Cameroon: Corruption, Civil War, and Cultural Heritage

PRECIS

Korup National Park, Cameroon, Sea view. Photo by Adesolive, 4 December 2024, CC0 1.0 Universal Public Domain Dedication.

Cameroon has asked the United States to impose sweeping import restrictions on virtually all of its cultural heritage, covering everything from Stone Age tools to nineteenth-century masks and regalia. The request amounts to a blanket embargo rather than the narrow, targeted protections envisioned under U.S. law.

The reality is that the United States plays no meaningful role in the circulation of Cameroonian art. Auction records from 2024–25 show just eleven Cameroonian objects sold in the U.S., together worth under $25,000. By contrast, Paris, Brussels, and Munich dominate the African art market, and Europe already regulates trade under strict EU rules. Blocking imports into the U.S. will not deter looting in Cameroon.

The real threats to Cameroon’s heritage are internal: political violence, separatist conflict, industrial quarrying, and chronic government neglect. The Bafut Palace was raided by government soldiers; Bidzar’s prehistoric rock carvings are being destroyed by cement quarrying; colonial architecture in Douala crumbles from abandonment. Cameroon’s own Ministry of Culture admits to inadequate staffing, stalled institutions, and budgets too small to function.

Meanwhile, Cameroonian art is already dispersed worldwide, much of it removed during colonial times. An embargo risks freezing these collections in place, depriving scholars, museums, and diaspora communities of access while doing nothing to protect heritage on the ground.

I. Introduction

This article is based upon the comments submitted by the Committee for Cultural Policy, Inc and Global Heritage Alliance, Inc on September 8, 2025 to the Cultural Property Advisory Committee to the President at the U.S. Department of State regarding the request for a Memorandum of Understanding (MOU) between the Republic of Cameroon and the U.S.

Mabuh mask (performed by secret society kwifon) Fungom or Wum, Cameroon, 19th century, acquired in 1910 from the estate of Hans Glauning, photo by Ji-Elle, Bode-Museum, Berlin, CCA-SA 4.0 International license.

Our comments address the continuing challenges faced by CPAC in applying the statute as written. The statute urges the United States to temporarily limit imports if doing so would protect Cameroon’s historical and prehistoric heritage from looting, to safeguard the American public’s access to Cameroon’s art for education, research, and opportunities for legitimate collecting, and the ability of U.S. museums and cultural institutions to acquire, preserve, and display it.

Like all requests for import limitations that have come before the CPAC committee in recent years, the Cameroon request is of extraordinary breadth and scope, covering virtually all objects in all media from ceramic, to bone, wood, stone and metal and covering the period from 100,000 BCE to the 19^th century CE.[1] This request functions as a sweeping embargo, not a targeted and statutory-compliant restriction. The CPIA authorizes import restrictions only when specific classes of cultural material are in jeopardy of pillage and when a U.S. market for such material is demonstrably contributing to the problem. By contrast, Cameroon’s request seeks unlimited restrictions on all ancient, antique, and ethnographic objects, regardless of whether they meet the CPIA’s definitions of archaeological or ethnological material, or whether they are at risk of looting. Such a blanket prohibition was never contemplated by Congress, and it cannot be justified as a measured response to an illicit U.S. market. Rather than a CPIA-compliant, narrowly drawn designated list, this request amounts to an impermissible blockade on lawful trade. The list meets neither the statute nor the facts.

The distribution of Cameroonian art and cultural heritage cannot be understood without acknowledging its colonial past. Germany declared Kamerun a protectorate in 1884, and after World War I the territory was divided between France and Britain under League of Nations mandates and later as UN trust territories.[2] French Cameroun achieved independence in 1960, and the following year the Southern Cameroons, which were formerly under British administration, voted to join, creating the modern Republic of Cameroon. This history left enduring marks on the ownership, movement, and preservation of Cameroon’s cultural property.

Today, important holdings of Grassfields regalia and ritual arts—particularly from Bamileke, Bamun/Bamoun, Tikar, and Kom traditions—are widely dispersed in European and American institutions. The British Museum and the Musée du quai Branly–Jacques Chirac both house substantial collections, while German museums, once central to the extraction of colonial-era artifacts, have returned very high-profile pieces, such as Berlin’s restitution of the Ngonnso’ figure to the Nso’ people. Municipal authorities have also participated in returns, such as Nuremberg’s return of objects removed during colonial rule. These dispersed collections are the legacy of colonial administration, but they also underscore the importance of ensuring lawful circulation, research access, and international loans today.

