Europol admits to having no reliable data to back its Pandora VII claim

Europol admits to having no reliable data to back its Pandora VII claim

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.

Financial Action Task Force Report’s anti trade approach rings alarm bells

Financial Action Task Force Report’s anti trade approach rings alarm bells

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.

W.C.O. data backs trade view of cultural heritage crime once again

W.C.O. data backs trade view of cultural heritage crime once again

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?

RAND Corporation report demolishes current thinking on antiquities trafficking

Most widely held assumptions are wrong,
it argues, and this has led to poor policy in tackling the problem

Report names and shames key figures involved
in creating hype and speculation, as well as bloggers and journalists

A major report by one of the most respected independent research organisations in the United States claims that current thinking on the trafficking of antiquities is mostly wrong.

Its findings have prompted it to propose a radical change in direction in the search for solutions.

The RAND Corporation argues that a lack of reliable evidence leads to wild speculation over trafficking[1] and poor policy in tackling the problem[2]. The illicit trade in antiquities is much smaller, opportunistic rather than organised, and more widely dispersed than previously thought, it concludes.[3]

“Our aggregate data suggest that the market for all antiquities, both licit and illicit, is on the order of, at most, a few hundred million dollars annually rather than the billions of dollars claimed in some other estimates … We believe that, going forward, scholars arguing that the illicit market is larger than we suggest here will need to more clearly articulate the means through which these goods are sold.”

Titled Tracking and Disrupting the Illicit Antiquities Trade with Open-Source Data, the report published on May 12 blames bloggers, journalists and advocacy groups for exaggerating – sometime ‘grossly exaggerating’ – the problem to attract headlines, funding and to effect policy change[4]. And it singles out one of the highest profile crusaders against trafficking, New York Assistant District Attorney Matthew Bogdanos, stating that the widely held but inaccurate belief that antiquities trafficking is linked to trafficking in drugs and weapons can mostly be traced back to him as the source.[5]

The report’s findings on this point go directly counter to the claim made by Europol Executive Director Catherine de Bolle in her official statement on the recent Athena II operation.[6]

The report also cites figures of $2 billion for Syria and $3 billion to $10 billion for Egypt quoted by Antiquities Coalition Founder and CEO Deborah Lehr in a Wall Street Journal article as misleading[7], while former AC Chief of Staff Katie Paul, who now heads the Athar Project, is accused of obtaining data and screenshots “with a RAND login to a third-party data provider that were published without consultation or permission”, an action deemed “ethically dubious”.[8]

Major findings in the RAND Corporation report

Major findings in the report, researched with the RAND Homeland Security Operational Analysis Center and partially funded though it work for the US Department of Defense, show that contrary to popular belief, illicit trade in antiquities is largely ad hoc rather than organised and a much smaller problem than previously thought. End markets are global, rather than focused on the West[9], policy and argument “has been dominated by speculation and hypotheses”, while almost no trafficking of antiquities is taking place via the dark web.[10]

It also notes that relatively low sell-through rates of legitimate antiquities at auction and through galleries, combined with the challenges of selling antiquities at all because of compliance, show muted demand, suggesting “that auctions could act only as a limited conduit for illicit sales”.[11]

“This reality that antiquities auctions represent a small market that is not always able to find buyers in well-advertised sales is at odds with the media’s assumption that there is a booming unmet demand for these goods that is capable of supporting a billion-dollar black market,” it concludes.

The report also finds that although fakes are a major issue in general, apparent attempts to traffic illicit items on Facebook are largely illusory, because a large number of the images posted have actually been lifted from recycled news articles or museum websites.[12]

The report concludes that current efforts to tackle trafficking are misguided, ineffective, costly and unrealistic, partially because they are based on inaccurate assumptions.[13]

Referring to transnational policing operations targeting traffickers, like Athena and Pandora, the report states: “For high-value goods and key nodes in the network, efforts by police and customs officials can successfully identify and prosecute criminal actors. However, these enforcement actions are time consuming, costly, and often require significant cross-border cooperation by law-enforcement agencies, which can often be difficult to organize. Instead, a broader-based approach aimed at undermining the trust among illicit actors and in the technologies they rely on could disrupt the illicit market more broadly and cheaply.”

