Statement of the European Association of Archaeologists and its Community on the Illicit Trade in Cultural Material

Marianne Mödlinger, Evelyne Godfrey, Andris Kairiss

The European Association of Archaeologists (EAA) notes with concern that, after leaving the European Union at the beginning of 2021, the government of the United Kingdom of Great Britain and Northern Ireland has indicated that it will not co-operate with the licensing system of EU regulation 2019/880. This regulation is aimed at protecting against the illicit trade in cultural property for the purpose of money laundering and financing of terrorist activities. The regulation was introduced by the EU in April 2019 and is due to be fully enforced by 2025.

The EAA notes that the UK has a ‘Sanctions and Anti-Money Laundering Act 2018’ in place, that allows for the imposition of regulations that it considers appropriate for the purposes of compliance with UN obligations. The current UK statutory guidance on cultural material from Syria implements a UN sanction obligation.

Considering that Britain forms a hub for the global market in art and ethnographic objects, and archaeological material, the EAA calls on the UK government to acknowledge that many archaeological and historical artefacts that pass through British auction houses and dealerships, especially those originating from Eastern European and Near Eastern sites, including but not limited to Syria, may have been looted and may be provided with false provenance papers. The exploitation for financial gain of the non-renewable resource of the in-situ archaeological record, and the vandalism of standing monuments in order to sell individual components, is accelerating the destruction of cultural heritage in many countries.

The EAA calls on the UK government to urgently consider widening the scope of application of the 2018 Anti-Money Laundering Act, including review of the rules, guidance and regulations associated with the Act, to ensure that robust, collective measures are in place to counter terrorist financing and money laundering from the sale in Britain of cultural heritage from any State.

According to EU Regulation 2019/880, import licences have to be obtained for objects older than 250 years, and deriving from any non-EU country, before the material can enter any EU country. This means that importers must prove that cultural heritage objects were legally exported from the country of origin. The introduction of archaeological material removed from the country where it was created or discovered, in breach of the laws and regulations of that country, is prohibited under Regulation 2019/880. This regulation constitutes a very important step forward against the illicit trade in archaeological material, especially from Western Asian, North African and Eastern European countries.

The EAA is concerned that the current legal and regulatory situation in the UK allows archaeological objects to be temporarily imported, sold, and then exported from Britain with ease.

The EAA will warmly welcome a response from the UK government that sets out a comprehensive strategy, based on international co-operation, to combat money laundering and terrorist financing through the selling of archaeological objects that may have been looted (whether from regular or clandestine excavations, or from museums, archives, or private collections), illegally exported, or provided with a false provenance, and that derive from any country of origin. We further look forward to assurance of the UK government’s commitment to implementing protection in law, not only for its own cultural heritage, but also the cultural heritage of other nations.


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