by ADA | Mar 22, 2026 | Views |
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?
by ADA | Jan 21, 2026 | Views |
Lack of data, high costs, poor resources and risks to human rights continue to blight the mission to trace trafficked cultural property
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 (Final report)
This report into what the European Commission believes should be done next to tackle the blight of cultural property trafficking is an eye-opener. It is telling that initial publication should take place just three months before the final enforcement of the previous mass enforcement measure, Reg 2019/880 on import licensing.
Nonetheless, this new report is fascinating because of what it reveals: specifically, the ongoing lack of data despite decades of study and multi-million euro funding for research; and high levels of self-awareness indicating an overwhelming lack of confidence in the viability of what is being proposed here. A continent-wide system linking up all existing databases (and adding new ones where needed) after they have adapted to a single standard could be a very effective means of combatting crime. However, as this 320-page report makes abundantly clear, too many obstacles persist to render this ambition anything but a fantasy.
Essentially the objective of the report is to pave the way for the introduction of a compulsory EU-wide registration and standardised due diligence system for reporting cultural property transactions. The idea is that this would allow national databases to interact with each other to create an EU-wide safety net and monitoring system.
EU-wide standardised network of databases
A continent-wide system linking up all existing databases (and adding new ones where needed) after they have adapted to a single standard could be a very effective means of combatting crime. However, as this 320-page paper makes abundantly clear, too many obstacles persist to render this ambition anything but a fantasy. Here are a few of the issues it raises:
– What would an effective single standard look like?
– Who would decide on what should be included?
– How do you define the parameters of what should be included on the databases?
– How do you get all Member States to comply when only nine of the 27 currently have databases and they are incompatible?
– What value threshold would you introduce if, as stated, the intention is to focus on high value goods (a wise course)? Matching the AML standard, as mooted, would mean €10,000, but that is very low and would risk overwhelming business, customs and possibly the databases themselves.
– Who would have access to the databases bearing in mind the historic protectionism exercised by existing databases? The report acknowledges that they would be ineffective if not publicly accessible.
– How do you persuade Member States to proceed when they have been unwilling so far and would largely have to fund the project themselves and set up support and enforcement teams? Initial estimated costs are €36.8 million, with an extra €383 million to link up Member States effectively.
– Why do we need further regulation when the same objectives are covered by existing measures such as EU Reg 2019/880 on import licensing?
– The report repeatedly emphasises the need for EU standards and human rights to be honoured, yet acknowledges just as repeatedly that what is being proposed risks breaching them.
As revealing is what comes in the preamble, where we discover the following:
– Data is hard to find and reliable data is largely non-existent, but art and antiques are seen as relatively high risk because they can be traded.
– Compliance value thresholds and claims of crime levels rely largely on guesswork.
– Law enforcement and others mostly extrapolate international crime levels from a few individual cases.
– Many of those cases involve art and criminals but not the art market.
– Risk categorisation for Terrorism Financing and Money Laundering are guesswork, with nation states acting on wish lists from law enforcement bodies and the belief that the risk must be high because it involves goods that can be traded.
Art Market input
As explained on page 277 of the report, apart from a few unspecified targeted interviews, consultation on this study with the art market was as follows:
An online survey targeting art market participants was launched in April 2024 and data was exported in July 2024. The survey aimed at gathering information about perceptions of the prevalence of trafficking, transaction recording practices and administrative costs and compliance costs incurred. A total of 32 replies were received from art dealers, galleries, auction houses, antique dealers and gallerists from Austria (1), Belgium (1), Czechia (1), Germany (11), France (2), Portugal (1), Sweden (6), Switzerland (1), the Netherlands (4) and the United Kingdom (3).
by ADA | May 22, 2023 | Views |
Europol has admitted not having any reliable statistics to support its headline claim over stolen objects in Operation Pandora VII, aimed at tackling cultural property trafficking.
Many media outlets have covered the results of the latest transnational operation co-ordinated by Interpol and Europol with a view to tackling trafficking in cultural property.
Pandora VII, led by the Guardia Civil in Spain, took place over 11 days in September 2022 with two cyber weeks in May and October.
The Europol media release itself stated that the operation led to the arrest of 60 people and the recovery of 11,049 stolen objects across 14 countries.
As the ADA knows well, there is a great deal of difference between seizing items and showing that they are stolen, just as arrests do not equate with convictions.
