RAND Corp Report Demolishes Assumptions on Antiquities and Terror

Major study overturns current thinking on illicit looting and sales of antiquities.

Thomas Kitchin, A General Map of the World, or Terraqueous Globe with all the New Discoveries and Marginal Delineations, Containing the Most Interesting Particulars in the Solar, Starry and Mundane System, 1794, public domain, Wikimedia Commons.

Cultural Property News covers the RAND Corporation’s revelations about Facebook and the supposed dark web trade in a companion CPN article, RAND Corporation Report Debunks Facebook & Dark Web Ties to Illegal Antiquities. The author and Cultural Property News wish to express their appreciation to IADAA for its contributions to this and other reporting on the RAND Corporation report.

“We have beautiful heroines, we have bad guys, we have supporters, we have the terrorists.” Deborah Lehr of the Antiquities Coalition, speaking to the Middle East Institute, April 24, 2014[i]

The most important story in the art world in the last decade illustrates how social influence, slick public relations, and steady repetition of false information can change the cultural policy of institutions, nations, even whole continents – even if the story is a lie. The lie is attractive, romantic, even heroic at times. There are times when the story is even partly true or just an oversimplification. There are bad apples and criminals in every occupation and the art world is certainly no exception. But the story is a lie all the same.

What is this false narrative? It is that the horrific cultural destruction in the world today and the looting of artistic heritage is driven by a handful of art dealers, collectors, and greedy museums. That respectable art dealers aren’t respectable at all – they are working hand in hand with terrorists and well-organized criminal networks that loot to order for unscrupulous collectors in the United States and Europe.

This story has already severely damaged the legitimate trade in ancient art and artifacts, including coins. More importantly, it has changed Western political agendas and pushed legislation that will cause permanent harm to cultural institutions dependent on public support for a relatively free circulation of art. It has captured the imagination of hundreds of journalists and influenced the teaching of art history, anthropology, and archaeology to a generation of students. Most dangerously, it has forwarded the careers of dictatorial rulers who play the ‘cultural heritage card’ to cloak human rights violations and even the deliberate destruction of cultural heritage by well-oiled authoritarian regimes in Egypt, Turkey, China, and elsewhere.

A major study by the RAND Corporation, Tracking and Disrupting the Illicit Antiquities Trade with Open Source Data, is the first major step in completely overturning current thinking on the size, geographical scope and participants in illicit looting and sales of antiquities. The RAND report was researched with the RAND Homeland Security Operational Analysis Center and partially funded through work for the US Department of Defense. The report shows that the conventional narrative promoted by many journalists and espoused by advocacy and archaeological organizations is dead wrong: the illicit antiquities trade is not a multi-billion-dollar enterprise operating through organized criminal networks, nor is it a significant source of revenue to terrorist organizations.

Map of ancient Syria, Description de L’Universe (Alain Manesson Mallet, 1683) www.columbia.edu, public domain, Wikimedia Commons.

The stark difference between popular assumptions about the antiquities market and the data contained in the RAND report raises questions about how false narratives have driven legislation to regulate the art trade – and misdirected law enforcement activities attempting to curb illicit trafficking. The RAND report notes that different facts require new strategies to address the problem of illegal trade; a working cultural heritage policy must use more accurate data in order to disrupt looting and deter consumers from buying illicit goods.

The RAND report blames bloggers, journalists and advocacy groups for exaggerating – sometime ‘grossly exaggerating’ – the problem to attract headlines, funding and to effect policy change.[ii]

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.[iii] The RAND report also notes that figures of $2 billion for Syria and $3 billion to $10 billion for Egypt repeated by the Antiquities Coalition have misled the public.[iv] Interestingly, top staff at this most influential advocacy organization have also volunteered to provide expert advice on high profile criminal cases prosecuted by the New York District Attorney’s office.[v]

Cultural Property News has earlier documented statements by the Antiquities Coalition regarding the size of the antiquities market.[vi] The Antiquities Coalition later partnered with the Asia Society and Middle East Institute as the #CultureUnderThreat Task Force, issuing a highly publicized April 2016 report that summarily declared a causal effect between a supposed “multi-billion dollar demand for art and antiquities” and the looting and destruction of ancient sites.[vii]

