Zinki Brigade, and
2017.266 Among the transactions reported by OFAC, the other non-Syrian-based Al-Qaeda or ISIL affiliates.278
Rawi network facilitated the transfer of US $300,000
to US $400,000 by a Deputy Commander for ISIL’s De- All of these groups are using Facebook as a platform for
partment of Oil to a Rawi family member, Umar Talib antiquities trafficking, whether through direct interac-
Zughayr al-Rawi, to trade gold and revert the gold pro- tion with buyers and sellers or through the use of mid-
ceeds back to ISIL.267 dlemen who straddle transactions between the general
public and terrorist groups. Facebook online antiquities
In November 2018, Coalition Forces advisors and their sales offer a broad display of various items such as an-
Partner Force in Iraq conducted a direct action raid of cient coins or larger sculptures and fragments. Libyan
a compound owned by Mushtaq al-Rawi and seized ev- looted antiquities were advertised on media pages on
idence of his business relationships with ISIL.268 Mush- Facebook groups such as the “Open Benghazi Market”
taq al-Rawi operated a network of various hawala es- page and the “Sell Anything Used for Free Benghazi”
tablishments in Iraq and Turkey.269 In April 2019, OFAC page. Particularly large artifacts, including mosaics, ar-
designated him and six other individuals and one entity chitectural elements, and Pharaonic coffins have also
as terrorists or persons providing support to terrorists.270 been offered—all still in situ.279 In these cases, the sellers
OFAC notes that the Rawi network uses hawalas to facil- or intermediaries are attempting to find buyers before
itate the movements of funds to ISIL.271 they invest in removing the objects.280
In 2017, Al-Haram Exchange was involved in a transac- In response to criticism including that of the ATHAR Re-
tion between Syria and Belgium and in 2019, members of port, Facebook has closed some of the groups and imple-
ISIL in Syria were ordered to conduct financial transac-
79
80
© Amr Al-Azm & Katie A. Paul, Facebook’s Black Market in Antiquities,
Trafficking, Terrorism, and War, Antiquities Trafficking and Heritage
Anthropology Research Project (June 2019).
mented281 stricter community policies regarding cultural have noted that VCoins adopted loose provenance re-
objects, but the data contained on their pages could pro- quirements, which is particularly problematic consider-
vide critical evidence to a judicial investigation. Further, ing provenance is vital in determining whether a coin is
new groups have continued to emerge. possibly looted or legitimately acquired.287 Looted items
from Cyrene, in Libya were traded through the VCoins
Other channels, such as Instagram or encrypted mes- platform.288
saging services such as Skype, Viber, Telegram, and
WhatsApp, also appear to be widely282 used by those LiveAuctioneers,289 another internet marketplace has
involved in trafficking of antiquities. During the Abu also been used for trading a Libyan antiquity, alongside
Sayyaf raid, U.S. Special Forces obtained the ISIL leader’s eBay, which was still heavily covered with terra rossa and
cellphone where they discovered images of stolen antiq- appeared to be “undoubtedly the product of recent loot-
uities sent through WhatsApp.283 ing.”290 The object was sold between 2016 and 2017.291
The use of online auctions has also been growing expo-

nentially. While global auction sales of art and antiquities
declined in 2015—falling as much as 11 percent—online
sales skyrocketed by 24 percent that same year, reaching
a staggering US $3.27 billion dollars.284 More antiquities
were offered through U.K. and U.S. eBay alone in four
months (215,641) than were offered through the three
main auction houses in thirty-five years (149,459). Among
those selling antiquities on eBay were convicted antiqui-
ties smugglers or sellers openly declaring that they are
exporting unlicensed antiquities.285
© Amr Al-Azm & Katie A. Paul, Facebook’s Black Market in Antiq-
uities, Trafficking, Terrorism, and War, Antiquities Trafficking and
Another online auction is VAuctions, a website that hosts Heritage Anthropology Research Project (June 2019).
auctions for credible coin dealers, and its sister com- © Amr Al-Azm & Katie A. Paul, Facebook’s Black Market in Antiq-
pany VCoins, which has over 300,000 ancient coins for uities, Trafficking, Terrorism, and War, Antiquities Trafficking and
sale including items from Iraq and Syria.286 Researchers Heritage Anthropology Research Project (June 2019).
81
82
III. Investigations in Europe
and the United States
The Docket’s research has established that archeological ties trade.

artifacts pillaged in Syria, Iraq, Libya, and Yemen are
trafficked to Europe and the United States via interna- The Docket notes that all persons are presumed innocent
tional networks where they are sold on the European until proven guilty by a court of law.
market, stored while waiting to be sold, or continue to be
trafficked and sold to other market countries, including 1. Christophe Kunicki and Richard
the United States.
Semper
This chapter contains several examples of current and
past investigations into the activities of European and Paris-based antiquities dealers and experts Christophe
U.S.-based antiquities dealers. All cases and names men- Kunicki and Richard Semper have been linked to the il-
tioned below have been previously reported on in the me- licit trade in looted antiquities and are allegedly current-
dia or in announcements made by the law enforcement ly under investigation in France for the trafficking and
agencies. To The Docket’s knowledge, so far all of these sale of antiquities looted during the conflict in Egypt and
investigations have focused on the individuals’ involve- brought to France and the United States.292
ment in the illegal trade of antiquities, rather than their
possible complicity in international crimes or financing According to media reports and information collected by
of terrorism. In the few instances where investigations the New York State District Attorney’s Antiquities Traf-
have led to prosecutions, these have resulted in insignifi- ficking Unit (the ATU) as part of their investigation into
cant sentences or fines on charges of customs violations, illicit antiquities trafficking connected to the U.S. mar-
fraud, forgery of documentation, and the like. While ket, Kunicki and Semper (and possibly other experts who
multiple items have been seized and restituted, the deal- collaborated with the Pierre Bergé & Associés auction
ers continued to operate unhindered. house) have been part of a network involved in the traf-
fic of looted antiquities from the Middle East and North
The evidence and legal analysis supplied by The Docket Africa.293
to relevant law enforcement agencies in Europe and the
United States should enable them to prosecute the antiq- Kunicki is an expert in Mediterranean archeology, “spe-
uities dealers on much more serious charges where ap- cialized in Greek, Roman, Egyptian and Near East an-
propriate, such as, possible complicity in war crimes and tiquities.”294 As expert, he has collaborated with auction
financing terrorism. Specific details of The Docket’s sub- houses in France, including Pierre Bergé & Associés,295
missions to law enforcement agencies cannot be shared Ader,296 Binoche & Gicquello,297 Drouot,298 and Maison
publicly at this time to avoid compromising the investi- Piasa.299 Before joining Pierre Bergé & Associés in 2005,
gations. The Docket is convinced, however, that this new Kunicki worked with French dealer Jean-Philippe Mari-
information and analysis, if properly followed up on with aud de Serres, a now deceased antiquities dealer, collec-
the use of law enforcement powers, such as the seizure of tor, and archeology expert who supplied international
financial records and electronic communication, could auctions houses and had also been linked to the illicit
result in successful prosecutions and significantly curb trade in antiquities.300
the financing of criminal activity through illicit antiqui-
83
84
The ATU’s investigation has been focused on the sales of
two unique and highly valuable Egyptian objects—the The ATU seized emails and other electronic evidence and
Stele of Pa-di-sena sold to the Cybèle Gallery in Paris (be- recovered thousands of images and videos in the posses-
fore being shipped to New York to be displayed for sale at sion of the two dealers,311 triggering an investigation by
The European Fine Art Fair in November 2019)301 and the the German authorities which led to Dib’s arrest in Au-
gold Egyptian Nedjemankh coffin sold to the Metropoli- gust 2020.312 The ATU found that “local thieves would
tan Museum in New York in 2017 for € 3.5 million.302 Of- loot artifacts and photograph the pieces immediately or
ficial investigations suggest that the items were sold by shortly after looting them” and email the photos to Dib
French auction house Pierre Bergé & Associés under the and Kunicki to assess their interest in the objects.313
expertise of Kunicki after being looted in Egypt and traf-
ficked through the UAE to Germany and then France.303 According to the ATU’s investigation, Dib has been reg-
ularly consulting with Kunicki on whether to purchase
According to news media and reports, Pierre Bergé & an object as well as to verify the object’s authenticity and
Associés played a significant role in the trade of pillaged value, including in the case of Egyptian antiquities.314
Libyan antiquities between 2007 and 2013. In 2007, a Once Dib agreed to buy a looted antiquity, the object was
Roman head advertised by the Pierre Bergé & Associés then smuggled out of the country of origin, and “Dib
auction house as coming from an old collection was iden- wired money to the local smugglers and traffickers in the
tified as looted from the UNESCO World Heritage Site Middle East in exchange for transporting the antiquities
of Sabratha, Libya. In 2010, Pierre Bergé & Associés dis- to Germany—often through Dubai.” 315
played two funerary sculptures accompanied by a statue
stolen from Cyrene between 1999 and 2000 (according to Once the objects arrived in Germany, Dib arranged for
Belzic’s estimates).304 In 2011, Pierre Bergé & Associés restoration and created false ownership histories for the
purchased a funerary portrait from Boisgirard Antonini objects and kept Kunicki and other dealers apprised of
(then Boisgirard & Associés), which had been previously the cleaning and restoration process.316 The restored and
sold by Millon, an auction house with addresses in Paris, laundered antiquities were then sold through Kunicki
Lyon, and Brussels.305 Millon was involved in the trade and Semper to the Cybele Gallery for the Stele of Pa-di-
of three items from Cyrene between 2008 and 2018.306 sena and to the Metropolitan Museum in New York for
Christophe Kunicki was also involved in the sale of a Lib- the gold Nedjemankh coffin.317
yan funerary portrait from the collection of Jean-Philippe
Mariaud de Serre and that was put for sale on January 10, Media sources indicate that Dib’s involvement with
2003 by French auction house Piasa.307 Kunicki and Semper was much more extensive than the
two high-profile items investigated by the ATU: Dib’s
In February 2020, French cultural crimes units—the Of- family appears in 14 of the 29 lots investigated by French
fice central de la lutte contre le trafic de biens culturels authorities as part of the “Pierre Bergé case.”318 It ap-
(OCBC) and the Office central pour la répression de la pears that Dib and his associates consigned the objects
délinquance financière (OCRGDF)—launched an inquiry to the Pierre Bergé & Associés auction house to be sold,319
into Pierre Bergé’s activities.308 On June 22 and 23, 2020, seemingly indicating an extensive network of looting and
five art experts were arrested in Paris on suspicion of laundering antiquities. In March 2022, Dib was charged
trafficking items “worth tens of millions of euros from for gang fraud and money laundering by French author-
conflict or post-conflict countries in the Middle East, ities.320
namely Egypt, Libya, Yemen, and Syria.” Kunicki and
Semper were then charged, according to media reports, Beyond the “Pierre Bergé case,” recent media reports in-
with “participating in a criminal association, organized dicate that Dib also appears to be involved in the traffick-
money laundering, forgery, and organized gang fraud.”309 ing of antiquities for the Aboutaams. In December 2016,
They were reportedly released under judicial supervision Dib was arrested in Veyrier, on the border between France
(contrôle judiciaire), while the investigation is seemingly and Switzerland, after being picked up by Ali Aboutaam’s
ongoing. driver in a car belonging to Phoenix Ancient Art, for car-
rying a Byzantine oil lamp valued between 10,000 and
2. Roben Galel Dib 15,000 Swiss francs that he did not declare.321 In October
2021, a Geneva court found Dib liable for the violation of
The investigation into the trafficking and sale by Kunic- Swiss law on the international transfer of cultural prop-
ki and Semper of the looted Egyptian items led to Ham- erty and ordered him to pay a fine of 1,000 Swiss francs
burg-based dealer, Roben Galel Dib the manager of Dio- fine as well as a suspended sentence of a fine of 4,000
nysos Ancient Coins and Antiquities.310 Swiss francs.322
85
3. Ali Aboutaam, Hicham two Syrian bas-reliefs sent by the Aboutaams to be ex-
hibited at the Brussels Art Fair (BRAFA), and the Belgian
Aboutaam, Jean-Baptiste Forestier, federal prosecutor (Parquet fédéral) allegedly opened an
and Phoenix Ancient Art investigation.332 According to the Antiquities Coalition
and The Wall Street Journal, the items were from the
Geneva-based Ali Aboutaam and U.S.-based Hicham ancient site of Mari, which has been under ISIL control
Aboutaam are both well-known antiquities dealers and since June 2014.333
have been under scrutiny on the suspicion of trading
looted antiquities. Their gallery, Phoenix Ancient Art, as In December 2016, Roben Dib was arrested in Veyrier, on
well as their associated business entities have been un- the border between France and Switzerland, after being
der investigation by various authorities for involvement picked up by Ali Aboutaam’s driver in a car belonging to
in the illicit trade of looted antiquities over the last few Phoenix Ancient Art, for carrying a Byzantine oil lamp
decades. valued between 10,000 and 15,000 Swiss francs that he
did not declare.334 In October 2021, a Geneva court found
In March 1999, according to a Lebanese news website, Roben Dib liable for the violation of Swiss law on the in-
an investigating judge in economic security cases in Da- ternational transfer of cultural property and ordered him
mascus issued a warrant for Ali Aboutaam and Hicham to pay a fine of 1,000 Swiss francs as well as a suspended
Aboutaam, for smuggling a cargo of Syrian antiquities sentence of a fine of 4,000 Swiss francs.335 The driver of
into Canada via Lebanon in the name of and via Phoenix the car, who was not charged or publicly identified, de-
Ancient Art.323 clared to the investigators that he had traveled several
times to New York’s John F. Kennedy International Air-
In May 2003, the Aboutaams attempted to sell a third port, carrying small antiquities in hand luggage to deliv-
century A.D. South Arabian Alabaster Stele via the So- er to a person working for Ali Aboutaam.336
theby’s auction house.324 Sotheby’s research revealed,
however, that the Stele had been stolen from the Aden Following Dib’s arrest in 2016, Swiss authorities detained
Museum in Yemen in 1994—the item was then seized by Biliana Aboutaam after she was seen moving antiquities
the U.S. authorities and returned to Yemen.325 out of Aboutaams’ Geneva Freeport storage but failed to
produce proper documentation of ownership and or-
In December 2003, Hicham Aboutaam was arrested for igin for some of those objects.337 According to customs
illegally importing a looted ceremonial drinking vessel authorities, this move was “sudden and suspicious” and
from Iran, known as the “Silver Griffin” into the United suggests an “obstruction to criminal law” for Ali Abouta-
States.326 Having sold the Silver Griffin for US $950,000 am to escape his obligations under VAT law.338 As a re-
in 2002, he then pled guilty in June 2004 to the misde- sult, Biliana Aboutaam, their driver, and their clean-
meanor charges of “falsifying a customs declaration” and er were ordered to pay fines from 600 to 4,000 Swiss
paid a fine of US $5000; the Silver Griffin was repatriated francs.339 On November 5, 2021, Swiss customs imposed
to Iran.327 a fine of 1.6 million Swiss francs on Ali Aboutaam for the
non-payment of VAT regarding objects imported into
In 2004, an Egyptian court sentenced Ali Aboutaam to 15 Switzerland.340 Swiss authorities also claimed more than
years in prison and a fine of LE 50,000 in absentia for 4 million Swiss francs in VAT payments for the imported
aiding a convicted antiquities smuggler Tarek El-Suesy items.341
with smuggling 280–300 artifacts from Egypt to Swit-
zerland in mislabeled packages.328 In October 2017, Swiss authorities seized approximately
11,000 antiquities from Phoenix in Geneva on the “sus-
In 2010, the Swiss customs authorities and the public picion of having illicit provenances.” As of August 2018,
prosecutor seized a sarcophagus from the Aboutaams’ about 6,000 items were still held by the Swiss authorities,
storage at the Geneva Freeport.329 Ali Aboutaam and his including 18 Greek, Roman, and Egyptian antiquities,
wife, Biliana, were charged with breaching their tax ob- valued at around US $8,000,000.342 Archeologist Mor-
ligations under the EU’s Value Added Tax (VAT) law, re- gan Belzic found that the Aboutaams have also traded in
ceiving stolen goods, and violating the law on the trans- Libyan items that were likely looted and then sold around
fer of cultural property.330 After a lengthy investigation, 2017 in Switzerland and in 2020 in the United States.343
the Swiss authorities ordered the repatriation of the sar-
cophagus in September 2015.331 On January 5, 2018, the New York State District Attorney
raided Phoenix Ancient Art’s Manhattan gallery and re-
In January 2016, Belgian customs authorities confiscated moved six items, presumed at the time to be in connec-
86
87
88
tion with their investigation into looted antiquities trad- their role in the sale of Greek and Roman antiquities
ed by billionaire Michael H. Steinhardt.344 The statement looted from Libya (Balagrae, Apollonia, and Cyrene) and
of facts filed in December 2021 by the New York District Egypt between 2014 and 2015 and trafficked to Europe.356
Attorney with regards to the plea deal offered to Michael The six items seized by authorities consisting of heads
Steinhardt reveals that Phoenix Ancient Art was connect- and torsos of statues were allegedly looted from northern
ed to the sale of 23 of the 180 illicitly trafficked antiquities Libyan sites that were under the control of ISIL affiliates
seized in relation to Steinhart.345 Many of these 23 antiq- Ansar Al Sharia Benghazi and Ansar Al Sharia Derna at
uities linked to Phoenix Ancient Art were connected to the time of the looting.357
Italian antiquities trafficker Giacomo Medici and many
had no provenance information prior to their sale or con- In 2014, Bagot sold a funerary deity from Cyrene in Bar-
signment to Phoenix Ancient Art.346 celona; it was later put on sale by Aguttes, the fourth-larg-
est French auction house358 and then seized in 2017 by
In June 2019, Belgian and French authorities raided the French authorities.359
Phoenix Ancient Art SPRL gallery in Brussels, where Hi-
cham Aboutaam was present at the time, as well as the According to official information released by the Spanish
private home of Jean Baptiste Forestier, linked to the authorities, the two suspects are charged with five dis-
Aboutaams’ Belgian operation.347 All objects exhibited tinct crimes: terrorism financing; membership in a crim-
in the gallery, the computer equipment, and various ac- inal organization; receiving stolen goods; smuggling;
counting documents were seized.348 and forgery of documentation. The charge sheet states
that Bagot and Palomar “led a network dedicated to the
Since 2017, the Aboutaams have faced public allegations illicit purchase of pieces from archeological sites looted
of connections to terrorist groups and terrorism financ- by groups related to the terrorist organization ISIL and
ing (including of ISIL): most prolifically, Paris Match349 whose sale allowed them to pay for their activities.” 360
and The Wall Street Journal350 made public the various
European investigations into potential ties the Abouta- Bagot and Palomar were released on bail (€ 12,000) on
ams could have to the various conflict countries (includ- the condition that neither individual leave Spain, both
ing Iraq and Syria) and the looting in such conflict areas surrender their passports, and both appear biweekly in
by terrorist groups.351 A Zaman Al Wasl article has also court while awaiting trial. 361
claimed that the Aboutaams have “possible links with
Daesh” and that there is an alleged commercial relation- 5. Michael H. Steinhardt
ship between the Aboutaam family and the Hezbollah
militant group and political party in Lebanon, particu-
In 2017, the New York District Attorney’s Office initiated
larly to its leader Hassan Nasrallah.352
a criminal investigation into Michael Steinhardt’s acqui-
sition, possession, and sale of antiquities.362 Steinhardt is
Media sources suggest that the Aboutaams had busi-
a well-known American billionaire, hedge fund manager,
ness dealings with the Pierre Bergé & Associés auction
and philanthropist.
house353 and French authorities have the Aboutaams on
a “list of 15 dealers” that they are focusing on specifically
In December 2021, following a three-year grand jury in-
“in connection with possible trading in antiquities looted
vestigation led by the New York District Attorney, Stein-
by Daesh.” 354
hardt entered into a plea deal, agreeing to a surrender of
180 objects worth a combined $70 million and a lifetime
4. Jaume Bagot Peix and Oscar ban on collecting antiquities.363 The objects will be repa-
Carreras Palomar triated to the countries of origin.364
Spanish authorities (Brigada de Patrimonio Histórico of The statement of facts from the District Attorney’s Of-
the National Police and Counterterrorism Unit) have been fice contains details of the antiquities looted and illegal-
investigating two Spanish antiquities dealers, Jaume Ba- ly smuggled out of 11 different countries and trafficked
got Peix and Oscar Carreras Palomar since 2015. Accord- by 12 criminal smuggling networks.365 Antiquities from
ing to media reports, the arrests of Bagot and Palomar Iraq, Libya, and Syria were among the seized items.366
are the result of a three-year investigation supported by The above mentioned Phoenix Ancient Art is connected
French, Italian, Belgian, and Libyan authorities.355 to more than 20 items mentioned in the statement.367
Bagot and Palomar were arrested on March 26, 2018 for In his statement, the District Attorney noted:368
89
“For decades, Michael Steinhardt displayed a statuette of King Shulgi suspected of having been looted
rapacious appetite for plundered artifacts with- from Iraq to Drouot auction house in Paris using a forged
out concern for the legality of his actions, the certificate with the name of Richard Wagner of Cape
legitimacy of the pieces he bought and sold, or Cod, who had been dead for three years.371 Claude Bois-
the grievous cultural damage he wrought across girard, of the French auction house Boisgirard-Antonini,
the globe. . . . His pursuit of ‘new’ additions to was involved in the sale as an auctioneer at Drouot and
showcase and sell knew no geographic or moral the statuette sold for € 240,000.372 Experts suspect that
boundaries, as reflected in the sprawling under- the Iraqi statuette was looted.373 In 2006, Iraqi authori-
world of antiquities traffickers, crime bosses, ties suspected Dere to be exhibiting looted artifacts from
money launderers, and tomb raiders he relied Iraq at Fortuna Fine Arts.
upon to expand his collection.”
In 2018, the FBI seized an Etruscan Aryballos vase from
Nonetheless, the New York District Attorney’s Office Fortuna Fine Arts, and launched an investigation into
decided not to pursue criminal charges.369 It is unclear Fortuna Fine Arts and Erdal Dere.374 That investigation
whether any of the criminal networks revealed in the led to the 2020 arrest and indictment of Erdal Dere and
statement will be subject to further investigation. Faisal Khan for fraud and wire fraud.375 Dere was also
separately charged with aggravated identity theft for fal-
6. Erdal Dere, Faisal Khan, and sifying provenance information of antiquities by listing
dead dealers in the antiquities’ provenances as well as
Fortuna Fine Arts fabricating supporting documents to sell them.376 Dere
and Khan were charged with an ongoing years-long fraud
Based largely in the United States, Erdal Dere, the previ- scheme from at least 2015 to September 2020.377 Erdal
ous owner of the now closed Manhattan art gallery Fortu- and his father Selim Dere are charged with using their
na Fine Arts, and his business associate Faisal Khan has gallery Fortuna Fine Arts Ltd., to facilitate the sales.378
been implicated in several cases involving transactions Khan participated by tracking down antiquities (primar-
with illicitly trafficked antiquities.370 ily in Asia) and then assisting Dere in selling those antiq-
uities.379 FBI agents seized “boxes and bags of apparent
In November 2005, Fortuna Fine Arts sold a Sumerian evidence” from Selim and Aysel Dere’s house, the parents
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91
of Erdal Dere.380 tion and Customs Enforcement special agent stated that
this was “the first time an alleged cultural property net-
Law enforcement has not yet released information on work has been dismantled within the United States.”386
what items were seized and which provenances relate to The agents noted that they had “identified the person in
the charges. The case appears ongoing. 381 the Middle East who was the conduit, [we’ve] identified
the broker, [we’ve] identified the individual providing
false provenance, and [we’ve] identified the end-all col-
7. Mousa Khouli, Salem Alshdaifat, lector.”387
Joseph A. Lewis II, and Ayman
Ramadan Khouli and Alshdaifat entered guilty pleas for their re-
spective charges and received fines totaling US $200
Mousa Khouli, originally from Syria, is an antiquities and US $1,000, respectively.388 Lewis received a deferred
dealer based in New York. In 2010, Khouli founded Pal- prosecution agreement and had the charges against him
myra Heritage Inc., which operates as a gallery.382 Pal- dismissed after completion of the agreement.389 Rama-
myra Heritage Gallery has been linked to items likely dan has not been prosecuted and has been a fugitive for
looted from Cyrene, including at least one item put up the duration of the proceedings.390 As part of the inves-
for sale in 2016 and 2017.383 tigation, U.S. authorities seized items from Libya, Iraq,
Afghanistan, and Egypt. 391
In July 2011, Salem Alshdaifat, Mousa Khouli, Joseph A.
Lewis II, and Ayman Ramadan were indicted in the East- 8. Mohamad Alcharihi
ern District of New York as alleged leaders of a smug-
gling ring and accused of smuggling antiquities worth Mohamad Yassin Alcharihi has been under investiga-
millions of dollars from Egypt, Libya, Iraq, and Afghani- tion in the United States since 2015 regarding the im-
stan.384 The indictment charged all four individuals with port into the United States of a Syrian mosaic depicting
conspiring to smuggle artifacts and launder money.385 Hercules.392 In 2018, a civil forfeiture action was filed in
the Central District of California for the mosaic.393 The
Following the three-year investigation, a U.S. Immigra-
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93
complaint states that the FBI believes that the mosaic
was looted from a conflict area in Syria and smuggled
into the United States: the shipping documents mis-
stated what was in the shipment, did not provide for the
mosaic’s true country of origin, and underreported the
item’s value.394 In 2020, Alcharihi was indicted in Califor-
nia federal district court for falsely classifying the import
documents for the mosaic and criminal forfeiture.395 The
case appears to be ongoing.396
94
IV. Legal Framework for
Prosecuting Antiquities Dealers as
Accomplices to International
Crimes and Financiers of Terrorism
Existing international, regional, and national legisla- al, or transfer of ownership of cultural property, and any
tion and policy instruments create a legal framework for archeological excavation unless it is strictly required to
protecting and preventing the illicit trade in looted an- safeguard or preserve the cultural property.398
tiquities, particularly antiquities originating in conflict
areas. However, due to a lack of effective enforcement The Convention on the Means of Prohibiting and Prevent-
mechanisms, inconsistent state implementation of re- ing the Illicit Import, Export, and Transfer of Ownership
gional and international instruments, and loopholes in of Cultural Property, adopted on November 14, 1970 (the
national legislations, this framework has been insuffi- 1970 UNESCO Convention), is the first international legal
cient for halting the illicit trade in conflict antiquities. instrument adopted to fight illicit trafficking of cultur-
The existing regulations focus primarily on the patrimo- al property in times of peace.399 Article 5 exhorts States
nial aspect of cultural heritage crimes, without consider- Parties to ensure the protection of cultural heritage by
ing its organized criminality dimension and its impact adopting in their domestic systems laws and regulations
on victims, who suffer from the crimes in conflict zones designed to secure the protection of cultural heritage,
and beyond. This chapter briefly addresses the existing among other responsibilities.400
legal framework for cultural heritage protection and pre-
vention of illicit trade, and further analyzes international The Convention on Stolen or Illegally Exported Cultur-
and national laws that allow for the prosecution of those al Objects (the UNIDROIT Convention) was adopted in
involved in trading in looted antiquities as accomplices 1995, in response to calls to develop a uniform body of ba-
to international crimes and terrorism. sic private law rules for the international art trade that
would complement the public law provisions of the 1970
1. International, regional, and UNESCO Convention.401 The UNIDROIT (International
Institute for the Unification of Private Law) Convention
national framework for cultural provides for the return of stolen or illegally exported cul-
heritage protection tural objects if the removal of the object “significantly
impairs” certain interests of the country from which it
1.1 International Instruments originated or if the object is “of significant cultural im-
portance” (Article 5(1)(d)). Implementing legislation cre-
Following the mass destruction of cultural property and ates private rights of action for recovery of stolen and
heritage that occurred during World War II, the Con- illegally exported cultural objects, whereas the 1970 UN-
vention for the Protection of Cultural Property in the ESCO Convention operates on a State-to-State basis.402
Event of Armed Conflict was adopted on May 14, 1954 However, the UNIDROIT Convention was ratified by very
(the Hague Convention).397 Article 4(3) of the Hague Con- few countries and only 15 EU member states.403 Key mar-
vention prohibits theft, pillage, and misappropriation ket countries, such as Belgium and the United Kingdom,
of cultural property in international armed conflict. Its have yet to ratify it.404
second protocol, dated March 26, 1999, applies to armed
conflicts not of international character (Article 22). Ar-
ticle 9 of that protocol provides that occupying parties
shall prevent or prohibit the illicit export, other remov-
95
The U.N. Security Council (UNSC) has adopt- and introduces enhanced due diligence measures to mon-
ed various resolutions condemning the de- itor suspicious transactions involving “high risk” coun-
struction of cultural heritage,405 repeatedly tries.415 Enhancing the due diligence requirement for EU
drawing the connection between the illicit member states, the European Parliament and Council
trade of artifacts, international crimes, and passed Regulation No. 880/2019 on the Introduction and
terrorism financing.406 the Import of Cultural Goods in 2019.416 This Regulation
is designed “to ensure the effective protection against il-
In Resolution 2347 (2017), the UNSC recognized in par- licit trade in cultural goods and against their loss or de-
ticular that “ISIL, ANF and other individuals, groups, struction and the prevention of terrorist financing and
undertakings and entities associated with Al-Qaida, are money laundering through the sale of pillaged cultural
generating income from engaging directly or indirectly goods to buyers in the Union.”417 The new rules apply only
in the looting and smuggling of cultural heritage items to cultural goods imported from countries outside of the
from archaeological sites, museums, libraries, archives, EU.418 They require importers to provide proof that their
and other sites in Iraq and Syria, which is being used to goods were legally exported from the country of origin in
support their recruitment efforts and strengthen their order to obtain a special license from an EU country.419
operational capability to organize and carry out terrorist
attacks . . . .”407 On July 20, 2021, the European Commission proposed
legislation to harmonize rules across the EU, including
In prior resolutions, the UNSC has called out terrorist the creation of a new authority to fight money launder-
organizations and armed groups for trafficking and de- ing.420 The proposal for a Regulation of the European
stroying cultural heritage. In Resolution 2199 (2015), the Parliament and of the Council on the Prevention of the
UNSC specifically condemned the looting, destruction, Use of the Financial System for the Purposes of Money
and trafficking of Iraqi and Syrian cultural property.408 Laundering or Terrorist Financing lists transactions in-
In Resolution 2379 (2017), it mandated the establishment volving cultural artifacts as presenting a higher risk of
of an Investigative Team to collect and preserve evidence money laundering and terrorism financing.421
for use in national courts of international crimes car-
ried out by ISIL.409 The same resolution condemns the 1.3 National Legislation
commission of acts by ISIL, including “its destruction
of cultural heritage, including archaeological sites, and States have enacted numerous laws and policies at the
trafficking of cultural property.”410 In other resolutions, national level to curb the illicit trade of looted antiquities.
the UNSC has exhorted States multiple times to take ap- Recent developments have focused on strengthening anti
propriate steps to prevent the trade of looted Syrian and terrorism financing and money laundering frameworks
Iraqi artifacts,411 “including by prohibiting cross-border by extending them to those who trade in antiquities.
trade in such items.”412
In 2016, France adopted the Act for Strengthening the
1.2 Regional Instruments Fight Against Organized Crime, Terrorism, and Its Fi-
nancing. It also amended the Criminal Code to include
The EU has adopted multiple instruments over the years the punishment of the import, export, transit, transport,
to deter the traffic of cultural artifacts in its member sale, acquisition or exchange of “cultural goods, having
states, emphasizing the role of illicit antiquities trade in an archaeological, artistic, historical or scientific interest
financing terrorism and organized crime. knowing that this property was stolen from a territory
which was at that time, an operational theater of terror-
According to the EU’s 2020 Security Union ist groups, and without being able to justify the lawful-
Strategy, “trafficking in cultural goods has ness of the origin of this property.”422
become one of the most lucrative criminal
activities and a source of funding for ter- In Germany, the Act on the Protection of Cultural Prop-
rorists as well as organised crime.”413 erty (Kulturgutschutzgesetz) passed in 2016. It reformed
the existing law on the protection of cultural property
The EU Fifth Anti-Money Laundering Directive entered and significantly strengthened the protections against
into force on July 9, 2018 and required implementation illegal trade in antiquities by requiring importers to have
into national law by all EU member states by January 10, proof of export from the country of origin, requiring
2020.414 The Fifth Anti Money Laundering Directive ex- due diligence for all actors who put cultural objects on
tends the “Know Your Customer” expectations and other the market and requiring retention of records of trans-
requirements to art dealers and other service providers action.423
96
After its ratification of the 1970 UNESCO Convention in the United States.
2003, Switzerland—a key European art and antiquities
trade hub and home to several freeports—introduced In international law, the four 1949 Geneva Conventions
the Cultural Property Transfer Act in 2005. This Act im- criminalized the commission of grave breaches during
plements the provisions of the Convention into Swiss international armed conflict. Similar provisions in Com-
law.424 In addition, the Swiss Federal Act on the Interna- mon Article 3 apply to conflicts of non-international in
tional Transfer of Cultural Property regulates the import character.431 Customary international law norms have
of cultural property into Switzerland, its transit and ex- expanded over time so that prohibited conduct in in-
port, and its repatriation. It has been supplemented with ternational armed conflict is similarly criminalized in
two additional ordinances related specifically to cultural non-international armed conflict as well.432
property originating in Iraq and Syria.425
The Rome Statute of the International Criminal Court
Recently, the United States has taken steps to strengthen (Rome Statute) criminalizes war crimes and crimes
its regulations on financing terrorism and anti-money against humanity. Article 8 criminalizes war crimes,
laundering by extending the Bank Secrecy Act to “per- which are defined as grave breaches of the 1949 Geneva
sons engaged in the trade of antiquities.”426 The Finan- Conventions, as well as enumerated crimes committed
cial Crimes Enforcement Network is currently drafting in the context of both international and non-internation-
proposed language to extend this legislation, which will al armed conflicts.433 Article 7 of the Rome Statute crimi-
be made public in 2022.427 The current administration’s nalizes as a “crime against humanity” any of a number of
strategy to counter corruption—which has been identi- underlying criminal acts, including murder, torture, and
fied as a core U.S. national security interest—echoes the sexual violence, when committed as part of a widespread
importance of the amendment to, and expansion of, the or systematic attack directed against any civilian popula-
Bank Secrecy Act to include the art and antiquities trade tion with knowledge of the attack and pursuant to or in
because these markets are “especially vulnerable to a furtherance of a State policy.434
range of financial crimes” including “illicit value transfer,
sanctions evasion, and corruption” due to the market’s Articles and provisions criminalizing war
“[b]uilt-in opacity, lack of stable and predictable pric- crimes and crimes against humanity have
ing, and inherent cross-border transportability of goods been incorporated into national law in Eu-
sold.” 428 rope and the United States.
2. Prosecuting illicit trade in looted In France, international crimes are prohibited under
Book II, Title I and Book IVbis of the French Criminal
antiquities as complicity in interna- Code.435 In Belgium, they are criminalized under Title
tional crimes and terrorism Ibis of the Belgian Criminal Code.436 In 2011, Switzerland
financing incorporated the relevant provisions of the Rome Statute
and international humanitarian law into the Swiss Crim-
inal Code.437 The Spanish Criminal Code criminalizes in-
2.1 Core International Crimes
ternational crimes under Title XXIV.438
The responsibility of armed groups oper-
In Germany, the Code of Crimes Against Internation-
ating in conflict areas across the MENA
al Law (Völkerstrafgesetzbuch or VStGB) prohibits war
region for a range of atrocity crimes, in-
crimes and crimes against humanity.439 In the United
cluding pillage, killings, enforced disap-
Kingdom, Part 5 of the International Criminal Court
pearances, torture, rape, displacement,
Act 2001 implements the Rome Statute and criminalizes
destruction of property, and other criminal
the acts of genocide, crimes against humanity, and war
acts has been well-documented over the
crimes.440
last decade.429
In the United States, war crimes are criminalized under
Justice actors/law enforcement/national authorities have
the 1996 War Crimes Act, which applies when either the
launched court proceedings across Europe as a result.430
victim or the perpetrator is a U.S. national or a member
of the U.S. Armed Forces at the time of the commission of
These acts, when committed as part of widespread or
the crime.441 In the context of a non-international armed
systematic assault against civilian population, are crim-
conflict, the War Crimes Act covers conduct constituting
inalized as war crimes and crimes against humanity in
a grave breach of Common Article 3 of the Geneva Con-
international law, as well as national laws in Europe and
97
ventions.442 While the United States does not have a com- In France, a perpetrator can be held liable as an accom-
prehensive criminal statute to prohibit crimes against plice to an international crime if they knowingly facilitat-
humanity, other statutory provisions within the U.S. fed- ed the preparation or commission of the primary offenc-
eral criminal code may allow for the prosecution of the es.452 In the context of crimes against humanity, French
underlying crimes even if they occurred abroad, includ- courts have long recognized that accomplices need not
ing torture,443 terrorism bombings,444 and other criminal share the criminal intent of the perpetrators nor intend
offenses carried out by terrorist organizations.445 to contribute to the same result.453 The French Supreme
Court recently confirmed this stance as it applies to cor-
2.2 Complicity in International porate accountability in the Lafarge case. This case sug-
Crimes gests that knowingly paying or otherwise supporting an
organization involved in committing crimes against ci-
Complicity and other forms of secondary liability have vilians and acts of terrorism is sufficient grounds to find
been a part of criminal law—international and nation- the entity accountable as an accomplice.454 The pursuit
al—since the inception of the criminal justice system, of a commercial activity does not impact the character-
recognizing that accomplices and instigators can be held ization of the mens rea; rather, it relates to the motive
as liable for criminal activities as the direct perpetrators. behind the offence.455
Under international law, complicity in international In Belgium, courts have broadly interpreted Articles 66
crimes has been expressed in decades of customary inter- and 67 of the Criminal Code on complicity. Courts have
national law jurisprudence—from the post-World War II admitted cases involving complicity when the accom-
Nuremberg trials to modern ad hoc and hybrid tribunals plice had a positive legal obligation to cause or prevent
and the Rome Statute. From the post-World War II era a certain act, but they voluntarily abstained and there-
onwards, customary international law has consistently by promoted the commission of the punishable act.456
held that individuals and entities who knowingly pro- Under the 2017 Belgian Law on the prevention of money
vide substantial assistance to the direct perpetrators of laundering and terrorist financing and on the restriction
international crimes are liable.446 The Nuremberg trials of the use of cash, professionals involved in the trade of
and ad hoc and hybrid tribunals have applied the same antiquities must comply with due diligence obligations,
complicity standard to individuals participating in cor- which arguably holds them to a higher standard with re-
porate or business activities that facilitates international gards to the interpretation of complicity under Articles
crimes.447 66 and 67 of the Belgian Criminal Code.457
The Rome Statute recognizes complicity as a mode of li- In Spain, an accomplice must have “knowledge of the
ability under Article 25(3)(c).448 While the Rome Statute perpetrator’s criminal plan” and can only be punished if
does not alter the complicity standards under customary their help “increases the probability that the perpetrator
international law, it provides a different degree of com- will successfully commit the offense.”458
plicity—a higher mens rea standard and a lower actus
reas standard449 —for those who are specifically subject Some national jurisdictions mirror the mens rea require-
to the jurisdiction of the International Criminal Court.450 ments of the Rome Statute, particularly in that the ac-
complice must share the purpose for the commission of
National laws and relevant jurisprudence also provide a the crime with the perpetrator.
framework for prosecuting dealers of looted antiquities
as accomplices to international crimes committed by the In Germany, complicity is characterized when a person
armed groups with whom they trade. Generally, national intentionally assists another in the intentional commis-
jurisdictions apply regular criminal standards of com- sion of an unlawful act.459
plicity to accomplices in international crimes.451
In the United States, the aider and abettor generally
Domestic courts around the world are must have the intent to facilitate the commission of the
pursuing international criminal cases using crime, share the requisite intent of the underlying of-
complicity theories of liability that mirror fense, assist or participate in the commission of the un-
the customary international law mens rea derlying offense, and have someone commit the under-
standard: prosecutors must demonstrate lying offense.460 Under the common law, “[t]he quantity
that accomplices have knowledge of the of assistance was immaterial, so long as the accomplice
crimes committed by the direct did ‘something’ to aid the crime,” and the common law
perpetrators. “maintained [that] every little bit helps—and a contri-
98
bution to some part of a crime aids the whole.”461 That have aided and abetted or conspired with someone sub-
principle “continues to govern aiding and abetting under ject to its jurisdiction.
§ 2.”462
Further, U.S. law criminalizes violations of executive
orders that prohibit transactions with terrorist groups,
2.3 Financing and Material Support among other things. This includes Executive Order 13224
to Terrorism (“Blocking Property and Prohibiting Transactions With
Persons Who Commit, Threaten to Commit, or Support
The 1999 International Convention for the Terrorism”),470 which prohibits U.S. persons from engag-
Suppression of the Financing of Terrorism ing in financial interactions with Specially Designated
includes in the definition of terrorism any Global Terrorists, including ISIL (designated 2004), the
“act intended to cause death or serious al-Nusrah Front (designated 2014), al-Qa’ida in the Ara-
bodily injury to a civilian, or to any other bian Peninsula (designated 2010), and Ansar al Shari’a
person not taking an active part in the (designated in 2014).471
hostilities in a situation of armed conflict,
when the purpose of such act, by its nature European jurisdictions have criminalized terrorism fi-
or context, is to intimidate a population, nancing as a result of the transposition of the European
or to compel a government or an interna- Parliament and Council Directive 2015/849 (2015) on the
tional organization to do or to abstain from prevention of the use of the financial system for the pur-
doing any act . . . .”463 poses of money laundering or terrorist financing.472
In its Resolution 1566 (2004), the UNSC included in the In Belgium, Article 140 of the Criminal Code states that
definition of terrorism “criminal acts, including against any person who participates in the activity of a terrorist
civilians, committed with the intent to cause death or se- group—including by providing information or material
rious bodily injury, or taking of hostages, with the pur- means to the group or by financing its activities—and
pose to provoke a state of terror in the general public or who had knowledge that this participation could con-
in a group of persons or particular persons, intimidate a tribute to committing a crime or misdemeanor, will be
population or compel a government or an international punished by imprisonment of five to ten years and a fine
organization to do or to abstain from doing any act.” 464 of €100 to €4,000.473
The United States and various European jurisdictions France criminalizes terrorism financing under 421-2-2 of
have legal frameworks to prosecute the illicit trade in an- the Criminal Code by making individuals and companies
tiquities looted by designated terrorist groups (including liable for providing, collecting or managing funds, secu-
ISIL, Hay’at Tahrir al-Sham, and Al Qaeda). These juris- rities or property of any kind with the intention that they
dictions recognize such trade as a form of material sup- are used or knowing that they are intended to be used
port or financing of terrorism. for the commission of any acts of terrorism (provided in
the Criminal Code).474 It is not relevant whether such acts
In the United States, antiquities dealers and collectors eventually take place.475
can be charged with providing material support or re-
sources to designated foreign terrorist organizations un- In Switzerland, Article 260quinquies of the Criminal
der 18 U.S. Code § 2339B. Under § 2339B, individuals in- Code holds that anyone who collects or provides funds
volved in the illicit trade of looted antiquities criminally with a view to financing a violent crime that is intended
liable and subject to fines and imprisonment if they pro- to intimidate the public or to coerce a state or interna-
vide material support to an organization that they know tional organization into carrying out or not carrying out
is a terrorist group.465 Section 2339B includes a broad ex- an act shall be liable to a custodial sentence not exceeding
traterritoriality provision and has a relatively low mens five years or to a monetary penalty.476
rea requirement: the statute requires that the offender
know that the organization is a designated foreign ter- In Spain, financing terrorism is criminalized under Arti-
rorist organization,466 or that the organization engages cle 573 of the Spanish Criminal Code.477 Relatedly, Article
in or engaged in terrorist activity467 or terrorism.468 Be- 576bis3 creates the possibility that legal persons can be
cause § 2339B extends broad jurisdiction,469 § 2339B can perpetrators in crimes against public order, including
cover a wide range of conduct that may have taken place for financing acts of terrorism.478 This law thus allows
outside of the United States, so long as the concerned infor terrorism financing charges to be brought against
dividuals and entities are present in the United States or galleries or other legal entities. A direct link between the
99
financing and the activities of the terrorist group is not
required; rather, it is sufficient to prove that the defen-
dant financed the activities, while knowing or having an
awareness that their act or conduct serves or supports a
terrorist organization.479 Defendants also cannot claim
deliberate ignorance by, for example, instructing an in-
termediary to facilitate the trade in looted antiquities so
as to “break” their direct interactions with terrorist orga-
nizations.480
100
V. Conclusion
The Docket’s investigation, detailed in this report, points to the existence of

