Heritage Crisis in Syria: a call for a moratorium on the antiquities trade

The world has been closely following the tumultuous political upheaval behind the devastated state of cultural heritage preservation in Syria. A recent New York Times article describes “a feeling of impotence” that academics and archaeologists are experiencing in the face of the sheer magnitude of the danger threatening the cultural heritage of Syria.

What will it take to stop the relentless destruction of Syria’s cultural heritage?

It is tempting to seek comparable remedies that suit other nations in the Middle East, where political unrest has also rendered cultural heritage exceptionally vulnerable.

In 2008, the United States implemented Import Restrictions Imposed on Archaeological and Ethnological Material of Iraq without proper documentation. This protection (although less robust than what was originally proposed in H.R. 2009/3497) is in place to this day. Since 2011, there have been highly publicized efforts to enact similar regulations for Egyptian antiquities, including an attempt to pass a Memorandum of Understanding (MoU) to impose restrictions on the U.S. importation of certain categories of Egyptian archaeological artifacts.

What about Syria? Could antiquities be banned from entering the United States? Would such import restrictions reduce the economic incentive to loot (the very purpose of the 1970 UNESCO Convention)? How are current circumstances in Syria different from the situation in Iraq, which led to the passage of trade restrictions between 2003 and 2008?

U.S. representatives Philip English (R-PA) and James Leach (R-IA) proposed the bill H.R.2009 (later modified to H.R. 3497) and initiated a momentum that led to the passage of S.1291. Could the other parties who contributed to H.R.2009 help draft and enact legislation to protect Syrian cultural heritage?

Unfortunately, both congressmen have left public office since, and it has been difficult to find out who else originally mobilized this legislative effort. Given the opposition that the bill faced from the art market community, and the eventual passage of a less restrictive bill, a similar political push for the protection of Syrian antiquities might be difficult to come by.

Given that the U.S. has suspended diplomatic relations with Syria, no MoU request has been made by the Syria government to the U.S. State Department to enable import restrictions of antiquities into the U.S., which has proven an effective means to curb the incentive to loot ancient sites.

On October 2013, the EU implemented this Regulation “to facilitate the safe return to their legitimate owners of goods constituting Syrian cultural heritage which have been illegally removed from Syria… and to provide for additional restrictive measures in order to prohibit the import, export or transfer of such goods.” In the UK, I reported that the Export Control Syria Sanctions Amendment Order 2014 SI 2014 1896 (the Order) was made on July 16, 2014, laid before the Parliament on July 18, 2014, and came into force on August 8, 2014.

On the international level, Syria is a member of the UN. But despite a petition initiated by The Syria Campaign, which collected nearly 17,000 signatures and asks the UN Security Council to “ban the trade in Syrian artefacts,” no resolution toward comprehensive protection of Syrian cultural heritage has thus far been enacted. Last May, UNESCO held an international meeting to decide about the creation of an Observatory to “the state of buildings, artefacts and intangible cultural heritage to combat illicit trafficking and collect information to restore heritage once the fighting is over.” This is not the same as the UN Security Council Resolution 1483 which called on all UN member states to prohibit trade in cultural heritage objects and to adopt other means to ensure the return of said objects to Iraq, which facilitated the passing of the Iraq Cultural Property Protection Act in the U.S.

The UN cannot take action utilizing the 1954 Hague Convention for the Protection of Cultural Property in the Event of Armed Conflict; that task is the responsibility of the International Criminal Court. Syrian leaders should keep in mind that the Republic of Syria remains a party to the 1954 Hague Convention and its First Protocol and has signed the Second Protocol. Non-state actors in Syria should also be aware that they, too, may be held accountable under the 1954 Hague Convention even though they never signed or ratified the Convention. The reason is that Hague ‘54 is considered customary international law and “will therefore bind not just states but non-state actors such as rebel factions or secessionist groups,” according legal expert Zoe Howe.

Key provisions of Hague ’54 include Article 4 (which obligates combatants to refrain from attacking cultural property unless required by military necessity and to prevent all theft, pillage, or vandalism of cultural property) and Article 19 (which applies the Convention to non-international armed conflicts, also known as civil wars). Sobering thoughts, to be sure.

Meanwhile, a New York Times op-ed piece published yesterday states that Syrian locals are being encouraged to loot sites under a kind of licensing arrangement referred to as an “Islamic khums tax,” which is supposedly based on the monetary value of their finds. It is difficult to understand how this system actually works. I hope that one day more details will be revealed. The op-ed indicates that sources are withheld for security reasons.

So, what can we do?

As stated in 2011 regarding Egyptian cultural heritage protection, SAFE believes that in order to curb looting in Syria, the demand for looted objects must be eliminated.

In his recent interview with the New York Times, Samuel Hardy, Honorary Research Associate at the Institute of Archaeology at University College London (and writer of the Conflict Antiquities) said, “There’s a huge amount coming out of Syria. The rebels have teams dedicated to looting and refugees are using portable statuettes, pots, and glass as an international currency.”

Here’s a thought:

Could museums and collectors agree to a moratorium on Syrian antiquities until order is restored? For a day … half-a-day?

In fact, since looting to feed the illicit antiquities trade is a global concern affecting even “first-world” countries such as France and Finland, why not take a pause from acquiring ALL antiquities without proper ownership history post-1970?

A broad-based moratorium would alleviate the burden of proof that artifacts have indeed been freshly looted, in the spirit of the 1970 UNESCO Convention. The ICOM Red Lists provide guidance as to which specific categories of objects from around the world that are most at risk, should assistance be needed in determining which objects to avoid — if only for a moment!

This would be a symbolic gesture of good will on the part of those who engage in the buying of antiquities which are being destroyed en masse, in some cases to fund the activities of the very destroyers themselves. After all, museums and collectors are the ones who create the demand. Could they be persuaded to take a step back to honor the need to protect, not destroy, the rich heritage in which these relics of our past were created?

Can we all stand together in a symbolic moment of silence to acknowledge such tragic moments as the damaging of the Citadel of Aleppo and nearby monuments by explosives, the raiding of archaeological sites throughout the country, and the looting of more than five museums?

This will send a clear message to the world that wanton destruction of cultural heritage must be condemned and stopped. Regardless of which side of the trade we are on, we can demonstrate our collective commitment to save the past for our future by not aiding and abetting the destruction of our shared heritage — with or without the presence of rules and regulations.


