Why UNESCO’s new Code of Ethics for the art market is an opportunity missed

Why UNESCO’s new Code of Ethics for the art market is an opportunity missed

After five years of dialogue, UNESCO has finally published its revised Code of Ethics for the international art market. The idea is that it should set improved standards of conduct that follow the latest ethical guidelines to protect national interests and prevent crimes such as looting and trafficking.

The Code is currently voluntary. Will it work?

The approach, tone and lack of precision leave it facing an uphill struggle to convince market professionals that it will also protect their interests.

The problems start in the first sentence: “Members of the trade in cultural property recognise the key role that trade has traditionally played in the dissemination of culture and in the distribution to museums and private collectors of foreign and domestic cultural property for the education and inspiration of all peoples.”

Yes, the trade does recognise this, but the question is whether UNESCO recognises it. No acknowledgement here.

Sentence two brings its own issues: “They [the trade] acknowledge the worldwide concern over the illicit trafficking of stolen, illegally alienated, clandestinely excavated and illegally exported and imported cultural property, in line with the MONDIACULT 2022 Declaration, and accept the following principles of professional practice intended to safeguard cultural property from criminal activities.”

Risk of undermining human rights

What does ‘illegally alienated’ mean in this context? No explanation appears. And the assumption that the trade falls in line with the Mondiacult 2022 Declaration is misguided. That Declaration makes a commitment to return cultural property to its countries of origin even if it was not removed illegally. The Declaration makes assumptions about ethics in relation to cultural property that are based on questionable current trends in ideology rather than a broader, long-standing moral and common-law principle. For instance, it stresses the importance of human rights but then sets out to undermine those rights when it comes to the private ownership of cultural property, by demanding an end to transactions where provenance documentation is incomplete. It appears to call on UNESCO to act beyond its remit.

The whole approach to how the trade should adopt and commit to the Code is unsettling. Far from being constructive and persuasive, the tone is menacing and manipulative. Traders who voluntary abide by the Code “should be recognised as having committed themselves to a set of professional standards”. This is unnecessary in the case of those who have already done so in becoming members of trade associations that have codes of practice – a stricter commitment than that required by a code of ethics.

Likewise, “Traders who have decided to abide by the principles of the Code will submit a declaration to that effect to UNESCO, as well as to their professional association. Professional associations of traders that support UNESCO in promoting their members’ compliance with the principles of the Code will submit a declaration to that effect to the UNESCO Secretariat.”

None of this sounds voluntary.

What a ‘living document’ might mean

What happens if they follow these directions? How long before UNESCO leverages this position to try to enforce its Code as national and international law by the back door?

The trouble with such declarations made in this way – and mentioning that they have consulted the art market – is that it suggests that the Code enjoys trade endorsement, which it doesn’t. Nor is it workable. The danger is that decision-makers will believe otherwise. And so the bar is raised ever higher, making trade professionals’ daily lives impossible.

Further enhancement along these lines seems likely in the context of Member States emphasizing that the Code should be considered as a ‘living document’, with UNESCO periodically assessing it with ‘relevant stakeholders’ to ensure its continued relevance in light of evolving challenges related to trafficking. This is nothing less than a blank cheque. It is not fair to ask the market to sign up to this.

Principle 1 distinguishes “illegally alienated” cultural property from that which may have been stolen… clandestinely excavated or illegally exported or imported. But what does illegally alienated mean here? As can be seen from the Member States’ caveat above, the goalposts are ever on the move. Goods legally sold and exported years ago are now being deemed national property and illicit in domestic law as nations update their cultural heritage legislation in ever more restrictive ways. Under the Code, this might well render such goods illicit internationally, even when they have been legally traded and owned privately for lengthy periods, and so might be subject to confiscation.

While Principle 2 reasonably commits traders to recording transactional information such as the identity of suppliers, any attempt to use that as a stepping stone to force them to reveal confidential information protected by contractual obligations would cause serious problems. This would be possible under a ‘living document’.

Further lack of clarity over terms

Principle 3 commits traders to conducting ‘proper’ due diligence without fully stipulating what that constitutes. Again it talks of ‘illegally alienated’ items, as well as checking “any other relevant information and documentation which they can reasonably obtain” and scrutinising ICOM Red Lists. What does ‘reasonably obtain’ mean? If due diligence is too burdensome, it would render much of the lower end of the market uneconomic. What measures have been put in place to prevent that?