Cameroon handicrafts, arranged on wooden shelves. Pgoto by Ayangma Belemena, 14 December 2024, CCA-SA 4.0 International license.

Within Cameroon itself, parts of the nation’s archaeological and ethnological heritage remain under threat, not from foreign markets but from internal challenges. Military conflict continues to endanger sites in certain regions, while industrial development—such as quarrying—has caused irreparable damage to ancient rock carvings. In neither case would a U.S. MOU have prevented destruction.

On paper, Cameroon has adopted self-help measures, including a 2013 framework law and a 2020 implementing decree, but these remain chronically underfunded and unenforced. Meanwhile, the evidence of U.S. market exposure is vanishingly small. Customs and Border Protection records show one seizure attributed to Cameroon. However, these are  misidentified – they are actually Nigerian Bakor monoliths that do not come from Cameroon, although a few fakes of the Nigerian monoliths are manufactured there.[3] At the same time, a broader international regime already exists: the European Union’s 2019/880 regulation on cultural goods establishes a concerted framework for addressing illicit trade across Europe, where the bulk of the market lies.

Given these realities, any U.S. agreement should be narrowly drawn and conditional. Restrictions must be limited to materials that clearly fall within the statutory definitions of the Cultural Property Implementation Act, applied only prospectively. They should also be structured with clear benchmarks for Cameroon itself: progress on inventories, improvements in site security within conflict zones, budgetary commitments, and transparent public reporting of museum and export controls. Just as importantly, any MOU must explicitly protect the lawful circulation of art by carving out documented material from pre-MOU European collections from its scope.

If CPAC advises in favor of an agreement, it should do so only on the basis of enforceable conditions and measurable standards. Without such benchmarks, a Cameroon MOU will be symbolic rather than effective, burdening the lawful circulation of art while doing nothing to safeguard cultural heritage that remains in jeopardy within Cameroon itself.

II.  Political Unrest, Failed Civil Society, and Separatist War

Doll figure, Dowayo people, Cameroon, Mid 20th century. Both a doll for girls to play with and also a powerful talisman against female sterility worn around the neck of an afflicted woman., photo by Ji-Elle, 11 January 2023, British Museum CCA-SA 4.0 International license.

Cameroon has been in a state of separatist and religious conflict amounting to a free-floating civil war – the Anglophone Crisis – since 2016. Unfortunately, the country’s state of political crisis and instability is paralleled by high levels of corruption and malfeasance. Cameroon’s human rights situation as reported by the U.S. Department of State’s Bureau of Democracy, Human Rights and Labor states that 2023 was characterized by “unchanged’ serious, recurrent abuses by state actors and non-state armed groups.

Key concerns raised by the State Department include arbitrary and extrajudicial killings; torture and ill-treatment; harsh, overcrowded prisons; arbitrary arrest and prolonged detention; weak judicial independence; privacy intrusions; suppression of expression, assembly, and association; restrictions on movement; entrenched corruption; harassment of NGOs; extensive gender-based violence; discrimination against ethnic minorities and Indigenous peoples; criminalization and abuse of LGBTQI+ persons; and systematic constraints on workers’ rights. Government accountability efforts were very limited, especially when government actors and security forces were involved.[4] The same report for 2024, described a very similar situation with both “positive and negative changes.”[5]

The Far North, where Boko Haram/ISIS-WA control much of the populated regions suffered killings, abductions, torture, and child soldier use by both separatists and the government. Teachers and officials are regularly targeted as well as subject to mass-casualty attacks. Only half of schools were operating in the Anglophone regions of Cameroon early in 2023.[6]

While many political parties are registered, the ruling party dominates through gerrymandering, appropriation of state-resources, and constraints on opposition organizing. Corruption is widespread despite high-profile prosecutions: for example, a former defense minister who fell out of favor received a 30 year sentence; a former water utility chief 15 years.  Human rights groups encountered harassment, access limits, and reauthorization hurdles. The Cameroon Human Rights Commission, created in 2019, conducts training and receives complaints but it lacks any enforcement power.[7]

III. CPIA Determination 1 — Is Cameroon’s cultural property “in jeopardy from pillage”?

Bandjoun Palace, ancient Bamileke architecture, depicting impressive traditional wooden structures, 26 February 2018, photo Bamiboi, CCA-SA 4.0 International license.