well organized international smuggling networks involved in the sales of loot-
ed antiquities from the Middle East and North Africa on European and U.S.
markets. Invaluable artifacts—statues, ornaments, jewelry, books, coins, pot-
tery—have been looted from archeological sites and museums by terrorist or-
ganizations, including ISIL, Jabhat al-Nusra, Hayat Tahrir al Sham, al Qaeda
in the Arabian Peninsula, and Ansar al Sharia as well as other armed groups
and sold via transnational networks to galleries, museums, and collectors in
Europe and the United States. The proceeds—tens of millions of dollars ac-
cording to the most conservative estimates—are then used by these terrorist
organizations and armed groups to further finance crimes against civilians
and acts of terror.
While an extensive legal corpus on the prohibition of trafficking of cultural

heritage objects exists, enforcement mechanisms and therefore the deterrent
effect have been difficult to achieve. This is because there has largely been a
focus on the restitution of the cultural heritage object itself, a focus on the
prosecution of lower-level crimes including art and property crimes, and the
absence of harmonization and a lack of resources at the national level. Even
when caught red handed European and U.S. dealers have received barely a
slap on the wrist, facing mere fines for customs or tax violations or low-level
criminal charges for forging provenance and import documents.
To dismantle these criminal networks and create accountability for antiq-