Principle 4 describes a trader’s ‘reasonable cause’ to believe that an item might be illicit and what their commitment must be under those circumstances but does not define ‘reasonable cause’ in this context.

Principle 4 also states: “A trader who is in possession of the item, where that country seeks its return within a reasonable period of time, will take all legally permissible steps under the trader’s applicable national law to co-operate in view of the return of that item of cultural property to the country of origin.” This appears to commit a trader to return an item simply on the basis of a claim, regardless of whether or not they hold the item lawfully. Long experience has shown that countries of origin claim items whatever their status, so without qualifying that the item must be illicit, the Code would prove unacceptable to the market. Such a catch-all condition would also be inconsistent with pre-existing national or international laws or conventions, such as statutes of limitation endorsed by UNESCO 1970 and UNIDROIT 1995 which are routinely ignored.

Principle 5 repeats the demands of Principle 4, putting the burden on the trader to ensure the item is returned.

No clause addresses the rights of the traders.

An opportunity missed

In recent years, art market stakeholders have been included in discussions about the drafting of the Code, but in the final two meetings earlier this year, CINOA, the global trade federation representing 5,000 dealers – the largest trade group in the world and the vital market stakeholder – was inexplicably not invited to attend. How did that happen?

UNESCO’s new Code of Ethics is an opportunity missed. It appears to blur the line between ethical aspiration and legal requirement. It should have been drafted as a constructive agreement between stakeholders to improve standards and create more clarity; instead its tone and terms appear intimidatory and opaque. It is inconsistent with the laws of numerous countries in relation to property rights and good faith purchases. Market stakeholders approached this initiative in good faith. The result is far from what they could agree to.

how big a problem is cultural goods trafficking?Let’s ask the World Customs Organisation

how big a problem is cultural goods trafficking?Let’s ask the World Customs Organisation

Out now for almost six months, the World Customs Organisation’s latest Illicit Trade Report (ITR) covers the year 2024. The introduction hails the report as offering “a comprehensive analysis of the dynamics and evolving trends of illicit trade. This edition underscores the complexity and adaptability of transnational criminal networks, highlighting impacts on public safety, global security, and sustainable development.”

So what does the highly detailed and analytical 305-page report have to say about cultural property crime?

Very little indeed.

On page 23, a bar chart provides The Number of Responses to the WCO Seizure Statistics. These appear to refer to the number of customs forces who have replied to a WCO survey asking for the number and volume of seizures in their jurisdiction. Responses concerning cultural goods rose from around 29 to 33 year-on-year to 2024.

A bubble chart on the following page appears to show a 75% rise in the number of cases involving cultural goods with a rise in the volume of goods seized somewhere below 5%. However, it also shows that the volume is tiny compared to any other form of illicit activity except for Explosive Precursors – chemicals that can be used in the creation of explosives.

On the following bubble chart showing year on year trends, cultural goods do not appear at all.

Chart 4 on page 26 illustrates priorities by commodity, with Cultural Goods listed as an Essential priority for around four out of 70 Customs administrations – the lowest score for any commodity. Around another eight administrations see it as a High priority, again the lowest score, and by some distance compared to most other commodities. These ratings remain almost unchanged from 2023, as the next bar chart shows us on page 27.

The attraction of fungible items

A key consideration making commodities attractive for money laundering is their fungibility, according to the introduction to the chapter on ML on page 37: “…the majority of these cases involve the illicit movement of bulk cash, but also include significant quantities of gold, rhodium, silver, and precious stones, including diamonds. These materials, due to their high value-to-weight ratio, fungibility, and ease of transport, remain attractive to criminal networks seeking to transfer or launder proceeds across borders while evading detection.”

As readers will know, a distinctive feature about artworks and antiquities is that they are not fungible.

Much of the Money Laundering and Counter Terrorism Financing chapter is dedicated to currency and gold smuggling – by far the biggest problem it identifies when it comes to ML, with an additional issue involving agricultural equipment in Brazil.

Saudi Arabia, Bangladesh and India reported the most cases, with Japan, Turkey and Sri Lanka next. All countries on the list are in the Middle East, Far East, Balkans and eastern Mediterranean. On page 68, the report concludes re ML: “The consistent involvement of departure points like UAE, Saudi Arabia, and Hong Kong-China, and destination corridors into India, Türkiye, Japan, and Bangladesh, suggests entrenched regional laundering networks that demand multi-jurisdictional enforcement.” Note: ‘regional’.