Featured Image: UNESCO Safeguarding Syrian Cultural Heritage at http://www.unesco.org/new/en/safeguarding-syrian-cultural-heritage/.

 

How the Ka-Nefer-Nefer/SLAM case could finally be put to rest

After more than three years of legal battle, the curious case of U.S. v. Mask of Ka Nefer Nefer finally came to a denouement. On June 12, Eighth Circuit Court of Appeals’ decided that the 3,200-year-old mummy mask of an Egyptian noblewoman should stay at St Louis Art Museum (SLAM). To the frustration of many who have been following the case, it was closed because of the attorney’s office’s administrative blunder—it failed to timely file a request to extend the deadline to amend its case. Consequently, the court affirmed the April 2012 decision by the U.S. District Court, Eastern District of Missouri, which stated that the government failed to articulate exactly how the mask was brought to the U.S. “contrary to law.” So Ka-Nefer-Nefer is still on view at SLAM.

But is this really the end of this story?

Maybe there could be a different ending to this story. What if SLAM simply offers Ka-Nefer-Nefer back to Egypt? For the past few years, the antiquities world has seen a tremendous shift in major museums’ and auction houses’ attitude toward repatriation. Recently, for example, the Metropolitan Museum of ArtSotheby’sNorton Simon Museum, and Christie’s all returned tenth-century sculptures looted from the Khmer temple of Prasat Chen in Koh Ker. These repatriation cases were all enthusiastically welcomed by Cambodia, with promises of future collaborations and loans for exhibitions.

SLAM, too, can turn this into a golden opportunity. This does not have to be a contentious and costly fight, but an opportunity for a demonstration of good will. Although the cases of Koh Ker sculptures had more obvious evidence that they had been looted (including the feet and bases of the sculptures left in Koh Ker), it is also true that Ka-Nefer-Nefer’s journey to the U.S. has many unanswered questions. For example, Malcolm Gay, a reporter of St. Louis’s Riverfront Times, writes that “an anonymous Swiss collector” in SLAM’s provenance cannot be convincingly identified. David Gill, 2012 Beacon Award Recipient and Professor of Archaeological Heritage at University Campus Suffolk, points out that the mask could not have possibly been in Cairo and the Kaloterna collection at the same time. Paul Barford, in responding to David Gill, rightly claims that even after the court ruling, SLAM still has ethical and moral obligation to fulfill.

SLAM’s insistence on keeping the object, therefore, seems rather outdated.

Right now, SLAM is swimming against the tide. Just to mention a few more well-known examples, the Met returned the famous Euphronios Krater in 2006; the Cleveland Museum of Art returned fourteen Italian antiquities in 2008; MFA Boston returned Weary Herakles in 2011 to Turkey, as well as eight antiquities to Nigeria last June. All cases included an agreement that the source countries recognized that the museums had acquired the objects in good faith without knowing their questionable ownership history.

SLAM’s insistence on keeping the object, therefore, seems rather outdated. The twenty-first century is finally moving away from the dark shadows of colonialism. The old guards of the museum world who once put up a fight for retentionism are losing their voices. As a college student, I admit that I do not know all the nuances and intricacies of the cultural heritage law and precedents. What I do know is this: ethics, morality, and good will are more important than retaining an Egyptian mask. SLAM already has the fabulous mummy case of Amen-Nestawy-Nakht and many other important Egyptian antiquities, whose ownership is not in question as far as I know.

Perhaps SLAM can consider returning the beautiful noblewoman’s mask back to her home in Egypt, maybe with a condition that Egypt recognizes that SLAM purchased the object in good faith under the limited information available to it in 1998? The Egyptian government has been very appreciative of all the recent repatriations, but has not been afraid to retaliate if agreements were not reached. Look at the case of this German couple, who was honored in a gala at the Egyptian Embassy in Germany for their return of a smuggled relief. But Egypt temporarily severed its tie with the Louvre and refused to permit French excavations on its land in 2009 when the Louvre did not return four wall reliefs stolen in Egypt in the 1980s.

For the Egyptians, repatriation is a question of pride. Former Egyptian Minister of Antiquities Mohamed Ibrahim said that Egypt “will not abandon its right to Ka-Nefer-Nefer mask.” SLAM could use this opportunity to establish renewed friendship with Egypt. Who knows, Egypt might loan invaluable treasures for future exhibitions at SLAM, just like Cambodia has done for the “Lost Kingdoms” exhibition currently on view at the Met.

If SLAM wants “to continue to provide all visitors to the museum, and the citizens we serve, this rich experience in the ancient art,” as SLAM director Brent R. Benjamin claims, then returning the mask to Egypt would truly serve these purposes.

What do you think?

How much looting needs to happen before we start to think twice?

In an atmosphere of general unrest and lack of control or safety provided by government, looting frequently rises to unprecedented levels as those desperate for quick cash plunder from the coffers of our global heritage. However, it is not the looters who stand to gain the most from such a timely situation, but rather the collectors who are able to add another invaluable piece to their collections, ripped from the fabric of civilization.

Yet even before the events of the Arab Spring raged across the Middle East and enraptured the world, the market for Syrian and Egyptian antiquities was booming. Many lots (objects for sale at auctions) were selling for above their estimated prices, with one pair of carved stone capitals from Syria selling for GBP 313,250 – more than five times its pre-sale estimate of GBP 60,000. With no provenance at all listed in the lot’s record, it’s incredible that a collector would nevertheless spend over a quarter of a million pounds on artifacts that could have been illicitly excavated or exported.

My process

I was curious as to how the looting and destruction that swept the Middle East during the Arab Spring might have impacted sales of Egyptian and Syrian antiquities, so I decided to compare pre-2011 and post-2011 sales in the hopes that this would shed some light on the issue.

I conducted this research both online and in libraries, accessing catalogues from past auctions from the Sotheby’s and Christie’s websites, as well as in the National Gallery of Art Library in Washington, D.C. and the National Art Library in London. I found the websites quite difficult to navigate, and it feels as though the online catalogues are there for casual perusing rather than serious research. There is no means of collating relevant items or auctions, and the information listed online leaves quite a lot to be desired.