uities dealers who finance conflict, war, and mass atrocities, The Docket’s
strategy is to pursue investigations and trigger criminal prosecutions against
antiquities dealers in Europe and the United States for complicity in interna-
tional crimes and terrorism financing. We believe this is the most effective
way to stop the financing of atrocities through the trade in illegal artifacts and
to protect the cultural heritage of the affected communities.
101
102
Endnotes
1 See, e.g., Ethnic Cleansing on a Historic Scale: Islamic State’s Systematic Targeting of Minorities in Northern Iraq, AM-
NESTY INT’L (Sep. 2, 2014), https://www.amnesty.org/en/documents/mde14/011/2014/en/; Syria ‘finds body of archaeologist Khaled
al-Asaad beheaded by IS’, BBC NEWS (Feb. 8, 2021) https://www.bbc.com/news/world-middle-east-55977964; Libya: Extremists Ter-
rorizing Derna Residents: Summary Executions, Public Floggings, No Rule of Law, HUM. RTS, WATCH (Nov. 27, 2014), https://www.
hrw.org/news/2014/11/27/libya-extremists-terrorizing-derna-residents. In December 2016, the U.N. General Assembly created the In-
ternational, Impartial, and Independent Mechanism (IIIM) with a mandate to “collect, consolidate, preserve and analyse evidence” for
future “national, regional or international courts or tribunals” with jurisdiction over crimes and violations committed in Syria since
the start of the conflict in March 2011. See International, Impartial and Independent Mechanism, https://iiim.un.org/who-we-are/
mandate/ (last visited May 17, 2022).
2 Int’l Crim. Court, Elements of Crimes, art. 8(2)(b)(xvi), war crime of pillaging, https://www.icc-cpi.int/sites/default/files/NR/
rdonlyres/336923D8-A6AD-40EC-AD7B-45BF9DE73D56/0/ElementsOfCrimesEng.pdf (last visited May 17, 2022).
3 The concept of “pillage” is encompassed in a variety of words including pillage, plunder, theft, stealing, ransack, digging, loot-
ing, and illegal excavation. Consistently across reports, the word “looting” is most often used. The Docket has standardized these terms
to “looting” and “pillage,” which may refer to any of mentioned acts.
4 The four source countries of Syria, Iraq, Libya, and Yemen have been selected as the focus for The Docket’s research due the
large-scale looting that can be attributed to specific armed groups (as opposed to more dispersed criminal activity) and because they
are most frequently mentioned as the source countries of looted antiquities appearing on European antiquities market.
5 UNESCO World Heritage Sites refers to “places deemed of Outstanding Universal Value, whose cultural and/or natural signif-
icance is so exceptional as to transcent national boundaries and to be of common importance for present and future generations of all
humanity.” Satellite-based Damage Assessment to Cultural Heritage Sites in Syria, UNITAR & UNOSAT 14 (2014), https://unosat.web.
cern.ch/unitar/downloads/chs/FINAL_Syria_WHS.pdf.
6 Tentative UNESCO sites refers to nomination list submitted by UNESCO State Parties of properties or sites that are consid-
ered to be “cultural and/or natural heritage of outstanding universal value and therefore suitable for inscription on the World Heritage
List.” See Tentative Lists, UNESCO WORLD HERITAGE CONVENTION, https://whc.unesco.org/en/tentativelists/ (last visited May 17,
2022 ).
7 “Site museums” refer to museums located at archaeological sites that house artifacts and items discovered at the archeological
site.
8 Even though it has been documented less, the pillaging in Libya and Yemen has been extensive. Researcher Neil Brodie writes
that the focus in looted antiquities has largely been on Iraq and Syria because of the performative and widely circulated destruction of
cultural property by Daesh. See Neil Brodie, “Why is No One Talking About Libya’s Cultural Destruction?”, 78(3) NEAR E. ARCHAEOL-
OGY 212, 213 (2015), https://traffickingculture.org/app/uploads/2017/07/Brodie-2015-No-one-talking-Libya.pdf.
9 See, e.g., Jesse Casana, Elise Jakoby Laugier & Peter F. Biehl, Satellite Imagery-based Monitoring of Archaeological Site
Damage in the Syrian Civil War, 12(11) PLOS ONE (Nov. 30, 2017), https://dx.plos.org/10.1371/journal.pone.0188589; Jesse Casana, Sat-
ellite Imagery-Based Analysis of Archaeological Looting in Syria, 78(3) NEAR E. ARCHAEOLOGY 142 (2015), https://www.journals.
uchicago.edu/doi/pdf/10.5615/neareastarch.78.3.0142; Jesse Casana & Mitra Panahipour, Satellite-Based Monitoring of Looting and
Damage to Archaeological Sites in Syria, 2(2) J. OF EASTERN MEDITERRANEAN ARCHAEOLOGY & HERITAGE STUDIES 128 (2014),
https://www.academia.edu/7543601/Satellite_Based_Monitoring_of_Looting_and_Damage_to_Archaeological_Sites_in_Syria; Sat-
ellite-based Damage Assessment to Cultural Heritage Sites in Syria, UNITAR & UNOSAT (2014), https://unosat.web.cern.ch/unitar/
downloads/chs/FINAL_Syria_WHS.pdf; Satellite-Based Damage Assessment of Cultural Heritage Sites 2015 Summary Report of Iraq,
Nepal, Syria & Yemen, UNITAR & UNESCO (June 2016), https://whc.unesco.org/en/activities/890/; Ancient History, Modern Destruc-
tion: Assessing the Status of Syria’s Tentative World Heritage Sites Using High-Resolution Satellite Imagery, AM. ASS’N FOR THE
ADVANCEMENT OF SCIENCE (2014), https://www.aaas.org/resources/ancient-history-modern-destruction-assessing-status-syr-
ia-s-tentative-world-heritage-sites-7; Ancient History, Modern Destruction: Assessing the Current Status of Syria’s World Heritage
Sites Using High-Resolution Satellite Imagery, AM. ASS’N FOR THE ADVANCEMENT OF SCI. (2014), https://www.aaas.org/resourc-
es/ancient-history-modern-destruction-assessing-current-status-syria-s-world-heritage-sites. For an assessment of satellite image
analysis in Syria and Iraq over the last two decades, see Brian Daniels & Katharyn Hanson, Archaeological Site Looting in Syria and Iraq:
A Review of the Evidence, COUNTERING ILLICIT TRAFFIC IN CULTURAL GOODS 83 (2015), https://www.academia.edu/19691171/Ar-
chaeological_Site_Looting_in_Syria_and_Iraq_A_Review_of_the_Evidence.
10 As described by Iconem, a leading organization for digital heritage mapping, digital mapping technology uses “the large-scale
scanning capacity of drones and the photorealistic quality of 3D to create digital replicas” of cultural heritage sites. See, e.g., Heritage
Projects Map, ICONEM, https://iconem.com/en/ (last visited May 17, 2022 ) (listing 3D digitized cultural heritage sites in Syria, Iraq,
Libya, and Yemen); Documenting Damage at Mari Site using 3D Technology, DIRECTORATE-GENERAL OF ANTIQUITIES & MU-
SEUMS SYRIA (Dec. 9, 2020), http://dgam.gov.sy/news/?lang=en); Claire Vonn, A 3D Database of Threatened Syrian Heritage Sites,
HYPERALLERGIC (Mar. 21, 2016), https://hyperallergic.com/284327/a-3d-database-of-threatened-syrian-heritage-sites/.
11 Designated terrorist organization refers to groups designated as terrorist organizations by the United Nations, the Euro-
pean Union, and/or the United States. See Narrative Summaries of Reasons for Listing, U.N. SEC. COUNCIL, https://www.un.org/
securitycouncil/sanctions/1267/aq_sanctions_list/summaries (last visited May 17, 2022); E.U. Terrorist List, COUNCIL OF THE EUR.
UNION, https://www.consilium.europa.eu/en/policies/fight-against-terrorism/terrorist-list/ (last accessed May 17, 2022); Foreign
103
Terrorist Organizations, U.S. DEP’T OF STATE, https://www.state.gov/foreign-terrorist-organizations/ (last visited May 17, 2022).
12 Islamic State in Iraq and the Levant (also known as Daesh, the Islamic State (IS), or the Islamic State of Iraq and Syr-
ia (ISIS)) is a Salafi militant organization with a goal of establishing an Islamic caliphate in Iraq and Syria. See The Islamic State,
CENTER FOR INT’L SECURITY AND COOPERATION, https://cisac.fsi.stanford.edu/mappingmilitants/profiles/islamic-state#-
text_block_12420 (last visited May 17, 2022). Daesh was designated as a terrorist organization by the U.N. Security Council in August
2014 with Security Council resolution 2170 (under the name Islamic State of Iraq and the Levant (ISIL)). S.C. Res. 2170 (Aug. 15, 2014),
https://www.un.org/securitycouncil/s/res/2170-%282014%29.
13 Hay’at Tahrir al-Sham, formerly al-Qaeda affiliated Jabhat al-Nusra (or the al-Nusra Front), is a Sunni opposition group
fighting against the Syrian government forces with aims to establish an Islamic Emirate in Syria. See Hay’at Tahrir al-Sham, CEN-
TER FOR INT’L SEC. AND COOPERATION, https://cisac.fsi.stanford.edu/mappingmilitants/profiles/hayat-tahrir-al-sham (last
accessed May 17, 2022). Jabhat al-Nusra was designated a terrorist organization by the U.N. Security Council in May 2013. S.C. Res.
2170 (Aug. 15, 2014), https://www.un.org/securitycouncil/s/res/2170-%282014%29.
14 Al Qaeda in the Arabian Peninsula (AQAP), also referred to as Ansar al-Sharia in Yemen, is a militant Sunni terrorist organi-
zation that is part of the al-Qaeda network. See Al Qaeda in the Arabian Peninsula, CENTER FOR INT’L SEC. AND COOPERATION,
https://cisac.fsi.stanford.edu/mappingmilitants/profiles/al-qaeda-arabian-peninsula (last accessed May 17, 2022). AQAP was des-
ignated as a terrorist organization by the U.N. Security Council on January 19, 2010. See Al-Qaida in the Arabian Peninsula (AQAP),
U.N. SEC. COUNCIL, https://www.un.org/securitycouncil/sanctions/1267/aq_sanctions_list/summaries/entity/al-qaida-in-the-ara-
bian-peninsula-%28aqap%29 (last accessed May 17, 2022); S.C. Res. 1904 (Dec. 17, 2009), https://www.undocs.org/S/RES/1904%20
(2009).
15 Houthi militias, also referred to as the Ansar Allah group (Supporters of God), is an Islamic political movement that emerged
from northern Yemen and is the de facto group in power in northern Yemen. On January 11, 2021, the United States announced it
would designate Yemen’s Houthis as a terrorist group. U.S. Designating Yemen’s Houthis a ‘Terrorist’ Group, AL JAZEERA (Jan. 11,
2021), https://www.aljazeera.com/news/2021/1/11/us-designating-yemens-houthis-a-terrorist-group.
16 Ansar al Sharia is affiliated with Al-Qaeda which operated from 2012 until its dissolution in 2017 and was first established in
Benghazi by Muhammed al-Zahawi. It became the largest jihadist organization in Libya between 2012 and 2014. It was divided into
two affiliate branches in Derna (led by Abu Sufian bin Qumm) and Ajdabiya. See Mary Fitzgerald & Mattia Toaldo, A Quick Guide to
Libya’s Main Players, EUR. COUNCIL ON FOREIGN REL. (Oct. 2016), https://www.ecfr.eu/mena/mapping_libya_conflict; Henrik
Gratrud & Vidar Benjamin Skretting, Ansar al-Sharia in Libya: An Enduring Threat, 11(1) PERSP. ON TERRORISM 40 (Feb. 2017),
https://www.universiteitleiden.nl/binaries/content/assets/customsites/perspectives-on-terrorism/2017/issue-1/0520171-ansar-al-
sharia-in-libya-an-enduring-threat-by-henrik-gratrud-and-vidar-benjamin-skretting.pdf; Kevin Truitte, The Derna Mujahideen
Shura Council: A Revolutionary Islamist Coalition in Libya, 12(5) PERSP. ON TERRORISM 4 (Oct. 2018), https://www.universite-
itleiden.nl/binaries/content/assets/customsites/perspectives-on-terrorism/2018/issue-5/truitte-2.pdf. In November 2014, the ISIL
and Al-Qaida Sanctions committee of the U.N. Security Council listed Ansar al Sharia on its terror list. See Narrative Summaries of
Reasons for Listing, U.N. SEC. COUNCIL, https://www.un.org/securitycouncil/sanctions/1267/aq_sanctions_list/summaries (last
accessed May 17, 2022) (designated in November 2014). Ansar Al Sharia in Benghazi and Derna are on the list of Foreign Terrorist
organizations established by the U.S. Department of State, Bureau of Counterterrorism. Foreign Terrorist Organizations, U.S. DEP’T
OF STATE, https://www.state.gov/foreign-terrorist-organizations/ (last accessed May 17, 2022) (designated in January 2014).
17 The Tarek Ibn Zayad Brigade was qualified as “an AQIM brigade in the Sahel” by the U.N. Security Council. See The Organi-
zation of Al-Qaida in the Islamic Maghreb, U.N. SEC. COUNCIL, https://www.un.org/securitycouncil/sanctions/1267/aq_sanctions_
list/summaries/entity/the-organization-of-al-qaida-in-the-islamic (last accessed May 17, 2022).
18 The Benghazi Revolutionary Shura Council (BRSC) was comprised mostly of the major Islamist militias in Benghazi (Libya
Shield, February 17th Martyrs Brigade, and Raf Allah al-Sahati Brigade) and was supported by the coalition of the Mujahidin Shura
Council of Derna. The BRSC claimed responsibility for a number of suicide bombings in early October 2014. See Ansar Al-Sharia
(Libya), STANFORD CENTER FOR INT’L SEC. AND COOPERATION, https://cisac.fsi.stanford.edu/mappingmilitants/profiles/an-
sar-al-shariah-libya#highlight_text_7849 (last accessed May 17, 2022).
19 The Islamic Youth Shura Council was founded in 2014, formed from the Battar Brigade and local jihadists, and affiliated with
Daesh centered in Derna. It pledged allegiance to the Daesh in October 2014. See Mary Fitzgerald & Mattia Toaldo, A Quick Guide to
Libya’s Main Players, EUROPEAN COUNCIL ON FOREIGN RELATIONS (Oct. 2016), https://www.ecfr.eu/mena/mapping_libya_con-
flict.
20 The al-Abbas Brigade later integrated into the 35th Armored Brigade is a group of Salafi allegiance and have benefited from
Saudi Arabian and Emirati financial support. Its leader, Abu al-Abbas, was designated as terrorist by the United States in October
2017. See Nicolas A. Heras, Securing Southern Yemen for the UAE: Abu al-Abbas and the Battle for Taiz, 9 MILITANT LEADERSHIP
MONITOR 5 (June 6, 2018), https://jamestown.org/brief/securing-southern-yemen-for-the-uae-abu-al-abbas-and-the-battle-for-
taiz/.
21 See generally Cheikhmous Ali, Special Report Current Status of the Syrian Museums 2011-2020, ASSOCIATION FOR THE
PROTECTION OF SYRIAN ARCHEOLOGY (2020), https://www.academia.edu/43428817/Special_Report_Current_Status_of_the_syri-
ans_museums_2011_2020.
22 Looted items taken from the International Council of Museums “Red List,” which includes examples and images of the
Syrian artifacts most in danger of being trafficked due to their value on the illicit antiquities market. Emergency Red List of Syrian
Cultural Objects at Risk, INT’L COUNCIL OF MUSEUMS (2013), https://icom.museum/en/ressource/emergency-red-list-of-syrian-
104
cultural-objects-at-risk/ (also available in French, German, Arabic, Turkish, and Swedish).
23 See Previous Damage Newsletters, HERITAGE FOR PEACE, https://www.heritageforpeace.org/syria-culture-and-heritage/
damage-to-cultural-heritage/previous-damage-newsletters/ (last accessed May 17, 2022).
24 See Updates from the Field, ASOR’S CULTURAL HERITAGE INITIATIVES, http://www.asor.org/chi/reports/weekly-monthly
(last accessed May 17, 2022).
25 See Jesse Casana, Satellite Imagery-Based Analysis of Archaeological Looting in Syria, 78(3) NEAR EASTERN ARCHAEOLO-
GY 142, 147 (2015), https://www.journals.uchicago.edu/doi/pdf/10.5615/neareastarch.78.3.0142; Jesse Casana, Elise Jakoby Laugier &
Peter F. Biehl, Satellite Imagery-based Monitoring of Archaeological Site Damage in the Syrian Civil War, 12(11) PLOS ONE 11–14 (Nov.
30, 2017), https://dx.plos.org/10.1371/journal.pone.0188589.
26 Jesse Casana, Elise Jakoby Laugier & Peter F. Biehl, Satellite Imagery-based Monitoring of Archaeological Site Damage in
the Syrian Civil War, 12(11) PLOS ONE 19 (Nov. 30, 2017), https://dx.plos.org/10.1371/journal.pone.0188589; Jesse Casana, Satellite
Imagery-Based Analysis of Archaeological Looting in Syria, 78(3) NEAR EASTERN ARCHAEOLOGY 142, 149–50 (2015), https://www.
journals.uchicago.edu/doi/pdf/10.5615/neareastarch.78.3.0142.
27 Jesse Casana, Elise Jakoby Laugier & Peter F. Biehl, Satellite Imagery-based Monitoring of Archaeological Site Damage in
the Syrian Civil War, 12(11) PLOS ONE 19 (Nov. 30, 2017), https://dx.plos.org/10.1371/journal.pone.0188589; Jesse Casana, Satellite
Imagery-Based Analysis of Archaeological Looting in Syria, 78(3) NEAR EASTERN ARCHAEOLOGY 142, 149–50 (2015), https://www.
journals.uchicago.edu/doi/pdf/10.5615/neareastarch.78.3.0142.
28 See Damage Newsletter March 26, 2014, HERITAGE FOR PEACE (Mar. 26, 2014), http://www.heritageforpeace.org/wp-con-
tent/uploads/2014/03/26-March-2014.pdf; Sammy Ketz, War, the Latest Visitor to Syria’s Fabled Palmyra, AFP (Mar. 16, 2014), https://
sg.news.yahoo.com/war-latest-visitor-syrias-fabled-palmyra-195450072.html.
29 Cheikhmous Ali, Special Report: Palmyra: Heritage Adrift (2015), http://www.asor.org/wp-content/uploads/2019/09/Palmy-
ra_Heritage_Adrift.pdf.
30 Sammy Ketz, War, the Latest Visitor to Syria’s Fabled Palmyra, AFP (Mar. 16, 2014), https://sg.news.yahoo.com/war-lat-
est-visitor-syrias-fabled-palmyra-195450072.html.
31 See Photos: Vandalism in Artaban Tomb in Palmyra, SYRIAN DIRECTORATE-GENERAL OF ANTIQUITIES (Nov. 11, 2014),
https://web.archive.org/web/20150729015515/http://www.dgam.gov.sy/?d=314&id=1483 (including photographs). See also SHI14
073, ASOR CHI - 2014 WEEKLY REPORT 13, 28–33 (Nov. 3, 2014) (including photographs), http://www.asor.org/wp-content/up-
loads/2019/09/ASOR_CHI_Weekly_Report_13r.pdf; SHI 15 0058, ASOR CHI - 2015 WEEKLY REPORT 34, 42–52 (Mar. 30, 2015), http://
www.asor.org/wp-content/uploads/2019/09/ASOR_CHI_Weekly_Report_34r.pdf (including photographs).
32 See, e.g., ISIS destroyed antiquities . . . or did it?, CNN (Mar. 13, 2017), https://www.cnn.com/videos/world/2017/03/13/iraq-
museum-artifacts-destroyed-by-isis-wedeman-pkg.cnn (including 16 videos as part of CNN’s ISIS destroys antiquities reports); ISIS
Destroys Mosul Museum Artifacts, N.Y. TIMES (Feb. 26, 2015), https://www.nytimes.com/video/world/middleeast/100000003537753/
isis-destroys-mosul-museum-artifacts.html; Alyssa Buffenstein, A Monumental Loss: Here Are the Most Significant Cultural Her-
itage Sites That ISIS Has Destroyed to Date, ARTNET NEWS (May 30, 2017), https://news.artnet.com/art-world/isis-cultural-heri-
tage-sites-destroyed-950060.
33 Satellite-based Damage Assessment to Cultural Heritage Sites in Syria, UNITAR & UNOSAT (2014), https://unosat.web.cern.
ch/unitar/downloads/chs/FINAL_Syria_WHS.pdf.
34 See, e.g., Ruth Maclean, Desecrated But Still Majestic: Inside Palmyra After Second Isis Occupation, GUARDIAN (Mar. 9,
2017), https://www.theguardian.com/world/2017/mar/09/inside-palmyra-syria-after-second-isis-islamic-state-occupation.
35 See, e.g., Kevin Beesley, Ancient City of Palmyra After ISIS Was Driven Out, NPR (Mar. 28, 2016), https://www.npr.org/sec-
tions/thetwo-way/2016/03/28/472143732/isis-pulls-out-of-palmyra-leaves-destruction-in-its-wake.
36 See SHI 16-0044, ASOR CHI - 2016 WEEKLY REPORT 87–88, 108–28 (Mar. 30 – Apr. 12, 2016), http://www.asor.org/wp-con-
tent/uploads/2019/09/ASOR_CHI_Weekly_Report_87%E2%80%9388r.pdf (including satellite images). See also Special Report: The
Recapture of Palmyra (Mar. 2016), http://www.asor.org/wp-content/uploads/2019/09/NEW2_PalmyraSpecialReport3-FINAL.pdf.
37 See Andrew Lawler, Ancient Sites Savaged in Yemen, Iraq: Firsthand Accounts Reveal Worse Damage Than Expected in War-
Torn Regions, 360(6385) SCIENCE 140, 140–41 (Apr. 13, 2018), https://science.sciencemag.org/content/360/6385/140.full. For satellite
analysis, see Satellite-based Damage Assessment to Cultural Heritage Sites in Syria, UNITAR & UNOSAT (2014), https://unosat.web.
cern.ch/unitar/downloads/chs/FINAL_Syria_WHS.pdf; Ancient History, Modern Destruction: Assessing the Status of Syria’s Ten-
tative World Heritage Sites Using High-Resolution Satellite Imagery, AM. ASS’N FOR THE ADVANCEMENT OF SCIENCE (2014),
https://www.aaas.org/resources/ancient-history-modern-destruction-assessing-status-syria-s-tentative-world-heritage-sites-7.
38 Satellite-based Damage Assessment to Cultural Heritage Sites in Syria, UNITAR & UNOSAT 79 (2014), https://unosat.web.
cern.ch/unitar/downloads/chs/FINAL_Syria_WHS.pdf.
39 See Fiona Greenland et al., A Site-Level Market Model of the Antiquities Trade, 26 INT’L J. OF CULTURAL PROPERTY 21,
35 (2019), https://www.cambridge.org/core/services/aop-cambridge-core/content/view/2645FD36F1E0765DC152CD76DF2BAA09/
S0940739119000018a.pdf/a-site-level-market-model-of-the-antiquities-trade.pdf. The experts use a machine-learning approach to
create an algorithm that predicts the distribution channel, lot packaging, and estimated sale price of objects based on observable
characteristics and then applied the algorithm to estimate the value of illegally excavated Syrian archaeological sites where a large
number of artifacts have been illegally excavated and documented. The sites are Dura Europos and Tell Bi’a.
40 See Damage Newsletter May 8, 2014, HERITAGE FOR PEACE (May 8, 2014), http://www.heritageforpeace.org/syria-cul-
ture-and-heritage/damage-to-cultural-heritage/previous-damage-newsletters/damage-to-syrias-heritage-08-may-2014/. See also
105 105
Satellite-based Damage Assessment to Cultural Heritage Sites in Syria, UNITAR & UNOSAT 76 (2014), https://unosat.web.cern.ch/
unitar/downloads/chs/FINAL_Syria_WHS.pdf.
41 Fiona Greenland et al., A Site-Level Market Model of the Antiquities Trade, 26 INT’L J. OF CULTURAL PROPERTY 21, 31
(2019), https://www.cambridge.org/core/services/aop-cambridge-core/content/view/2645FD36F1E0765DC152CD76DF2BAA09/
S0940739119000018a.pdf/a-site-level-market-model-of-the-antiquities-trade.pdf.
42 Was most of the looting at the most extensively looted site in Syria conducted under the Islamic State or the Free Syrian
Army?, CONFLICT ANTIQUITIES (Mar. 12, 2015), https://conflictantiquities.wordpress.com/2015/03/12/syria-islamic-state-free-syri-
an-army-paramilitary-funding-dura-europos/.
43 Fiona Greenland et al., A Site-Level Market Model of the Antiquities Trade, 26 INT’L J. OF CULTURAL PROPERTY 21, 31
(2019), https://www.cambridge.org/core/services/aop-cambridge-core/content/view/2645FD36F1E0765DC152CD76DF2BAA09/
44 See Fiona Greenland et al., A Site-Level Market Model of the Antiquities Trade, 26 INT’L J. OF CULTURAL PROPERTY 21,
31 (2019), https://www.cambridge.org/core/services/aop-cambridge-core/content/view/2645FD36F1E0765DC152CD76DF2BAA09/
45 See Latest News on Dura Europos, SYRIAN DIRECTORATE-GENERAL OF ANTIQUITIES (Oct. 31, 2016), https://web.
archive.org/web/20200929190337/http://www.dgam.gov.sy/index.php?d=314&id=2093. See also SHI 16-0161, ASOR CHI - 2016
WEEKLY REPORT 117–118, 15–17 (Nov. 1–15, 2016), http://www.asor.org/wp-content/uploads/2019/09/ASOR_CHI_Weekly_Re-
port_117%E2%80%93118r.pdf (including satellite images).
46 See SHI 14-080, ASOR CHI - 2014 WEEKLY REPORT 15, 9–10 (Nov. 17, 2014), http://www.asor.org/wp-content/up-
loads/2019/09/ASOR_CHI_Weekly_Report_15r.pdf (including satellite images); Mary Shepperson, Destruction at the Ancient Site of
Mari in Syria, GUARDIAN (Apr. 19, 2018), https://www.theguardian.com/science/2018/apr/19/destruction-at-the-ancient-site-of-
mari-in-syria?CMP=twt_gu.
47 See Ancient History, Modern Destruction: Assessing the Status of Syria’s Tentative World Heritage Sites Using High-Reso-
lution Satellite Imagery, AM. ASS’N FOR THE ADVANCEMENT OF SCIENCE (2014), https://www.aaas.org/resources/ancient-histo-
ry-modern-destruction-assessing-status-syria-s-tentative-world-heritage-sites-7.
48 See Satellite-based Damage Assessment to Cultural Heritage Sites in Syria, UNITAR & UNOSAT (2014), https://unosat.web.
49 See Andrew Lawler, Ancient Sites Savaged in Yemen, Iraq: Firsthand Accounts Reveal Worse Damage Than Expected in War-
Torn Regions, 360(6385) SCIENCE 140, 140–41 (Apr. 13, 2018), https://science.sciencemag.org/content/360/6385/140.full. For satellite
analysis, see Satellite-based Damage Assessment to Cultural Heritage Sites in Syria, UNITAR & UNOSAT (2014), https://unosat.web.
50 The Docket’s sources indicate that Daesh was in control of Mari from around late June/early July 2014 until November 2017,
at which point the Syrian government and affiliated forces took over nearby Abu Kamal once Daesh retreated.
51 See SHI 17‐0140, ASOR CHI - 2017 08 AUGUST MONTHLY REPORT, Appendices, 30–32 (Aug. 2017), http://www.asor.org/
wp-content/uploads/2019/09/ASOR_CHI_August17_Appendices.pdf (including satellite images).
52 See generally Cheikhmous Ali, Special Report Current Status of the Syrian Museums 2011-2020, ASSOCIATION FOR THE
PROTECTION OF SYRIAN ARCHEOLOGY (2020), https://www.academia.edu/43428817/Special_Report_Current_Status_of_the_syri-
ans_museums_2011_2020.
53 See Samar Kadi, World Heritage in Syria and Libya Agonising Under the World’s Idle Eyes, ARAB WEEKLY (Apr. 8, 2018),
https://thearabweekly.com/world-heritage-syria-and-libya-agonising-under-worlds-idle-eyes.
54 See SHI 14-041, ASOR CHI - 2014 WEEKLY REPORT 9, 10–24 (Oct. 6, 2014), http://www.asor.org/wp-content/up-
loads/2019/09/ASOR_CHI_Weekly_Report_09r.pdf (including photographs).
55 See SHI 17-0106, ASOR CHI - 2017 JUNE MONTHLY REPORT, Appendices, 58–60 (June 2017), http://www.asor.org/wp-con-
tent/uploads/2019/09/ASOR_CHI_Monthly_Appendices_072017r.pdf (including satellite images and photographs); Special Report:
Current Status of the Raqqa Museum, ASOR CHI (Jan. 5, 2018), http://www.asor.org/wp-content/uploads/2019/09/DOS-SPECIAL-
REPORT-%E2%80%93-Raqqa-Museum-Status-Report-2018.pdf; SHI 17-0106 Update, ASOR CHI - 2017 SEPTEMBER MONTHLY
REPORT, Appendices, 34–35, http://www.asor.org/wp-content/uploads/2019/09/ASOR_CHI_September17_Appendices.pdf (including
photographs).
56 See SHI 15-0075, ASOR CHI - 2015 WEEKLY REPORT 38, 34–36 (Apr. 27, 2015), http://www.asor.org/wp-content/up-
loads/2019/09/ASOR_CHI_Weekly_Report_38r.pdf (including photographs).
57 The identification of the basalt face of a head of a statue, taken from the temple of Ishtar at Ain Dara archaeological site, was
made by a Syrian archaeologist familiar with the site who is working with The Docket.
58 See Syria: Turkish Ground Troops Enter Afrin Enclave, BBC NEWS (Jan. 21, 2018), https://www.bbc.com/news/world-mid-
dle-east-42765697.
59 See Erika Engelhaupt, Iconic Ancient Temple is Latest Victim in Civil War, NATIONAL GEOGRAPHIC (Jan. 30, 2018), https://
www.nationalgeographic.com/history/article/syria-temple-ain-dara-destroyed-archaeology.
106
ex A.2. includes maps, graphs, and graphics depicting incidents of pillage as well as the position of armed groups, particularly in Syria within the last decade. All images are taken
ublicly available sources and all sources are noted in the caption of each image. Captions include a description of the maps, taken either from the source (indicated with quotatio
60 Hum. Rights Council, 21st Report of the Commission of Inquiry on the Syrian Arab Republic, ¶ 63, U.N. Doc. A/HRC/45/31
(Aug. 14, 2020), https://undocs.org/A/HRC/45/31.
61 Bassem Mroue, Jewish Artifacts Disappear from Damascus in Fog of Syria War, AP NEWS (June 18, 2018), https://apnews.
com/article/58077d7bfb9e4bc2b0d67c5cc95b8b0f; JOSEPH W. MERI, THE CULT OF SAINTS AMONG MUSLIMS AND JEWS IN ME-
DIEVAL SYRIA 33 (OUP 2002).
62 Opposition and Regime Forces Took Turns Looting Eliyahu Hanavi Synagogue, Jobar, SYRIANS FOR TRUTH AND JUSTICE
(2019), https://stj-sy.org/en/opposition-and-regime-forces-took-turns-looting-eliyahu-hanavi-synagogue-jobar/.
63 Cheikhmous Ali, Special Report Current Status of the Syrian Museums 2011-2020, ASSOCIATION FOR THE PROTECTION
AN-
OF SYRIAN ARCHEOLOGY 16 (2020), https://www.academia.edu/43428817/Special_Report_Current_Status_of_the_syrians_muse-

