The Financial Action Task Force (FATF), also known by its French name Groupe d’action financière (GAFI ), is an intergovernmental organization founded in 1989 by the G7 to combat money laundering. Its mandate later expanded to include terrorist financing and the financing of weapons proliferation. FATF sets international standards through its “40 Recommendations,” which guide countries in creating effective laws and policies to fight financial crime. FATF conducts peer reviews of its members (called “mutual evaluations”) to assess how well they implement these standards. It also tracks emerging threats like virtual assets and publishes risk assessments. FATF is best known for its blacklist and greylist, which name countries with deficiencies in anti-money laundering and counter-terrorism financing. Being listed can lead to reputational and economic consequences for those countries. While FATF has no enforcement power, its influence is global: over 200 jurisdictions follow its standards, and it works closely with bodies like the UN, IMF, World Bank, and national financial intelligence units. It is therefore a serious concern when FATF reiterates inaccurate and misleading information on the circulation and trade in art and antiquities.
Cultural Property News thanks Ivan Macquisten, Adviser to the International Association of Dealers in Ancient Art (IADAA) and the Antiquities Dealers Association (ADA) for sharing his analysis of the most recent, July 2025 FATF REPORT – Comprehensive Update on Terrorist Financing Risks.
A Comprehensive Update on Terrorist Financing Risks?
FATF issued its latest Comprehensive Update on Terrorist Financing Risks, Financial Action Task Force in July 2025. When the FATF published its earlier Money Laundering and Terrorist Financing in the Art and Antiquities Market in February 2023, it made three important points about art market professionals and illicit activity:
- “The vast majority of participants have no connection to illicit activity.” (Executive Summary, page 3)
- “The majority of participants involved in selling, purchasing, or holding cultural objects – whether large auction houses, small antique dealers, institutional investors, or amateur enthusiasts – do not have a connection to illicit activity.”
(Introduction, Background, 2, page 5) - “Nevertheless, the vast majority of market participants like auction houses, art and antique dealers and investors do not have a connection to illicit activity.” (Conclusions, 111, page 41).
As IADAA’s analysis of the report at the time showed, while many of the case studies it cited involved art, they did not involve the art market. Instead, perpetrators tended to be drug dealers (Box 2 Case Study), a banker (Box 3 Case Study), corrupt officials and others.
IADAA’s analysis also exposed inaccuracies in the report relating to the Rotenberg sanctions-busting case and claims attributed to the United Nations Office of Drugs and Crime (UNODC).
Failings involving the art market, as cited by the FATF, related to relatively minor markets, with Brazil, India and Russia the focus.
Perhaps most enlightening was the FATF’s own admission relating to reliable data: “The lack of reliable statistics concerning looting activities, especially from conflict zones, makes it difficult to assess the scale of the phenomenon.”
Despite this, it immediately followed with: “However, considering the volume of looted archaeological goods seized in certain international or national police operations, it appears that this is a large-scale activity.” Even so, the footnote this statement linked to involved an estimated 520,000 artefacts looted annually within France and its jurisdiction, so nothing to do with MENA countries, or terrorism, and far more likely to be linked to France’s flawed laws on treasure finds, which do not reward the discoverer.
Where the FATF did quote statistics, they related to the transnational operations overseen by Europol and Interpol: 407 arrests, 147,050 seizures under Operation Pandora; but as IADAA research has also shown, no figures have ever been published for ensuing successful prosecutions and confirmation that the seizures were valid. Indeed, a survey conducted by IADAA and the ADA in March 2025 seeking data from 12 of the leading global authorities in this sphere, including Europol and Interpol, showed that no reliable trafficking data is available at all. Europol has confirmed at least twice that it does not have such data, while Interpol has also admitted to never having it nor ever expecting to have it.
Why all this remains important is that in its new globally comprehensive 134-page report, the FATF dedicates just two pages to illicit trade and trafficking in cultural property.
In summary, these tell us that terrorist organisations such as ISIL have exploited antiquities, but that the scale of proceeds remains unknown.
It goes on to state that some terrorist groups have systematically looted cultural property, making it “an important source of revenue”, and claiming that “While the precise amount is still unknown, the most conservative estimates point to tens of millions of dollars stemming from these activities alone”. It gives no source for this secondary claim. However, as analysis of the Abu Sayyaf documents from 2015 – the only directly reliable intelligence ever gathered on the subject – shows, this is not true.
Much of the remaining claims are little more than surmise based on guesswork, with no given sources. Social media is also rightly highlighted as an issue, although the FATF admitted to finding no relevant cases involving fakes.
It does quote three ‘successful’ cases:
- The seizure of an extraordinarily well-preserved statue looted from the ancient city of Palmyra thanks to the Antiquities Trafficking Unit of the Manhattan District Attorney’s Office.
- Efforts of the Spanish National Police, with the support of Europol, that led to the dismantling of a network of intermediaries trafficking antiquities from sites in Libya.
- The 2022 reiteration of Operation Pandora—a joint pan-European law enforcement operation—that led to 60 arrests and the seizure of over 11,000 cultural objects.
The report does not identify the Palmyra statue, but if it is the funerary relief seized from the New Jersey storage unit of Lebanese pharmaceutical mogul Georges Lotfi in February 2022, that was thought to have been looted in the 1980s and has no known connection with terrorism financing.
As for Operation Pandora, see the reference above.
What does all this tell us? In brief, if this is the FATF’s comprehensive global update on the subject, then it appears to have precious little reliable information on the issue of looting and trafficking of cultural property at all, let alone that connected with terrorism financing. Such crime must certainly be taken seriously, but so must the approach to researching it and the validity of the data used to report it, and on this front the FATF does not pass muster.