Techniques used by auction houses

sothebys Unprovenanced Syrian stone capitals sold at Sotheby’s

Many of the artifacts, like the stone capitals described above, have no provenance listed, or will have an incredibly sparse record, like this Syrian limestone head which was simply “acquired prior to 1987” or this basalt torso of Herakles “said to have been found prior to World War II” (both pieces auctioned in 2010). The Herakles statue sold for 230,000 USD, twice its estimate. Many other pieces sold for over their estimates, indicating that a healthy appetite for Egyptian and Syrian artifacts still exists.

One of the thinnest provenances I saw was simply a listing of previous auctions, as if having made it through the system once before is enough proof that an artifact is fair game to be auctioned again. (If you’re interested in seeing some of these techniques in action, check out any catalogues from auctions of antiquities at Sotheby’s or Christie’s and you will quickly come across them.)

I had hoped that perhaps things would have improved after the events of 2011, but this was not the case. Provenance listings were no more specific or accurate than they had been previously, and there was no indication from any major auction house that they were taking into account the uncertainty in the Middle East when it came to acquiring objects for auction. In auctions taking place immediately after the Arab Spring, there were no reassuring notices placed in the front of the glossy antiquities catalogues confirming that the auction house had ensured the legality of all pieces (although perhaps they had — I’m not making accusations, just observations).

Even if an auction house deigns to ask a country if it believes an item has been looted, there are no public records from illicit excavations, and therefore no way for that country to prove that it was taken, from where, or even when.

Another way auction houses shift attention from an artifact’s physical origins to its aesthetic qualities is by listing multiple countries as the possible place of creation. As Colin Renfrew explains in Loot, Legitimacy and Ownership, having an unclear place of origin prevents any one country from laying claim to the item. Moreover, even if an auction house deigns to ask a country if it believes an item has been looted, there are obviously no public records from illicit excavations, and therefore no way for that country to prove that it was taken, from where, or even when.

I had expected to see a huge increase in the number of items placed for sale following the 2011 revolutions. However, there actually appears to have been no increase, which surprised me. Auction activity was relatively uniform from 2009 to 2013. Had there actually not been any items looted during the general state of instability and anarchy that seized much of the region? My suspicion is that these objects just haven’t had enough time to reach the international market. Looting is absolutely happening, as evidenced by photographs of sites speckled with large holes and scattered artifacts.

Evidence for looting

Indefatigable Egyptian archaeologist Monica Hanna has been single-handedly exposing an incredible amount of looting in Egypt, even going so far as to confront some of the armed looters herself. Hanna sent me some pictures of the landscape at Abu Sir el-Malaq, where looters have left behind piles of ravaged bones and mummies in favor of more saleable and attractive artifacts. This is just some of the damage that she has documented at that site:

abu sir el malaq 4 Bones left behind as looters uncover graves
abu sir el malaq 3 A child carries an artifact tossed aside by looters
abu sir el malaq 2 Archaeologists survey the damage at Abu Sir el-Malaq
abu sir el malaq 1 The pockmarked lunar landscape left by looters

The reality is that looting is definitely happening in Egypt. We haven’t yet seen these artifacts reach a public market, but they are out there. Or — even worse — as the events of the last week have shown, stolen artifacts may have actually been destroyed by those who took them, like we saw at the Malawi Museum. Hanna herself was at the Malawi Museum when looters stormed its doors, and defended its treasures against armed attackers. Some of the artifacts taken have since been returned, but hundreds remain missing, and it is possible that many of those still at large have been irreparably destroyed.

Trafficking Culture, a research programme into the global trade of looted artifacts based at the University of Glasgow, advocates using Google Earth as a means of tracking looting. This screenshot from Google Maps seems to show holes dug by looters south of the Great Pyramids at Giza:

Giza Holes

Conclusion

There has yet to be a “boom” in the number of Near Eastern antiquities for sale because dealers can afford to wait. As demonstrated by the mere existence of the Swiss Freeport (and its shameful role in Giacomo Medici’s looting empire, documented in The Medici Conspiracy), it’s fairly easy to have such a backlog of illicitly obtained items so as to not need to immediately sell newly acquired ones. Moreover, dealers aren’t dumb: they know that flooding the market with unprovenanced antiquities not only looks suspicious, but also will devalue each item as supply increases. Just as the Mugrabi family carefully plays the market to keep Warhol’s value high, so antiquities dealers know when to buy and when to sell.

It is disturbing that the public appetite for antiquities is so great that one can easily buy a faience figurine for just a few hundred dollars and no thought of import laws.

Tess Davis, a member of the “Trafficking Culture” project, is researching the process that many artifacts go through as they are essentially smuggled into legitimacy. It will be interesting to see the conclusions that her research yields, and I hope that it will shed some light on the process that looted artifacts have — and are still — undoubtedly been going through for the past two years.

Even searching for something as simple as “Egyptian antiquity” on eBay turns up multiple results for unprovenanced objects. While it is very likely that these are fakes rather than looted originals, it is disturbing that the public appetite for antiquities is so great that one can easily buy a faience figurine for just a few hundred dollars and no thought of import laws, UNESCO or otherwise. (Luckily, UCLA archaeologist Charles Stanish believes that eBay’s large selection of fakes is actually helping to stop looting, estimating that 95 percent of the archaeological artifacts listed on eBay are forgeries).

“The only Good Collector is an ex-Collector.” – Colin Renfrew

The idea of a benevolent collector has been problematized many times, including by Renfrew, who concludes that “the only Good Collector is an ex-Collector” (Public Archaeology, 2000). Renfrew does not have a problem with the act of collecting (identifying Old Master paintings and cigarette cards as hypothetical items exempt from his condemnation), but rather the practice of collecting specifically unprovenanced antiquities. But beyond just provenance, are there other issues at hand when it comes to looting and sales?

My conclusion is not that this research proves that the sale of Middle Eastern antiquities is out of control due to a single incident or period of conflict (as satisfying a conclusion as that would have been). Rather, it is that the looting specifically is out of control. It is likely that some will make the counter-argument that until we see these artifacts on the market, there is nothing we can do, or perhaps even that until such objects turn up at an auction, there isn’t any real proof that damage to the cultural record is happening.