No evidence was supplied in the #CultureUnderThreat Task Force report that supported the claim that the antiquities trade has brought “multi-billion dollars” in revenue to terrorist organizations like ISIS. The Task Force report noted the oft-quoted $1.25 million estimation from the Abu Sayyaf raid[viii] and warnings from the State Department that “Daesh has earned several million dollars from antiquities trafficking since mid-2014.[ix] But its tenor was wildly alarmist and it called for everyone from National Security Agency to the Peace Corps to dedicate themselves to stamping out the art trade. Despite the obvious difference between “million and “billion,” the description of a “multi-billion industry” in looted antiquities has been repeated often by the Antiquities Coalition’s publications and found its way from that source into hundreds of news articles and academic writings.[x]

A Committee for Cultural Policy report, “Bearing False Witness,” published December 2017, lists 95 articles which make specific reference to a hundreds of millions to multi-billion dollar illicit trade in antiquities by in the Mideast. (This was only a partial list of those appearing in the mainstream media over a three year period ending in 2017).[xi]

However, as the RAND report notes, even advocates such as Deborah Lehr of the Antiquities Coalition have acknowledged that “[t]he biggest challenge in this field is that there’s no real information or statistics on the size of this illegal trade.”[xii]

Despite this acknowledgement, the impact of a tsunami of misinformation and bad data has gone far beyond Mideast policy-making; it has misdirected legislation on import restrictions and money-laundering in the US and the EU and compromised planning for protecting heritage around the world.  By describing the actual working of the illicit trade, the RAND report makes clear that antiquities trade in the Mideast is not founded on sophisticated criminal networks but is instead opportunistic, disorganized and far, far smaller than reported. The actual facts, based on the data in the RAND report, should replace the popular myths and be used to reverse damaging policy directions and develop more effective strategies to combat looting.

Terrorist networks are not funded by antiquities trade

One of the most important results of the systemic analysis of illicit trafficking in the RAND report is to overturn claims that despite an increase in the looting of antiquities as a result of war and civil strife in the Middle East, the antiquities trade has been a significant source of revenue to terrorists. The RAND report notes that “the scale, scope, and significance of the antiquities trade and its role in terrorist, criminal, and militant financing remains poorly understood,”[xiii] but states that, “In the absence of grounded data, journalists, researchers, and policy experts regularly inflate the importance of antiquities trafficking in funding for international terrorism and organized crime.”[xiv]

The mistaken notion that antiquities sales were funding terrorism began with well-publicized stories about the capture of an ISIS operative in 2014. What started as an article offering a statistic on the sum total of ISIS’s revenue in a particular region led to the earliest claims in the media that ISIS’s revenue came from antiquities looting.

On June 15, 2014, Martin Chulov of The Guardian reported that in one area of Syria alone, ISIS had raised $36 million in funding.[xv] According to one source, the $36 million figure was the first fixed dollar amount supported by substantiated documents.[xvi] Chulov’s article detailed how 160 computer flash drives were found in a raid of ISIS leader Abu Abdulrahman al-Bilawi’s hideout, giving counterintelligence the first substantive insight into ISIS’s funding operations. In the article, one intelligence officer reported that they had found spreadsheets that indicated that ISIS “had taken $36mn from [the mountainous region] of al-Nabuk alone. The antiquities there are up to 8,000 years old.”

Within the context of Chulov’s article, the $36 million number referred not to the sale of antiquities alone, but instead to ISIS’s cumulative activities in the al-Nabuk region, including the commandeering of oilfields and pillage of raw materials—as well as antiquities looted from archaeological digs.

The RAND report gives samples of the Chulov article’s misuse:

“Sheera Frankel, “How ISIS Became the Richest Terrorist Group in the World,” Buzzfeed, August 28, 2014; Deborah Lehr and Peter Hardich, “Trading Treasure for Weapons: ISIS Campaign of Terror Strikes at Culture,” Huffington Post, September 10, 2015; Homeland Security News Wire, “ISIS Is Brutal, but Also Business-Savvy,” September 23, 2014; Sam Hardy, “How the West Buys ‘Conflict Antiquities’ from Iraq and Syria (and Funds Terror),” Reuters, October 27, 2014; Howard, Prohov, and Elliott, 2014.”[xvii]

These articles all embraced the idea that the antiquities trade was directly tied to terrorist actions.