Cameroon’s cultural heritage is facing widespread threat, ranging from both government and separatist violations to neglect, industrial exploitation, and weak policy implementation. The most shocking case is the Bafut Palace in the Northwest Region, once a symbol of national identity and a UNESCO World Heritage candidate. During a military operation, the palace was by Rapid Intervention Battalion (BIR) soldiers during a ceremony attended by 200 people, a bronze mask and gold ornaments from its museum collections seized, and its sacred birds were shot.[8] This incident illustrates not only the vulnerability of cultural sites in conflict zones but also the state’s own role in destroying heritage it should be protecting.

International organizations have had to intervene repeatedly. UNESCO has mounted emergency actions to safeguard damaged museums and community heritage, underscoring domestic capacity gaps and a chronic reliance on external actors for even basic conservation responses.[9]

Other sites remain under continuous risk. The Bidzar petroglyphs, which preserve prehistoric rock art, are directly threatened by quarrying by the cement industry. Despite their importance, the site remains only on UNESCO’s Tentative List and has received little meaningful protection.[10]

Bandjoun Palace, ancient Bamileke architecture, wooden structure with carved pillars, 26 February 2018, photo Bamiboi, CCA-SA 4.0 International license.

The government’s own vulnerability register adds to the picture, acknowledging that a wide range of major sites—including Bimbia, the historic port tied to the slave trade; the prehistoric site of Shum Laka; the Njock tunnels; Bafut Palace; and the Kola gorges—are all awaiting restoration/management. Urban cultural heritage is also endangered. In Douala, Cameroon’s largest city, colonial-era architectural assets are being lost through neglect and demolition, symptomatic of a broader failure to integrate cultural heritage into urban policy.[11]

Cameroon’s cultural patrimony is both officially recognized as endangered and actively imperiled by conflict, industrial exploitation, and policy neglect. The cumulative effect is a heritage landscape where emblematic sites remain “awaiting restoration” indefinitely, dependent on international rescue efforts and funding, and where the state has not only failed to protect heritage but, in some cases, has directly contributed to its destruction.

However, they do not demonstrate an ongoing, cross-border market-driven pillage of the kind that the CPIA was intended to address. The threats are episodic, site-specific, and often the result of internal political violence or neglect, rather than evidence that Cameroon’s cultural patrimony as a whole is in jeopardy from pillage.

IV.  CPIA Determination 2 — Has Cameroon “taken measures consistent with the 1970 UNESCO Convention”?

Here the Cameroon request fails most clearly.

Cameroon has laws to protect cultural heritage, but they are aspirational regulations – models for possible preservation and cultural protection, rather than actually enforced.

Dance Helmet Mask, Cameroon, Brücke-Museum Berlin, photo Nick Ash, Berlin, 14 June 2021, CC0 1.0 Universal Public Domain Dedication.

The primary cultural heritage law is Law No. 2013/003 of 18 April 2013. It regulates Cameroon’s cultural heritage (movable and immovable), providing for classification, inventories, and protective measures.[12] Decree No. 2020/4601/PM of 21 Sept. 2020 implemented and defined several provisions of the 2013 law – its inventories, classifications and controls.  Cameroon cultural professionals interact with ICOMOS – in 2025, the Diy-Gid-Biy Cultural Landscape of the Mandara Mountains received a nomination from ICOMOS, but it was classified as ‘vulnerable.’’[13]

Cameroon’s Ministry of Arts and Culture (MINAC) program 148 (“Conservation de la culture et de l’art camerounais”) calls for national inventories, site protection, and restoration, but even planned funding is mostly theoretical. These plans come from the government’s 2023–2025 Medium-Term Expenditure Framework.”[14] To provide a general picture of government funding, Cameroon spends ~2.6–3% of GDP on education; culture and museums receive a far smaller share.[15]

To summarize the Ministry of Culture’s own analysis of its primary cultural plan:

The Ministry of Arts and Culture in Cameroon is facing significant difficulties in carrying out public finance reforms and implementing cultural policies. A central challenge lies in human resources: staffing levels remain critically low, with many departmental delegates lacking any collaborators, which makes it impossible for structures to function effectively or to ensure close monitoring of cultural actors and activities. Institutional weaknesses further compound the problem. Several major cultural bodies, such as the National Film Archive, the National Library, and the National Institute of Arts and Culture, still lack founding statutes, while others, including the National Archives, the National Museum, and the National Ensemble, operate only at a minimal level, with leadership positions filled but without full organizational development.