This is wrong - looting is happening now, and without more awareness, it will continue to happen until there is nothing left to be learned from the decontextualized and ravaged objects. Monica Hanna told me that “raising awareness is really what we need,” so please help SAFE spread the word. A community on Facebook called Egypt’s Heritage Task Force has done a tremendous amount of work to track and stop looting and destruction of heritage sites, and it is that cooperation that we will continue to need in the coming months.

You can also join SAFE’s latest campaign, Say Yes to Egypt, and read more about our efforts to raise awareness about the looting going on in Egypt here.

Archaeological Looting is an Environmental Issue

The supporters of the indiscriminate market in dug-up ancient relics are fixated on representing the fundamental issues at stake as those of “ownership”, whether by a state (by their use of labels such as “retentionist”, “Nationalist”) or private individuals (accompanied by a lot of “cold dead hands”-type fighting talk). What lobbyists of this persuasion strenuously fight shy of is admitting that the current pace of depletion of the finite and fragile archaeological record by looting is a non-sustainable misuse of a precious resource. Looting is not an ownership issue, but an environmental issue.

The attempts to deflect the attention of the public and policy makers from the environmental aspects of the issues is of course a cynical manipulation. Lobbyists know they will get no sympathy from presenting the activity they are engaged in as the destroyer of a finite resource. That is why they will always play down the role of the indiscriminate market in the erosion. This is why they play on alarmist notions that “the enemy” wants to take away private property, and they are fighting the good fight to protect property rights. (Somehow they miss out the step of the argument which explains how they “got” the rights over the dismembered bits of the archaeological heritage taken clandestinely from the citizens of other countries.)

Archaeological organizations should be promoting a more accurate picture of the real issue at stake, the erosion and destruction of the archaeological resource by looting. On my blog, I suggest that perhaps there is a need for a World Archaeological Resource Awareness Day (WARAD?) that could in some way focus attention on the issue of the nature and importance of the archaeological record and how prone to damage it is. While we can do little against such threats as dessication, soil erosion, coastal erosion and some other natural causes of damage to archaeological sites, there are some forms of damage which arguably are avoidable. Looting is one of them. Public attention should be brought to the fact that current modes of indiscriminate collecting are shielding the looters from scrutiny and giving them a market. A worldwide awareness day – perhaps in some way linked to Earth Day at the end of April – may well be a useful tool in the process of public education about the damage caused by looting and indiscriminate and irresponsible collecting of archaeological artefacts.

Originally posted on March 28, 2010

Experts lend opinions to the discussion of unprovenanced antiquities

The New York Times reported on Tuesday, July 10 about the growing tension over new guidelines “making it more difficult for collectors of antiquities to donate, or sell, the cultural treasures that fill their homes, display cases and storage units.” As museums and auction houses react to recent measures taken by the U.S. to stem the illicit antiquities trade, they are increasingly reluctant to acquire items with no documented provenance prior to 1970, the benchmark year the international community adopted in the 1970 UNESCO Convention.

Neil Brodie Neil Brodie

Many collectors claim they are being treated unfairly and are increasingly depicted “as the beneficiaries of a villainous trade.” However, SAFE Beacon Award winner and former Director of the Illicit Antiquities Research Centre at the University of Cambridge, Neil Brodie, dismisses these claims saying, “Collectors know that without provenance it is impossible to know whether an object was first acquired by illegal or destructive means.” Dr. Brodie is a Senior Research Fellow at the University of Glasgow and was instrumental in the formation of a new team that will study the illegal trade in antiquities. The team was recently awarded a £1m grant by the European Research Council.

Larry Rothfield, SAFE blog contributor and founder of the Cultural Policy Center at the University of Chicago, pointed out that lack of provenance is not necessarily the only reason these items cannot be sold. Their historical or aesthetic value can affect their sale for any number of reasons. “Even if the objects in question were not excluded from acquisition,” he said, “most of them would not be acquired anyway.”

The article further poses that the price of protecting the world’s cultural heritage may very well be that some items without provenance will remain in the hands of collectors who may be unable to sell or donate their treasures.

Larry Rothfield Larry Rothfield

SAFE appreciates our supporters for lending their voices to our anti-looting mission in so many ways. Read more articles by Larry on the SAFE blog.

What do you think? Should the US relax its guidelines and laws on provenance or is it more important to keep tightening the noose around the illicit antiquities trade? Is there a solution that allows objects to be donated to museums without encouraging looting and black market trade in the process? Join the discussion by commenting below or contacting us at info@savingantiquities.org.

Britain’s Portable Antiquities Scheme Debated in Archaeological Journal

.
The latest edition (volume 20) of the Papers of the Institute of Archaeology has a timely debate, with a typically thought-provoking and balanced keynote paper by David Gill which asks the fundamental question: “The Portable Antiquities Scheme and the Treasure Act: Protecting the Archaeology of England and Wales?“. This follows the usual format of academic debate in a printed journal, the keynote article is followed by five independently written invited responses, to which the original author then replies. Although a normal printed peer-reviewed journal, PIA also has an open access policy and the texts are available in full online:

Keynote text by David W. J. Gill: The Portable Antiquities Scheme and the Treasure Act: Protecting the Archaeology of England and Wales?

Trevor Austin: The Portable Antiquities Scheme and the Treasure Act: Protecting the Archaeology of England and Wales? A Response.

Paul Barford: Archaeology, Collectors and Preservation: a Reply to David Gill

Gabriel Moshenska: Portable Antiquities, Pragmatism and the ‘Precious Things’

Colin Renfrew: Comment on the Paper by David Gill

Sally Worrell: The Crosby Garrett Helmet

David W. J. Gill: Reply to Austin, Barford, Moshenska, Renfrew and Worrell

Apparently Roger Bland, head of the PAS, was – as the editor put it – “less willing to contribute” a response to what Gill had written, which in the circumstances is a great pity.

The five comments are notable for their varied approach. Renfrew’s was quite short but raised a few cogent points in connection with what Gill had written, Worrell’s concentrated on a single aspect and does not add much to what Gill had said. Austin, representing UK metal detectorists (as head of the National Council for Metal Detectorists) does his hobby no favours by an aggressive attack on the British archaeological establishment, but simply ignoring most of the points Gill made. Moshenska also tries to defend artefact hunters against straw men. Barford is typically long-winded, but identifies part of the problem raised by Gill in the current weakness of position of the PAS and postulates strengthening it by embodying it more firmly in legislation.