The RAND report states:

“Linking cultural property crimes to these high-profile law enforcement issues offers a means to bring funding and political attention to what has traditionally been an underrecognized issue. However, the facts and figures used to support these arguments are often misinterpreted or overstated. Unsubstantiated claims about the relationship among looting, weapons, drugs, and money laundering are common in both expert and popular publications, and inaccurate or exaggerated estimates of stolen items’ value abound. The absence of a comprehensive effort to quantify the trade has also encouraged the spread of misleading or inaccurate statistics.”[xviii]

Even researchers with extensive local knowledge and expertise erred and made initial assumptions about the existence of an actual market for the unsalable bits of bronze and ceramic pulled from sites by hopeful looters (likely encouraged by dozens of international media reports about a supposed billion dollar market). In 2014, Michael Danti stated that that looting is “the second largest source of revenue”[xix] for ISIS. Some, including the Wall Street Journal, [xx] subsequently equated “looting” exclusively with “looting of antiquities” in their reporting. Others, however, have been quick to point out that “looting” came from the value of all commodity looting, what Jason Felch termed “the spoils of war.” [xxi]

Hartmann Schedel, Map of the World, 1493.

But is the international antiquities trade really high value or high demand? Some claim that it is. The RAND report notes researcher Michael Danti’s comments before the U.S. House of Representatives in 2015, that, “This market is highly opaque, fragmented, and relatively unregulated at all levels. In the case of antiquities, which are highly prized as investments and status items, demand exceeds the modest legal supply.”[xxii]

Compare Danti’s 2015 suggestion of an avid market for looted goods to the succinct remark by a regular art market reporter to New Yorker journalist Ben Taub at an 2015 event on illicit trafficking at the Metropolitan Museum in New York: “The idea that there’s a shadowy mass of collectors interested in purchasing crap that they can never sell again is absolutely ludicrous. Nobody wants esoteric, untraceable numismatics.”[xxiii] At the same event, during which there were reports of high demand and sales of looted objects worth hundreds of millions of dollars, art dealer Randall Hixenbaugh told attendees that while looting and destruction was of great concern for cultural heritage, an “insatiable demand in the West” for looted Near Eastern antiquities does not actually exist. “There are hundreds of thousands of legally acquired antiquities from Mesopotamia in the United States,” he said. “Palmyra reliefs are generally unpopular. They often go unsold at auction.”[xxiv] Hixenbaugh told Taub later, “We’re looking at objects that are worth hundreds of dollars here”… “When we say that these antiquities are worth millions of dollars, I think that prompts people to pick up shovels in eastern Syria. Are we not adding to the problem right now, by hyperbolic assessments of value?”[xxv]

Regrettably, as the RAND report notes, wild exaggerations about the scale of looting and the market for antiquities continue to dominate the policy dialog on international crime. 

Failures in field research

The RAND report also identifies particular issues with current field research, which has a number of analytical weaknesses including too much reliance on unsubstantiated anecdotal data.[xxvi] It identifies as “leading voices in discussions… the International Council of Museums, which classifies and publishes registers on categories of endangered archaeological objects; the American Schools of Oriental Research Cultural Heritage Initiative (ASOR CHI), which brings together scholars and institutions to document, protect, and preserve the cultural heritage in the Middle East; and the Antiquities Coalition, a U.S.-based nonprofit dedicated to combating what they call “cultural racketeering.”[xxvii]

“Although research by reporters and academics has documented an increase in the looting of antiquities as a potential source of revenue that can be tapped by opportunistic actors in the Middle East, little systematic analysis has attempted to empirically describe and measure the entire process of looting and trafficking in the region.”[xxviii]

And

“Surveys using satellite imagery, for example, have traced the scale and progress of the looting of historic sites in great detail, but remote sensing cannot describe the goods found or trace their fate.”[xxix]