Jewellery and the high-risk traveller

On page 63, it reports: “Jewellery smuggling via couriers remains a key modality: The high number of pieces seized in Saudi Arabia, Türkiye, and Japan indicates frequent interception of concealed jewellery worn or carried by passengers, underlining the importance of profiling high-risk travellers and body-worn concealment detection.”

Overall, the ITR is extremely detailed, providing numerous graphs, data sets, case studies and photographs of seizures on extensive chapters concerning ML and terrorism financing, drug trafficking, environmental crime, intellectual property rights, health and safety, revenue fraud and smuggling, and security breaches.

Cultural goods had their own chapter – albeit revealing just how small the problem is – for several years until the early 2020s. No more, however.

Considering the level of intelligence in every other sphere of interest across such a wide number of jurisdictions, it is hardly credible that the dearth of data when it comes to cultural goods can be explained entirely by under reporting. At no point in any past WCO report have cultural goods ever shown any significant contribution to illicit trade on a global scale in comparison to other spheres. Now they show even less, despite all the lobbying claims to the contrary.

Customs administrations have consistently ranked it as their lowest priority. Could this be because it is the smallest issue that they face in this context?

Setting the right pain threshold is the key to success in setting anti-money laundering laws

Setting the right pain threshold is the key to success in setting anti-money laundering laws

In 2025 a bipartisan group of U.S. Senators pushed for new anti-money laundering regulation of the art market under the Bank Secrecy Act.

Already in force in the UK and Europe, AML laws as they apply to the art market may help fight crime and deter wrong doers, but the burden of compliance can come at a significant cost in terms of money and time.

A serious study of AML impact on the art market in the UK, which leads the world with regards to these measures in this sector, has yet to take place, but anecdotal evidence indicates that at least some would-be buyers are being put off by the requirements of compliance on their part, and by the intrusion into their privacy. This is not because they have something to hide but because the hassle has spoiled their enjoyment of the process of acquisition and they simply can’t be bothered to go through with it.

How do you balance the interests of crime prevention with those of the market?

The most obvious way would be to raise what appears to be an arbitrarily low value threshold for compliance: set at €10,000 for a single transaction or group of linked transactions (not always clearly defined), in the UK that is changing to £10,000.

Take a risk-based approach

Raising the threshold significantly can be argued from taking that vital ‘risk-based approach’ when one considers reporting in France, the European Union’s largest art market. The latest figures, as published in the Ministry of Economy & Finance’s 2024 report, show a total of 12 Suspicious Activity Reports (SARs) relating to art and antique dealers and intermediaries from 2022-2024 inclusive. For auction houses the number rises to 426 for the same period. Respectively, those figures account for 0.1% and 2.0% of reports across all sectors. No information is forthcoming about how many of those reports proved valid.

Some have argued that the low figures for the art market are the result of under reporting. Effectively, the logic of this argument is that art-related ML must be high under any circumstances, regardless of reporting, a standpoint that is simply not credible. If the reports are misleading, don’t publish them.

Another issue that has arisen in the UK is that although expert support from compliance companies has made things easier, interventions from enforcement teams working for HMRC have not where enforcement officers have not understood the law properly. Again, anecdotal evidence relates episodes of overreach, intimidation and damaging interference to legitimate business at inappropriate times.

Also challenging is the fact that after more than five years of enforcement in the UK, aspects of what is proving to be a complex regulation are still not clear. If the compliance companies and HMRC are still debating them, what hope have Art Market Participants (AMPs) of complying fully?

What Congress needs to consider

These factors must all be considered in the United States as Congress considers the proposed Art Market Integrity Act.

Some have argued that the art market is not bound by the anti-money laundering and counter-terrorism financing standards set by the Bank Secrecy Act. However, their qualifying transactions are already subject to these standards via the banking process.

The Senate voted down a previous attempt at regulation in 2022. The proposed Enablers Act risked undermining fundamental principles of the rule of law and citizens’ rights, argued the American Bar Association.

Such fears are justified because these rights are already being extensively undermined in relation to the art market by the plethora of bilateral agreements (also known as Memoranda of Understanding) with third countries that effectively give them a veto on cultural property imports that belong to U.S. citizens. Article 1 of the MoU with Egypt, for example, demonstrates this clearly. The seizure and return of items for which no proof of illegality is forthcoming has become commonplace. The reversal of the burden of proof to ‘guilty until proven innocent’ is all but standard in this sphere today. Such arbitrary interference with citizens’ property is in direct contravention of the 5th and 14th Amendments of the U.S. Constitution, as well as Article 17.2 of the Universal Declaration of Human Rights.