These operations, along with others named Athena and Odysseus, have been running for almost a decade, and to our knowledge, the authorities have never published either conviction rates or figures confirming how many seizures later proved justified. The ADA and fellow trade association IADAA have sought this information from Europol more than once, but Europol has replied each time that it does not have it, which makes its official release claim this time that 11,049 seized items were stolen all the more surprising.
The twin priorities in carrying out these operations have always been to clamp down on money laundering and terrorism financing, but while there may have been limited evidence of the former across the years, we have heard of no evidence at all of the latter.
Once again we contacted Europol asking the following: a) How many arrests have led to successful convictions? b) How many seizures proved to be valid + how many had to be returned to their owners? c) How many seizures were shown to be linked to money laundering? d) How many seizures proved to be linked to terrorism financing?
As others have also argued, without these accurate clear-up figures, the data serves no purpose beyond propaganda.
Europol’s media office ADMITS IT HAS NO ACCESS TO VITAL DATA
Europol’s media office replied on May 10 as follows: “Unfortunately, we won’t be able to help as 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.”
Confirmation, then, yet again that Europol has no statistics to support the claims it makes, with the further emphasis that Europol is “not a statistical organisation”. If so, what is it doing making statistical claims it admits it cannot support in the introduction to its media release, claims that history tells us will influence policy at a national and international level, as with the introduction to this recent important European Commission document?
Interpol, which has also denied having any reliable statistical information in this field, compounded the error.
Arguably more shameful is the number of media outlets that have reported the unsupported claims Europol has put out in this release without checking them. Newspapers, art market websites and others – all of them experts in their own fields and trained to check their sources – have singly failed to do so in this case.
They include Yahoo News, Artnet News, Euronews, and Reuters, among others.
It also includes outlets whose credibility entirely relies on accurate data, such as the Organised Crime and Corruption Reporting Project, and Border Security Report (the Journal of border security and transnational crime).
This is not the first time this has happened; these operations have been going on for a decade and the ADA and IADAA have highlighted the failure of intelligence on numerous occasions. As we showed in this instance, a single email request revealed the truth. So why can’t the experienced journalists working on this story make such a simple check as this to ensure that their reporting is accurate?
One of the worst offenders was Ursula Scheer, a journalist for Frankfurter Allgemeine, who not only swallowed everything she was told without checking, but added even more bogus data to the story unchecked: “According to estimates by the FBI and UNESCO, the annual turnover of the global black market for art and antiques is ten billion dollars, which puts the black market right behind the illegal drug and arms trade.” She also stated: “Selling art and antiques helps mafia activities finance terrorism and war.”
Those who want to know where the bogus data ends and the accurate data begins can check on our Facts & Figures page, which includes independently verifiable data through quoted sources and direct weblink.
by ADA | Mar 2, 2023 | News, Views
Just released, the Financial Action Task Force’s new report, Money Laundering and Terrorist Financing in the Art and Antiquities Market, takes a highly irresponsible approach.
The FATF is an independent global body investigating crime whose reports should prove key to policy making. Not this one, however.
Arguably the most salient conclusion it comes to is as follows: “The markets for art, antiquities and other cultural objects are diverse in size, business models and geographic reach. Most are relatively small, and the vast majority of participants have no connection to illicit activity.”
However, this is buried deep in the text, while the FATF has focused on launching the report with a headline grabbing video that gives the clear impression that the art market is awash with criminals committing offences linked to money laundering and terrorism financing.
Needless to say, anti-market forces have leapt on this to condemn the trade and demand further legal restraints, while ignoring the lack of substance in the report or the fact that rigorous anti-money laundering laws already apply in the UK, for instance.
As with so many other reports of this ilk, fact checking has been a casualty. The most important initial independent statistic the report quotes as it launches into its arguments is wrong. In paragraph 3 of the Introduction Background on page 5, it notes that the United Nations Office on Drugs and Crime (UNODC) “has estimated that in 2011, as much as USD 6.3 billion in illicit proceeds could have been laundered through or associated with the trade in cultural objects”. In fact, the figure, which was sourced from House of Commons Select Committee evidence in 2000 – now almost a quarter of a century ago – does nothing of the sort as CINOA’s Bogus Statistics report proves. FATF has simply taken UNODC’s word for it, thereby adding to the dissemination of fake news. This being the case, how reliable is the rest of the report?