No comparison to drugs and weapons trade

The RAND report notes that, “no governmental or international body maintains comprehensive statistics on the global antiquities trade”… Despite pressure from the International Criminal Police Organization’s (INTERPOL’s) Expert Group on Stolen Property for better data gathering and systematic research, “it remains impossible, to this day, to precisely rank illicit traffic in cultural objects so as to measure it to other types of transnational crimes.”[xxx]

Any comparative analysis makes clear that trafficking in antiquities/cultural property cannot be ranked in importance next to drugs and weapons because the data is not there to show this. Nonetheless, groups such as the Antiquities Coalition have insisted for years that there was a direct link between trade in weapons and antiquities.[xxxi]

The RAND report dismisses this linkage, and makes a pointed comment:

“In addition to the many weapons offered through [Telegram and other dark Web] channels, the Foreign Policy article also includes the image of a worn silver coin offered for sale under a subheading “Antiquities trafficking.” The authors [of the Foreign Policy article] quote Danti, who observed that “[t]here is frequently overlap in the smuggling and sale of weapons and antiquities. The two illicit trades, he said, tend to share similar routes, shipments, and dealers.” Although this assumption is widely held among antiquities researchers, there is little evidence to support this conclusion. Most citations supporting this claim refer to a single original source, U.S. Marine Corps Reserve Colonel Matthew Bogdanos’s experiences during the Iraqi Civil War. In fact, evidence from the postings on this channel suggest that there is little overlap of these markets in online platforms.”[xxxii]

In sum, the RAND report finds that antiquities trafficking from Iraq and Syria follows a different structure from the secretive, closed networks for illicit weapons and drugs.[xxxiii]

This different structure and pattern elucidated by the RAND report calls into serious question the policies and enforcement strategies being promoted by, for example, Europol Executive Director Catherine de Bolle are not supported by the facts. De Bolle stated:

“Organised crime has many faces. The trafficking of cultural goods is one of them: it is not a glamorous business run by flamboyant gentlemen forgers, but by international criminal networks. You cannot look at it separately from combating trafficking in drugs and weapons: we know that the same groups are engaged, because it generate big money. Given that this is a global phenomenon affecting every country on the planet – either as a source, transit or destination, it is crucial that Law Enforcement all work together to combat it. Europol, in its role as the European Law Enforcement Agency, supported the EU countries involved in this global crackdown by using its intelligence capabilities to identify the pan-European networks behind these thefts.”[xxxiv]

Then who are the smugglers?

The RAND researchers were skeptical of unsubstantiated tales of terrorist networks trading for weapons and drugs along with antiquities on the dark Web and supplying professional dealers in the West, and conducted their own interviews with traders in Turkey and the Middle East:

“Our informants described a decentralized network of individuals who worked irregularly as antiquities traffickers. Contrary to the belief that antiquities trafficking overlapped with other high-risk criminal activities (e.g., weapons or drug trafficking), our respondents were instead small-time smugglers and economic opportunists whose other trafficked goods included such mundane items as electronics, household goods, and agricultural products. Rather than being organized as formal criminal gangs, antiquities traffickers in the regions where we conducted our interviews self-organize around preexisting social and clan ties and use technology to facilitate their deals.”[xxxv]

The RAND researchers also discovered that the typical scale of transactions was small, and that breaking up the fragmented system would be difficult, with other small time traders moving in and taking the place of any participants who were arrested and removed:

“A second observation is that the demand for their goods is quite diffuse. All participants we interviewed described an irregular supply of goods from sellers in Syria and Iraq and piecemeal sales—typically only one or two items to a single person and few repeat customers. Rather than a black market organized around central kingpins and dealers, these dynamics suggested a distributed and varied demand. This decentralized structure is evident in the important role that middlemen and brokers play. Because smugglers could not sell their products to a small number of buyers who would purchase items in bulk, brokers were required to search widely for potential buyers to make individual sales. From an enforcement perspective, the problem is dealing with very diffuse demand and a broad network with few key nodes to disrupt.”[xxxvi]

Market is often local – not just in West

The RAND report provides a number of arguments based on real data refuting claims that there is a significant market for looted antiquities in Europe and the United States and that profits accrue only to marketers in the developed world. Its research indicates that current international cultural policy has overlooked local demand as a primary trigger for looting activities.