Current proposals under the Act are unworkable

Current proposals under the Art Market Integrity Act would be unworkable because they are far too wide in scope. Defining an AMP as “a person engaged in the trade in works of art, including a dealer, advisor, consultant, custodian, gallery, auction house, museum, collector, or any other person who engages as a business as an intermediary in the sale of works of art”, it allows for certain very limited exclusions. The key exclusion is someone who “has not, during the prior year, participated in total transactions valued at $50,000 that involved a work of art”.

To be clear, this is not a threshold of $50,000 for a single work of art, but a total sales value for all artworks sold over a period of 12 months of $50,000. This ‘mom and pop’ level of trade would not have the time and money to pay for compliance, meaning that the new regulation would simply put them out of business.

If Congress is to proceed with the Act, this section must be struck out or the result would be a disaster for ordinary U.S. citizens.

Lost Horizon – what is all this E.U. funding for?

Lost Horizon – what is all this E.U. funding for?

Countless millions are spent investigating cultural property trafficking to little effect

Preventing trafficking in cultural goods is a major preoccupation of the European Union.

It is one of the key objectives of the constantly updating anti-money laundering regulations; it is the main plank of the import licensing regulation introduced last year; and it led to the creation of Germany’s highly restrictive Cultural Property Protection Act in 2016.

Fears of cultural property trafficking, especially within Europe, have resulted in an ongoing series of co-ordinated law enforcement crackdowns across more than 80 countries since 2014, namely: Operations Odysseus (2014), Aureus (2015) Pandoras I, II, III, IV, V and more (2017-), Sardica (2018), and Achei (2019). These all come under the umbrella of the EMPACT initiative (European Multidisciplinary Platform Against Criminal Threats).

Four current projects running for several years and funded by Europe’s Horizon Project to the tune of €18 million follow on from countless others of the same ilk as they investigate the scourge of trafficking. They are Anchise (€4m), Aurora (€3.5m), Enigma (€4m), and Rithms (€5m) plus another €1.5m being assigned.

Their various remits include:

–      Developing methods and digital tools for the protection, identification and traceability of cultural goods.

–      Protection, tracing, restitution and safeguarding, as well as provenance research.

–      The production of evidence-based research to support the deployment of preventative measures against looting and illicit trade of cultural goods.

–      Raising awareness, mobilising and further strengthening cooperation among citizens, stakeholders, experts, policy makers and all actors involved.

Plenty of research but nothing to show for it

In Germany from 2015 to 2019, the €1.2m ILLICID Project analysed over 6,100 ancient objects as it attempted to identify the level and patterns of crime and how they might support money laundering and terrorism financing. At no point did its concluding report identify any trafficked goods or any terrorism financing, the prime goal of the whole project.

Now, a project headlined Culture, Creativity and Inclusive Society will enjoy another €5 million for ‘capacity building’, ‘evidence and intelligence gathering’, ‘cross domain co-operation’ and ‘consolidated tools and platforms’ – for which read more of the same.

So, with all this time and money spent on assessing the scope, methods and other characteristics of the trafficking of cultural goods in Europe and beyond, how big is the problem and what is this illicit trade worth?

The answer so far is that no one has a clue.

Organisations like UNESCO have tried to get round this in the past by quoting substantial figures (in UNESCO’s case $10 billion annually, first quoted in October 2020) that do not stand up to the slightest scrutiny, and which they have since stopped using, admitting that they had no basis in fact.

In March 2025, The European Commission published its final report under the title Study on measures to increase traceability of cultural goods in the fight against cultural goods trafficking at the Member State level and at the EU level.

It detailed the outcomes of Operations Odysseus, Aureus, Pandora and the rest (costs unknown but certainly in the tens of millions of euros based on minimal available data).

Arrest and seizures but no record of outcomes

Of the operations from 2015-2023, it reported: “These operations seized over 234,000 cultural objects (including small items such as coins), with at least 1,255 investigations initiated and 534 arrests made.”

However, despite these figures, no attempt has been made to measure the effectiveness of these operations. Europol, which helped co-ordinate the operations, has admitted to having no data on how many arrests have led to convictions, nor about how many seized items later had to be returned as licit.