The FATF’s work is important, so it is a shame that it, too, appears to have fallen into the trap of putting publicity before purpose in drawing attention to itself to justify its existence.
Further analysis of the report will follow.
by ADA | Nov 2, 2022 | News, Uncategorized, Views |
The World Customs Organisation has finally published a new report following the 2019 report, covering two years from 2019-2021, probably delayed because of the Covid 19 pandemic. Its results once again show that global levels of illicit trade in cultural property are far lower than claimed.
In the press release we read: “This year, the analysis provided in this Report is based on data collected from 138 Member administrations. Previously composed of six sections, the Report now covers seven key areas of risk in the context of Customs enforcement: Anti-money laundering and terrorist financing; Cultural heritage; Drugs; Environment; IPR, health and safety; Revenue; and Security.”
It also states: “The analysis contained in this Report is mainly based on the collection of data from the WCO Customs Enforcement Network (CEN) — a database of worldwide Customs seizures and offences”….
“However, the CEN database relies heavily on voluntary submissions by Members hence the quantity and quality of the data submitted to the system has its limitations”…
“However, as part of this new methodology, the data and information sources used to elaborate this Report has been enlarged to include various open sources.”
While the rest of the report might be “mainly based on the collection of data from the WCO Customs Enforcement Network (CEN)”, in the introduction to the Cultural Heritage chapter on page 57, the WCO goes further, admitting: “Unfortunately, the data received through the WCO’s Customs Enforcement Network (CEN) in 2020-2021 being incomplete, the following analysis will be mostly based on open source information.”
Case studies based on media reports rather than primary research
The result for the Cultural Heritage section is that most of the case studies are based on newspaper articles, sometimes even on events that happened decades ago, and have nothing to do with recent trafficking activities. This is alarming as much of the problem with false data plaguing the cultural property sector stems from misreporting in the media. It is even more alarming when the misleading picture created by a surface reading of the chapter will undoubtedly be used as ‘evidence’ in future campaigns against the art market, as past reports have been.
The WCO is supposed to report recent and reliable figures, like figure 3 on page 35, showing that the number of worldwide reported cultural goods cases for 2021 is a mere 156, that is 1.1 case per reporting country….
A newly introduced graph (shown here) in the WCO report (Page 17, Fig. 4) reveals precisely what the ADA and its fellow association IADAA have reported over the past years: the illicit trade in cultural heritage is so small that it barely shows in the statistics. Not only is it the smallest category – so small that you have to look carefully in case you miss it – but the graph also shows that seizures have fallen by around 50% between 2019 and 2021.
Let’s not forget, too, that the Cultural Heritage category is not limited to antiquities, as so many mistakenly believe; it covers 13 distinct sub-categories, including: all forms of art, antiques and collectables, household items, flora and fauna, books and manuscripts. In 2019, the top three categories of recovered item sub-categories were: Fauna, Flora, Minerals, Anatomy & Fossils; Other; and Hand-painted or Hand-drawn articles and works of art. No mention of antiquities, which did not even warrant its own sub-category.
All of this begs the question as to why, in its chapter on Cultural Heritage, the WCO has chosen to focus exclusively on photographs of seized antiquities (at least one of which seems to be a fake) alongside fossils and coins. The choice appears politically charged.Consistent reporting of
The WCO has stated in the past and here that there is under-reporting of crime in the culture sector and that it only counts seizures and cases reported via the Customs Enforcement Network (CEN), the implication being that the problem is much larger.
Figures consistently show low rate of illicit trade in cultural property
However, the miniscule share of illicit trade represented in its reports over the years by cultural property has been consistent, only now augmented by media reports not sourced via the CEN.
It further boosts this chapter of the report with a summary of Pandora VI, the latest in a seven-year campaign of international operations involving mass seizures and arrests. What the WCO, Europol or Interpol have never done, however, is to provide data on how many of their seizures and arrests later prove to be justified and how many were shown to be related to terrorism financing. It is not just the trade asking for these figures, academic investigators want them too to see how effective these operations are.
Previously the WCO has attempted to rebut the ADA and IADAA’s analysis of its reports, stating that the figures cannot be relied on. As our analysis always provides transparent sources for the data emanating from the reports, however, the WCO’s case against our analysis simply does not stand up.
Ultimately, its figures must be indicative of the global state of affairs; if they are misleading, why publish them?
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