I discuss some of the contributions at more length on my blog.
.

Oscar Muscarella’s "Fifth Column" of Plunder Culture

All too often, debates about cultural property are made to look simply like battles between curators/collectors/dealers and archaeologists. In an article published in Studies in Honor of Altan Çilingiroglu. A Life Dedicated to Urartu on the Shores of the Upper Sea, Eds. H. Saglamtimur, et al. Arkeoloji ve Sanat Yayinlari, Istanbul, 2009, “The Fifth Column Within the Archaeological Realm: The Great Divide,” Dr. Oscar White Muscarella looks at the network of plunder in all the complexity it deserves, and pays special attention to an overlooked accomplice in the continued destruction of the past.

According to Muscarella there are four visible mutually supporting columns operating within the realm of “Plunder Culture.” These groups, in order, are: on-site looters or tombaroli, smugglers and local dealers, professional antiquities dealers, and lastly, wealthy collectors, including museums and universities, both public and private.

Cultural heritage may be endangered most, however, by the fifth invisible column whose members are within the archaeological community. Muscarella illustrates the ways in which professional archaeologists facilitate Plunder Culture, and their participation does not just include the more obvious examples of performing authenticity evaluations for wealthy collectors. Members of the archaeological community also enable plunder by accepting money, invitations, committee memberships and appointments from fourth column institutions with dishonorable acquisition policies and compromised attitudes toward the value of context.

The hypocrisy in these affiliations has yet to be broadly acknowledged by the media and by the field of archaeology. The members of the fifth column have yet to be publicly denounced, and as a result:

They continue to flourish, their activities proceed successfully and unabated, they get awarded – revealing that the discipline of archaeology has no comprehensive sense of itself, no unclouded self-knowledge, no awareness of its moral and academic weakness.

Muscarella is unafraid to name names (of both the good and bad, the individuals and institutions) and avoids ambiguous and ineffective discourse about the problems of cultural property. He urges archaeologists to reconsider the consequences of their professional, academic, and personal associations, and to those who consider themselves clean, he urges active participation in the protection of cultural heritage.

To join Dr. Muscarella’s SAFE tour at the Metropolitan Museum on Friday, October 23 at 6:30 PM, you can buy tickets from our website.

In the name of ethics…

Yesterday, a French celebrity collector, Pierre Berge, alleged that he offered to donate two Chinese bronze animal heads to Taiwan’s National Palace Museum but was turned down. AFP reports that the museum’s refusal was rooted in ethical reasons as well as a reluctance to incite conflict with China. The article quotes the director of the museum, Chou Kung-shin saying: “In accordance with professional museum ethics, we can’t collect disputed artefacts.”

“Disputed” is the keyword here. These artifacts were not recently looted, but stolen from Beijing by the British and French during the Opium Wars in 1860, and Beijing has repeatedly asked for their repatriation. There were no laws in place 150 years ago to protect these items – the museum’s refusal to accept the bronzes was on moral, not legal, grounds. This incident is reflective of what I hope is a growing consciousness of the role that cultural heritage plays in a country’s relations with other nations.

Ethics in the Museum?


A great topic to be discussing in this day and age! With the Metropolitan Museum of Art reviewing its policies and museum associations like the American Association of Museums drafting new guidelines, ethics in the museum should be discussed.

The Institute of Museum Ethics has announced the 1st Biennial Graduate Student Conference: “New Directions in Museum Ethics.” The event will be held on November 14, 2009 at Seton Hall University. Visit the website to register!

Using the AAMD Object Registry

After almost a year of inactivity on the Object Registry of the Association of Art Museum Directors (AAMD), it seems that a few more pieces have finally been added. Recently posted are acquisitions of sculptures from China, Mexico, and India by the Metropolitan Museum of Art. These are the first additions since the Portland Art Museum presented its Indian sculpture from the 11th century on the site.

Olmec sculpture, The Metropolitan Museum of Art, 2008.637

It was on June 4, 2008 that the registry was uploaded for public use thanks to initiatives of the Indianapolis Museum of Art. At that time, the AAMD published a new report on the Acquisition of Archaeological Materials and Ancient Art. The policy was reworked as a response to the “financial and reputational harm” experienced by museums being forced to return objects. These guidelines recognize the 1970 UNESCO Convention as the threshold for future antiquities acquisitions. However, neither the guidelines nor the registry are tailored to review existing collections, which is part of the American Association of Museums (AAM) Standards regarding Archaeological Material and Ancient Art published in July 2008.

Please feel free to browse and share this information as well as look into the provenance of these objects.

Unrecorded Ancient Coins from Britain for Sale in the United States: Grumblings and a Positive Response

On May 18, I called attention to two different mass suppliers of ancient coins in the United States who regularly sell bulk lots of “uncleaned ancient coins” from all over Europe and the Middle East (“Having Cake and Eating it too: Unrecorded and Freshly Dug British Coins Sold in the USA,” Numismatics and Archaeology). These two sellers had recently offered bulk lots of coins from Britain, which apparently were not imported into the U.S. with an export license from the UK and, perhaps more importantly, were not recorded in Britain’s Portable Antiquities Scheme (PAS) designed to recorded finds made by metal detectorists. Ten days later, I provided an update following an inquiry, launched by the PAS, to the two sellers in question and the Ancient Coin Collectors Guild (ACCG) (“Update: Unrecorded and Freshly Dug British Coins Sold in the USA“).

The ACCG was queried because it claims to be the voice for ancient coin collectors in the United States and is headed by several ancient coin dealers. The group has often touted the PAS as a solution to the “looting problem,” though there seems to be little self-regulation in the market itself that deals with illicitly exported coins.

Several dealers and ACCG members initially felt threatened by the attention that these two discussions gave them and, in fact, one ACCG intransigent tirelessly continues to make excuses for the lack of recording and to make personal attacks on the commentators who called attention to it and talked about it (see discussions of the attacks/excuses by Paul Barford here, here, here, here, and here).

In spite of the bluster from the one individual, some good has come of the incidents and the attention brought to it. After the PAS inquiry, former ACCG President, Peter Tompa, posted on his blog some links to export guidelines pertinent to coins and antiquities from Britain, which was followed some days later (one day after my update) by a post on the ACCG website: “UK Authorities Post Helpful Advice for Export of Coins.”