ums_2011_2020.
NEX A.2.
64 See SHI 18-0138 Heritage Response Report, ASOR CHI - 2018 SEPTEMBER MONTHLY, Appendices, 35–36 (Sept. 2018),
http://www.asor.org/wp-content/uploads/2020/07/ASOR_CHI_September18_Appendices.pdf.
65 See SHI 16-0032, ASOR CHI - 2016 WEEKLY REPORT 81–82, 20–74 (Feb. 17 – Mar. 1, 2016), http://www.asor.org/wp-con-
tent/uploads/2019/09/ASOR_CHI_Weekly_Report_81%E2%80%9382r.pdf (including detailed description of the looting and destruc-
tion of all churches and accompanying before and after photographs); SHI 16 0032 Update, ASOR CHI - 2016 WEEKLY REPORT
93–94, 28–29 (May 11 –245, 2016), http://www.asor.org/wp-content/uploads/2019/09/ASOR_CHI_Weekly_Report_93%E2%80%9394r.
pdf (including photographs).
Maps of Pillage Incidents and Armed Groups
66 See SHI 16-0032, ASOR CHI - 2016 WEEKLY REPORT 81–82, 20–74 (Feb. 17 – Mar. 1, 2016), http://www.asor.org/wp-con-
tent/uploads/2019/09/ASOR_CHI_Weekly_Report_81%E2%80%9382r.pdf (including detailed description of the looting and destruc-
tion of all churches and accompanying before and after photographs); SHI 16 0032 Update, ASOR CHI - 2016 WEEKLY REPORT
93–94, 28–29 (May 11 –245, 2016), http://www.asor.org/wp-content/uploads/2019/09/ASOR_CHI_Weekly_Report_93%E2%80%9394r.
pdf (including photographs).
67 The Docket interview, Iraq, November 2021.
68 See New Damage at Samaan Castle, SYRIAN DIRECTORATE-GENERAL OF ANTIQUITIES (Nov. 14, 2014), https://web.
archive.org/web/20150729015520/http://www.dgam.gov.sy/?d=314&id=1497. See also SHI 14-079, ASOR CHI - 2014 WEEKLY REPORT
15, 7–8 (Nov. 17, 2014), http://www.asor.org/wp-content/uploads/2019/09/ASOR_CHI_Weekly_Report_15r.pdf (including photograph).
69 See SHI 15-0069, ASOR CHI - 2015 WEEKLY REPORT 37, 23–24 (Apr. 20, 2015), http://www.asor.org/wp-content/up-
loads/2019/09/ASOR_CHI_Weekly_Report_37r.pdf; SHI 15-0162, ASOR CHI - 2015 WEEKLY REPORT 71–72, 29–31 (Dec. 9–22, 2015),
ge numbers) or as summarized by The Docket based on information from the source document.
http://www.asor.org/wp-content/uploads/2019/09/ASOR-CHI-weekly-report-71%E2%80%9372r.pdf.
70 See SHI 18-0073, ASOR CHI - 2018 MARCH MONTHLY REPORT (Mar. 2018), http://www.asor.org/wp-content/up-
loads/2019/08/ASOR_CHI_March18_Report.pdf.
71 See SHI 18-0090, ASOR CHI - 2018 APRIL MONTHLY REPORT, Appendices, 65–67 (Apr. 2018), http://www.asor.org/wp-con-
tent/uploads/2019/08/ASOR_CHI_April18_Appendices.pdf (including photographs).
72 See SHI 18-0161, ASOR CHI - 2018 JULY MONTHLY REPORT, Appendices, 11–18 (July 2018), http://www.asor.org/wp-con-
tent/uploads/2020/07/ASOR_CHI_July18_Appendices.pdf (including photographs).
73 See SHI 18-0090 Update, ASOR CHI - 2018 OCTOBER MONTHLY REPORT, Appendices, 6–19 (Oct 2018), http://www.asor.
org/wp-content/uploads/2020/07/ASOR_CHI_October18_Appendices.pdf (including photographs and satellite images).
74 Hum. Rights Council, 21st Report of the Commission of Inquiry on the Syrian Arab Republic, ¶ 64, U.N. Doc. A/HRC/45/31
(Aug. 14, 2020), https://undocs.org/A/HRC/45/31.
75 Looted items taken from the International Council of Museums “Red List,” which includes examples and images of the Iraqi
artifacts most in danger of being trafficked due to their value on the illicit antiquities market. Emergency Red List of Iraqi Antiquities
at Risk, INT’L COUNCIL OF MUSEUMS (2018), https://icom.museum/en/ressource/emergency-red-list-of-iraqi-antiquities-at-risk/
(also available in French and Arabic). See also Emergency Red List of Iraqi Cultural Objects at Risk – 2015 Update, INT’L COUNCIL
OF MUSEUMS (2015), https://icom.museum/en/ressource/emergency-red-list-of-iraqi-cultural-objects-at-risk-2015-update/ (also
available in French, German, Arabic, Turkish, and Swedish).
76 Shia militias are part of the Popular Mobilization Forces, an umbrella organization comprising of various Iraq and Iran
sponsored militias that have fought against Daesh throughout Iraq and Syria. See Priyanka Boghani, Iraq’s Shia Militias: The Dou-
ble-Edged Sword Against ISIS, FRONTLINE (Mar. 21, 2017), https://www.pbs.org/wgbh/frontline/article/iraqs-shia-militias-the-dou-
ble-edged-sword-against-isis/. Some of the militias have been linked to human rights abuses and war crimes. See Iraq: Possible War
Crimes by Shia Militia, HUMAN RIGHTS WATCH (Jan. 31, 2016), https://www.hrw.org/news/2016/01/31/iraq-possible-war-crimes-
shia-militia#; Absolute Impunity: Militia Rule in Iraq, AMNESTY INT’L (2014), https://www.amnesty.org.uk/files/absolute_impuni-
ty_iraq_report.pdf.
77 Update: Mosul Post-ISIL: Heritage Destruction and the Future of the City, ASOR CULTURAL HERITAGE INITIATIVES,
http://www.asor.org/chi/announcements/updates/Mosul-Post-ISIL-Heritage-Destruction-and-the-Future-of-the-City. See also IHI
16-0010, ASOR CHI WEEKLY REPORT 89–90, 60–66 (Apr. 13–26, 2016), http://www.asor.org/wp-content/uploads/2019/09/ASOR_
CHI_Weekly_Report_89%E2%80%9390r.pdf.
78 See IHI 16-0013, ASOR CHI - 2016 WEEKLY REPORT 91–92, 93–104 (Apr. 27 - May 10, 2016), http://www.asor.org/wp-con-
tent/uploads/2019/09/ASOR_CHI_Weekly_Report_91%E2%80%9392r.pdf (including photographs and maps); Update: Mosul Post-ISIL:
Heritage Destruction and the Future of the City, ASOR CULTURAL HERITAGE INITIATIVES, http://www.asor.org/chi/announce-
ments/updates/Mosul-Post-ISIL-Heritage-Destruction-and-the-Future-of-the-City.
107
looted sites between 2011-2016 against ISIS territory in Syria and Iraq. Demonstrates large extent of ISIS looting as well as looting by other parties (Syrian arm
79 See IHI 15-0097 Update, ASOR CHI - 2017 APRIL MONTHLY REPORT, Appendices, 86–89 (Apr. 2017), http://www.asor.org/
wp-content/uploads/2019/09/ASOR_CHI_April17_Appendices_r.pdf (including pictures and satellite image of new road).
http://www.asor.org/chi/announcements/updates/Mosul-Post-ISIL-Heritage-Destruction-and-the-Future-of-the-City; IHI 16-
0010 Update, ASOR CHI - 2016 WEEKLY REPORT 101–102, 77–80 (July 20 – Aug. 2, 2016), http://www.asor.org/wp-content/up-
loads/2019/09/ASOR-CHI-Weekly-Report-103-104r.pdf (including satellite images).
ource: Jesse Casa- na & Elise Jakoby Laugier, Satellite Imagery-based Monitoring of Archaeological Site Damage in the Syrian Civil War, 12 PLOS ONE e0188589 (2017).
81 Nimrud was nominated as a tentative UNESCO site in 2000. See Nimrud, UNESCO WORLD HERITAGE CONVENTION,
https://whc.unesco.org/en/tentativelists/1463/ (last accessed Feb. 10, 2021).
82 See Satellite-Based Damage Assessment of Cultural Heritage Sites 2015 Summary Report of Iraq, Nepal, Syria & Yemen,
UNITAR & UNESCO 4 (June 2016), https://whc.unesco.org/en/activities/890/; IHI 15-0067 Update, ASOR CHI WEEKLY REPORT 34,
53–85 (Mar. 2015), https://www.asor.org/wp-content/uploads/2019/09/ASOR_CHI_Weekly_Report_34r.pdf (including satellite images
and photographs).
83 See IHI 17-0015, ASOR CHI WEEKLY REPORT 125–128, Appendices, 144 (Jan. 2017), http://www.asor-syrianheritage.org/
wp-content/uploads/2018/01/ASOR_CHI_January17_Appendices.pdf.
84 The Docket site visit and interviews, Nimrud, November 2021.
85 The Docket site visit and interviews, Hatra, November 2021.
15-0017, ASOR CHI - 2015 WEEKLY REPORT 30, 90–91 (Mar. 2, 2015), http://www.asor.org/wp-content/uploads/2019/09/ASOR_CHI_
Weekly_Report_30r.pdf.
87 See IHI 15-0017, ASOR CHI - 2015 WEEKLY REPORT 30, 90–91 (Mar. 2, 2015), http://www.asor.org/wp-content/up-
loads/2019/09/ASOR_CHI_Weekly_Report_30r.pdf.
88 Laura C. Mallonee, 8,000 Books and Manuscripts Lost After ISIS Bombs Mosul Library, HYPERALLERGIC (Feb. 25, 2015),
https://hyperallergic.com/185590/8000-books-and-manuscripts-lost-after-isis-bombs-mosul-library/.
89 The Docket interviews, Mosul, November 2021.
15-0034 Update, ASOR CHI WEEKLY REPORT 31, 58–79 (Mar. 9, 2015), http://www.asor.org/wp-content/uploads/2019/09/ASOR_
CHI_Weekly_Report_31r.pdf (including pictures and video captures).
91 See Suadad al-Salhy, The Full Story Behind ISIL’s Takeover of Mosul Museum, AL JAZEERA (Mar. 9, 2015), https://www.alja-
zeera.com/features/2015/3/9/the-full-story-behind-isils-takeover-of-mosul-museum.
92 See Joshua Hammer, The Salvation of Mosul, SMITHSONIAN MAGAZINE (Oct. 2017), https://www.smithsonianmag.com/
history/salvation-mosul-180964772/.
93 The Docket site visit and interviews, Mosul, November 2021.
94 See IHI 17-0039, ASOR CHI - 2017 JUNE MONTHLY REPORT, Appendices, 111–13 (June 2017), http://www.asor.org/wp-con-
tent/uploads/2019/09/ASOR_CHI_Monthly_Appendices_072017r.pdf.
95 See Destroying the Soul of the Yazidis: Cultural Heritage Destruction During the Islamic State’s Genocide Against the
Yazidis, RASHID INT’L (Aug. 2, 2019), https://rashid-international.org/publications/report-destroying-the-soul-of-the-yazidis/.
96 See ‘They came to destroy’: ISIS Crimes Against the Yazidis, Conference Room Paper, U.N. IND. INT’L COMM OF INQUIRY,
A/HRC/32/CRP.2 (June 15, 2016), https://www.ohchr.org/Documents/HRBodies/HRCouncil/CoISyria/A_HRC_32_CRP.2_en.pdf.
97 The Docket interviews, Duhok, November 2021.
98 For example, between August and September 2014, the destruction of the oldest Christian monastery in Iraq, Dair Mar Elia
deemed heretical by Daesh fighters. Claire Voon, Satellite Images Confirm the Destruction of Iraq’s Oldest Christian Monastery by
ISIS, HYPERALLERGIC (Jan. 20, 2016), https://hyperallergic.com/269367/satellite-images-confirm-the-destruction-of-iraqs-old-
est-christian-monastery-by-isis/
99 See IHI 17-0005 Update, ASOR CHI - 2017 MARCH MONTHLY REPORT, Appendices, 104–11 (Mar. 2017), http://www.asor.
org/wp-content/uploads/2019/09/ASOR_CHI_March17_Appendices.pdf (including photographs); IHI 17 0005, ASOR CHI - 2017
and opposition groups).
JANUARY MONTHLY REPORT, Appendices, 85–94 (Jan. 2017), http://www.asor.org/wp-content/uploads/2019/09/ASOR_CHI_Jan-

uary17_Appendices.pdf. Daesh also intentionally destroyed the site in 2014, in line with its practice of both pillaging and destroying
cultural heritage sites. Id.
100 See IHI 17-0005 Update, ASOR CHI - 2017 MARCH MONTHLY REPORT, Appendices, 104–11 (Mar. 2017), http://www.asor.
org/wp-content/uploads/2019/09/ASOR_CHI_March17_Appendices.pdf (including photographs).
101 See IHI 17-0027, ASOR CHI - 2017 MAY MONTHLY REPORT, Appendices, 107–10 (May 2017), http://www.asor.org/wp-con-
tent/uploads/2019/09/ASOR_CHI_May17_Monthly_Appendices.pdf (including photographs).
102 See IHI 17-0046, ASOR CHI - 2017 JUNE MONTHLY REPORT, Appendices, 151–53 (June 2017), http://www.asor.org/wp-con-
tent/uploads/2019/09/ASOR_CHI_Monthly_Appendices_072017r.pdf.
103 See IHI 16-0035 Update, ASOR CHI - 2016 WEEKLY REPORT 117–118, 33–35 (Nov. 1–15, 2016), http://www.asor.org/wp-con-
Map depicting
forces
tent/uploads/2019/09/ASOR_CHI_Weekly_Report_117%E2%80%93118r.pdf (including photographs).