Bidzar petroglyphs are located near Bidzar village, on the road toward Guider. Figures were engraved into the marble using a hammer and an engraving tool. They are mostly geometrical, consisting of groups of circles. It has been speculated that the engraving represent concepts or stories from myths, or elaborate a cosmogeny. They are thought to be 300-3000 years old. photo by 2ddanga. 28 May 2016, CCA-SA 4.0 International license.

These shortcomings have particularly weakened efforts to safeguard collective memory and cultural heritage. Initiatives such as the modernization of historical archives, the creation of a coherent national museum heritage, the promotion of publishing and film production, and the training of qualified professionals remain stalled. Even public reading services are only minimally functional, preventing Cameroon from maintaining its long-standing literary tradition. Financial constraints make the situation worse: the Ministry’s budget allocation is inadequate, while restrictive regulatory mechanisms and quotas limit flexibility and hinder the optimization of resources.

To address these challenges, proposed solutions include seeking external financing from organizations such as UNESCO, drawing on external expertise while improving internal capacity through new appointments, developing public-private partnerships, and collaborating with the National Institute of Statistics. Finally, stronger integration of budget regulation mechanisms into planning and prioritization, along with a focus on projects less dependent on disbursement agreements, is recommended to improve implementation.[16]

Transparency International ranked Cameroon poorly at 145 out of 180 countries in its 2024 Corruption Perceptions Index (score: 26/100). Such endemic corruption undermines any confidence that resources, laws, or import restrictions will be enforced honestly.[17]

Based on its government’s own assessment, Cameroon has not “taken measures consistent with the Convention” within the meaning of CPIA. Instead, it has enacted purely symbolic legislation while failing to deliver inventories, budgets, or effective enforcement.

Cameroon is reliant on outside assistance – UNESCO has deployed emergency funds to assess damage/protection needs; France’s development agency (AFD/Expertise France) supports museum and heritage-capacity projects. Both of these efforts signal that international partners shoulder crucial conservation tasks.

V.  CPIA Determination 3 — Would U.S. restrictions be of “substantial benefit” as part of a concerted international response?

This is where the request collapses. The data and policy landscape demonstrate that U.S. import restrictions would not have a material effect on the preservation of Cameroonian cultural heritage.

The Actual Market for Cameroonian Art

Morning assembly of tribal chiefs and members in Foumban, Cameroon, photo Heather Powell, 8 December 2018, CCA-SA 4.0 International license.

Auction data shows that the global market for Cameroonian objects is both limited in value and overwhelmingly centered in Europe. The total value of all Cameroonian objects sold at international auctions in 2024 and through August 2025 amounts to approximately $336,557 USD (converted at mid-2025 exchange rates: GBP≈1.30, EUR≈1.10, CHF≈1.10).[18] Of this, only 11 Cameroonian objects were sold in U.S. auctions, generating a combined total of just $23,502 USD.[19] None of these works showed any indication of recent removal from Cameroon.

The 11 U.S. sales were minor ethnographic pieces: a Mubi shield ($166), Bamileke and Mambila figures (ranging from $512–$6,820), Bamun pipes and pipe bowls ($496–$1,536), a Bangwa staff ($7,040), a Bamileke mask ($1,408), and a Bamileke gong ($248).[20] The highest single price realized was $7,040. These figures confirm that the U.S. market for Cameroonian objects is extremely small and low-value.

A currency breakdown further illustrates the distribution: €262,691 from 59 objects sold in Europe; $23,502 from 11 objects sold in the U.S.; CHF 15,799 from 24 objects sold in Switzerland; and £5,166 from 4 objects sold in the U.K.[21] The overwhelming weight of the market is European.

Why the U.S. is Not a Significant Market
Scholarly research, dealer reports, and auction house records all confirm that the main market for African art—particularly for Cameroonian traditions such as Bamileke, Bamun, and Tikar—is in Europe, not the U.S.[22] The largest and most frequent African art auctions are held in Paris, Brussels, and Munich. The major European museums—including the Musée du quai Branly in Paris, the Berlin Ethnological Museum, and the British Museum—hold the most significant Cameroonian collections. By contrast, U.S. museums and collectors play only a secondary or tertiary role.