“Our analysis suggests that it is unlikely that large volumes of looted antiquities are being sold through observable channels in Europe or the Americas.”[xxxvii]

“The end market for looted antiquities is not only the West. It is often assumed that the end market for looted antiquities is the Europe and the United States. But our informant interviews suggest that antiquities from the Middle East and Levant are ending up in Iran, Turkey, the Persian Gulf States, and other nearby countries. Furthermore, the prices being paid to middlemen for low- or medium-quality goods are on par with what would be paid in the end market in Europe or North America. These observations are contrary to the assumption that middlemen are paid just a fraction of the final price as they help in moving antiquities to Europe or the United States. The implication of this finding is that it is important to tailor policy responses to the situation if, indeed, the supply chains for certain goods are different from was has been assumed.”[xxxviii]

Antiquities market is weak and its size is exaggerated

 

Paolo Petrini, Map of the World, 1700, public domain, Wikimedia Commons.

The widely held assumption that antiquities are generally valuable was contradicted by market data gathered by the researchers – especially since the RAND studies looked at major auction houses representing the highest level of the antiquities trade. In fact, they concluded, the overall market is not only far smaller than assumed, but it is also weak and very slow to move goods.[xxxix] Instead of Michael Danti’s characterization of an eager market cited above, their analysis found “a market in which sellers struggled to find buyers.”[xl]

They noted that, “One takeaway from our analysis is that the difficulty of marketing and selling classical art and artifacts should not be understated. Much of the analysis in the field that has focused on the illicit supply of looted artifacts has assumed that they are easily sold.”[xli]

“We gathered data about antiquities sales by major auction houses by collecting data from all available online auction catalogues for the auction houses that are members of the International Association of Dealers of Ancient Art. From this larger data set, we focused our analysis on only the three largest houses—Bonhams, Sotheby’s, and Christie’s—because smaller firms did not list all their sales online. We collected data on 21,020 successful sales that, after excluding the handful of famous pieces that sold for more than $10 million, averaged about $21,300.”[xlii]

The RAND finding showed an unenthusiastic and sluggish market overall, with the exception of a very few extremely high value items. (The Committee for Cultural Policy’s research has found that in virtually every instance of a high value antiquities sale over the last decade, a key factor in the high market price is a well-established and lengthy ownership history, with a two-tier market having evolved for pre-1970 and post-1970 provenances.) The RAND report states that:

“Moreover, 25 percent of all the items offered at auction were not sold, either because there was no bidder or because the reserve price was not met. Although news stories have called attention to looted items that have appeared at auction over the past several decades, the statistics for the overall market suggest that auctions could act only as a limited conduit for illicit sales.”

They affirm their low valuation of all antiquities markets:

“We find no evidence that illegal sales are occurring in large or even steady quantities on deep web platforms, such as Facebook or Telegram, and we find virtually no evidence of antiquities being traded on the dark web. As for the “visible” market of auction houses, dealers, eBay, and other online outlets, we find that the entire market (looted or not) is not likely to be larger than a few hundred million dollars each year. Even this is likely an overestimate, given that our appraisals contain data with fakes, replicas, and other non-antiquities.[xliii]

The RAND report states:

“Simply put, while we cannot claim to measure the size of the illicit market, we can show that observable market channels are too small to act as conduits for a billion-dollar-a-year illicit trade.”[xliv]

Nonetheless, as Cultural Property News has noted in the past, big numbers get big attention. The self-replicating flood of press reports that ISIS has raked in millions in revenue from its illicit antiquities trade has prompted national governments to devote extensive discourse and resources to legislative efforts and task forces to stop ISIS’s antiquities profiteering.[xlv] For example, the Protect and Preserve International Cultural Property Act (H.R. 1493) directing the President to impose import restrictions on archaeological or ethnological material from Syria, was signed into law in May 2016. To support passage of the bill, a “Fact Sheet” was issued April 26, 2016, which stated that “ISIS earns tens of millions annually from looting and trafficking antiquities to fund terror.”[xlvi]

Bloggers, journalists, and advocacy groups have fueled a false narrative

Fractal forms on the coverside of a microwaved DVD, photo by D-Kuru, 6 August 2007, Creative Commons Attribution-Share Alike 2.0 Austria license.