Recognising that “legal standards can be troublesome because a plethora of various laws exist between and within countries, meaning that the correct legal standard that must be met can vary from object to object”, RAND recommends better targeting of clearly identified problem areas.

“…if the market is instead made up of ad hoc opportunists, then there are few centralized nodes that can be targeted to disrupt the whole market,” it argues. “Moreover, expensive and resource-intensive investigations may be inefficient in a market comprising small-scale dealers. In such cases, broader-based disruption tactics, which highlight the risks involved or publicize the damages that looting causes, might be more effective by reshaping the decisions of the individual actors involved.”

It recommends turning to disinformation campaigns: “Messaging campaigns conducted online—for example, through Facebook groups that are used by illicit actors along the supply chain (as discussed in Chapter Four)— would allow destabilizing information to be injected into trafficking networks.”


[1] See Summary, page xi

[2] See Policy Responses Based on Findings, page xiii and Directions for Future Research, page 97

[3] See Findings, page xi to xii

[4] See Introduction, page 3, and Issues with the Current Approach for Assessing the Antiquities Market’s Relationship to Terrorist Funding, page 10

[5] See Antiquities Trafficking Using Telegram, page 49-50

[6] See press release quote issued May 6, 2020 in relation to Operation Athena II: https://www.europol.europa.eu/newsroom/news/101-arrested-and-19000-stolen-artefacts-recovered-in-international-crackdown-art-trafficking

See also Issues with the Current Approach for Assessing the Antiquities

Market’s Relationship to Terrorist Funding, page 10 and Summary page 41

[7] See Issues with the Current Approach for Assessing the Antiquities Market’s Relationship to Terrorist Funding, page 11

[8] See Footnote, page 43

[9] See Findings, page xii

[10] See Findings, page xii

[11] See Issues with the Current Approach for Assessing the Antiquities Market’s Relationship to Terrorist Funding, page 12, and Measuring the international trade in antiquities, page 73, and Summary page 84 and 85

[12] See Antiquities Trafficking on Arabic-Language Facebook Groups, page 54

[13] See Policy Responses Based on Findings, page xiii and Responding to Illicit Networks, page 96

RAND Corporation report demolishes current thinking on antiquities trafficking

RAND Corporation report demolishes current thinking on antiquities trafficking

Most widely held assumptions are wrong, it says, leading to poor policy in tackling problem

Report names and shames key figures involved in creating hype and speculation, as well as bloggers and journalists

A major report by one of the most respected independent research organisations in the United States claims that current thinking on the trafficking of antiquities is mostly wrong.

Its findings have prompted it to propose a radical change in direction in the search for solutions.

The RAND Corporation argues that a lack of reliable evidence leads to wild speculation over trafficking[1] and poor policy in tackling the problem[2]. The illicit trade in antiquities is much smaller, opportunistic rather than organised, and more widely dispersed than previously thought, it concludes.[3]

“Our aggregate data suggest that the market for all antiquities, both licit and illicit, is on the order of, at most, a few hundred million dollars annually rather than the billions of dollars claimed in some other estimates … We believe that, going forward, scholars arguing that the illicit market is larger than we suggest here will need to more clearly articulate the means through which these goods are sold.”

Titled Tracking and Disrupting the Illicit Antiquities Trade with Open-Source Data, the report published on May 12 blames bloggers, journalists and advocacy groups for exaggerating the problem to attract headlines, funding and to effect policy change[4]. And it singles out one of the highest profile crusaders against trafficking, New York Assistant District Attorney Matthew Bogdanos, stating that the widely held but inaccurate belief that antiquities trafficking is linked to trafficking in drugs and weapons can be traced back to him as the source.[5]

The report’s findings on this point go directly counter to the claim made by Europol Executive Director Catherine de Bolle in her official statement on the recent Athena II operation.[6]

The report also cites figures of $2 billion for Syria and $3 billion to $10 billion for Egypt quoted by Antiquities Coalition Founder and CEO Deborah Lehr in a Wall Street Journal article as misleading[7], while former AC Chief of Staff Katie Paul, who now heads the Athar Project, is accused of obtaining data and screenshots “with a RAND login to a third-party data provider that were published without consultation or permission”, an action deemed “ethically dubious”.[8]