The Commission report also reveals that in at least five of the operations, no data is available relating to the number of investigations launched as a result, and in at least three of them no record is available relating to the number of arrests.

The Commission’s publication of the report in March 2025 coincided with the Antiquities Forum’s launch of a survey of a dozen leading bodies concerned with the issue of cultural heritage crime across the world, from the European Commission itself to the FBI, UNESCO, Europol, Interpol and others. What independently verifiable data did any of them have to demonstrate the level and extent of trafficking, money laundering and terrorism financing using cultural property? Not all of them answered, but those that did provided no data at all.

After so many years of investigations and enforcement operations, what is the problem? Why are Europol and Interpol not tracking outcomes from their operations? With so little hard data to go on, one must ask what the point of these exercises are beyond propaganda and to justify the funding for law enforcement bodies.

Art market risk downgraded by the authorities

Art market representatives at the January 2026 meeting of experts with the European Commission to discuss progress with the import licensing regulation put the question again: what data does the European Union have to show the size and scope of trafficking, as well as the actual value of the illicit market in such objects? This is important bearing in mind the enormous level of resources – including public money – being spent on researching this issue. We await an answer.

After countless investigations, operations and reports over the past 15 years, none of the leading bodies among government, law enforcement and the NGOs can provide any idea whatsoever of the scale of the problem, nor any reliable data beyond the extremely occasional case, which almost never involves the art market. Even where it supposedly does – for example with The Louvre scandal – years after the arrests and claims are made, we still await any concrete result. So what does that tell us?

The European Union continues to fund multiple projects and initiatives to prevent the trafficking and looting of cultural property, primarily through Horizon Europe, the Internal Security Fund (ISF), and direct cooperation with UNESCO. While there is no single, isolated budget line for this, the EU Action Plan (2022–2025) provides a comprehensive framework, with millions allocated to specific research, technological, and law enforcement projects.

Among other recent and current initiatives in addition to those listed above are:

–      Specific Horizon 2026 Call: A dedicated call in 2026 for ‘Preventing and fighting illicit trafficking of cultural goods’ – €5 million.

– ARTDETECT, which focuses on cutting-edge technologies like AI and blockchain to detect stolen items. Part of an EU-funded €7.5 million research project via the Horizon programme led by Global technology company Orfium called AIXpert, the ultimate objective is to improve transparency and accountability in artificial intelligence systems across sectors.

– PRISM (2025-2027), which aims to fight trafficking in museums. This is part of a multiple set of distinct EU-funded ‘PRISM’ initiatives, the most recent being a €7.6 million project (PEACEPLUS programme) for manufacturing innovation and another focusing on cultural heritage protection.

–      The European Commission has co-delegated €2.8 million to UNESCO for a 36-month project (ending roughly 2025-2026) to fight illicit trafficking of cultural property in the Western Balkans.

In all, current projections account for a total of €22.9 million dedicated to future related initiatives. With the €18 million already accounted for, that’s a total of more than €40 million being funneled into multiple projects essentially doing the same thing. And yet, hard data showing the size, nature and scope of trafficking in cultural property, and its links to terrorism financing, remain all but non-existent.

What are these generous budgets really for?

Is it possible that the funds spent on research into cultural property looting and trafficking are actually greater than the value of the property looted and trafficked globally? Of course we cannot know because despite all the money spent, no one has any idea of what that figure is. What these budgets do ensure, however, is significant funding for academics, technocrats, civil servants and law enforcement as part of the incessant NGO/public policy forum gravy train, with the travelling circus of symposia and forums in plush hotels and conference centres around the globe. Enormous focus is put on process and projects, but precious little on effective outcomes and reliable intelligence. This extraordinarily lavish largesse seems unstoppable. Exactly who is holding those with the purse strings to account as the money disappears over the horizon?

None of the world’s top authorities able to supply accurate global data on cultural goods trafficking

None of the world’s top authorities able to supply accurate global data on cultural goods trafficking

Despite myriad figures for illicit trade worth billions or even tens of billions of dollars, no one can point to any reliable source for claims

A survey of a dozen of the world’s top law enforcement agencies and government departments has revealed that none of them appears to have any accurate data regarding the value of cultural goods trafficking globally.

This is despite multiple claims going back years of an illicit trade worth tens of billions of dollars.