The RAND report finds unsubstantiated claims both damaging to the public and self-serving for the makers.

“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.”[xlvii]

“Fueling this disconnect between reported looting and assumed markets for these goods is the problem that bloggers, journalists, and advocacy groups, although often producing high-quality research, are rewarded for sensational headlines and claims that bring attention to their issues and readers to their pages or sites. In the context of antiquities trafficking, this disconnect between the scale of looting and its estimated market value has led to seemingly exaggerated claims about the size of the market for these goods and has muted more-moderate voices in the debate arguing that, despite the appalling destruction that looters are causing to cultural heritage, the economic value of these goods is relatively small.”[xlviii]

Conclusion: How cultural policy must change

The RAND report contains recommendations for changing cultural policy strategy to make it effective. It finds that existing policy is often unrealistic and unenforceable and concludes that current efforts to tackle trafficking are misguided, ineffective, costly and unrealistic, partially because they are based on inaccurate assumptions.[xlix]

The report finds that the end market for antiquities is not primarily the West, as is assumed by policies directed at consumers and anti-money laundering legislation in the U.S. and Europe. Instead, the market for looted antiquities is geographically dispersed and fragmented. Failure to recognize this means that “existing policy frameworks may be poorly suited to addressing the decentralized nature of the problem.”[l]

Policy should therefore move away from ineffective “expensive and resource-intensive investigations” [like Pandora and Athena[li]] towards “broader-based disruption tactics” such as undermining confidence in online sales using messaging campaigns.

“For high-value goods and key nodes in the network, efforts by police and customs officials can successfully identify and prosecute criminal actors…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.”[lii]

Instead, to combat looting, the RAND researchers opine that:

“…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. 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.”[liii]

“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.”[liv]

The authors of this ground-breaking RAND report hope – and the art world should share this fundamental goal – that “Rather than rely on speculation and anecdote, which can lead to mistaken analyses and ill-informed policies, this report will contribute to the growing conversation about evidence-based policy solutions for fighting the illicit antiquities trade and mitigating the destruction of ancient sites around the world.”[lv]

 

[i]Middle East Institute, Stolen Heritage: Cultural Racketeering in Egypt, YouTube (May 7, 2014) https://youtu.be/h4BaIXjMWnw.

[ii] Matthew Sargent, James V. Marrone, Alexandra Evans, Bilyana Lilly, Erik Nemeth, Stephen Dalzell, Tracking and Disrupting the Illicit Antiquities Trade with Open Source Data, The RAND Corporation, 2020 (hereafter RAND) at 3, 10.

[iii] RAND, at 49-50

[iv] Middle East Institute, “Stolen Heritage: Cultural Racketeering in Egypt,” YouTube video, May 7, 2014. It should be stated that the Antiquities Coalition claims not to be anti-art trade, but at the same time, the organization appears to question the legitimacy of all art transactions described in its website and publications. One noteworthy Antiquities Coalition paper likens art transactions to pollution and suggests that art dealers should pay a portion of their revue as a ‘pollution tax’, which funds would be used to discourage the art trade. See Lawrence Rothfield, APollutionTax on the Antiquities Trade. Policy Brief No. 2., The Antiquities Coalition, December 2016, https://thinktank.theantiquitiescoalition.org/how-can-we-fight-against-antiquities-looting-and-trafficking/

[v] Bogdanos has utilized the voluntary services of Tess Davis, the executive director of the Antiquities Coalition, as an ‘expert in the laws of patrimony’ in cases filed by his office involving the antiquities trade, for example, in a case pending against art dealer Nancy Weiner. https://www.artcrimeresearch.org/wp-content/uploads/2017/10/Wiener-Complaint.pdf

[vi] See Katherine Brennan and Kate Fitz Gibbon, Bearing False Witness: The Media, ISIS and Antiquities, A Committee for Cultural Policy Special Report, 4-5, Cultural Property News, 1 December 2017, https://culturalpropertynews.org/bearing-false-witness-the-media-isis-and-antiquities/

[vii] #CultureUnderThreat: Recommendations for the U.S. Government at 6, Apr. 2016, http://taskforce.theantiquitiescoalition.org/wp-content/uploads/2015/01/Task-Force-Report-April-2016-Complete-Report.pdf. (Citing Andrew Keller, Documenting ISIL’s Antiquities Trafficking: The Looting and Destruction of Iraqi and Syrian Cultural Heritage: What We Know and What Can Be Done, United States Department of State, Sept. 29, 2015, https://2009-2017.state.gov/e/eb/rls/rm/2015/247610.htm.)