104 See IHI 16-0031, ASOR CHI - 2016 WEEKLY REPORT 113–114, 27–32 (Oct. 1–15, 2016), http://www.asor.org/wp-content/up-
loads/2019/09/ASOR_CHI_Weekly_Report_113%E2%80%93114r.pdf (including photographs and satellite images).
108
105 See IHI 15-0101, ASOR CHI - 2016 WEEKLY REPORT 73–74, 46–52 (Dec. 23, 2015 – Jan. 5, 2016), http://www.asor.org/
wp-content/uploads/2019/09/ASOR-CHI-weekly-report-73%E2%80%9374r.pdf (including photographs).
106 Looted items taken from the International Council of Museums “Red List,” which includes examples and images of the
Libyan artifacts most in danger of being trafficked due to their value on the illicit antiquities market. Emergency Red List of Libyan
Cultural Objects at Risk, INT’L COUNCIL OF MUSEUMS (2015), https://icom.museum/en/ressource/emergency-red-list-of-libyan-
cultural-objects-at-risk/ (also available in French, German, and Arabic).
107 See Archaeological Site of Cyrene, UNESCO WORLD HERITAGE CONVENTION, https://whc.unesco.org/en/list/190/ (last
accessed Jan. 20, 2021).
108 Morgan Belzic, Les sculptures funéraires de Cyrénaïque sur le marché de l’art, 48 LIBYAN STUDIES 105–116 (2017), https://
www.researchgate.net/publication/320168375_Les_sculptures_funeraires_de_Cyrenaique_sur_le_Marche_de_l’art.
109 See generally Henrik Gratrud & Vidar Benjamin Skretting, Ansar al-Sharia in Libya: An Enduring Threat, 11(1) PERSPEC-
TIVES ON TERRORISM 40 (Feb. 2017), https://www.universiteitleiden.nl/binaries/content/assets/customsites/perspectives-on-ter-
rorism/2017/issue-1/0520171-ansar-al-sharia-in-libya-an-enduring-threat-by-henrik-gratrud-and-vidar-benjamin-skretting.pdf;
Mary Fitzgerald & Toaldo Mattia, A quick guide to Libya’s main players – European Council on Foreign Relations, ECFR (May 19,
2016), https://ecfr.eu/special/mapping_libya_conflict/.
110 Jean-Luc Martinez, Cinquante propositions françaises pour protéger le patrimoine de l’humanité, RAPPORT AU PRES-
IDENT DE LA REPUBLIQUE 17 (Nov. 2015), https://www.culture.gouv.fr/Espace-documentation/Rapports/Cinquante-proposi-
tions-francaises-pour-proteger-le-patrimoine-de-l-humanite.
111 Report: The State of Illicit Trade and Looting of Libyan Antiquities: 2011-2020, AMERICAN SCHOOL FOR ORIENTAL RE-
SEARCH 50 (Dec. 31, 2020), http://www.asor.org/wp-content/uploads/2021/01/Looted-Antiquities-Libya-ASOR-Report-reduced-size.
pdf. The five jars have been well documented and the Appendix provides detailed descriptions and photographs of the objects. See
Report: The State of Illicit Trade and Looting of Libyan Antiquities: 2011-2020, Appendix, AMERICAN SCHOOL FOR ORIENTAL RE-
SEARCH 118–21 (Dec. 31, 2020), http://www.asor.org/wp-content/uploads/2021/01/Looted-Antiquities-Libya-ASOR-appendices-FI-
nal.pdf.
pdf.
pdf.
pdf.
115 See Mustafa Fetouri, How Libyans are Reviving Their Heritage, One Building at a Time, AL-MONITOR (June 6, 2016), https://
www.al-monitor.com/originals/2016/06/libya-heritage-sites-destruction-looting.html.
pdf.
pdf.
118 See Sufi Cultural Sites Targeted Amid Ongoing Civil War in Libya, DAILY SABAH (Mar. 16, 2020), https://www.dailysabah.
com/politics/sufi-cultural-sites-targeted-amid-ongoing-civil-war-in-libya/news.
119 Laurent Ribadeau Dumas, Patrimoine libyen: SOS chefs d’oeuvre en péril, FRANCEINFO AFRIQUE (Dec. 27, 2015), https://
www.francetvinfo.fr/monde/afrique/libye/patrimoine-libyen-sos-chefs-d-oeuvre-en-peril_3066443.html.
120 Laurent Ribadeau Dumas, Patrimoine libyen: SOS chefs d’oeuvre en péril, FRANCEINFO AFRIQUE (Dec. 27, 2015), https://
www.francetvinfo.fr/monde/afrique/libye/patrimoine-libyen-sos-chefs-d-oeuvre-en-peril_3066443.html.
121 Libye: Tripoli dénonce la destruction de mausolées et promet la fermeté, LE POINT (Aug. 25, 2012), https://www.lepoint.fr/
monde/libye-tripoli-denonce-la-destruction-de-mausolees-et-promet-la-fermete-25-08-2012-1499218_24.php; Des images satellite
confirment la destruction du temple de Bêl, LA PRESSE (Aug. 30, 2015), https://www.lapresse.ca/international/dossiers/le-groupe-
etat-islamique/201508/30/01-4896442-des-images-satellite-confirment-la-destruction-du-temple-de-bel.php.
122 See Patrick Kingsley, Isis Vandalism Has Libya Fearing for its Cultural Treasures, GUARDIAN (Mar. 7, 2015), https://www.
theguardian.com/world/2015/mar/07/isis-destroy-libya-cultural-treasures.
123 L’UNESCO condamne le vandalisme du patrimoine religieux de la vieille ville de Tripoli, U.N. NEWS (Oct. 15, 2014), https://
news.un.org/fr/story/2014/10/298492-lunesco-condamne-le-vandalisme-du-patrimoine-culturel-et-religieux-de-la.
pdf.
125 See Laura Allsop, Looting of Libyan Treasure Highlights Illicit Antiquities Trade, CNN WORLD (Nov. 11, 2011), https://www.
cnn.com/2011/11/11/world/europe/looted-treasure-libya/index.html;
109
Mike Elkin, The Libyan Job: Insiders Used War to Steal Priceless Artifacts, WIRED (Mar. 16, 2012), https://www.wired.com/2012/03/
libyan-job/.
126 Donna Yates, Benghazi Treasure, TRAFFICKING CULTURE (Sept. 12, 2012), https://traffickingculture.org/encyclopedia/
case-studies/benghazi-treasure/.
127 Report: The State of Illicit Trade and Looting of Libyan Antiquities: 2011-2020, 49 ASOR, http://www.asor.org/wp-content/
uploads/2021/01/Looted-Antiquities-Libya-ASOR-Report-reduced-size.pdf.
128 See The Illicit Trade in Conflict Antiquities: Report from the Republic of Yemen, ANTIQUITIES COALITION & THE REPUB-
LIC OF YEMEN (Mar. 5, 2019), https://theantiquitiescoalition.org/publics-help-needed-to-recover-blood-antiquities/; The Degrada-
tion of History: Violations Committed by the Warring Parties against Yemen’s Cultural Property, MWATANA FOR HUMAN RIGHTS
(Nov. 2018), https://mwatana.org/wp-content/uploads/2018/12/The-Degradation-of-History-English.pdf; Exclusive – Houthis
Accused of Destroying Yemen’s History, Landmarks, ASHAR AL-AWSAT (May 18, 2019), https://english.aawsat.com/home/arti-
cle/1728156/exclusive-%E2%80%93-houthis-accused-destroying-yemen%E2%80%99s-history-landmarks.
129 See The Degradation of History: Violations Committed by the Warring Parties against Yemen’s Cultural Property, MWATA-
NA FOR HUMAN RIGHTS 93, 98 (Nov. 2018), https://mwatana.org/wp-content/uploads/2018/12/The-Degradation-of-History-En-
glish.pdf.
130 A report compiled by Yemeni archeologists and government officials in Arabic (translated into English by the Antiquities
Coalition) compiled data and items suspected to have been looted from the three major museums. See The Illicit Trade in Conflict
Antiquities: Report from the Republic of Yemen, ANTIQUITIES COALITION & THE REPUBLIC OF YEMEN (Mar. 5, 2019), https://
theantiquitiescoalition.org/publics-help-needed-to-recover-blood-antiquities/. Other examples of looted items taken from the
International Council of Museums “Red List,” which includes examples and images of the Yemeni artifacts most in danger of being
trafficked due to their value on the illicit antiquities market. Emergency Red List of Cultural Objects at Risk – Yemen, INT’L COUN-
CIL OF MUSEUMS (2018), https://icom.museum/en/ressource/emergency-red-list-of-cultural-objects-at-risk-yemen/ (also available
in French, German, Turkish, and Arabic).
131 Al Qaeda in the Arabian Peninsula (AQAP), also referred to as Ansar al-Sharia in Yemen, is a militant Sunni terrorist orga-
nization that is part of the al-Qaeda network. See Al Qaeda in the Arabian Peninsula, CENTER FOR INTERNATIONAL SECURITY
AND COOPERATION, https://cisac.fsi.stanford.edu/mappingmilitants/profiles/al-qaeda-arabian-peninsula (last accessed May 17,
2022). AQAP was designated as a terrorist organization by the U.N. Security Council on January 19, 2010. See Al-Qaida in the Arabian
Peninsula (AQAP), U.N. SECURITY COUNCIL, https://www.un.org/securitycouncil/sanctions/1267/aq_sanctions_list/summaries/en-
tity/al-qaida-in-the-arabian-peninsula-%28aqap%29 (last accessed May 17, 2022). S.C. Res. 1904 (Dec. 17, 2009), https://www.undocs.
org/S/RES/1904%20(2009).
132 Houthi militias, also referred to as the Ansar Allah group (Supporters of God), is an Islamic political movement that emerged
from northern Yemen and is the de facto group in power in northern Yemen. On January 11, 2021, the United States announced it
would designate Yemen’s Houthis as a terrorist group. US Designating Yemen’s Houthis a ‘Terrorist’ Group, AL JAZEERA (Jan. 11,
2021), https://www.aljazeera.com/news/2021/1/11/us-designating-yemens-houthis-a-terrorist-group.
133 See The Illicit Trade in Conflict Antiquities: Report from the Republic of Yemen, ANTIQUITIES COALITION & THE REPUB-
LIC OF YEMEN (Mar. 5, 2019), https://theantiquitiescoalition.org/publics-help-needed-to-recover-blood-antiquities/.
134 See Deborah Lehr & Ahmed Awad Bin Mubarak, Opinions: The U.S. Art Market for Stolen Antiquities from Yemen Must Be
Shut Down, WASHINGTON POST (Jan. 1, 2019), https://www.washingtonpost.com/opinions/the-us-art-market-for-stolen-antiqui-
ties-from-yemen-must-be-shut-down/2019/01/01/c3df44aa-db9d-11e8-85df-7a6b4d25cfbb_story.html; Tom Mashberg, Yemen Asks
U.S. for Help to Curb Smuggling of Looted Ancient Artifacts, N.Y. TIMES (Mar. 6, 2019), https://www.nytimes.com/2019/03/06/arts/
design/yemen-united-states-looted-artifacts.html.
135 See Yemeni Security Forces in Marib Thwart Attempts to Smuggle Ancient Statues, ARAB NEWS (Nov. 7, 2018), https://www.
arabnews.com/node/1400596/middle-east.
136 See The Illicit Trade in Conflict Antiquities: Report from the Republic of Yemen, ANTIQUITIES COALITION & THE RE-
PUBLIC OF YEMEN (Mar. 5, 2019), https://theantiquitiescoalition.org/publics-help-needed-to-recover-blood-antiquities/; The
Degradation of History: Violations Committed by the Warring Parties against Yemen’s Cultural Property, MWATANA FOR HUMAN
RIGHTS (Nov. 2018), https://mwatana.org/wp-content/uploads/2018/12/The-Degradation-of-History-English.pdf; Jérémie Schiette-
catte, Yémen. Un patrimoine vandalisé dans un pays en proie au chaos, PROCEEDINGS OF THE INTERNATIONAL CONFERENCE
ARCHAEOLOGY OF CONFLICT, ROUTES DE L’ORIENT, 63–88 (2019), https://halshs.archives-ouvertes.fr/halshs-02173209; Exclusive
– Houthis Accused of Destroying Yemen’s History, Landmarks, ASHAR AL-AWSAT (May 18, 2019), https://english.aawsat.com/home/
article/1728156/exclusive-%E2%80%93-houthis-accused-destroying-yemen%E2%80%99s-history-landmarks.
137 The Illicit Trade in Conflict Antiquities: Report from the Republic of Yemen, ANTIQUITIES COALITION & THE REPUBLIC
OF YEMEN (Mar. 5, 2019), https://theantiquitiescoalition.org/publics-help-needed-to-recover-blood-antiquities/.
138 Exclusive – Houthis Accused of Destroying Yemen’s History, Landmarks, ASHAR AL-AWSAT (May 18, 2019), https://english.
aawsat.com/home/article/1728156/exclusive-%E2%80%93-houthis-accused-destroying-yemen%E2%80%99s-history-landmarks.
NA FOR HUMAN RIGHTS 39 (Nov. 2018), https://mwatana.org/wp-content/uploads/2018/12/The-Degradation-of-History-English.
pdf.
NA FOR HUMAN RIGHTS 101 (Nov. 2018), https://mwatana.org/wp-content/uploads/2018/12/The-Degradation-of-History-English.
110
pdf.
141 The eyewitness later walked-back some of his statements, stating that the general confusion of the conflict made it unclear
to determine who took the antiquities from the museum. See The Degradation of History: Violations Committed by the Warring
Parties against Yemen’s Cultural Property, MWATANA FOR HUMAN RIGHTS 104 (Nov. 2018), https://mwatana.org/wp-content/up-
loads/2018/12/The-Degradation-of-History-English.pdf.
142 The Docket interview, remote, January 2021.
143 The Degradation of History: Violations Committed by the Warring Parties against Yemen’s Cultural Property, MWATANA
FOR HUMAN RIGHTS 98 (Nov. 2018), https://mwatana.org/wp-content/uploads/2018/12/The-Degradation-of-History-English.pdf.
144 The Degradation of History: Violations Committed by the Warring Parties against Yemen’s Cultural Property, MWATANA
FOR HUMAN RIGHTS 92–93 (Nov. 2018), https://mwatana.org/wp-content/uploads/2018/12/The-Degradation-of-History-English.
pdf.
145 Wes H. Cooper, The Dark Side of the Economy: A Comparative Analysis of the Islamic State’s Revenue Stream, 8 JOURNAL
OF TERRORISM RESEARCH 1, 34 (Feb. 2017), https://www.researchgate.net/publication/313544512_The_Dark_Side_of_the_Econo-
my_A_Comparative_Analysis_of_the_Islamic_State’s_Revenue_Streams; Marina Lostal, Islamic State and Illicit Traffic of Cultural
Property, in THE INTERNATIONAL CRIMINAL RESPONSIBILITY OF WAR’S FUNDERS AND PROFITEERS 130, 131 (2020), https://
ssrn.com/abstract=3696445.
146 In comparison, al-Qaeda was mostly funded by the private fortune of Osama Bin Laden and was a smaller organization than
Daesh. See Marina Lostal, Islamic State and Illicit Traffic of Cultural Property, in INTERNATIONAL CRIMINAL RESPONSIBILITY
OF WAR’S FUNDERS AND PROFITEERS 130 (2020), https://ssrn.com/abstract=3696445.
147 Blood Antiquities: The Devil is in the Demand, EU AML/CFT GLOBAL FACILITY (Mar. 30, 2021), https://www.global-aml-
cft.eu/blood-antiquities-the-devil-is-in-the-demand/; Marc-André Renold, The Legal and Illegal Trade in Cultural Property to and
Throughout Europe: Facts, Findings, and Legal Analysis, Engaging the European Art Market in the Fight against the Illicit Trafficking
of Cultural Property, Capacity-Building Conference held March 20–21, 2018, http://www.unesco.org/new/fileadmin/MULTIMEDIA/
HQ/CLT/images/630X300/Study_Prof_Renold_EN_02.pdf.
148 U.S. Department of State: Documenting ISIL Antiquities Trafficking, Remarks by Andrew Keller, Deputy Assistant Secretary
for Counter Threat Finance and Sanctions with the Bureau of Economic and Business Affairs at the U.S. Department of State (Sep. 29,
2015), https://2009-2017.state.gov/e/eb/rls/rm/2015/247739.htm.
149 Wes H. Cooper, The Dark Side of the Economy: A Comparative Analysis of the Islamic State’s Revenue Stream, 8 JOURNAL
OF TERRORISM RESEARCH 1, 37 (Feb. 2017).
150 Christophe Pacaud, Le Trafic d’œuvres d’Art, un Financement Important de Daesh, RTL, Sept. 20, 2015, https://www.rtl.fr/
actu/international/le-trafic-d-oeuvres-d-art-un-financement-important-de-daesh-7779786809.
151 Jean-Luc Martinez, Cinquante propositions françaises pour protéger le patrimoine de l’humanité, RAPPORT AU PRES-
IDENT DE LA REPUBLIQUE 34 (Nov. 2015), https://www.culture.gouv.fr/Espace-documentation/Rapports/Cinquante-proposi-
tions-francaises-pour-proteger-le-patrimoine-de-l-humanite.
152 Reuters, Seized Documents reveal Daesh’s “Department of War Spoils,” DAILY SABAH (Dec. 29, 2015), https://www.dailysa-
bah.com/mideast/2015/12/29/seized-documents-reveal-daeshs-department-of-war-spoils.
153 Aymenn Jawad Al-Tamimi, Unseen Documents from the Islamic State’s Diwan al-Rikaz, MIDDLE EAST FORUM (Oct. 12,
2015), https://www.meforum.org/5735/unseen-documents-from-the-islamic-state-diwan-al.
154 See, e.g., U.S. Department of State: Documenting ISIL Antiquities Trafficking, Presentation by Andrew Keller, Deputy
Assistant Secretary for Counter Threat Finance and Sanctions with the Bureau of Economic and Business Affairs at the U.S. Depart-
ment of State (Sep. 29, 2015), https://eca.state.gov/files/bureau/final_presentation_to_met_on_isil_antiquities_trafficking_for_das_
keller_9.29.2015_.pdf; Aymenn Jawad Al-Tamimi, Unseen Documents from the Islamic State’s Diwan al-Rikaz, MIDDLE EAST FO-
RUM (Oct. 12, 2015), https://www.meforum.org/5735/unseen-documents-from-the-islamic-state-diwan-al; Katie A. Paul, How Daesh
Turns Illicit Digs Into Dollars, ANTIQUITIES COALITION (Nov. 8, 2016), https://theantiquitiescoalition.org/how-daesh-turns-illicit-
digs-into-dollars/; Martin Chulov, How an Arrest in Iraq Revealed Isis’s $2bn Jihadist Network, GUARDIAN (June 15, 2014), https://
www.theguardian.com/world/2014/jun/15/iraq-isis-arrest-jihadists-wealth-power. Besides financial, pillage and destruction also
feed into Daesh’s ideology. See Christopher W. Jones, Understanding ISIS’s Destruction of Antiquities as a Rejection of Nationalism,
6 J. OF EASTERN MEDITERRANEAN ARCHEOLOGY & HERITAGE STUDIES 1–2, 31 (2018) (linking ISIS’s destruction of antiquities
with the group’s rejection of the idea of a nation-state), https://www.jstor.org/stable/10.5325/jeasmedarcherstu.6.1-2.0031?seq=1;
Helga Turku, When Cultural Property Becomes a Tool of Warfare: Law, Politics, and International Security, 1 INTER GENTES 2, 3
(2017), https://intergentes.com/wp-content/uploads/2017/07/cultural-property-becomes-a-tool-of-warfare-law-politics-and-inter-
national-security_helga-turku.pdf; Joseph Josy Lévy & Alain Cohen, Les vestigicides contemporains ou la ruine des ruines, FRON-
TIÈRES (Feb. 2, 2017), https://www.erudit.org/fr/revues/fr/2016-v28-n1-fr02922/1038866ar/.
155 Aymenn Jawad Al-Tamimi, Unseen Documents from the Islamic State’s Diwan al-Rikaz, MIDDLE EAST FORUM (Oct. 12,
2015), https://www.meforum.org/5735/unseen-documents-from-the-islamic-state-diwan-al.
156 Olivier Moos, Antiquities Trafficking in Syria: Salafists, Tomb Raiders and “Buried Treasures,” RELIGIOSCOPE 17, 40 (2020),
https://english.religion.info/wp-content/uploads/2020/02/2020_02_Moos_Antiquities_Syria.pdf.
157 See MATTHEW SARGENT ET AL., TRACKING AND DISRUPTING THE ILLICIT ANTIQUITIES TRADE WITH OPEN
SOURCE DATA 32 (2020), https://www.rand.org/pubs/research_reports/RR2706.html.
111
SOURCE DATA 15, 26, 32 (2020), https://www.rand.org/pubs/research_reports/RR2706.html.
SOURCE DATA 32 (2020), https://www.rand.org/pubs/research_reports/RR2706.html; U.S. Department of State: Documenting
ISIL Antiquities Trafficking, Remarks by Andrew Keller, Deputy Assistant Secretary for Counter Threat Finance and Sanctions with
the Bureau of Economic and Business Affairs at the U.S. Department of State (Sep. 29, 2015), https://2009-2017.state.gov/e/eb/rls/
rm/2015/247610.htm.
SOURCE DATA 15, 26 (2020), https://www.rand.org/pubs/research_reports/RR2706.html.
162 The Docket interview, southern Turkey, August 2021.
163 For example licenses, see U.S. Department of State: Documenting ISIL Antiquities Trafficking, Remarks by Andrew Keller,
Deputy Assistant Secretary for Counter Threat Finance and Sanctions with the Bureau of Economic and Business Affairs at the U.S.
Department of State (Sep. 29, 2015), https://2009-2017.state.gov/e/eb/rls/rm/2015/247610.htm.
164 Khums: An Un-Islamic Tax for an Islamic Antiquities Market, CONFLICT ANTIQUITIES (Aug. 17, 2014), https://conflictan-
tiquities.wordpress.com/2014/08/17/syria-iraq-islamic-antiquities-trafficking-tax/.
166 Barbara Starr, Laura Smith-Spark & Ray Sanche, Abu Sayyaf, key ISIS figure in Syria, killed in U.S. raid, CNN NEWS (May
17, 2015), https://www.cnn.com/2015/05/16/middleeast/syria-isis-us-raid/index.html.
167 How Much Money is ISIS Making from Antiquities Looting, GATES OF NINEVEH (Jan. 12, 2016), https://gatesofnineveh.
wordpress.com/2016/01/12/how-much-money-is-isis-making-from-antiquities-looting/.
169 Press Release, United States Seeks Warrant to Seize Ring Trafficked by ISIS, U.S. Dep’t of Justice (Dec. 6, 2017), https://www.
justice.gov/usao-dc/pr/united-states-seeks-warrant-seize-ring-trafficked-islamic-state-iraq-and-syria-isis.
170 STAFF OF H. COMM. ON FINANCIAL SERVICES, 114TH CONG., STOPPING TERROR FINANCE: SECURING THE U.S. FI-
NANCIAL SECTOR 6 (Dec. 20, 2016) (citing U.N. Sec. Council, Letter dated 13 November 2014 from the Chair of the Security Council
Committee pursuant to resolutions 1267 (1999) and 1989 (2011) concerning Al-Qaida and associated individuals and entities addressed
to the President of the Security Council, U.N. Doc. S/2014/815 (Nov. 14, 2014)), https://www.hsdl.org/?view&did=797477.
171 MATTHEW SARGENT ET AL., TRACKING AND DISRUPTING THE ILLICIT ANTIQUITIES TRADE WITH OPEN SOURCE
DATA 166 (2020), https://www.rand.org/pubs/research_reports/RR2706.html.
172 Russel Howard, Jonathan Prohov & Marc Elliott, Digging In and Trafficking Out: How the Destruction of Cultural Heritage
Funds Terrorism, 8(2) CTC SENTINEL (Feb. 2015), https://www.ctc.usma.edu/digging-in-and-trafficking-out-how-the-destruction-
of-cultural-heritage-funds-terrorism/.
173 Olivier Moos, Antiquities Trafficking in Syria: Salafists, Tomb Raiders and “Buried Treasures,” RELIGIOSCOPE 31 (Feb. 11,
2020), https://english.religion.info/wp-content/uploads/2020/02/2020_02_Moos_Antiquities_Syria.pdf.
176 Oliver Moos, Antiquities Trafficking in Syria: Salafists, Tomb Raiders and “Buried Treasures,” RELIGIOSCOPE 40 (2020),
https://english.religion.info/wp-content/uploads/2020/02/2020_02_Moos_Antiquities_Syria.pdf.
180 The HTS members were—likely pseudonyms—Abu Sulayman al-Homsi (based in Idlib), Abu Hamzah (from Ma’arret al-
Nu’man) and Al-Mu’tasim Billah Abu Inad (based in Ad-Dana). Olivier Moos, Antiquities Trafficking in Syria: Salafists, Tomb Raiders
and “Buried Treasures,” RELIGIOSCOPE 7 (Feb. 11, 2020), https://english.religion.info/wp-content/uploads/2020/02/2020_02_Moos_
Antiquities_Syria.pdf.
182 Olivier Moos, Antiquities Trafficking in Syria: Salafists, Tomb Raiders and “Buried Treasures,” RELIGIOSCOPE 7 (Feb.
11, 2020) (according to sources contacted by the author via the Telegram groups), https://english.religion.info/wp-content/up-
loads/2020/02/2020_02_Moos_Antiquities_Syria.pdf.
112
191 See Illicit Trade in Cultural Goods in Europe: Characteristics, Criminal Justice Responses and an Analysis of the Applica-
bility of Technologies in the Combat Against the Trade, EUROPEAN COMMISSION DIRECTORATE-GENERAL FOR EDUCATION,
YOUTH, SPORT & CULTURE 123 (2018), https://catalogus.boekman.nl/pub/P19-0434.pdf.
192 Taylor Luck, Syrian Rebels Loot Artifacts to Raise Money for Fight Against Assad, WASHINGTON POST (Feb. 12,
2013), https://www.washingtonpost.com/world/middle_east/syrian-rebels-loot-artifacts-to-raise-money-for-fight-against-as-
sad/2013/02/12/ae0cf01e-6ede-11e2-8b8d-e0b59a1b8e2a_story.html.
193 Marina Lostal, Islamic State and Illicit Traffic of Cultural Property, in INTERNATIONAL CRIMINAL RESPONSIBILITY OF
WAR’S FUNDERS AND PROFITEERS 130, 133 (2020), https://ssrn.com/abstract=3696445.
195 Neil Brodie & Isber Sabrine, The Illegal Excavation and Trade of Syrian Cultural Objects: A View from the Ground, 43(1) J. OF
FIELD ARCHEOLOGY 74, 81, https://traffickingculture.org/app/uploads/2018/10/Brodie-and-Sabrine-2018.pdf.
197 Alex Barker, Looting, the Antiquities Trade, and Competing Valuations of the Past, 47(1) ANNUAL REVIEW OF ANTHRO-
POLOGY 463 (2018), https://www.annualreviews.org/doi/10.1146/annurev-anthro-102116-041320.
198 See Kevin Truitte, The Derna Mujahideen Shura Council: A Revolutionary Islamist Coalition in Libya, 12(5) PERSPECTIVES
ON TERRORISM 4 (Oct. 2018); Mary Fitzgerald & Mattia Toaldo, A Quick Guide to Libya’s Main Players, EUROPEAN COUNCIL ON
FOREIGN RELATIONS (Oct. 2016), https://ecfr.eu/special/mapping_libya_conflict/.
199 See Kevin Truitte, The Derna Mujahideen Shura Council: A Revolutionary Islamist Coalition in Libya, 12(5) PERSPECTIVES
ON TERRORISM 4 (Oct. 2018); Mary Fitzgerald & Mattia Toaldo, A Quick Guide to Libya’s Main Players, EUROPEAN COUNCIL ON
FOREIGN RELATIONS (Oct. 2016), https://ecfr.eu/special/mapping_libya_conflict/; Henrik Gratrud & Vidar Benjamin Skretting,
Ansar al-Sharia in Libya: An Enduring Threat, 11(1) PERSPECTIVES ON TERRORISM 40 (Feb. 2017), https://www.universiteitleiden.
nl/binaries/content/assets/customsites/perspectives-on-terrorism/2017/issue-1/perspectives-on-terrorism-volume-11-issue-1-2017.
pdf.
pdf.
201 Arturo Varvelli, Islamic State’s Re-Organization in Libya and Potential Connections with Illegal Trafficking, GEORGE
WASHINGTON UNIVERSITY’S PROGRAM ON EXTREMISM (Nov. 2017), https://extremism.gwu.edu/sites/g/files/zaxdzs2191/f/
Varvelli%20IS%20Reorganization%20in%20Libya%20and%20Trafficking.pdf.
202 Referred to as such by Michael Danti, archeologist and advisor to the U.S. Department of State on the issue of illicit antiq-
uities trafficking and terrorism financing. Joe Parkinson, Ayla Albayrak & Duncan Mavin, Syrian ‘Monuments Men’ Race to Protect
Antiquities as Looting Bankrolls Terror, WALL STREET JOURNAL (Feb. 10, 2015), https://www.wsj.com/articles/syrian-monu-
ments-men-race-to-protect-antiquities-as-looting-bankrolls-terror-1423615241.
203 See, e.g., Peter Campbell, The Illicit Antiquities Trade as a Transnational Criminal Network: Characterizing and Anticipating
Trafficking of Cultural Heritage, 20(2) INT’L J. OF CULTURAL PROPERTY 113 (2013), https://doi.org/10.1017/S0940739113000015.
204 Frédéric Loore, Trafic d’art et Terrorisme : L’enquête de Paris Match Rebondit en Espagne, PARIS MATCH (Mar. 29, 2018),
https://parismatch.be/actualites/132038/trafic-dart-et-terrorisme-lenquete-de-paris-match-rebondit-en-espagne. See also Sam
Hardy, How the West Buys ‘Conflict Antiquities’ from Iraq and Syria (and Funds Terror), REUTERS (Oct. 27 2014), http://blogs.reu-
ters.com/great-debate/2014/10/27/how-the-west-buys-conflict-antiquities-from-iraq-and-syria-and-funds-terror/.
205 Aryn Baker & Majdal Anjar, Syria’s Looted Past: How Ancient Artifacts are Being Traded for Guns, TIME (Sept. 12, 2012),
http://world.time.com/2012/09/12/syrias-looted-past-how-ancient-artifacts-are-being-traded-for-guns/; Boris Mabillard, Snapshot
of a Syrian Smuggler: Arms, Antiquities and Jihad Along Turkey’s Border, LE TEMPS (Aug. 31, 2013).
206 See Joanne Bajjaly, Arms for Antiquities: Syrian Artifacts Smuggling Bleeds Sites Dry, SANTOS REPUBLIC (Sept. 3, 2013),
113
https://thesantosrepublic.com/2013/09/03/arms-for-antiquities-syrian-artifact-smuggling-bleeds-sites-dry/.
207 Neil Brodie, The Criminal Organization of the Transnational Trade in Cultural Objects: Two Case Studies, in PALGRAVE
HANDBOOK ON ART CRIME 439, 454 (Saskia Hufnagel & Duncan Chappell eds., 2019), https://traffickingculture.org/app/up-
loads/2019/07/Brodie-2019-criminal-organisation.pdf.
208 Neil Brodie, The Criminal Organization of the Transnational Trade in Cultural Objects: Two Case Studies, in THE PAL-
GRAVE HANDBOOK ON ART CRIME, 439–461. (S. Hufnagel and D. Chappell eds.) (2019), https://traffickingculture.org/publications/
the-criminal-organization-of-the-transnational-trade-in-cultural-objects/.
SOURCE DATA 77, 89 (2020), https://www.rand.org/pubs/research_reports/RR2706.html.
210 See Amr Al-Azm, Salam Al-Kuntar & Brian I. Daniels, ISIS Antiquities Sideline, N.Y. TIMES (Sept. 2, 2014), https://www.
nytimes.com/2014/09/03/opinion/isis-antiquities-sideline.html.
212 Simon Cox, The Men Who Smuggle the Loot that Funds IS, BBC NEWS (Feb. 17, 2015), https://www.bbc.co.uk/news/maga-
zine-31485439.
213 Annex to the letter dated 31 March 2016 from the Permanent Representative of the Russian Federation to the United Nations
addressed to the President of the Security Council, U.N. Doc. S/2016/298 (Mar. 31, 2016), https://documents-dds-ny.un.org/doc/UN-
DOC/GEN/N16/091/19/PDF/N1609119.pdf?OpenElement. See also Natasha Bertrand, ‘Relax, they are our friends’: One quote shows
why Turkey’s ISIS problem is only going to get worse, INSIDER (Apr. 14, 2016), https://www.businessinsider.com/turkey-isis-syr-
ia-border-problem-2016-4.
215 See Turkey Investigating Russian Claims on Smuggled Syrian Antiquities, REUTERS (Apr. 7, 2016), https://www.re-
uters.com/article/us-mideast-crisis-antiquities-turkey/turkey-investigating-russian-claims-on-smuggled-syrian-antiqui-
ties-idUSKCN0X42K9.
216 Neil Brodie & Isber Sabrine, The Illegal Excavation and Trade of Syrian Cultural Objects: A View from the Ground, 43 J.
FIELD ARCHAEOLOGY 1 (2018), https://www.tandfonline.com/doi/abs/10.1080/00934690.2017.1410919?journalCode=yjfa20.
217 James Harkin, Stealing Syria’s Past, AMERICAN PROSPECT: PULITZER CENTER (Aug. 27, 2014), https://pulitzercenter.org/
reporting/stealing-syrias-past.
218 Annex to the letter dated 31 March 2016 from the Permanent Representative of the Russian Federation to the United Nations
addressed to the President of the Security Council, U.N. Doc. S/2016/298 (Mar. 31, 2016), https://documents-dds-ny.un.org/doc/UN-
DOC/GEN/N16/091/19/PDF/N1609119.pdf?OpenElement.
220 Palmyra, looting under the rebels, the Assad regime and the Islamic State?, CONFLICT ANTIQUITIES (July 3, 2015), https://
conflictantiquities.wordpress.com/2015/07/03/palmyra-looting-rebels-regime-islamic-state-propaganda/.
221 Marina Lostal, Islamic State and Illicit Traffic of Cultural Property, in THE INTERNATIONAL CRIMINAL RESPONSIBILITY
OF WAR’S FUNDERS AND PROFITEERS 130, 137 (Nina H.B. Jørgensen ed., 2020), https://ssrn.com/abstract=3696445.
222 Simon Cox, The Men Who Smuggle the Loot that Funds IS, BBC NEWS (Feb. 17, 2015), https://www.bbc.co.uk/news/maga-
zine-31485439.
223 Hezbollah’s presence makes Lebanon not only a transit point for antiquities, but also for drugs, weapons, and migrants. See
Yaya J. Fanusie & Alexander Joffe, Monumental Fight: Countering the Islamic State’s Antiquities Trafficking, CENTER ON SANC-
TIONS & ILLICIT FINANCE: FOUNDATION FOR DEFENSE OF DEMOCRACIES CENTER ON SANCTIONS & ILLICIT FINANCING
13 (Nov. 2015), https://s3.us-east-2.amazonaws.com/defenddemocracy/uploads/documents/Monumental_Fight.pdf. See also Samuel
Hardy, ISIS and the missing treasures, the missing treasures and ISIS?, CONFLICT ANTIQUITIES (2016), https://conflictantiquities.
wordpress.com/2016/04/28/iraq-syria-uk-islamic-state-antiquities-market-evidence-interpretation-explanation/; Artifacts looted
from Syrian national museums seen in the office of a Lebanese official, ENAB BALADI (Oct. 21, 2021), https://english.enabbaladi.net/
archives/2021/10/artifacts-looted-from-syrian-national-museums-seen-in-the-office-of-a-lebanese-official/.
224 ISIS and the Missing Treasures, the Missing Treasures and ISIS?, CONFLICT ANTIQUITIES (Apr. 28, 2016), https://con-
flictantiquities.wordpress.com/2016/04/28/iraq-syria-uk-islamic-state-antiquities-market-evidence-interpretation-explanation/.
225 The Docket interviews, Lebanon, October 2020.
226 See Samar Kadi, Narrowing for Illicit Trade of Syrian Antiquities, DAILY STAR LEBANON (Mar. 14, 2015), https://www.dai-
lystar.com.lb/News/Lebanon-News/2015/Mar-14/290754-narrowing-markets-for-illicit-trade-of-syrian-antiquities.ashx.
227 Assad Seif, Illicit Traffic in Cultural Property in Lebanon: A Diachronic Study, in COUNTERING ILLICIT TRAFFIC IN CUL-