I applaud the ACCG for highlighting this information. I do hope this reflects a growing sensitivity within the trade community and that the ACCG leadership will, in the future, be more proactive in addressing the looting problem directly rather than simply lobbying against and challenging protective legislation. Knowledge will only be preserved if all stakeholders, including dealers and collectors, start to value it over purely commercial and self-interests. The preservation of information is something we should all be concerned about and something which we all ought to work towards, especially for those of us who study the past or buy and sell pieces of it.

What cultural nations do…

My eye was initially caught by the large photo in the article (Egypt to retrieve ancient statue from Netherlands) about a case that has already been in the news recently about the shabti bought by a private collector which has been identified as coming from Sakkara and having been stolen. The accompanying text contains, unintended by the author, a comment which raises a question. It says:

the export of archaeological artefacts is strictly forbidden from Egypt, as from other cultural nations.

So what do we call nations which do little to prevent and punish the import of precious archaeological evidence which has been looted from the archaeological record in other countries only to be sold as aesthetically pleasing collectable gee-gaws? Cultural? I think not. It’s nice to see from this case that some private collectors are trying to find out where “their” treasures come from and have scruples.

SAFE applauds Penn Cultural Heritage Center

Nearly forty years ago, the University of Pennsylvania Museum led the way in the adoption of ethical museum collecting practices by issuing the “1970 Philadelphia Declaration,” which renounced the acquisition of unprovenanced antiquities by collecting institutions. This long and distinguished history of leadership now takes an important new turn with the launch of Penn Cultural Heritage Center under the directorship of Dr. Richard Leventhal.

SAFE applauds the creation of this new center, which you can read about in their August 18 Press Release.

ICOM paper denounces practice of art-for-rent

A story in The Art Newspaper by Anna Somers Cocks (July 1, 2008) Loan fees risk killing the goose that lays the golden eggs raises interesting questions about museum collections for rent. It reports on a paper issued by the Italian branch of the International Council of Museums (ICOM), reminding “everybody that the 1986 ethical code of ICOM states that museum collections are for the benefit of the public and should never be considered financial assets. The great lending museums and their boards should remember this, not least because they risk killing the goose that lays the golden eggs. After all, why should they be deserving of tax-free status, of donations from business and the rich, of being considered superior to ordinary commercial life if they themselves become so commercial as to rent our their collections? Have your fundraising parties, your glitzy tours for billionaires, your exquisite restaurants and your boutiques, but don’t forget what you are really there for, which is to spread knowledge and understanding through your art, an objective too noble to be sold off to the highest bidder. Loan fees are bad, as ICOM Italia has spelled out.”

Good Faith, Due Diligence, and Market Activities

Recently, I have been taking note of the use of the term “good faith” and particularly how the term is used by opponents of import restrictions on antiquities that do not have proper documentation, repatriations of looted material, and advocates of a “free-market” in ancient objects.

Yesterday, David Gill reported that a relief fragment from an Egyptian tomb was repatriated to Egypt after it had been withdrawn from a sale at Bonhams (London) earlier this year, when someone from the Metropolitan Museum of Art recognized it from an Egyptian tomb, where it was once in situ (“Tomb of Mutirdis (TT410): Update,” Looting Matters, 30 June 2008). A spokesperson for Bonhams would not identify the individual or dealership from whom they acquired the object, but stated that it appeared to have been acquired in “good faith.”

Also on David Gill’s weblog, and elsewhere, there has been discussion of the Association of Art Museum Director’s (AAMD) new guidelines for the acquisition of antiquities (“AAMD and Antiquities: a Revised Position,” Looting Matters, 5 June 2008). In light of this, he has recently discussed the use of a 1970 vs. 1983 date in response to Lee Rosenbaum, who suggested the 1983 cutoff date for repatriations (D.W.J. Gill, “Towards a Ceasefire in the ‘Antiquities Wars': a Response to Lee Rosenbaum,” Looting Matters, 26 June 2008; id., “The ‘Antiquities Wars': Further Thoughts,” Looting Matters, 27 June 2008; L. Rosenbaum, “Towards a Ceasefire in the Antiquities Wars: The Next Step (Part I),” CultureGrrl, 25 June 2008; id., “Towards a Ceasefire in the Antiquities Wars: The Next Step (Part II),” CultureGrrl, 27 June 2008). Peter Tompa, current president of the Ancient Coin Collectors Guild (ACCG) and an attorney, has also weighed in on the debate (“Memo to AAMD Members: Pick 1970 or 1983 as a Trigger for your Cultural Property Returns,” Cultural Property Observer, 26 June 2008). While Gill and Rosenbaum prefer different dates based on various legal and ethical precedents, 1970 (as per the 1970 UNESCO Convention) and 1983 (as per US legislation subscribing to the UNESCO Convention via the Cultural Property Implementation Act (CPIA)), respectively, Tompa suggests that repatriations be based on the date that a foreign nation’s request for import restrictions on cultural property is recognized by the U.S. Department of State be used as the guideline. He also makes the statement early on that “Repatriation decisions should never be taken lightly, particularly when lack of provenance information does not necessarily mean lack of good faith.”

Last week, it was brought to the attention of the Iraq Crisis Discussion List that some rare Iraqi Jewish books were smuggled out of Iraq and traded in Israel (“Rare Iraqi Jewish Books ‘Surface in Israel,'” Yahoo! News, 27 June 2008). There has been a protracted discussion on the Iraq Crisis Discussion List, to which many have contributed, including Jeff Spurr, Dorothy King, Paul Barford, Michael Balter, John Robertson, Patty Gerstenblith, Donny George, Peter Tompa, and others (visit the June and July archives to view individual contributions to the thread). Mr. Tompa and Mr. Barford have both blogged about the discussion and pertinent issues (P. Tompa, “Jewish Books Smuggled from Iraq to Israel,” Cultural Property Observer, 28 June 2008; P. Barford, “‘Stuff Happens': US ‘Torah Rescue’ from Iraq?Cultural Heritage in Danger (SAFECorner), 30 June 2008). In regard to a related issue on these Iraqi Jewish books, Tompa again brings up “good faith”: “In any event, the Torah described in the article would not easily fit into either category so I think we must assume (unless proven otherwise) that all concerned have acted in good faith.”