Indeed, in at least one case – Interpol – the only reference to the size of the problem comes in a ten-year-old video still prominent on its website, in which former Secretary General Jürgen Stock makes the claim that the black market in art is as lucrative as the illicit markets in drugs, weapons and counterfeit goods – a claim long since exposed as untrue.

Carried out on behalf of several art market trade associations, the survey sought responses from the European Commission, the EU Directorate for Culture, the European Anti-Fraud Office (OLAF), the US State Department, Interpol, Europol, the FBI, Homeland Security, the Financial Action Task Force, the UK’s National Crime Agency, the World Customs Organisation and UNESCO.

Care was made to approach the correct source for such information in each case, and follow-up requests were made when advised by the relevant authority of a different source.

The aim was to get a clear picture of trafficking levels

The aim of the survey was to establish a clear picture of global trafficking data for cultural property.

“It is important to establish credible data to defeat the extensive misinformation and disinformation surrounding this subject, which plays a significant part in hampering effective policy making,” the authorities were told.

Each was asked the following: “Do you have any independently verifiable figures relating to the value of trafficking of cultural property, especially any global figures for the annual value of this risk area?”

And each was asked to supply the data and its sources if it was available. Not one did. More than one admitted that it didn’t have the information or that it simply did not exist. These included organisations producing extensive reports claiming cultural goods trafficking is a huge problem.

Others either did not respond or directed the request to another source. In one case, the UK’s National Crime Agency, the request was met with refusal to respond on the grounds that it was not a public body.

No relevant data from Interpol or Europol

Despite mass data being made available for associated issues and other categories of risk via the World Customs Organisation annual Illicit Trade Reports, together with arrests and seizure data from Interpol and Europol via Operations such Pandora, not one authority was able to provide any credible data on the size of cultural goods trafficking.

Having previously stated on its website that it had no data showing the size of the problem and adding that it never expected to have any reliable data on global trafficking in cultural property, Interpol says it is a “lucrative black market” and introduces its Cultural Heritage Crime section as follows: “Trafficking in cultural property is a low-risk, high-profit business for criminals with links to organized crime. From stolen artwork to historical artefacts, this crime can affect all countries, either as origin, transit or destinations.”

Requests to both Europol and the World Customs Organisation have proved equally fruitless.

Europol directed the request to its website, which gives no such data. However, it had responded to an earlier request, stating: “We do not have these figures. Europol is not a statistical organisation – Europol’s priority is to support cross-border investigations and the information available is solely based on investigations supported by Europol.”

Europol has since confirmed that it does not have the relevant data.

When emailed in February, asking why it no longer included any relevant data in its annual Illicit Trade Report on Cultural Goods, The WCO explained that global data on illicit trade “does not exist”.

When emailed again in March, it did not respond.

No relevant data available from Eurostat

The European Commission’s information service directed the request to Eurostat, but that does not have any relevant data.

The Financial Action Task Force directed the request to its 2023 report: Money Laundering and terrorist Financing in the Art and Antiquities Market. However, much of that report is based on historically inaccurate data and provides no credible figures for global trafficking at all. It also acknowledges that it does not have the data, stating on page 28: “The lack of reliable statistics concerning looting activities, especially from conflict zones, makes it difficult to assess the scale of the phenomenon. However, taking into account the volume of looted archaeological goods seized in certain international or national police operations, it appears that this is a large-scale activity.” This view does not tally with the global data published by the World Customs Organisation.

The US State Department directed the request to the Office of Civilian Security, Democracy, and Human Rights, providing two phone numbers. One had a voicemail, so a request was left for an email address, with no result; the other number did not work. The weblink provided by the State department gave no information on the ‘Office’. Extensive web searching came up with no contact details. No further response came.

A March 12 response from the FBI referred the request to an online request form, which was filled in the same day. To date, no further response has arisen.

No relevant data from the European Anti-Fraud Office

A follow-up request elicited a response from the European Anti-Fraud Office (OLAF). It welcomed the attempt to gather credible data but said its work did not relate directly to doing so itself.

No responses came at all from the Directorate-General for Education, Youth, Sport and Culture (DG EAC) (Cultural Heritage Unit); UNESCO’s Information Service (for all UNESCO data); or Homeland Security.

Readers will have their own views as to what this means, but the complete lack of any reliable data – or any data at all in most cases – raises the question as to what the unending slew of claims over global trafficking in cultural property are really based on.

A more detailed summary of individual responses is available.

  • This article will be updated by any further responses of note.