Major findings show size and nature of problem contrary to popular belief

Major findings in the report, researched with the RAND Homeland Security Operational Analysis Center and partially funded though it work for the US Department of Defense, show that contrary to popular belief, illicit trade in antiquities is largely ad hoc rather than organised and a much smaller problem than previously thought. End markets are global, rather than focused on the West[9], policy and argument “has been dominated by speculation and hypotheses”, while almost no trafficking of antiquities is taking place via the dark web.[10]

It also notes that relatively low sell-through rates of legitimate antiquities at auction and through galleries, combined with the challenges of selling antiquities at all because of compliance, show muted demand, suggesting “that auctions could act only as a limited conduit for illicit sales”.[11]

“This reality that antiquities auctions represent a small market that is not always able to find buyers in well-advertised sales is at odds with the media’s assumption that there is a booming unmet demand for these goods that is capable of supporting a billion-dollar black market,” it concludes.

The report also finds that although fakes are a major issue in general, apparent attempts to traffic illicit items on Facebook are largely illusory, because a large number of the images posted have actually been lifted from recycled news articles or museum websites.[12]

The report concludes that current efforts to tackle trafficking are misguided, ineffective, costly and unrealistic, partially because they are based on inaccurate assumptions.[13]Referring to transnational policing operations targeting traffickers, like Athena and Pandora, the report states: “For high-value goods and key nodes in the network, efforts by police and customs officials can successfully identify and prosecute criminal actors. However, these 

enforcement actions are time consuming, costly, and often require significant cross-border cooperation by law-enforcement agencies, which can often be difficult to organize. Instead, a broader-based approach aimed at undermining the trust among illicit actors and in the technologies they rely on could disrupt the illicit market more broadly and cheaply.”

Recognising that “legal standards can be troublesome because a plethora of various laws exist between and within countries, meaning that the correct legal standard that must be met can vary from object to object”, RAND recommends better targeting of clearly identified problem areas.

“…if the market is instead made up of ad hoc opportunists, then there are few centralized nodes that can be targeted to disrupt the whole market,” it argues. “Moreover, expensive and resource-intensive investigations may be inefficient in a market comprising small-scale dealers. In such cases, broader-based disruption tactics, which highlight the risks involved or publicize the damages that looting causes, might be more effective by reshaping the decisions of the individual actors involved.”

It recommends turning to disinformation campaigns: “Messaging campaigns conducted online—for example, through Facebook groups that are used by illicit actors along the supply chain (as discussed in Chapter Four)— would allow destabilizing information to be injected into trafficking networks.”

“ADA chairman Joanna van der Lande said: “As with so many of my colleagues and fellow association members, I am delighted that this report, from arguably the most respected independent research organisation in the US, confirms what we have been saying for years.

“In exposing the propaganda and misinformation, the RAND Corporation also highlights how major international policy has been shaped by dishonest agendas rather than solid evidence, and this is truly shocking when one considers the cost not only to the legitimate art market, but also to cultural heritage protection. Those responsible need to be honest about their motives and be held to account in future if they continue to manipulate and misappropriate the evidence.”

See https://www.rand.org/pubs/research_reports/RR2706.html


[1] See Summary, page xi

[2] See Policy Responses Based on Findings, page xiii and Directions for Future Research, page 97

[3] See Findings, page xi to xii

[4] See Introduction, page 3, and Issues with the Current Approach for Assessing the Antiquities Market’s Relationship to Terrorist Funding, page 10

[5] See Antiquities Trafficking Using Telegram, page 49-50

[6] See press release quote issued May 6, 2020 in relation to Operation Athena II: https://www.europol.europa.eu/newsroom/news/101-arrested-and-19000-stolen-artefacts-recovered-in-international-crackdown-art-trafficking

See also Issues with the Current Approach for Assessing the Antiquities

Market’s Relationship to Terrorist Funding, page 10 and Summary page 41

[7] See Issues with the Current Approach for Assessing the Antiquities Market’s Relationship to Terrorist Funding, page 11

[8] See Footnote, page 43

[9] See Findings, page xii

[10] See Findings, page xii

[11] See Issues with the Current Approach for Assessing the Antiquities Market’s Relationship to Terrorist Funding, page 12, and Measuring the international trade in antiquities, page 73, and Summary page 84 and 85

[12] See Antiquities Trafficking on Arabic-Language Facebook Groups, page 54

[13] See Policy Responses Based on Findings, page xiii and Responding to Illicit Networks, page 96