It was also reported this month that a Norwegian soldier who served in Afghanistan attempted to donate a hoard of coins and an ancient bottle he acquired there to a museum in Oslo and that Afghanistan is now seeking the return of the illicitly exported – and probably looted – material (N. Berglund, “Afghanistan Seeks Return of ‘Stolen Treasures,'” Aftenposten: News from Norway, 18 June 2008). Dorothy King provided a short discussion of it on her blog (“A Little Afghan Looting…Updated,” PhDiva, 23 June 2008). In the comments section of this post, Peter Tompa commented:

“This soldier should be given the benefit of the doubt. It is likely he bought these artifacts in good faith from desperately poor farmers who found the material, and I will assume this to be the case unless and until someone proves otherwise. This only became a story when the archaeological blogs picked it up. I suspect they helped egg on the Afghan Museum authorities to demand the repatriation of this material and an investigation. Before the Communists and Taliban took over, the government tolerated sales of minor artifacts such as this. A change of sensibilities in the elites that run the archaeological establishment, will not change the facts on the ground. Desperately poor farmers will sell whatever they find to whomever will buy it. Better to put in some system akin to Treasure Trove, that records everything, rather than assume Afghanistan has the funds and archaeologists necessary to conserve every piece of ancient history in its museums.”

A comment by Sebastian Heath in response to Tompa on the same entry is worth reading as well as his “Say What?Mediterranean Ceramics, 23 June 2008.

The purpose of this post is not to “slam” Mr. Tompa. I have respect for him and he uses more discretion and reason than many of the dealers with whom I have tried to have discussions in the past (to be clear, Tompa is not a dealer, but rather a collector). Instead, I am trying to highlight a fundamental difference in perception and argumentation that people on different sides of the “antiquities debate” have. Tompa, for example, seems to present the notion that “good faith” and “the benefit of the doubt” are enough for the trading of antiquities. On the other hand, David Gill, among others, have argued the need for stronger “due diligence” processes in the acquisition of antiquities by dealers, collectors, and museums.

In the early spring of 1999, a 60 kilogram parcel of ancient coins, which was only part of a larger shipment, estimated to be in the neighborhood of a ton (literally), was intercepted at Frankfurt Airport (R. Dietrich, “Cultural Property on the Move – Legally, Illegally,” International Journal of Cultural Property 11.2 (2002): 294-304). The coins were falsely declared and were spirited out of Bulgaria and destined for sale in the United States. The Bulgarian national was and still is an active coin dealer and wholesaler to other dealers in the United States. Online correspondence on ancient coin discussion lists indicate this dealer was selling coins en masse to other dealers and collectors at a major North American coin show just a few months after customs officials released the parcel under peculiar circumstances (see the article for fuller discussion of the release from customs). Many collectors were excited by these coins and I am certain they purchased them in “good faith,” but does this excuse the way in which they made it to the marketplace? Although they may have been buying in “good faith,” were the dealers and collectors that purchased from this importer practicing adequate “due diligence”? Were they asking about how he acquired them, and if so, simply taking his word for whatever answer he might have supplied?

A couple of years ago, Classical Numismatic Group (CNG) acquired a very rare coin of Brutus commemorating Caesar’s assassination and paid approximately $23,000 for the coin (a wholesale price), which it in turn would have tried to sale for around $30,000 (D. Alberge, “Swoop by Customs Returns Brutus to Scene of the Crime,” Times Online, 15 June 2006; L. Worden, “Ancient Coin Buyers, Beware,” COINage Magazine 42.11 (Nov. 2006)). The Greek government claimed the coin was smuggled out of Greece and the coin was returned. Mr. McFadden of CNG acted in “good faith” in buying the coin and returned it to the Greek embassy when asked to do so. But how extensive was the “due diligence” process? The Times Online article stated:

“Mr McFadden, whose company is regarded as one of the world’s leading specialists in Greek and Roman coins, told The Times: ‘He did some work for Nino [Scavona] in the 1980s … One doesn’t refuse to deal with someone because he has a slightly shady background.

‘One looks at the deal on the table. We’re business people. If there’s any indication something’s not legitimate, we don’t deal in it.'”

Here is an excerpt from the COINage Magazine article:

“‘After the cash was seized,’ McFadden said, ‘his daughter kept phoning up, asking when her father could get his money back.’ That provided a clue that the man was indeed the seller. ‘That’s something that happened after the fact,’ McFadden said. ‘Not only did I not know about it, but I couldn’t have known about it.’ After all, it was the coin dealer who vouched for his ability to sell the coin. ‘If someone brings a coin in to you and says they own it and they can sell it to you and they guarantee the authenticity — obviously I’m aware of any recent reports of theft, so if the coin had been reported stolen, I would have known about it — then there’s nothing more one can do,’ McFadden said. Longtime coin dealer Wayne Sayles, executive director of the Ancient Coin Collectors Guild, agreed. ‘There is no tradition in the world market for the background-checking of sellers, nor is there any real reason for it,’ Sayles said. ‘There are pertinent and applicable laws in most countries that deal with import, theft, etc., and dealers do, in my experience, try diligently to follow those laws as they apply at the point of sale.’ Sayles lamented that ‘we may have lost an opportunity to contest a claim that seems to be arguable on several grounds.’

It is clear that existing due diligence processes in the antiquities trade are not as rigorously applied as one might hope and much of the existing processes seem to rely very much on the mere word of profiteers and suppliers. “Good faith” purchases and dealings are not enough. Dealers and collectors would add dignity to their activities if they were to follow the example of the AAMD and adopt more stringent due diligence processes and acquisition guidelines. This would decrease the demand for recently looted material by diminishing the market for it and profitability of it.

(Image of an Egyptian relief withdrawn from a Bonhams sale and now repatriated to Egypt. Source: D.W.J. Gill, “Tomb of Mutirdis (TT410): Update,” Looting Matters, 30 June 2008)

This post has been cross-posted from Numismatics and Archaeology: “Good Faith, Due Diligence, and Market Activities.”

A Long Legacy of Protecting Cultural Heritage

A couple of days ago I visited the AIA’s Archaeology Watch resource page. I have visited the site several times before, but I have always glossed over the first little paragraph at the top of the page. This time, however, the little blurb about the Antiquities Act caught my eye. I was well aware that the AIA (Archaeological Institute of America), founded in 1879, was chartered by an Act of the U.S. Congress in 1906, but I had not realized until then that its charter coincided with President Theodore Roosevelt’s passage of the Antiquities Act and the role the AIA played in it is development. This may not be news to anyone but me, but I founded it interesting for a couple of reasons.