TURAL GOODS 65, 71–75 (France Desmarais ed., 2015), https://www.formazioneloescher.it/wp-content/uploads/2019/01/I.6-Book_
observatory_illicit_traffic_version_issuu.pdf#page=78.
228 The names and details are on file with the Docket and have been handed over to the prosecutors in relevant jurisdictions.
They cannot be publicized at the time due to an ongoing investigation.
229 Report: The State of Illicit Trade and Looting of Libyan Antiquities: 2011-2020, AMERICAN SCHOOLS OF ORIENTAL
RESEARCH 64 (Dec. 31, 2020), https://www.asor.org/wp-content/uploads/2021/01/Looted-Antiquities-Libya-ASOR-Report-re-
114
duced-size.pdf.
230 Sehad Alkhadry, Former Director of Antiquities of Damietta Describes Antiquities Thieves Using Furniture Trucks, AL
WATAN (Oct. 29, 2013), https://www.elwatannews.com/news/details/347701.
duced-size.pdf.
232 Report: The State of Illicit Trade and Looting of Libyan Antiquities: 2011-2020, Appendix, AMERICAN SCHOOLS OF ORI-
ENTAL RESEARCH 198 (Dec. 31, 2020), http://www.asor.org/wp-content/uploads/2021/01/Looted-Antiquities-Libya-ASOR-appendi-
ces-FInal.pdf.
ces-FInal.pdf.
duced-size.pdf.
duced-size.pdf.
duced-size.pdf.
duced-size.pdf.
duced-size.pdf.
duced-size.pdf.
duced-size.pdf.
241 Tom Mashberg, Yemen Asks U.S. for Help to Curb Smuggling of Looted Ancient Artifacts, N.Y. TIMES (Mar. 6, 2019, https://
www.nytimes.com/2019/03/06/arts/design/yemen-united-states-looted-artifacts.html.
OF YEMEN 2 (Mar. 5, 2019), https://theantiquitiescoalition.org/publics-help-needed-to-recover-blood-antiquities/.
244 Nabil Abdoullah al-Tamimi Aden, Le Yémen sévit contre la contrebande d’antiquités, AL-MASHAREQ (July 12, 2018), https://
almashareq.com/fr/articles/cnmi_am/features/2018/07/12/feature-02.
246 Andy Corbley, Over 1 Million Yemeni Archaeological Artifacts Stolen During War by U.S.-Emirati Smuggling Ring, WORLD
AT LARGE (Dec. 4, 2019), https://www.worldatlarge.news/world-conflict/yemen-artifacts-stolen.
247 Owen Jarus, “Blood Antiquities” Looted from War-Torn Yemen Bring in $1 Million at Auction, LIVE SCIENCE (June 5, 2019),
https://www.livescience.com/65641-yemen-blood-antiquities-investigation.html.
248 Ali Mahmood, Aden Port Officials Foil Attempt to Smuggle Yemeni Antiques, NATIONAL (Aug. 19, 2018), https://www.then-
ationalnews.com/world/mena/aden-port-officials-foil-attempt-to-smuggle-yemeni-antiques-1.761448. The objects were identified
by Ali Bahasan, an official at Yemen’s Antiquities Authority, as following: “jars, jugs, jambiyas, necklaces, rings - some made of silver
mixed with gold, housewares made of silver and gems, in addition to boxes made of decorative wood.” See also The Response of the
U.S. and International Community to the Crisis: A Roundtable Discussion About Cultural Heritage Destruction in Yemen, ANTIQ-
UITIES COALITION (2019), https://theantiquitiescoalition.org/the-response-of-the-u-s-and-international-community-to-the-cri-
sis-a-roundtable-discussion-about-cultural-heritage-destruction-in-yemen/.
249 How Qatar supported artifact smugglers in Yemen?, EGYPT TODAY (Aug. 1, 2017), https://www.egypttoday.com/Arti-
cle/1/15054/How-Qatar-supported-artifact-smugglers-in-Yemen.
250 Ivan Dikov, Bulgarian Police Seize Ancient Roman Archaeology Artifacts, Slab with Sumerian Motifs from Treasure Hunters,
ARCHAEOLOGY IN BULGARIA (Mar. 24, 2015), http://archaeologyinbulgaria.com/2015/03/24/bulgarian-police-seize-ancient-ro-
man-archaeology-artifacts-slab-with-sumerian-motifs-from-treasure-hunters/; Ivan Dikov, Bulgarian Archaeologist Concludes Ro-
man Artifacts Seized from Smugglers Authentic, Originated in Asia Minor and the Middle East, ARCHAEOLOGY IN BULGARIA (Aug.
115
12, 2015), http://archaeologyinbulgaria.com/2015/08/12/bulgarian-archaeologist-concludes-roman-artifacts-seized-from-smug-
glers-authentic-originated-in-asia-minor-and-the-middle-east/.
251 See, e.g., Vincent Michel, Illegal Trafficking of Cultural Goods in Countries in Conflict, PATRIMOINES (2020), https://
netcher.eu/project-news/illegal-trafficking-of-cultural-goods-in-countries-in-conflict/.
252 Nathalie Revenu, Un trésor archéologique saisi à Roissy, LE PARISIEN (Sep. 29, 2016), http://www.leparisien.fr/faits-divers/
un-tresor-archeologique-saisi-a-roissy-21-09-2016-6136959.php; Benoit Faucon, Georgi Kantchev & Alistair MacDonald, Antiquities:
The Men Who Trade ISIS Loot, WALL STREET JOURNAL (Aug. 7, 2017), https://www.wsj.com/articles/the-men-who-trade-isis-
loot-1502017200.
253 David Segal, Swiss Freeports Are Home for a Growing Treasury of Art, N.Y. TIMES (July 21, 2012), https://www.nytimes.
com/2012/07/22/business/swiss-freeports-are-home-for-a-growing-treasury-of-art.html.
254 Silke Koltrowitz & Arnold Paul, Freeports Boom Highlights Risks of Shady Activities, REUTERS (Sept. 22, 2016), https://
www.reuters.com/article/us-swiss-freeports-idUSKCN11S1OL.
255 See, e.g., Henri Neuendorf, Switzerland’s Tough New Stance on Freeports Will Shake the Art World, ARTNET NEWS (Nov.
19, 2015), https://news.artnet.com/market/switzerland-freeport-regulations-367361. See also Silke Koltrowitz & Arnold Paul, Free-
ports Boom Highlights Risks of Shady Activities, REUTERS (Sept. 22, 2016), https://www.reuters.com/article/us-swiss-freeports-
idUSKCN11S1OL.
256 See Intergovernmental Committee for Promoting the Return of Cultural Property to its Countries of Origin or its Restitu-
tion in Case of Illicit Appropriation, UNESCO (July 2016), http://www.unesco.org/new/fileadmin/MULTIMEDIA/HQ/CLT/pdf/2_FC_
free_port_working_document_Final_EN_revclean.pdf.
257 FATF Report: Money Laundering Vulnerbilities of Free Trade Zones, FINANCIAL ACTION TASK FORCE (Mar. 2010), https://
www.fatf-gafi.org/media/fatf/documents/reports/ML%20vulnerabilities%20of%20Free%20Trade%20Zones.pdf; Controlling the
Zone: Balancing Facilitation and Control to Combat Illicit Trade in Free Trade Zones, INT’L CHAMBER OF COMMERCE BUSINESS
ACTION TO STOP COUNTERFEITING AND PIRACY (2020), https://iccwbo.org/content/uploads/sites/3/2020/12/2020-bascap-re-
port.pdf.
258 Counterfeiting & Piracy, INT’L CHAMBER OF COMMERCE BUSINESS ACTION TO STOP COUNTERFEITING AND PIRA-
CY, https://iccwbo.org/global-issues-trends/bascap-counterfeiting-piracy/ (last accessed May 17, 2022).
259 The Role of Freeports in the Global Art Market, ARTSY (July 17, 2017), https://www.artsy.net/article/artsy-editorial-free-
ports-operate-margins-global-art-market.
260 Christopher Davidson, Dubai: The Security Dimensions of the Region’s Premier Freeport, 25 MIDDLE EAST POLICY COUN-
CIL 2 (May 28, 2008), https://onlinelibrary.wiley.com/doi/abs/10.1111/J.1475-4967.2008.00354.X. See also Neil Brodie, The Criminal
Organization of the Transnational Trade in Cultural Objects: Two Case Studies, in THE PALGRAVE HANDBOOK ON ART CRIME
439–461 (S. Hufnagel & D. Chappell eds., 2019), https://traffickingculture.org/publications/the-criminal-organization-of-the-trans-
national-trade-in-cultural-objects/.
261 Hawala is an informal method of transferring money without any physical money actually moving. It is described as a
“money transfer without money movement.” Another definition is simply “trust.” Hawala is used today as an alternative remittance
channel that exists outside of traditional banking systems. Transactions between hawala brokers are made without promissory notes
because the system is heavily based on trust and the balancing of hawala brokers’ books.
264 U.S. Dep’t of the Treasury, Treasury Targets Wide Range of Terrorists and Tehir Supporters Using Enhanced Counterterror-
ism Sanctions Authorities, https://home.treasury.gov/news/press-releases/sm772 (last accessed May 17, 2022); U.S. Dep’t of State,
Executive Order 13224, https://www.state.gov/executive-order-13224/ (last accessed May 17, 2022).
265 The Docket interview, Turkey, August 2021.
266 U.S. Dep’t of the Treasury, Treasury Designates Key Nodes of ISIS’s Financial Network Stretching Across the Middle East,
Europe, and East Africa, https://home.treasury.gov/news/press-releases/sm657 (last accessed May 17, 2022).
270 U.S. Department of the Treasury, Treasury Designates Key Nodes of ISIS’s Financial Network Stretching Across the Middle
East, Europe, and East Africa, https://home.treasury.gov/news/press-releases/sm657 (last accessed May 17, 2022).
ism Sanctions Authorities, https://home.treasury.gov/news/press-releases/sm772 (last accessed May 17, 2022).
116
276 Report: The State of Illicit Trade and Looting of Libyan Antiquities: 2011-2020, AMERICAN SCHOOL OF ORIENTAL RE-
pdf.
277 Amr Al-Azm & Katie A. Paul, Facebook’s Black Market in Antiquities, Trafficking, Terrorism, and War, ANTIQUITIES
TRAFFICKING AND HERITAGE ANTHROPOLOGY RESEARCH PROJECT 3 (June 2019), http://atharproject.org/wp-content/up-
loads/2019/06/ATHAR-FB-Report-June-2019-final.pdf.
TRAFFICKING AND HERITAGE ANTHROPOLOGY RESEARCH PROJECT 3 (June 2019), http://atharproject.org/wp-content/up-
279 Report: The State of Illicit Trade and Looting of Libyan Antiquities: 2011-2020, AMERICAN SCHOOL OF ORIENTAL RE-
pdf.
TRAFFICKING AND HERITAGE ANTHROPOLOGY RESEARCH PROJECT (June 2019), http://atharproject.org/wp-content/up-
281 See, e.g., Tom Mashberg, Facebook, Citing Looting Concerns, Bans Historical Artifact Sales, N.Y. TIMES (June 23, 2020),
https://www.nytimes.com/2020/06/23/arts/design/facebook-looting-artifacts-ban.html.
283 Countering Looting of Antiquities in Syria and Iraq, Research and Training on Illicit Markets for Iraqi and Syrian Art and
Antiquities, TERRORISM, TRANSNATIONAL CRIME AND CORRUPTION CENTER & U.S. DEP’T OF STATE BUREAU OF COUN-
TERTERRORISM 13 (Jan. 7, 2019), https://traccc.schar.gmu.edu/wp-content/uploads/2020/10/Final-TraCCC-CTP-CTAQM-17-006-
Report-Jan-7-2019.pdf.
284 Neil Brodie, How to Control the Internet Market in Antiquities? The Need for Regulation and Monitoring, THINK TANK
(2017), https://thinktank.theantiquitiescoalition.org/how-to-control-the-internet-market-in-antiquities-the-need-for-regula-
tion-and-monitoring/.
285 See Neil Brodie, The Internet Market in Antiquities, in COUNTERING ILLICIT TRAFFIC IN CULTURAL GOODS: THE
GLOBAL CHALLENGE OF PROTECTING THE WORLD’S HERITAGE (F. Desmarais ed., 2015), https://wpmedia.outlandish.com.
s3.amazonaws.com/trafficking/2016/01/27133045/2015-Brodie-ICOM-Internet.pdf.
286 See VAUCTIONS, https://www.vauctions.com/ (last accessed May 17, 2022); VCOINS, https://www.vcoins.com/fr/Default.
aspx (last accessed May 17, 2022).
288 Report: The State of Illicit Trade and Looting of Libyan Antiquities: 2011-2020, Appendix, AMERICAN SCHOOLS OF ORIEN-
TAL RESEARCH 209, 211 (Dec. 31, 2020), http://www.asor.org/wp-content/uploads/2021/01/Looted-Antiquities-Libya-ASOR-appen-
dices-FInal.pdf.
289 See LIVEAUCTIONEERS, https://www.liveauctioneers.com/ (last accessed May 17, 2022).
290 Report: The State of Illicit Trade and Looting of Libyan Antiquities: 2011-2020, AMERICAN SCHOOL OF ORIENTAL
RESEARCH 130 (Dec. 31, 2020), http://www.asor.org/wp-content/uploads/2021/01/Looted-Antiquities-Libya-ASOR-Report-re-
duced-size.pdf.
291 Report: The State of Illicit Trade and Looting of Libyan Antiquities: 2011-2020, AMERICAN SCHOOL OF ORIENTAL
RESEARCH 130 (Dec. 31, 2020), http://www.asor.org/wp-content/uploads/2021/01/Looted-Antiquities-Libya-ASOR-Report-re-
duced-size.pdf.
292 CFJ notes that, although Christophe Kunicki and Richard Semper have been indicted in this case, they are presumed inno-
cent unless the prosecution proves guilt beyond a reasonable doubt in a court of law.
293 See Letter from Matthew Bogdanos, Chief of the Antiquities Trafficking Unit of the Office of the New York District Attor-
ney, to Jean Pierre Montesinos, regarding the Stele of Pa-di-sena 5 (Jan. 19, 2020), https://www.artcrimeresearch.org/wp-content/
uploads/2020/11/Unsealed-Public-ATU-Stele-Report-1.pdf. The letter from Matthew Bogdanos regarding the Sarcophagus of Ned-
jemankh is not publicly available.
294 See CHRISTOPHE KUNICKI, http://www.kunicki.eu/Kunickiexpertise/Activite.html (last accessed Jan. 21, 2021). The web-
site has since been taken down.
295 Kunicki has regularly served as an expert at Pierre Bergé & Associés since at least September 2014. The journal Minerva:
The International Review of Ancient Art & Archaeology lists Kunicki as an expert in the September/October 2014 issue (Volume 25,
Number 5). See Lynda Albertson, Restitution: Met Museum agrees to return its 1st century B.C.E Mummiform coffin, inscribed in
the name of Nedjemankh, to Egypt, ASSOCIATION FOR RESEARCH INTO CRIMES AGAINST ART (Feb. 16, 2019), https://art-crime.
117
blogspot.com/2019/02/restitution-met-museum-agrees-to-return.html. Kunicki served in that role until around November 2019.
Stephane Joahny, Un vaste trafic d’antiquités démantelé, des oeuvres “litigieuses” vendues au Louvre d’Abou Dhabi, LE JOURNAL
DU DIMANCHE (June 28, 2020), https://www.lejdd.fr/Societe/un-vaste-trafic-dantiquites-demantele-des-oeuvres-litigieuses-ven-
dues-au-louvre-dabou-dhabi-3977791 (non-firewalled version: https://pressfrom.info/us/news/world/-468490-a-vast-traffic-in-an-
tiquities-dismantled-litigious-works-sold-at-the-louvre-in-abu-dhabi.html).
296 See e.g., Art d’Orient – Archeology, ADER, https://www.ader-paris.fr/specialite/art-orient-islam-et-inde (last accessed Jan.
22, 2021) (referring to Kunicki as an “archaeology expert”; his name has since been removed); CHRISTOPHE KUNICKI, http://www.
kunicki.eu/Kunickiexpertise/Activite.html (last accessed Jan. 21, 2021). The website has since been taken down.
297 See e.g., Archéologie, BINOCHE & GIQUELLO (May 30, 2012), https://www.binocheetgiquello.com/vente/12320 (identifying
Kunicki as an “expert” for their archaeology auction); CHRISTOPHE KUNICKI, http://www.kunicki.eu/Kunickiexpertise/Activite.
html (last accessed Jan. 21, 2021). The website has since been taken down.
298 See, e.g., Christophe Joron-Derem, HOTEL DROUOT (June 28, 2013) (listing Kunicki as “archeological expert”),
http://188.165.186.89/artsdeco/images/centredoc/Multimedias/doc-artnouveau-artdeco/catalogues-de-vente-en-ligne/Joron-Der-
em/2013-06-28-Joron-Derem-Putman.pdf.
299 Chercheurs d’Art (1/2): la vente de la princesse Minnie de Beauvau-Craon, BFM BUSINESS (June 12, 2015), https://bfmbusi-
ness.bfmtv.com/mediaplayer/video/chercheurs-d-art-12-la-vente-de-la-princesse-minnie-de-beauvau-craon-1206-554643.html
(Kunicki provided his expertise on an Egyptian piece sold by Maison Piasa in a show aired in June 2015).
ces-FInal.pdf.
301 Letter from Matthew Bogdanos, Chief of the Antiquities Trafficking Unit of the Office of the New York District Attorney,
to Jean Pierre Montesinos, regarding the Stele of Pa-di-sena 1 (Jan. 19, 2020), https://www.artcrimeresearch.org/wp-content/up-
loads/2020/11/Unsealed-Public-ATU-Stele-Report-1.pdf.
302 Vincent Noce, Paris dealer who sold golden sarcophagus to New York’s Metropolitan Museum charged with fraud and
money laundering, ART NEWSPAPER (June 27, 2020), https://www.theartnewspaper.com/news/paris-dealer-who-sold-golden-sar-
cophagus-to-new-york-s-metropolitan-museum-charged-with-fraud-and-money-laundering.; Un expert en archéologie et son mari
en examen pour traffic d’antiquités pillées, PARIS MATCH (June 27, 2020), https://www.parismatch.com/Actu/Societe/Un-expert-en-
archeologie-et-son-mari-en-examen-pour-trafic-d-antiquites-pillees-1691541.
303 See Letter from Matthew Bogdanos, Chief of the Antiquities Trafficking Unit of the Office of the New York District Attor-
ney, to Jean Pierre Montesinos, regarding the Stele of Pa-di-sena (Jan. 19, 2020), https://www.artcrimeresearch.org/wp-content/up-
ces-FInal.pdf.
305 See Home, MILLON, https://www.millon.com (last accessed May 17, 2022).
ces-FInal.pdf.
ces-FInal.pdf.
308 Béatrice de Rochebouët, Le Marché de l’Art de Nouveau dans la Tourmente, LE FIGARO (June 24, 2020), https://www.lefiga-
ro.fr/culture/le-marche-de-l-art-de-nouveau-dans-la-tourmente-20200624.
309 Vincent Noce, Paris dealer who sold golden sarcophagus to New York’s Metropolitan Museum charged with fraud and mon-
ey laundering, ART NEWSPAPER (June 27, 2020), https://www.theartnewspaper.com/news/paris-dealer-who-sold-golden-sarcopha-
gus-to-new-york-s-metropolitan-museum-charged-with-fraud-and-money-laundering.
310 Vincent Noce, French Dealer Sues over Egyptian Stele Seized on Way to Tefaf New York, ART NEWSPAPER (Sept. 4, 2020),
https://www.theartnewspaper.com/news/french-dealer-sues-over-seized-egyptian-stele.
312 Vincent Noce, French dealer sues over Egyptian stele seized on way to Tefaf New York, ART NEWSPAPER (Sept. 4, 2020),
https://www.theartnewspaper.com/2020/09/04/french-dealer-sues-over-egyptian-stele-seized-on-way-to-tefaf-new-york.
118
317 See Letter from Matthew Bogdanos, Chief of the Antiquities Trafficking Unit of the Office of the New York District Attorney,
320 Vincent Noce, Dealer suspected of selling looted antiquities to the Metropolitan Museum of Art and Louvre Abu Dhabi
detained in Paris, ART NEWSPAPER (March 25, 2022), https://www.theartnewspaper.com/2022/03/25/dealer-suspected-of-sell-
ing-looted-antiquities-to-the-metropolitan-museum-of-art-and-louvre-abu-dhabi-detained-in-paris.
321 Sylvain Besson & Catherine Boss, Le roi genevois des antiquités doit payer 6 millions au fisc et aux douanes, TDG (Dec. 22,
2021), https://www.tdg.ch/le-roi-genevois-des-antiquites-doit-payer-6-millions-au-fisc-et-aux-douanes-414622311237; Un expert
signait de fausses attestations pour Phoenix Ancient Art, GOTHAM CITY, (Nov. 3, 2021),
https://gothamcity.ch/2021/11/03/un-expert-signait-de-fausses-attestations-pour-phoenix-ancien-art/.
322 Un expert signait de fausses attestations pour Phoenix Ancient Art, GOTHAM CITY, (Nov. 3, 2021),
323 Ethar Abdulhaq, Aboutaam Brothers: Traders of Antiquities and Blood, ZAMAN AL-WASL (Mar. 7, 2019), https://en.
zamanalwsl.net/news/article/42027.
324 See U.S. Immigration and Customs Enforcement, Cultural Property, Art and Antiquities Investigations (Dec. 12, 2011),
https://www.ice.gov/factsheets/cultural-artifacts; U.N. Office on Drugs and Crime, Dat Hamin Stele, https://www.unodc.org/res/cld/
case-law-doc/traffickingculturalpropertycrimetype/usa/dat_hamin_stele_html/Dat_Hamin_Stele.pdf (last accessed Oct. 8, 2020).
325 See U.S. Immigration and Customs Enforcement, Cultural Property, Art and Antiquities Investigations (Dec. 12, 2011),
https://www.ice.gov/factsheets/cultural-artifacts; U.N. Office on Drugs and Crime, Dat Hamin Stele, https://www.unodc.org/res/cld/
326 See Barry Meier & Martin Gottlieb, LOOT: Along the Antiquities Trail; An Illicit Journey Out of Egypt, Only a Few Questions
Asked, N.Y. TIMES (Feb. 23, 2004), https://www.nytimes.com/2004/02/23/world/loot-along-antiquities-trail-illicit-journey-egypt-
only-few-questions-asked.html.
327 See Benoit Faucon & Georgi Kantchev, Prominent Art Family Entangled in ISIS Antiquities-Looting Investigations, WALL
STREET JOURNAL (May 31, 2017), https://www.wsj.com/articles/prominent-art-family-entangled-in-investigations-of-looted-an-
tiquities-1496246740; Ron Stodghill, Do You Know Where That Art Has Been?, N.Y. TIMES (March 18, 2007), https://www.nytimes.
com/2007/03/18/business/yourmoney/18Art.html; U.N. Office on Drugs and Crime, Dat Hamin Stele, https://www.unodc.org/res/cld/
328 Leila Amineddoleh, Phoenix Ancient Art and the Aboutaams in Hot Water Again, ART & CULTURAL HERITAGE LAW
NEWSLETTER, Vol. I, Issue No. V (Spring 2009), https://traffickingculture.org/app/uploads/2014/12/Phoenix-Ancient-Art.pdf;
David Gill, A Dealer, Interpol and Sofia Airport, LOOTING MATTERS (Jan. 15, 2009), https://lootingmatters.blogspot.com/2009/01/
dealer-interpol-and-sofia-airport.html; Isabel Vincent, Antiquities Smuggle Rap Zapped, N.Y. POST (Jan. 18, 2009), https://nypost.
com/2009/01/18/antiquities-smuggle-rap-zapped/.
329 Laure Lugon, Les confessions d’Ali Aboutaam, marchand d’art aussi puissant que controversé, LE TEMPS (Oct. 6, 2017),
https://www.letemps.ch/suisse/confessions-dali-aboutaam-marchand-dart-puissant-controverse.
332 Frédéric Loore, Trafic d’antiquités et financement du terrorisme: la Belgique au cœur de tous les soupçons, PARIS MATCH
(Nov. 30, 2017), https://fondspourlejournalisme.be/vitrine/IMG/pdf/trafic_antiquites_3.pdf.
333 Brussels Linked to Illicit Antiquities Trade which Funds Terrorism, ANTIQUITIES COALITION (Nov. 1, 2016), https://the-
antiquitiescoalition.org/brussels-linked-to-illicit-antiquities-trade-which-funds-terrorism/.
2021), https://www.tdg.ch/le-roi-genevois-des-antiquites-doit-payer-6-millions-au-fisc-et-aux-douanes-414622311237; Un expert
signait de fausses attestations pour Phoenix Ancient Art, GOTHAM CITY, (Nov. 3, 2021),
335 Un expert signait de fausses attestations pour Phoenix Ancient Art, GOTHAM CITY, (Nov. 3, 2021),
STREET JOURNAL (May 31, 2017), https://www.wsj.com/articles/prominent-art-family-entangled-in-investigations-of-looted-antiq-
119
uities-1496246740.
337 See Sylvain Besson & Catherine Boss, Le roi genevois des antiquités doit payer 6 millions au fisc et aux douanes, TdG (Dec.
22, 2021), https://www.tdg.ch/le-roi-genevois-des-antiquites-doit-payer-6-millions-au-fisc-et-aux-douanes-414622311237; Un expert
signait de fausses attestations pour Phoenix Ancient Art, GOTHAM CITY (Nov. 3, 2021),
uities-1496246740.
2021), https://www.tdg.ch/le-roi-genevois-des-antiquites-doit-payer-6-millions-au-fisc-et-aux-douanes-414622311237.
340 Elisa Larvego, After five years of investigation - The Geneva king of antiquities must pay 6 million to the tax authorities and
customs, ARCHYDE (Dec. 22, 2021, https://www.archyde.com/after-five-years-of-investigation-the-geneva-king-of-antiquities-
must-pay-6-million-to-the-tax-authorities-and-customs/.
2021), https://www.tdg.ch/le-roi-genevois-des-antiquites-doit-payer-6-millions-au-fisc-et-aux-douanes-414622311237.
342 Anna Brady, Swiss Prosecutor Returns ‘Mesopotamian’ Terracotta Animal Made by Dealer’s 11-year-old-Daughter—Along
with 5,000 Seized Antiquities, ART NEWSPAPER (Aug. 31, 2018), https://www.theartnewspaper.com/news/swiss-prosecutor-re-
turns-mesopotamian-terracotta-animal-made-by-dealer-s-11-year-old-daughter-along-with-5-000-other-seized-antiquities.
343 See Report: The State of Illicit Trade and Looting of Libyan Antiquities: 2011-2020, AMERICAN SCHOOL FOR ORIENTAL
RESEARCH 186, 191 (Dec. 31, 2020), http://www.asor.org/wp-content/uploads/2021/01/Looted-Antiquities-Libya-ASOR-Report-re-
duced-size.pdf. Appendix K of the Report features research by Morgan Belzic regarding the presence of Libyan funerary objects likely
looted from Cyrene, Libya in Western Markets. Belzic writes that in 2017, Ali and Hicham Aboutaam listed for sale a Libyan funerary
portrait via their Geneva-based branch, which had previously been sold at Bonham’s auction house in 2010. Id. at 186. More recently,
Belzic writes that in June 2020, Colorado-based Artemis Gallery organized an online sale where they sold a Libyan funerary portrait
likely illicitly excavated from Cyrene that stated the item was “sponsored by Ali and Hicham Aboutaam, owners of Ancient Phoenix
Art.” Id. at 191.
344 See List of 6 (additional) objects and warrant details on objects seized from Phoenix Ancient Art by New York State Dis-
trict Attorney’s Office, ASSOCIATION FOR RESEARCH INTO CRIMES AGAINST ART (Jan. 9, 2018), https://art-crime.blogspot.
com/2018/01/list-of-6-additional-objects-and.html; David Gill, Steinhardt Seizure in Manhattan, LOOTING MATTERS (Jan. 6, 2018),
https://lootingmatters.blogspot.com/2018/01/steinhardt-seizure-in-manhattan.html; James C. McKinley Jr., Looted Antiques Seized
From Billionaire’s Home, Prosecutors Say, N.Y. TIMES (Jan. 5, 2018) (referenced as “six pieces on display at the Phoenix Ancient Art
Gallery on 66th Street”), https://www.nytimes.com/2018/01/05/nyregion/antiques-seized-from-billionaire-michael-steinhardt-
cyrus-vance.html.
345 District Attorney, New York County, Statement of Facts: In the Matter of a Grand Jury Investigation into a Private New
York Antiquities Collector 16-20, 23-28, 30-31, 33, 56-58, 73, 113 (Dec. 6, 2021), https://www.artcrimeresearch.org/wp-content/up-
loads/2021/12/2021-12-06-Steinhardt-Statement-of-Facts-w-Attachments-Filed.pdf.
347 Frédéric Loore, Un Marchand D’Art International: Au Cœur D’Une Vaste Enquête à Bruxelles, PARIS MATCH (June 27, 2019),
https://www.journalistefreelance.be/IMG/pdf/trafic_antiquites_4.pdf.
348 Frédéric Loore, Un Marchand D’Art International: Au Cœur D’Une Vaste Enquête à Bruxelles, PARIS MATCH (June 27, 2019),
https://www.journalistefreelance.be/IMG/pdf/trafic_antiquites_4.pdf.
349 Frédéric Loore, Trafic d’antiquités et financement du terrorisme, La Belgique au Cœur de tous les soupçons, PARIS MATCH
(Nov. 20 – Dec. 6, 2017), https://fondspourlejournalisme.be/vitrine/IMG/pdf/trafic_antiquites_3.pdf.
350 Benoit Faucon & Georgi Kantchev, Prominent Art Family Entangled in ISIS Antiquities-Looting Investigations, WALL
uities-1496246740.
351 Frédéric Loore’s investigative articles in Paris Match and Benoit Faucon and Georgi Kantchev’s in the Wall Street Journal
discussed the various European authorities’ investigations of the Aboutaams as possibly linked to looting in conflict countries and
ISIS financing starting in 2017. See Aboutaam v. Dow Jones & Co., Complaint, No. 156399/2017, ¶ 33 (N.Y. Sup. Ct. 2019), https://www.
courthousenews.com/wp-content/uploads/2017/07/Aboutaam-WSJ-COMPLAINT.pdf; See also Corinne Ramey, New York Judge
Tosses Libel Case Against Dow Jones, WALL STREET JOURNAL (Mar. 26, 2019), https://www.wsj.com/articles/new-york-judge-toss-
es-libel-case-against-dow-jones-11553637430.
352 Ethar Abdulhaq, Aboutaam Brothers: Traders of Antiquities and Blood, ZAMAN AL-WASL (Mar. 7, 2019), https://en.
zamanalwsl.net/news/article/42027.
353 Vincent Noce, Former Louvre Curator Arrested Among Five Arrested in Paris in Antiquities Trafficking Investigation, ART
NEWSPAPER (June 24, 2020), https://www.theartnewspaper.com/news/christophe-kunicki-who-sold-an-allegedly-looted-golden-
sarcophagus-to-the-metropolitan-museum-is-among-five-art-experts-arrested-in-paris-this-week.
354 Benoit Faucon & Georgi Kantchev, Prominent Art Family Entangled in ISIS Antiquities-Looting Investigations, WALL
120
uities-1496246740.
355 Anne Barker, Tracking the smugglers’ trail of priceless Islamic State loot to art markets in the West, ABC NEWS (June 2018),
https://www.abc.net.au/news/2018-06-06/priceless-antiques-looted-by-is-smuggled-into-western-markets/9833554?nw=0.
356 See Un anticuario de Barcelona, detenido por vender piezas robadas por el Dáesh, EL ESPAÑOL (Mar. 27, 2018), https://
www.elespanol.com/cultura/patrimonio/20180327/anticuario-barcelona-detenido-vender-piezas-robadas-daesh/295220885_0.html.
357 See Illicit Trade in Cultural Goods in Europe: Characteristics, Criminal Justice Responses and an Analysis of the Applica-
bility of Technologies in the Combat Against the Trade, EUROPEAN COMMISSION DIRECTORATE-GENERAL FOR EDUCATION,
YOUTH, SPORT & CULTURE 123 (2018), https://catalogus.boekman.nl/pub/P19-0434.pdf.
358 See Auction House, AGUTTES AUCTION HOUSE, https://www.aguttes.com/en/auction-house (last accessed May 17, 2022).
ces-FInal.pdf.
360 Departamento de Seguridad Nacional, Lucha Contra el Terrorismo, https://www.dsn.gob.es/es/actualidad/seguridad-na-
cional-ultima-hora/nacional-%E2%80%93-lucha-contra-terrorismo-3 (“Los detenidos lideraban una red dedicada a la compra ilícita
de piezas provenientes de yacimientos arqueológicos saqueados por grupos afines a la organización terrorista DAESH y cuya venta
permitía sufragar sus actividades.”) (last accessed May 17, 2022) (unofficial translation).
361 Un anticuario de Barcelona, detenido por vender piezas robadas por el Dáesh, EL ESPAÑOL (Mar. 27, 2018), https://www.
elespanol.com/cultura/patrimonio/20180327/anticuario-barcelona-detenido-vender-piezas-robadas-daesh/295220885_0.html. See
also Jaque a las antigüedades de sangre, ABC ESPAÑA (Mar. 28, 2018), https://www.abc.es/espana/abci-jaque-antiguedades-san-
gre-201803281319_noticia.html; Lynda Albertson, Illegal Chains Which Mirror Legal Ones and Function in the Penumbra of the Legal
Ones, ASSOCIATION FOR RESEARCH INTO CRIMES AGAINST ART (Mar. 30, 2018), https://art-crime.blogspot.com/2018/03/illegal-
chains-which-mirror-legal-ones.html. The Docket notes that all persons are presumed innocent unless the prosecution proves guilt
beyond a reasonable doubt in a court of law.
362 See Press Release, D.A. Vance: Michael Steinhardt Surrenders 180 Stolen Antiquities Valued at $70 Million, Manhattan Dis-
trict Attorney’s Office (Dec. 6, 2021), https://web.archive.org/web/20211207160818/https:/www.manhattanda.org/d-a-vance-michael-
steinhardt-surrenders-180-stolen-antiquities-valued-at-70-million/.
363 Press Release, D.A. Vance: Michael Steinhardt Surrenders 180 Stolen Antiquities Valued at $70 Million, Manhattan District
Attorney’s Office (Dec. 6, 2021), https://web.archive.org/web/20211207160818/https://www.manhattanda.org/d-a-vance-michael-
steinhardt-surrenders-180-stolen-antiquities-valued-at-70-million/; District Attorney, New York County, Statement of Facts: In the
Matter of a Grand Jury Investigation into a Private New York Antiquities Collector 141–42 (Dec. 6, 2021), https://www.artcrimere-
search.org/wp-content/uploads/2021/12/2021-12-06-Steinhardt-Statement-of-Facts-w-Attachments-Filed.pdf.
steinhardt-surrenders-180-stolen-antiquities-valued-at-70-million/; District Attorney, New York County, Statement of Facts: In the
Matter of a Grand Jury Investigation into a Private New York Antiquities Collector 141–42 (Dec. 6, 2021), https://www.artcrimere-
search.org/wp-content/uploads/2021/12/2021-12-06-Steinhardt-Statement-of-Facts-w-Attachments-Filed.pdf.
365 District Attorney, New York County, Statement of Facts: In the Matter of a Grand Jury Investigation into a Private New York
Antiquities Collector 12–13 (Dec. 6, 2021), https://www.artcrimeresearch.org/wp-content/uploads/2021/12/2021-12-06-Steinhardt-
Statement-of-Facts-w-Attachments-Filed.pdf.
366 District Attorney, New York County, Statement of Facts: In the Matter of a Grand Jury Investigation into a Private New York