[viii] May 2015 U.S. special forces raid in Syria, Wikipedia, https://en.wikipedia.org/wiki/May_2015_U.S._special_forces_raid_in_Syria

[ix] #CultureUnderThreat: Recommendations for the U.S. Government at 10, Apr. 2016, http://taskforce.theantiquitiescoalition.org/wp-content/uploads/2015/01/Task-Force-Report-April-2016-Complete-Report.pdf. (Citing a now defunct State Department publication: U.S. Department of State, Documenting ISIL’s Antiquities Trafficking: The Looting and Destruction of Iraqi and Syrian Cultural Heritage: What We Know and What Can Be Done, 2015, http://www.state.gov/e/eb/rls/ rm/2015/247610.htm, but presumably citing Andrew Keller, Documenting ISIL’s Antiquities Trafficking: The Looting and Destruction of Iraqi and Syrian Cultural Heritage: What We Know and What Can Be Done, United States Department of State, Sept. 29, 2015, https://2009-2017.state.gov/e/eb/rls/rm/2015/247610.htm..)

[x] #CultureUnderThreat Task Force Unveils Recommendations to Combat Antiquities Trafficking, Middle East Institute, Apr 13, 2016, http://www.mei.edu/content/cultureunderthreat-task-force-unveils-recommendations-combat-antiquities-trafficking; Karin Zeitvogel, Destruction, Looting of Antiquities Robs Nations of Their Heritage, Bankrolls Terrorism, The Washington Diplomat, May 5, 2017, http://www.washdiplomat.com/index.php?option=com_content&view=article&id=15257:destruction-looting-of-antiquities-robs-nations-of-their-heritage-bankrolls-terrorism&catid=1557&Itemid=428 (reposted on the Antiquities Coalition’s website: https://theantiquitiescoalition.org/ac-news/destruction-looting-of-antiquities-robs-nations-of-their-heritage-bankrolls-terrorism/); Think Tank, Antiquities Coalition, https://theantiquitiescoalition.org/cultural-heritage-think-tank/

[xi] RAND, note 5.

[xii] Jim Michaels, Demand still high for ISIL’s stolen antiquities from Palmyra, elsewhere, USA Today, Mar. 31, 2016, https://www.usatoday.com/story/news/world/2016/03/31/demand-still-high-isils-stolen-antiquities-palmyra-elsewhere/82476346/

[xiii] RAND, at 7.

[xiv] RAND, at 10.

[xv] Martin Chulov, How an arrest in Iraq revealed Isis’s $2bn jihadist network, The Guardian, June 15, 2014, https://www.theguardian.com/world/2014/jun/15/iraq-isis-arrest-jihadists-wealth-power.

[xvi] Christopher Jones, How Much Money is ISIS Making from Antiquities Looting?, Gates of Nineveh, Jan. 12, 2016, https://gatesofnineveh.wordpress.com/2016/01/12/how-much-money-is-isis-making-from-antiquities-looting/.

[xvii] RAND, note 24 at 31.

[xviii] RAND, at 10.

[xix]Michael Danti’s assessment appeared in Justine Drennan, The Black-Market Battleground, Foreign Policy, Oct. 17, 2014, http://foreignpolicy.com/2014/10/17/the-black-market-battleground/.ISIS’s profits from looting may be second only to the revenue the group derives from illicit oil sales”)

[xx] Duncan Mavin, Calculating the Revenue From Antiquities to Islamic State, The Wall Street Journal, Feb. 11, 2015,  https://www.wsj.com/articles/calculating-the-revenue-from-antiquities-to-islamic-state-1423657578

[xxi] Jason Felch, Danti’s Inference: The Known Unknowns of ISIS and Antiquities Looting, Nov. 18, 2014, https://chasingaphrodite.com/2014/11/18/dantis-inference-the-known-unknowns-of-isis-and-antiquities-looting/.