Existing International Measures
A “concerted international response” already exists. The European Union has adopted Regulation 2019/880, which bars imports of archaeological and certain ethnological objects unless they were demonstrably outside Cameroon before 1972.[23] Europe, as the largest and most active market for Cameroonian art, is already subject to a strict legal framework. By comparison, adding U.S. restrictions would contribute little, since the U.S. is a marginal market both in terms of volume and value.

Effectiveness and Incentives

Performers of traditional music and dance from Cameroon, photo by John Mbenguè, 29 March 2023, CCA-SA 4.0 International license.

The CPIA requires that U.S. restrictions be effective if applied “in concert” with other nations. Here, they would be redundant. Looting and site destruction in Cameroon are not driven by international demand but by local poverty, armed conflict, and destructive development practices such as quarrying concessions. The burning and looting of Bafut Palace, for example, were acts of state violence in the context of civil conflict, not international antiquities trafficking.[24] Quarrying at Bidzar is tied to industrial exploitation, not to transnational smuggling rings.[25] In both cases, the root causes are domestic governance failures, not foreign collectors.
The evidence shows that Cameroonian cultural property is vulnerable, but not in ways that U.S. import restrictions can effectively address. The U.S. market is negligible; Europe already regulates the bulk of the trade. The true threats arise from local conflict, neglect, and development pressures. Under the CPIA’s standard, U.S. restrictions would not be of “substantial benefit” in deterring pillage, nor would they add meaningful weight to a concerted international response.

Seized “Cameroon” heritage in U.S. is not from Cameroon at all.

The supposed U.S. seizures from Cameroon (referred to as “ancient carved stones” shipped with false papers are not actually from Cameroon. They are from Nigeria and were transshipped via Cameroon. These large stone sculptural forms are known as Bakor monoliths.

Nigeria. Chiefs of Oyengi with the last remaining carved monolith. The chiefs and their communities are seeking the return of monoliths to Nigeria. Photo by Ferdinand Saumarez Smith. Courtesy Factum Foundation.

There has been major research on the history and trade of the Bakor monoliths by Ferdinand Saumarez Smith in coordination with the Factum Foundation, which is documented in “Thefts, Fakes and Facsimiles: Preserving the Bakor Monoliths of Nigeria.”^[26] The monoliths are actually found in Nigeria, in the Bakor region, not Cameroon, and in some cases have been brought over the border to Cameroon, from which they were sent to Europe. A great many of these monoliths were recorded during fieldwork conducted by Philip Allison in 1961–62. Saumarez Smith revisited these sites and identified 215 of the 300 recorded by Allison as well as adding additional monoliths to the record. Because of Allison’s earlier documentation Saumarez Smith was able to infer that up to one third of the monoliths had been removed since the late 1960s. However, Saumarez Smith’s sophisticated digital documentation means that any monoliths that are removed in future can easily be identified as stolen and returned to Nigeria without need of any MOU under the CPIA. Saumarez Smith also recounts that there are at least two workshops in Nigeria and one in Cameroon that are producing fakes today.^[27] Saumarez Smith has identified several fakes in European and U.S. private and museum collections.

VI.  CPIA Determination 4 — Are restrictions consistent with “the general interest of the international community in the interchange of cultural property” for scientific, cultural, educational purposes?

Mask with two faces attributed to the Bankon (sing. Nkon), Cameroon, before 1898, Mission de Bâle, Dépôt du Musée des Cultures de Bâle. Inv. 2019.46, photo by Ji-Elle, 10 May 2023, CCA-SA 4.0 International license.

The CPIA requires that restrictions support—not undermine—the general interest of the international community in the interchange of cultural property for scientific, cultural, and educational purposes. In the case of Cameroon, restrictions would not advance that goal.

Cameroon’s colonial history explains why the vast majority of important Cameroonian artifacts are already located outside the country. Following the German conquest in 1884, and later under French and British mandates after 1919, thousands of objects—including thrones, masks, and regalia—were taken into European museums and private collections.[28] These objects entered lawful circulation decades before Cameroon’s 2013 heritage law and long before UNESCO’s 1970 Convention.[29] Attempting to block their movement now through a U.S. embargo amounts to an extraterritorial and retroactive claim—something the CPIA was never designed to authorize.