Antiquities Collector 12–13 (Dec. 6, 2021), https://www.artcrimeresearch.org/wp-content/uploads/2021/12/2021-12-06-Steinhardt-
Statement-of-Facts-w-Attachments-Filed.pdf.
370 See generally Lynda Albertson, Some Background on Erdal Dere and Faisal Khan and Fortuna Fine Arts Ltd., Charged in
the SD/New York, ASSOCIATION FOR RESEARCH INTO CRIMES AGAINST ART (Sept. 23, 2020), https://art-crime.blogspot.
com/2020/09/some-background-on-erdal-dere-and.html.
371 Documentary, Romain Bozinger, Trafic d’art: Le trésor de guerre du terrorisme, SPICEE (2011), https://www.imdb.com/title/
tt8137706/?ref_=nm_flmg_dr_1.
tt8137706/?ref_=nm_flmg_dr_1. The looted item was traced back to Selim Deré, owner of the Fortuna Fine Art Gallery in New York,
who has been involved in looted antiquities for decades and is currently under investigation by the FBI and the Manhattan District
121
Attorney’s Office. See Margaret Carrigan, Two Manhattan Antiquities Dealers Arrested on Charges of Fraud, ART NEWSPAPER
(Sept. 23, 2020), https://www.theartnewspaper.com/news/two-manhattan-antiquities-dealers-arrested-on-charges-of-years-long-
fraud-scheme.
tt8137706/?ref_=nm_flmg_dr_1.
374 See David Klein, For Arrested NYC Antiquities Dealer, Illegal Trade is Family Business, ORGANIZED CRIME AND COR-
RUPTION REPORTING PROJECT (Oct. 2, 2020), https://www.occrp.org/en/daily/13201-for-arrested-nyc-antiquities-dealer-ille-
gal-trade-is-family-business.
375 U.S. Department of Justice, Antiquities Dealers Arrested for Fraud Scheme (Sept. 22, 2020), https://www.justice.gov/us-
ao-sdny/pr/antiquities-dealers-arrested-fraud-scheme#_ftn1; United States v. Dere and Khan, Sealed Indictment, No. 1:20-cr-00501-
LAP (S.D.N.Y. Sept. 15, 2020), https://www.justice.gov/usao-sdny/press-release/file/1318981/download.
ao-sdny/pr/antiquities-dealers-arrested-fraud-scheme#_ftn1.
377 United States v. Dere and Khan, Sealed Indictment, No. 1:20-cr-00501-LAP (S.D.N.Y. Sept. 15, 2020), https://www.justice.
gov/usao-sdny/press-release/file/1318981/download.
380 Jerry DeMarco, FBI Raids Ridgewood Home of Former Upper East Side Art Gallery Owner, DAILY VOICE (Sept. 22, 2020),
https://dailyvoice.com/new-jersey/ridgewood/police-fire/fbi-raids-ridgewood-home-of-former-upper-east-side-art-gallery-own-
er/794751/.
381 The Docket notes that all persons are presumed innocent unless the prosecution proves guilt beyond a reasonable doubt in a
court of law.
382 See Palmyra Heritage, FACEBOOK, https://www.facebook.com/palmyra.heritage/ (last accessed May 17, 2022).
383 Report: The State of Illicit Trade and Looting of Libyan Antiquities: 2011-2020, Appendix, AMERICAN SCHOOLS OF ORIEN-
TAL RESEARCH 189–90 (Dec. 31, 2020), http://www.asor.org/wp-content/uploads/2021/01/Looted-Antiquities-Libya-ASOR-appendi-
ces-FInal.pdf.
384 See United States v. Mousa Khouli, Salem Alshdaifat, Joseph A. Lewis II & Ayman Ramadan, Case No. 1:11 cr 00340 (E.D.N.Y.
May 4, 2011); see also Kiran Khalid, Feds: Global Antiquities Smuggling Ring Dismantled, CNN, http://edition.cnn.com/2011/
CRIME/07/15/new.york.antiquities.smuggling/ (July 15, 2011); Kate Taylor, 4 Charged in Smuggling Egyptian Antiquities, N.Y. TIMES
(July 14, 2011), https://www.nytimes.com/2011/07/15/arts/design/federal-authorities-charge-4-people-in-antiquities-smuggling.html.
385 Kiran Khalid, Feds: Global Antiquities Smuggling Ring Dismantled, CNN, http://edition.cnn.com/2011/CRIME/07/15/new.
york.antiquities.smuggling/ (July 15, 2011).
388 Neil Brodie, The Criminal Organization of the Transnational Trade in Cultural Objects: Two Case Studies, in PALGRAVE
HANDBOOK ON ART CRIME 439, 447 (Saskia Hufnagel & Duncan Chappell eds., 2019), https://traffickingculture.org/app/up-
loads/2019/07/Brodie-2019-criminal-organisation.pdf; Alshdaifat v. United States, Order, Case No. 11-51067 (E.D. Mich. Sept. 6, 2011),
https://www.govinfo.gov/content/pkg/USCOURTS-mied-2_11-mc-51067/pdf/USCOURTS-mied-2_11-mc-51067-1.pdf.
389 See Rick St. Hilaire, U.S. v. Khouli et al. Update: Second Guilty Plea Expected Today in Egyptian Antiquities Case, Cultural
Heritage Lawyer (Dec. 21, 2012), https://culturalheritagelawyer.blogspot.com/2012/12/us-v-khouli-et-al-update-second-guilty.html
court of law.
391 For list of some of the items seized, see Seized Cultural Property Identified in Khouli + 3 Case, CULTURAL HERITAGE LAW-
YER, https://culturalheritagelawyer.blogspot.com/2011/08/seized-cultural-property-identified-in.html (Aug. 19, 2011).
392 United States Moves to Forfeit Antiquity from Time of Roman Empire that was Looted from Syria and Recovered from High
Desert Home, U.S. Department of Justice (May 25, 2018), https://www.justice.gov/usao-cdca/pr/united-states-moves-forfeit-antiqui-
ty-time-roman-empire-was-looted-syria-and-recovered.
Desert Home, U.S. DEPARTMENT OF JUSTICE (May 25, 2018), https://www.justice.gov/usao-cdca/pr/united-states-moves-forfeit-
antiquity-time-roman-empire-was-looted-syria-and-recovered.
Desert Home, U.S. DEPARTMENT OF JUSTICE (May 25, 2018), https://www.justice.gov/usao-cdca/pr/united-states-moves-forfeit-
antiquity-time-roman-empire-was-looted-syria-and-recovered.
395 Los Angeles-area man charged with unlawfully importing ancient mosaic, U.S. IMMIGRATION AND CUSTOMS ENFORCE-
122
MENT (July 24, 2020), https://www.ice.gov/news/releases/los-angeles-area-man-charged-unlawfully-importing-ancient-mosaic.
United States v. Alcharihi, CR 2:20-cr-00307-MWF (Central District of Cal. 2020).
court of law.
397 Hague Convention for the Protection of Cultural Property in the Event of Armed Conflict, May 14, 1954, S. Treaty Doc. 106-1,
249 U.N.T.S. 216.
398 Second Protocol to the Hague Convention of 1954 for the Protection of Cultural Property in the Event of Armed Conflict art.
22, March 26, 1999, 38 I.L.M. 769, 2253 U.N.T.S. 172.
399 Convention on the Means of Prohibiting and Preventing the Illicit Import, Export and Transfer of Ownership of Cultural
Property, Nov. 14, 1970, 10 I.L.M. 289, 823 U.N.T.S 231.
400 Convention on the Means of Prohibiting and Preventing the Illicit Import, Export and Transfer of Ownership of Cultural
Property art. 5, Nov. 14, 1970, 10 I.L.M. 289, 823 U.N.T.S 231.
401 UNIDROIT Convention on Stolen or Illegally Exported Cultural Objects, Jun. 24, 1995, 34 I.L.M. 1322, 2421 U.N.T.S. 457.
402 Patty Gerstenblith, Implementation of the 1970 UNESCO Convention by the United States and Other Market Nations, in
THE ROUTLEDGE COMPANION TO CULTURAL PROPERTY 70–99 (2017), https://archive.law.upenn.edu/live/files/6423-gersten-
blith-patty-2017-implementation-of-the-1970.
403 Neil Brodie & Donna Yates, ILLICIT TRADE IN CULTURAL GOODS IN EUROPE: CHARACTERISTICS, CRIMINAL JUSTICE
RESPONSES AND AN ANALYSIS OF THE APPLICABILITY OF TECHNOLOGIES IN THE COMBAT AGAINST THE TRADE 146 (2019),
https://catalogus.boekman.nl/pub/P19-0434.pdf.
404 Alice Munnelly, Compliant or Complicit? Security Implications of the Art Market, 23 EU INST. FOR SECURITY STUD 1, 3
(2021), https://www.iss.europa.eu/sites/default/files/EUISSFiles/Brief_23_2021.pdf.
405 See S.C. Res. 2199 (Feb. 12, 2015), https://www.undocs.org/S/RES/2199%20(2015); S.C. Res. 2253, at 21 (Dec. 17, 2015) (noting
the “threat posed by the presence of ISIL and its affiliates in Iraq, the Syrian Arab Republic, Libya, and Afghanistan”), https://www.
undocs.org/S/RES/2253%20(2015); S.C. Res. 2347, at 2 (Mar. 24, 2017) https://www.undocs.org/S/RES/2347%20(2017) (noting “with
concern that the Islamic State in Iraq and the Levant (ISIL, also known as Da’esh), Al-Qaida and associated individuals, groups,
undertakings and entities are generating income from engaging directly or indirectly in the illegal excavation and in the looting
and smuggling of cultural property from archaeological sites, museums, libraries, archives, and other sites, which is being used to
support their recruitment efforts and to strengthen their operational capability to organize and carry out terrorist attacks”); S.C. Res.
2379, at 1 (Sept. 21, 2017), https://undocs.org/S/RES/2379(2017) (condemning the acts of violence by ISIL that may amount to amount
to war crimes, crimes against humanity or genocide, including the destruction of cultural property).
406 Alice Munnelly, Compliant or Complicit? Security Implications of the Art Market, 23 EU INST. FOR SECURITY STUD 5
(2021), https://www.iss.europa.eu/sites/default/files/EUISSFiles/Brief_23_2021.pdf.
407 S.C. Res. 2199 ¶ 16 (Feb. 12, 2015), https://www.undocs.org/S/RES/2199%20(2015); S.C. Res. 2253, at 21 (Dec. 17, 2015), https://
www.undocs.org/S/RES/2253%20(2015); S.C. Res. 2347, at 2 (Mar. 24, 2017) https://www.undocs.org/S/RES/2347%20(2017).
408 See S.C. Res. 2199 ¶ 16 (Feb. 12, 2015), https://www.undocs.org/S/RES/2199%20(2015) (listing the categories of objects subject
to sanctions); see also Zeynep Boz et al., Résolution 2199 : Contrer la vente du patrimoine pour des causes barbares, 32 JURIS ART
ETC. 28, 28 (2016), https://www.dalloz-revues.fr/Juris_art_etc.-cover-50404.htm.
409 S.C. Res. 2379 (Sept. 21, 2017), https://undocs.org/S/RES/2379(2017).
410 S.C. Res. 2379 (Sept. 21, 2017), https://undocs.org/S/RES/2379(2017).
411 S.C. Res. 1483, ¶ 7 (May 22, 2003), http://unscr.com/en/resolutions/1483.
412 S.C. Res. 2199, ¶ 17 (Feb. 12, 2015), https://www.undocs.org/S/RES/2199%20(2015); S.C. Res. 2253, at 21 (Dec. 17, 2015), https://
www.undocs.org/S/RES/2253%20(2015);
413 Communication From the Commission to the European Parliament, the European Council, the Council, the European Eco-
nomic and Social Committee and the Committee of the Regions on the EU Security Union Strategy, at 19, COM (2020) 605 final (July
24, 2020), https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52020DC0605&from=EN;
414 Directive 2018/843 of the European Parliament and of the Council of 30 May 2018 amending Directive (EU) 2015/849 on the
prevention of the use of the financial system for the purposes of money laundering or terrorist financing, and amending Directives
2009/138/EC and 2013/36/EU, 2018 O.J. (L 156), https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32018L0843.
415 Cates Saleeby, Recent EU Developments in Art Law and Cultural Heritage, CENTER FOR ART LAW (Aug. 20, 2019), https://
itsartlaw.org/2019/08/20/recent-eu-developments-in-art-law-and-cultural-heritage/.
416 Regulation 2019/880 of the European Parliament and of the Council of 17 April 2019 on the introduction and the import of
cultural goods, 2019 O.J. (L 151) 1.
cultural goods, 2019 O.J. (L 151) ⁋ 1.
cultural goods, 2019 O.J. (L 151) ⁋ 1.
419 Catherine Hickley, EU Adopts New Rules on Cultural Heritage Imports, ART NEWSPAPER (Apr. 10, 2019), https://www.
theartnewspaper.com/2019/04/10/eu-adopts-new-rules-on-cultural-heritage-imports.
420 European Commission Press Release IP/21/3690, Beating Financial Crime: Commission Overhauls Anti-Money Laundering
and Countering the Financing of Terrorism Rules (July 20, 2021), https://ec.europa.eu/commission/presscorner/detail/en/IP_21_3690;
123
European Parliament ‘EU Legislation in Process’ Briefing: Proposal for a regulation to fight money laundering and counter terrorist
financing (Dec. 2021), https://www.europarl.europa.eu/RegData/etudes/BRIE/2021/698862/EPRS_BRI(2021)698862_EN.pdf.
421 Proposal for a Regulation of the European Parliament and of the Council on the prevention of the use of the financial system
for the purposes of money laundering or terrorist financing, at art 16, annex II, COM (2021) 420 final (July 20, 2021).
422 CODE PENAL [C. PEN. FR.] (PENAL CODE), art 322-3-2 (Fr.).
423 Kulturgutschutzgesetz [KGSG] [Cultural Property Protection Act], July 31, 2016, BGBl. I S. 1914, § 5, http://www.gese-
tze-im-internet.de/englisch_kgsg/index.html (Eng. translation)
424 Jean-Robert Gisler, Federal Office of Police, Switzerland addresses the traffic in cultural goods, 80 WCO NEWS 16, 16 (2016),
https://mag.wcoomd.org/magazine/wco-news-80/switzerland-addresses-the-traffic-in-cultural-goods/.
425 For measures on Syria, see Ordonnance instituant des mesures à l’encontre de la Syrie, RO 2012 3489 (June 8, 2012), https://
www.fedlex.admin.ch/eli/oc/2012/394/fr; Ordonnance instituant des mesures à l’encontre de la Syrie, RO 2015 45 (Dec. 17, 2014),
https://www.fedlex.admin.ch/eli/oc/2015/14/fr. For measures against Iraq, see Ordonnance instituant des mesures économiques
envers la République d’Irak, 946.206 (Aug. 7, 1990), https://www.fedlex.admin.ch/eli/cc/1990/1316_1316_1316/fr; amended by Ordon-
nance instituant des mesures économiques envers la République d’Irak, RO 2003 1887 (May 28, 2003), https://www.fedlex.admin.ch/
eli/oc/2003/283/fr.
426 Financial Crimes Enforcement Network Notice, FinCEN Informs Financial Institutions of Efforts Related to Trade in Antiq-
uities and Art, FIN-2021-NTC2 (Mar. 9, 2021), https://www.fincen.gov/sites/default/files/2021-03/FinCEN%20Notice%20on%20Antiq-
uities%20and%20Art_508C.pdf.
427 See Financial Crimes Enforcement Network Press Release, FinCEN Launches Regulatory Process For New Antiquities
Regulations (Sept. 23, 2021), https://www.fincen.gov/news/news-releases/fincen-launches-regulatory-process-new-antiquities-reg-
ulations. See also Clooney Foundation for Justice, Conflict Antiquities: US Financial Crimes Enforcement Network Should Strength-
en Regulations on Antiquities Trade (Oct. 27, 2021), https://cfj.org/news_posts/conflict-antiquities-us-financial-crimes-enforce-
ment-network-should-strengthen-regulations-on-antiquities-trade/.
428 WHITE HOUSE, UNITED STATES STRATEGY ON COUNTERING CORRUPTION, PURSUANT TO THE NATIONAL SECU-
RITY STUDY MEMORANDUM ON ESTABLISHING THE FIGHT AGAINST CORRUPTION AS A CORE UNITED STATES NATIONAL
SECURITY INTEREST (2021). https://www.whitehouse.gov/wp-content/uploads/2021/12/United-States-Strategy-on-Counter-
ing-Corruption.pdf.
429 See Statement by Paulo Pinheiro, Chair of the Independent International Commission of Inquiry on the Syrian Arab Repub-
lic, to the 49th Session of the United Nations Human Rights Council (Mar. 18, 2022), https://www.ohchr.org/en/statements/2022/03/
statement-paulo-pinheiro-chair-independent-international-commission-inquiry; S.C. Res. 2379, ¶ 1 (Sept. 21, 2017), https://undocs.
org/S/RES/2379(2017) (stating that “those responsible in this group [ISIL (Da’esh)] for such acts, including those that may amount
to war crimes, crimes against humanity, and genocide, must be held accountable”); S.C. Res. 1970, at 1 (Feb. 26, 2011) (considering
that the “widespread and systematic attacks currently taking place in the Libyan Arab Jamahiriya against the civilian population
may amount to crimes against humanity”), https://www.undocs.org/S/RES/1970%20(2011); Office of the High Commissioner of
Human Rights Press Release, Yemen: U.N. Experts Highlight Possible War Crimes Committed by Parties to Conflict, (Aug. 28, 2018),
https://www.ohchr.org/en/press-releases/2018/08/yemen-united-nations-experts-point-possible-war-crimes-parties-conflict?Lan-
gID=F&NewsID=23479 (expressing “reasonable grounds to believe that persons within the Government of Yemen and the coalition
allegedly carried out attacks in violation of the principles of distinction, proportionality and precaution, which could constitute war
crimes”).
430 See, e.g., Jenny Hill, German Court Finds Syrian Colonel Guilty of Crimes Against Humanity, BBC NEWS (Jan. 13, 2021),
https://www.bbc.com/news/world-europe-59949924; Iraqi Man Convicted in Sweden of War Crimes, AP NEWS (Dec. 6, 2016), https://
apnews.com/article/7cd2068f756449bb87167276dcc4b981.
431 Convention for the Amelioration of the Condition of the Wounded and Sick in Armed Forces in the Field, Aug. 12, 1949, 6
U.S.T. 3114; 75 U.N.T.S. 31; Convention for the Amelioration of the Condition of Wounded, Sick and Shipwrecked Members of Armed
Forces at Sea, Aug. 12, 1949, 6 U.S.T. 3217; 75 U.N.T.S. 85; Geneva Convention Relative to the Treatment of Prisoners of War, Aug. 12,
1949, 6 U.S.T. 3316; 75 U.N.T.S. 135; Geneva Convention Relative to the Protection of Civilian Persons in Time of War, Aug. 12, 1949, 6
U.S.T. 3516; 75 U.N.T.S. 287; see also Protocol Additional to the Geneva Conventions of 12 August 1949, and Relating to the Protection
of Victims of International Armed Conflicts (Protocol I), June 8, 1977, 1125 U.N.T.S. 3.; Protocol Additional to the Geneva Conventions
of 12 August 1949, and Relating to the Protection of Victims of Non-International Armed Conflicts (Protocol II), June 8, 1977, 26 I.L.M.
568, 1125 U.N.T.S. 609.
432 See International Committee of the Red Cross, Rule 156. Definition of War Crimes, IHL DATABASE: CUSTOMARY IHL (last
accessed May 17, 2022), https://ihl-databases.icrc.org/customary-ihl/eng/docindex/v1_rul_rule156 (noting that State practice estab-
lishes this rule as a norm of customary international law applicable in both international and non-international armed conflicts).
433 Rome Statute of the International Criminal Court, art. 8, July 17, 1998, 2187 U.N.T.S. 90; See also INTERNATIONAL CRIMI-
NAL COURT, ELEMENTS OF CRIMES art. 8 (2011).
434 Rome Statute of the International Criminal Court, art. 7, July 17, 1998, 2187 U.N.T.S. 90; see also, INTERNATIONAL CRIMI-
NAL COURT, ELEMENTS OF CRIMES art. 7(1) (2011).
435 CODE PENAL [C. PEN. FR.] (PENAL CODE), arts. 211-1—215-3, 461–15 (Fr.).
436 CODE PENAL [C. PEN. BELG.] (PENAL CODE), arts. 136-140 (Belg.).
437 SCHWEIZERISCHES STRAFGESETZBUCH [STGB] [CRIMINAL CODE] Dec. 21, 1937, SR 757 (1938), as amended by Gesetz,
124
Oct. 4, 1991, AS 2465 (1992), art 264a (Switz.). Article 264a criminalizes crimes against humanity but does not require the existence
of a State or organizational policy to prove the commission of a widespread or systematic attack. See TRIAL INTERNATIONAL, LA
LUTTE CONTRE L’IMPUNITE EN DROIT SUISSE : COMPETENCE UNIVERSELLE ET CRIMES INTERNATIONAUX 95 (2 ed., 2016),
https://trialinternational.org/wp-content/uploads/2016/06/La-lutte-contre-limpunite-en-droit-suisse-publication.pdf.
438 CÓDIGO PENAL (PENAL CODE), arts 605, 616bis (Spain).
439 VÖLKERSTRAFGESETZBUCH (CODE OF CRIMES AGAINST INTERNATIONAL LAW), at §§ 7, 8–12 (Ger.)
440 International Criminal Court Act 2001, c. 17, Part V.
441 18 U.S.C. § 2441(a).
442 18 U.S.C. § 2441(c)(3).
443 18 U.S.C. § 2340A(b) (noting that torture applies to conduct outside of the United States and providing that “[t]here is juris-
diction over the activity prohibited” if “the alleged offender is present in the United States, irrespective of the nationality of the victim
or alleged offender”).
444 18 U.S.C. § 2332f(b) (providing for jurisdiction over offenders who committed an offense by detonating an explosive outside
of the United States but are subsequently found in the United States).
445 These offenses include the following: taking hostages (18 U.S.C. § 1203); terrorism transcending national boundaries (18
U.S.C. § 2332b); threats and violence against foreign officials, official guests, and internationally protected persons (18 U.S.C. §§ 112,
878, 1116). U.S. law also allows broad jurisdiction for destruction of aircraft, violence at international airports, and air hijacking (18
U.S.C. §§ 32, 37 and 49 U.S.C. § 46502) and violence against ships (18 U.S.C. § 2280).
446 See, e.g., United States v. Friedrich Flick et. al (Case V), in Trials Of War Criminals Before The Nuernberg Military Tribu-
nals Under Control Council Law No. 10 1187, 1217 (1947) (holding that “[o]ne who knowingly by his influence and money contributes
to the support [of a violation of the law of nations] must, under settled legal principles, be deemed to be, if not a principal, certainly
an accessory to such crimes”); Prosecutor v. Furundžija, Case No. IT-95-17/1-T, Judgement, ¶ 245 (Int’l Crim. Trib. for the Former
Yugoslavia Dec. 10, 1998) (concluding that the accomplice need only “have knowledge that his actions will assist the perpetrator in the
commission of the crime”); Prosecutor v. Šainović et al., Case No. IT-05-87-A, Judgement, ¶ 1772 (Int’l Crim. Trib. for the Former Yu-
goslavia Jan. 23, 2014) (“It is firmly established in the jurisprudence of the Tribunal that to satisfy the mens rea requirement for aiding
and abetting, it must be shown that the aider and abettor knew that his acts or omissions assisted the commission of the specific
crime by the principal.”); Prosecutor v. Brima, Kamara & Kanu, Case No. SCSL-2004-16-T, Judgement, ¶ 776 (Sp. Ct. for Sierra Leone
June 20, 2007); Prosecutor v. Taylor, Case No. SCSL-03-01-T, Judgement, ¶¶ 486-87 (Sp. Ct. for Sierra Leone May 18, 2012); Prosecutor
v. Kaing, Case No. 001/18-07-2007/ECCC/TC, Judgement, ¶ 535 (Extraordinary Chambers in the Courts of Cambodia July 26, 2010);
Prosecutor v. Kalimanzira, Case No. ICTR-05-88-T, Judgement, ¶ 161 (June 22, 2009).
447 See, e.g., United States v. Friedrich Flick et. al (Case V), in Trials Of War Criminals Before The Nuernberg Military Tribunals
Under Control Council Law No. 10 1187, 1217 (1947) (holding that “[o]ne who knowingly by his influence and money contributes to the
support [of a violation of the law of nations] must, under settled legal principles, be deemed to be, if not a principal, certainly an
accessory to such crimes”); Trial of Bruno Tesch and Two Others (“The Zyklon B Case”), 1 Law Reports of Trials of War Criminals 93,
101 (1947) (Brit. Mil. Ct., Hamburg Mar. 1-8, 1946) (the defendants “knew that the gas was to be used for the purpose of killing human
beings”).
448 See Rome Statute of the International Criminal Court, arts. 25(3)(c), 30(2)(b), July 17, 1998, 2187 U.N.T.S. 90; Kai Ambos, Arti-
cle 25, in ROME STATUTE OF THE INTERNATIONAL CRIMINAL COURT: A COMMENTARY 979, 1009 (Otto Triffterer & Kai Ambos
eds., 2016) (noting that the drafters “set aside the . . . jurisprudence” of the ICTY and ICTR). It should be noted that commentators
have opined that “purpose” may modify the provision of assistance, rather than the completion of the criminal conduct by the prin-
cipal. See, e.g., Thomas Weigend, How to Interpret Complicity in the ICC Statute, JAMESGSTEWART.COM (Dec. 15, 2014), http://
jamesgstewart.com/how-to-intepret-complicity-in-the-icc-statute/.
449 See Prosecutor v. Bemba et al., ICC-01/05-01/08-3343, Art. 74 Judgment Pursuant to Article 74 of the Statute, ¶ 93 (Mar. 21,
2016) (“Article 25(3)(c) . . . does not require the meeting of any specific threshold. The plain wording of the statutory provision does
not suggest the existence of a minimum threshold.”); Prosecutor v. Yekatom, ICC-01/14-01/18, Corrected version of ‘Decision on the
Confirmation of Charges against Alfred Yekatom and Patrice-Edouard Ngaissona’, ¶ 101 (Int’l Crim. Ct. Dec. 11, 2019) (no mention of
“substantial” effect on the defendant’s aiding and abetting activities).
450 See Prosecutor v. Mbarushimana, ICC-01/04-01/10-465-Red, Decision on the Confirmation of Charges, ¶ 274, n.653 (Int’l
Crim. Ct. Dec. 16, 2011) (acknowledging that the Rome Statute’s unique mens rea standard departs from the ad hoc tribunal jurispru-
dence).
451 See, e.g., CODE PÉNAL [C. PÉN. FR.] (PENAL CODE), art. 121-7 (Fr.); CODE PENAL [C. PEN. BELG.] (PENAL CODE), art 66
(Belg.); SCHWEIZERISCHES STRAFGESETZBUCH [STGB] [CRIMINAL CODE] Dec. 21, 1937, SR 757 (1938), as amended by Gesetz,
Oct. 4, 1991, AS 2465 (1992) Section 27, ¶1 (Switz.); 18 U.S.C. § 2(a) (“Whoever commits an offense against the United States or aids,
abets, counsels, commands, induces or procures its commission, is punishable as a principal.”)
452 CODE PENAL [C. PEN. FR.] (PENAL CODE), art. 121-7 (Fr.).
453 Jindan-Karena Mann, Money as Complicity: Can Banking and Finance Services Facilitate International Crimes?, RETHINK-
ING SLIC (June 8, 2020), https://www.rethinkingslic.org/blog/criminal-law/70-money-as-complicity-can-banking-and-finance-ser-
vices-facilitate-international-crime. See also Cour de cassation [Cass.] [supreme court for judicial matters] crim,. Jan. 23, 1997,
96-84.822; Cour de cassation [Cass.] [supreme court for judicial matters] crim., Sept. 7, 2021, 19-87.367, ¶ 81-82.Error! Hyperlink
reference not valid.
125
454 Cour de cassation [Cass.] [supreme court for judicial matters] crim,. Jan. 23, 1997, 96-84.822; Cour de cassation [Cass.] [su-
preme court for judicial matters] crim., Sept. 7, 2021, 19-87.367, ¶ 81-82.
455 Cour de cassation [Cass.] [supreme court for judicial matters] crim,. Jan. 23, 1997, 96-84.822; Cour de cassation [Cass.] [su-
preme court for judicial matters] crim., Sept. 7, 2021, 19-87.367, ¶ 81-82. The case concerns Lafarge, a French cement company (part of
Swiss LafargeHolcim), which maintained the active operations of its cement plant in northern Syria through its Syrian subsidiary be-
tween 2012 and 2015. During this time period, the territory on which the cement plant is located experienced fighting and occupation
by various armed groups, including Da’esh. The Court held that sufficient and detailed knowledge of the primary crimes committed
is enough to meet the complicity standard and found that “the knowing payment of a sum of several million dollars to an organiza-
tion whose purpose is only criminal is sufficient to characterize the complicity by aid and assistance.
456 Cour de cassation [Cass.] [supreme court for judicial matters]., Feb. 22, 1937, Pas. 1937, I, 67; Cour de cassation [Cass.] [su-
preme court for judicial matters]., Jan. 8, 1973, Pas. Cour de cassation [Cass.] [supreme court for judicial matters]., April 5, 1996, J.T.
1996, p. 411.
457 Loi du 18 septembre 2017 relative à la prévention du blanchiment de capitaux et du financement du terrorisme et à
la limitation de l’utilisation des espèces [Law on the prevention of money laundering and terrorist financing and on the re-
striction of the use of cash], M.B., Oct. 6, 2017, arts. 19, 35, https://www.ejustice.just.fgov.be/cgi_loi/change_lg.pl?language=-
fr&la=F&cn=2017091806&table_name=loi.
458 Carlos Gómez-Jara Díez & Luis E. Chiesa, Spanish Criminal Law, in THE HANDBOOK OF COMPARATIVE CRIMINAL LAW
25 (Kevin Jon Heller & Markus D. Dubber, eds., 2011).
459 TRIAL INTERNATIONAL, UNIVERSAL JURISDICTION LAW AND PRACTICE IN GERMANY 14 (2019), https://www.justi-
ceinitiative.org/publications/universal-jurisdiction-law-and-practice-germany.
460 While courts vary somewhat in describing the elements of aiding and abetting, the listed components are the core elements.
See, e.g., United States v. Sineneng-Simon, 910 F.3d 461, 482 (9th Cir. 2018); see also CONG. RESEARCH SERV., ACCOMPLICES,
AIDING AND ABETTING, AND THE LIKE: AN OVERVIEW OF 18 U.S.C. § 2, 3 (2020) (reciting the elements as through reference to
case law as: “[1] that a defendant in some sort associate himself with the venture, [2] that he participate in it as something that he
wishes to bring about, [3] that he seek by his action to make it success, and [4] that someone commits the offense.”).
461 See Rosemond v. U.S., 572 U.S. 65, 72–3 (2014) (internal citations omitted) (emphasis in original).
462 See Rosemond v. U.S., 572 U.S. 73 (2014).
463 International Convention for the Suppression of the Financing of Terrorism, Dec. 9, 1999, 116 Stat. 724, 2178 U.N.T.S. 197.
464 S.C. Res. 1566, ¶ 3 (Oct. 8, 2004), https://www.un.org/ruleoflaw/files/n0454282.pdf.
465 18 U.S.C. § 2339B(a)(1) (assigning a penalty of up to 20 years or life if a death results).
466 18 U.S.C. § 2339B(g)(6) (defining “terrorist organization” as a group designated as such under section 219 of the Immigration
and Nationality Act).
467 18 U.S.C. § 2339B(a)(1) (requiring that the person have knowledge that the organization engaged or engages in terrorist activ-
ity as defined in section 212(a)(3)(B) of the Immigration and Nationality Act).
468 18 U.S.C. § 2339B(a)(1) (requiring that the person have knowledge that the organization engaged or engages in terrorist activ-
ity as defined in section 140(d)(2) of the Foreign Relations Authorization Act, Fiscal Years 1988 and 1989).
469 18 U.S.C. § 2339B(d)(2) (specifying that “there is extraterritorial Federal jurisdiction over an offense under this section.”), §
2339B(d)(1)(C) and 2339B(d)(1)(F) (providing jurisdiction if “after the conduct required for the offense occurs an offender is brought
into or found in the United States, even if the conduct required for the offense occurs outside the United States” and if an offender
aids and abets or conspires with a person over whom there is jurisdiction under the statute).
470 See 50 U.S.C. §§ 1701–05; Exec. Order No. 13,224, 31 C.F.R. 594 (2001).
471 See Michael Taxay et al., What to Charge in a Terrorist Financing or Facilitation Case, 62 U.S. ATTORNEYS’ BULLETIN 9, 12
(2014), https://www.justice.gov/sites/default/files/usao/legacy/2014/09/23/usab6205.pdf; Exec. Order No. 13,224, 31 C.F.R. 594 (2001);
Sanctions List Search, OFFICE OF FOREIGN ASSETS CONTROL, https://sanctionssearch.ofac.treas.gov/ (last accessed May 17,
2022).
472 Loi du 18 septembre 2017 relative à la prévention du blanchiment de capitaux et du financement du terrorisme et à
la limitation de l’utilisation des espèces [Law on the prevention of money laundering and terrorist financing and on the re-
striction of the use of cash], M.B., Oct. 6, 2017, arts 19, 35, https://www.ejustice.just.fgov.be/cgi_loi/change_lg.pl?language=-
fr&la=F&cn=2017091806&table_name=loi.
473 CODE PENAL [C. PEN. BELG.] (PENAL CODE), art. 140 (Belg.).
474 CODE PENAL [C. PEN. FR.] (PENAL CODE), art. 421-2-2 (Fr.).
475 CODE PENAL [C. PEN. FR.] (PENAL CODE), art. 421-2-2 (Fr.).
476 SCHWEIZERISCHES STRAFGESETZBUCH [STGB] [CRIMINAL CODE] Dec. 21, 1937, SR 757 (1938), as amended by Gesetz,
Oct. 4, 1991, AS 2465 (1992), art 260quinquies (Switz.).
477 CÓDIGO PENAL (PENAL CODE), art. 573 (Spain).
478 CÓDIGO PENAL (PENAL CODE), art. 576bis3 (Spain).
479 See T.S., Oct. 1, 2007, J.T.S. 798/2007 (Spain).
480 See e.g., Lorenzo D’Agostino & Judith Vonberg, Two Spaniards Arrested Over Smuggling of Artifacts Looted by ISIS, BBC
NEWS (Mar. 29, 2018), https://www.cnn.com/2018/03/29/europe/spain-arrests-isis-artifacts-libya-intl/index.html.
126
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Conflict The Need for Prosecuting