[xxii] RAND, at 125, citing to Michael D. Danti, “The Finance of Global Terrorism Through Cultural Property Crime in Syria and Northern Iraq,” written statement submitted for Testimony Before the House Committee on Foreign Affairs, Subcommittee on Terrorism, Nonproliferation, and Trade, Washington, D.C., November 17, 2015.

[xxiii] Ben Taub, “The Real Value of the ISIS Antiquities Trade,” New Yorker, December 4, 2015, https://www.newyorker.com/news/news-desk/the-real-value-of-the-isis-antiquities-trade

[xxiv] Id.

[xxv] Id.

[xxvi] RAND, at 10.

[xxvii] RAND, at 9.

[xxviii] RAND, at 2.

[xxix] Id.

[xxx] RAND, at 8-9, quoting Frances Desmarais, “An International Observatory on Illicit Traffic in Cultural Goods,” in Frances Desmarais, ed., Countering Illicit Trade in Cultural Goods, Paris: International Council of Museums, 2015.

[xxxi] Deborah Lehr and Peter Herdich, Trading Treasure for Weapons: ISIS Campaign of Terror Strikes at Culture, Huffington Post, June 19, 2015, https://www.huffingtonpost.com/deborah-lehr/trading-treasure-for-weap_b_5794902.html (“ISIS netted up to $36 million from looted antiquities in just one area of Syria alone, according to The Guardian.”)

[xxxii] RAND, at 49-50.

[xxxiii] RAND, at 113.

[xxxiv] Europol, 101 arrested and 19,000 stolen artefacts recovered in international crackdown on art trafficking, press release, May 6, 2020, https://www.europol.europa.eu/newsroom/news/101-arrested-and-19000-stolen-artefacts-recovered-in-international-crackdown-art-trafficking.

[xxxv] RAND, at 41.

[xxxvi] RAND, at 42.

[xxxvii] RAND, at 85.

[xxxviii] RAND, at xii.

[xxxix] RAND, at 73.

[xl] RAND, at 73.

[xli] RAND, at 84

[xlii] RAND, at 71.

[xliii] RAND, at xii.

[xliv] RAND, at 70.

[xlv] Statement by the Press Secretary on H.R. 1493 and H.R. 2908, The White House, May 9, 2016, https://obamawhitehouse.archives.gov/the-press-office/2016/05/09/statement-press-secretary-hr-1493-and-hr-2908; Eileen Kinsella, Are We Experiencing A New Boom in the $3 Billion Global Antiquities Market?, Artnet News, June 29, 2015; https://news.artnet.com/art-world/isis-selling-looted-antiquities-312593; Joe Parkinson and Duncan Mavin, West Seeks Tighter Curbs on Trade in Antiquities Looted by Islamic State, The Wall Street Journal, Mar. 30, 2015, https://www.wsj.com/articles/west-seeks-tighter-curbs-on-trade-in-looted-antiquities-1427761561.

[xlvi] Press Release: Senate Passes Engel Bill to Curb ISIS Antiquities Looting, United States House of Representatives Committee on Foreign Affairs, Apr. 14, 2016, https://foreignaffairs.house.gov/press-releases?ID=28A86C59-A73E-4BC7-84D7-ED81D931F0C8.

[xlvii] RAND, at 84-85.

[xlviii] RAND, at 3.

[xlix] RAND, at xiii and 96

[l] RAND, at xiii.

[li] See INTERPOL, 101 arrested and 19,000 stolen artefacts recovered in international crackdown on art trafficking, Interpol, https://www.interpol.int/en/News-and-Events/News/2020/101-arrested-and-19-000-stolen-artefacts-recovered-in-international-crackdown-on-art-trafficking.

[lii] RAND, at 96.

[liii] RAND, at 91

[liv] RAND, at 96.

[lv] RAND, at 97.

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