Restrictions would also be counterproductive to cultural exchange. Cameroonian law does not provide reciprocal access: long-term loans are prohibited, and U.S. museums have virtually no opportunity to exhibit Cameroonian material except through temporary arrangements.[30] A blanket embargo would therefore further isolate Cameroonian art from the American public, cutting off opportunities for research, cultural dialogue, and education.

Finally, the CPIA emphasizes interchange, not permanent embargoes. Far from fostering international interchange, U.S. restrictions in this case would stifle it, to the detriment of scholarship and public understanding.

VII. Conditions CPAC Should Attach to Any U.S.–Cameroon MOU

If CPAC nevertheless determines that an agreement with Cameroon is warranted, it should be carefully tailored to comply with the Cultural Property Implementation Act (CPIA) and include strict conditions to ensure reciprocity, transparency, and genuine conservation benefit.

1. Narrow, CPIA-Compliant Designated Lists
   The Designated List should be tightly limited to the categories contemplated by the CPIA. Restricted archaeological material should include only pre-colonial or prehistoric objects that are normally discovered through excavation—such as stone tools or rock-art panels detached from in situ contexts—that meet the statutory 250-year threshold and were first discovered within Cameroon. Restricted ethnological material should be tribal materials of recognized cultural significance, for example sovereign regalia or distinctive ritual masks and costumes. By contrast, the list should explicitly exclude generic tourist art, mass-produced or industrial items, ordinary colonial-era industrial goods, and coins that fail to meet the CPIA’s archaeological or ethnological definitions. Equally important, any object without a Cameroon findspot—i.e., not “first discovered within” Cameroon—should be excluded from coverage, as required by statute.[31]
2. Prospective Application and Lawful Pre-Convention Circulation
   Restrictions must be prospective, applying only to objects illicitly exported after the effective date of the agreement. CPAC should recommend explicit safe harbors for items that can be documented as outside Cameroon before key international dates. For example, under European Union law, Regulation 2019/880 permits importer statements where objects left the country of origin prior to April 24, 1972.[32] While U.S. law is distinct, CPAC could recommend that similar principles be reflected in the Federal Register notice, diplomatic notes, or implementation guidance, thereby avoiding collateral damage to lawfully circulating art.
3. Concrete, Measurable “Self-Help” Benchmarks
   To satisfy the CPIA’s requirement that Cameroon take meaningful steps to preserve its own heritage, any MOU must establish enforceable benchmarks:
4. National Inventory and Open Access. Cameroon should be required to publish an online photographic register of classified movable heritage, with annual progress targets (for example, adding 200–300 new entries each year) and georeferenced lists of sites.
5. Development-Led Archaeology and Site Security. Heritage impact assessments and mitigation measures must be made mandatory for major infrastructure projects such as quarries, roads, and dams. Protective buffer zones should be established immediately at the Bidzar rock-art site, with public reporting on quarry concessions near the engravings. Community rangers and low-cost surveillance cameras should be deployed at vulnerable palaces and community museums in conflict-affected areas.[33]
6. Budget Transparency. The Ministry of Arts and Culture (MINAC) should publish detailed line-item allocations and execution reports for Program 148 (covering inventories, conservation laboratories, storage, and training). These allocations should be increased each year from their currently extremely modest base.[34]
7. Law-Enforcement Reporting. Cameroon should provide annual public reports documenting seizures, prosecutions, restitutions, and instances of cross-border cooperation, particularly with Nigeria, given shared challenges in protecting trans-frontier rock-art and stone heritage.[35]
8. Loans and Exchanges. Cameroon should commit to offering long-term loans of cultural material to U.S. museums and to facilitating joint research and conservation projects. This would ensure public access to Cameroonian heritage while reducing incentives for illicit removal.[36]

By attaching these conditions, CPAC would not only ensure that any agreement complies with the letter of the CPIA but also reinforce the principle that cultural property restrictions must serve genuine conservation ends while promoting, rather than obstructing, international cultural exchange.

VIII.  Conclusion

Cameroon’s cultural heritage faces real challenges, but these arise primarily from internal conflict, governance failures, and development pressures rather than a U.S. market in illicit antiquities. The data show that the United States plays only a negligible role in the circulation of Cameroonian objects, while Europe remains the dominant market and is already tightly regulated. Under the CPIA, restrictions must be both effective and consistent with the broader public interest in cultural exchange. A blanket U.S. embargo would neither deter looting nor address the true causes of heritage loss in Cameroon. If an agreement proceeds, it must be narrowly drawn, prospective in scope, and conditioned on concrete benchmarks for Cameroon’s own stewardship of its heritage—ensuring that the CPIA’s requirements are met in both letter and spirit.