The full Report is available online on our web-

The Docket, an initiative of the Clooney Foundation for

© Cyrus Vance Jr., Manhattan District Attorney’s Office (2019).

Invaluable artifacts—statues, ornaments, jewelry, books,

~ A Syrian engineer, interviewed in Turkey

Conflict antiquities traded in Europe State and non-state armed

The global traffic in looted cultural objects is at times dismissed as a vic-

Illegal looting continues at archaeological sites to

Reports indicate that pillage was rampant in Mari,

© Google Earth. Captured by Clooney Foundation for Justice.

Understanding these routes, as well as those through

Specific routes vary depending on the country of origin

In December 2016, the United States Department of

© Press Release, United States Files Complaint Seeking Forfeiture of Antiquities

As circulated in Red Lists of Cultural Objects at Risk by the International Coun-

~ A Syrian digger and smuggler, interviewed

Freeports are tax-free warehouses created to tem-

Transit countries are essential for the process of “laun-

Freeports—essentially, tax-free warehouses created to

© Matthew Sargent et al., Tracking and

The ATHAR Project conducted an in-depth study of

© Amr Al-Azm & Katie A. Paul, Facebook’s Black Market in Antiquities,

The World Atlas of Illicit Flows

© World Atlas of Illicit Flows, INTERPOL

International enforcement efforts have focused almost

While the legal frameworks differ from jurisdiction to

Need for criminal prosecutions

© Clooney Foundation for Justice

~ A curator of an archeological site near

The Docket recommends conducting investigations and pursuing criminal prose-

To the UN Security Council, UNESCO, UNITAD,

º Reflecting the international nature of these crimes and networks, in-

º The United Nations Security Council should condemn the looting of

º UNESCO should leverage its expertise on cultural heritage and applica-

º The International Criminal Court’s Office of the Prosecutor should ad-

º International organizations should support the establishment of per-

To INTERPOL, EUROPOL, and law

º Law enforcement agencies should allow for effective collaboration be-

º Law enforcement agencies should develop and implement trainings be-

º Law enforcement agencies should report data on cultural property sei-

To national authorities and governments

º States should actively support and cooperate with the International

º States should hold individuals and corporations accountable for their

º States should provide funding and resources to ensure law enforcement

º States should open and support structural investigations of these net-

º Where necessary, States should enact domestic legislative changes to

º To protect the abuse of international and domestic financial systems

º States should implement non-self-executing international instruments

º Civil society actors should develop digital collaboration between aca-

º Civil society actors should enhance transdisciplinary collaboration be-

º Civil society actors should develop synergies with responsible partners

º Civil society actors should enhance collaboration between international

º Civil society actors should participate in criminal and judicial processes

To the art and antiquities industry and relat-

º As persons most likely to be in contact with looted antiquities, private

º Private institutions should support and develop self-regulated trade

º Private institutions should support the strengthening of due diligence

º Private institutions should develop and implement trainings to ensure

To online sale platforms and social networks