NOTES

[1] The full request was listed only a week before comments were due on September 8, 2025. It states: “The Government of the Republic of Cameroon seeks protection for archaeological and ethnological materials from 100,000 B.C. to the 19th century A.D., from the following time periods and cultures: Paleolithic (circa 100,000 – 2,000 B.C.), Neolithic (circa 9,000 – 500 A.D.), Metal Age (circa 3,000 – 300 A.D.), Historic Period (circa 1500 A.D.), Ethnological Period (circa 1,000 B.C. – 19th century A.D.), including objects made from stone (tools and weapons), ceramic (pottery and vessels), metal (jewelry, weapons, tools), fossil and bone (human and animal remains). The ethnological materials requested include objects made from wood (masks, statues, furniture), metal (jewelry, weapons, tools), textiles (ceremonial clothing, tapestries, embroidery), animal skins (clothing, drums, ritual objects), and bone (jewelry, tools, ritual objects).” https://www.state.gov/cultural-property-advisory-committee-meeting-september-15-17-2025/

[2] German Kamerun (1884-1916), Britannica, https://www.britannica.com/place/Cameroon/German-Kamerun-1884-1916

[3] Ferdinand Saumaurez Smith, Thefts, Fakes and Facsimiles: Preserving the Bakor Monoliths of Nigeria,” Cultural Property News, May 20, 2021, https://culturalpropertynews.org/thefts-fakes-and-facsimiles-preserving-the-bakor-monoliths-of-eastern-nigeria/

[4] Bureau of Democracy, Human Rights and Labor, Cameroon 2023 Report, U.S. DEPARTMENT OF STATE, https://www.state.gov/wp-content/uploads/2024/02/528267-CAMEROON-2023-HUMAN-RIGHTS-REPORT.pdf

[5] Bureau of Democracy, Human Rights and Labor, Cameroon 2024 Report, U.S. DEPARTMENT OF STATE, https://www.state.gov/wp-content/uploads/2025/07/624521_CAMEROON-2024-HUMAN-RIGHTS-REPORT.pdf

[6] Id.

[7] Cameroon Human Rights Commission, https://www.cdhc.cm/index.php?lang=eng

[8] World Heritage Site Attacked in Cameroon, Human Rights Watch, October 11, 2019, https://www.hrw.org/news/2019/10/11/world-heritage-site-attacked-cameroon

[9] Preventive Conservation of Museums Collections and First Aid to Cultural Heritage in Times of Crisis, Doula Cameroon workshop report, UNESCO, 13-15 April 2021, https://www.unesco.org/en/articles/preventive-conservation-museums-collections-and-first-aid-cultural-heritage-times-crisis. See also https://www.gov.nt.ca/ecc/sites/ecc/files/enr-150911-1.climatechange-culturalterrainmapping.fr_.pdf

[10] “Bidzar,” Wikipedia, https://en.wikipedia.org/wiki/Bidzar.

[11]  UN Habitat, Urban Planning & Infrastructure in Migration Contexts – Vision, Area Planning & Action Plan Report, DOUALA,” https://unhabitat.org/sites/default/files/2025/01/250126_upimc_cameroon_visio n_and_area_planning_final_for_publishing.pdf

[12] Law No. 2013/003 of April 18, 2013 governing cultural heritage in Cameroon, https://www.african-archaeology.net/heritage_laws/cameroon2013.html

[13] ICOMOS Report to the World Heritage Committee, Evaluation of Nominations of Cultural and Mixed Properties, https://documents.chitra.live/api/v1/documents/36a8afcc-f920-478c-a0e7-8fa4e9dab299/download/ICOMOS-Evaluations-2025.pdf

[14] Ministry of Arts and Culture, Cadre de Depenses a Moyen Terme (CDMT 2023-2025), https://minepat.gov.cm/wp-content/uploads/2022/07/14-MINAC-CDMT-2023-2025-ajs-fr-17-08-2022-08h30.pdf

[15] Peter Nsoesie, Cameroon tables estimated 2025 State Budget of 7317 Billion FCFA to Parliament, CEMAC ECO FINANCE, https://cemac-eco.finance/cameroon-tables-estimated-2025-state-budget-of-7317-billion-fcfa-to-parliament.

[16] Id. Translation and summary of pages 34-35.

[17] Transparency International’s Corruption Perceptions Index, https://www.transparency.org/en/cpi/2024.

[18] Artkhade, Report 2024, Art Media Agency, https://www.artkhade.com/en/publications/wjeipr2uvcs2uwdhhgu2nkdc/artkhade-report-2024 and Artkhade, Report 2025, Art Media Agency, https://www.artkhade.com/en/publications/l37z54pj055do9p4j3g9hbix/artkhade-report-2025

[19] Ibid. Eleven Cameroonian objects sold in the U.S. market in 2024 totaled $23,502 USD

[20] Ibid. Lot details: DPY-119889 (Mubi Shield, $166); IIA-194801 (Bamileke Mupo Figure, $3,224); SWC-193489 (Mambila Figure, $512); BWJ-081117 (Bamun Pipe, $1,536); IHL-191788 (Mambila Figure, $1,092); QFF-191258 (Mambila Figure, $6,820); XIN-191256 (Bamun Pipe Bowl, $496); UUL-189463 (Bangwa Staff, $7,040); ANX-189510 (Mambila Figure, $960); LMH-188086 (Bamileke Babanki Mask, $1,408); ATJ-187960 (Bamileke Gong, $248).

[21] Ibid. Currency conversion applied using mid-2025 exchange rates (GBP≈1.30, EUR≈1.10, CHF≈1.10).

[22] See, e.g., Musée du quai Branly, “Collections: Cameroon,” https://www.quaibranly.fr; Berlin Ethnological Museum, “Africa Collections,” https://www.smb.museum; The British Museum, “Cameroon Collections,” https://www.britishmuseum.org

[23] European Union, “Regulation (EU) 2019/880 of the European Parliament and of the Council of 17 April 2019 on the introduction and the import of cultural goods,” https://eur-lex.europa.eu/eli/reg/2019/880/oj/eng.

[24] Human Rights Watch, supra, n 9.

[25] Wikipedia, supra n.11.

^[26] Ferdinand Saumaurez Smith, “Thefts, Fakes and Facsimiles: Preserving the Bakor Monoliths of Nigeria,” Cultural Property News, May 30, 2021, https://culturalpropertynews.org/thefts-fakes-and-facsimiles-preserving-the-bakor-monoliths-of-eastern-nigeria/ and “Interview: Factum Foundation’s Ferdinand Saumarez Smith on Preserving the Bakor Monoliths,” Cultural Property News, May 31, 2021, https://culturalpropertynews.org/interview-factum-foundations-ferdinand-saumarez-smith/.

[27] Id. Among the carvers making fakes, are Philip Nsuko of Njemetop village (Nselle clan) and Ekon Nsakpe of Emeakpen village (also Nselle), both of whom are convinced that the British Museum example is not authentic.

[28] Supra, n. 23.

[29] UNESCO, “Convention on the Means of Prohibiting and Preventing the Illicit Import, Export and Transfer of Ownership of Cultural Property, 1970,” https://en.unesco.org/fighttrafficking/1970.

[30] Cameroon, Law No. 2013/003 of April 18, 2013 Relating to Cultural Heritage (Yaoundé: Government of Cameroon, 2013).

[31] 19 U.S.C. §§ 2601–2602; see also Federal Register notices implementing MOUs.

[32] European Union, “Regulation (EU) 2019/880 … on the introduction and the import of cultural goods,” https://eur-lex.europa.eu/eli/reg/2019/880/oj/eng.

[33] “Bidzar,” Wikipedia, https://en.wikipedia.org/wiki/Bidzar.

[34] Monique Ngo Mayag, Ministry of Culture has the government’s smallest budget, STOPBLABLACAM, 26 January 26, 2017, https://www.stopblablacam.com/culture-and-society/2601-386-ministry-of-culture-has-the-governments-smallest-budget; see also Econuma.com, “MINAC budget execution.”

[35] Cameroon Customs (Douanes), Government of Cameroon, https://www.douane.cm.

[36] Law No. 2013/003 of April 18, 2013 Relating to Cultural Heritage, Republic of Cameroon