The Antiquities Act was supported by the AIA and lawmakers in order to give the American president power to counter looters and ‘pot hunters’ from destroying Native American cultural heritage in the American West [a Wikipedia article on the Act is also available – caveat emptor].

The AIA has been actively involved in raising awareness on problem of pillage and advocating protective legislation now for over 100 years. The AIA is frequently targeted by dealers for its stance on cultural property issues. In light of this fact, I find it even more peculiar that several antiquities dealers attempt to characterize the AIA’s position on the illicit trade in antiquities and looting as 1.) a recent development and 2.) a deliberate attempt to exclude “independent scholars” [i.e. dealers/collectors] from participating in academic discourse (for example, see my discussion at Numismatics and Archaeology: “‘Dilettanti and Shopmen': Divergent Interests in Looting and Cultural Heritage Issues,” 7 May 2008). Is this just one component of the tactics employed by profiteers, who attempt to portray their activities as scholarly in their public-relations battle with archaeologists and cultural preservation advocates? (cf. J.L. Hall, “The Fig and the Spade: Countering the Deceptions of Treasure Hunters,” AIA Archaeology Watch. 15 Aug. 2007).

For a very long time there has been a clear difference between the interests of scholars and scientists and those who exploit our history for mere financial profit. The public should not be deceived. The AIA has a long legacy of supporting efforts to protect cultural heritage from destruction.

Coins, ethics and scheduled monuments

Nathan Elkins has raised some important issues in “Codes of Ethics vs. the Financial Interest“. It has drawn my attention to the code of ethics published by the ACCG.

Appended to the rather brief list is this statement:

“The ACCG Board of Directors also agreed that the standards of conduct of museum professionals and archaeologists ought to include certain issues like conservation, publishing responsibilites, respect for private ownership and public access. These concerns will be communicated to the appropriate organizations or associations in the form of an ACCG petition for consideration.”

In the interest of dialogue, can I take the opportunity to give some feedback on ACCG point 1?

“Coin Collectors and Sellers will not knowingly purchase coins illegally removed from scheduled archaeological sites or stolen from museum or personal collections, and will comply with all cultural property laws of their own country.”

Elkins has already commented on the clause “comply with all cultural property laws of their own country”. But we have seen with the return of antiquities from North American collections to Italy that objects apparently purchased or donated and in compliance with US laws were still deemed to have left their country of origin illegally. (See observations by Gill and Chippindale on the Boston return.) There were good ethical (and professional) reasons for distinguished institutions like the Metropolitan Museum of Art in New York, the Museum of Fine Arts in Boston, and the J. Paul Getty Museum to co-operate with the Italian authorities.

But what about the first section, “coins illegally removed from scheduled archaeological sites”? In the UK “scheduled” has a distinct meaning. But I presume that this part of the code suggests that it is unacceptable to remove coins from known, listed (“scheduled”) archaeological sites. But what about the archaeological sites that have yet to be discovered? Is it acceptable to destroy undisturbed archaeological contexts because by “chance” the site is unknown to archaeological science?

Then there is the phrase “will not knowingly purchase coins”. Elkins has commented on the “Don’t Ask, Don’t Tell” policy. So an ethical policy needs to ask questions. A purchasing strategy needs to be rigorous.

So can I presume to make a humble stab at rephrasing code 1? (And can I suggest three clauses?)

a. Coin Collectors and Sellers will seek to be rigorous in establishing the collecting history (“provenance”) of the coins that they acquire.

b. Coin Collectors and Sellers will not buy coins that they know or reasonably suspect were removed from archaeological sites or stolen from museum or personal collections.

c. Coin Collectors and Sellers will comply with all cultural property laws of the countries associated with the material that they aspire to acquire.

Codes of Ethics vs. the Financial Interest

It is curious that some groups of antiquities dealers have adopted “Codes of Ethics,” which do not seem to be rigorously enforced or acknowledged in practice. One group of ancient coin dealers that claims to advocate for cultural preservation, while opposing any legislative efforts designed to curb looting and the trade in illicit antiquities that also affect the unregulated trade ancient coins (routinely found in archaeological contexts), has adopted such a code. The Ancient Coin Collectors Guild (ACCG) has adopted a “Code of Ethics” for its members, which states: “Coin Collectors and Sellers will not knowingly purchase coins illegally removed from scheduled archaeological sites or stolen from museum or personal collections, and will comply with all cultural property laws of their own country.” VCoins, an online “coin show” hosting multiple dealer inventories, also has a similar statement in its “Code of Ethics.” The careful wording of the ACCG “Code of Ethics” seemingly allows the dealer lobby and its members to skirt the actual problem of provenance by stating that they will not trade in coins that come from “scheduled archaeological sites.” Does this mean they can feel free to trade in coins robbed from historical sites that are not currently being excavated?

The vast majority of ancient coins imported by dealers and subsequently sold have no recorded find spot or an old pedigree, so where do they come from anyway? Who knows! Additionally, the statement that the ACCG “will comply with all cultural property laws of their own country,” along with the relative lack of enforcement, allows for the potential to import illegally excavated and exported material with a clean conscience since the U.S. does not have import restrictions on ancient coins with many foreign nations (except Iraq and, recently, Cyprus), although it is illegal prospect for or to export coins from most source countries without a permit – especially important source countries like those in the Balkans.

Generally, among the North American ancient coin dealing community, there appears to be a “Don’t Ask, Don’t Tell” policy in effect regarding their participation in the trade of undocumented and potentially illegally excavated/exported material: import and sell the material, just “don’t ask and don’t tell” where it came from (for example see some dealer suggestions to circumvent legal issues with illicitly imported coins in David Gill’s blog entry, “Cyprus, eBay and the Coin Lobby”). Should American citizens and coin collectors expect or even accept such unscrupulous activity from sellers? It is documented that similar practices amongst dealers of other sorts of antiquities exist (see Cook 1991, 533-534; cf. Karich 2006). Dealers of uncleaned ancient coins have also adopted a “Code of Ethics,” which deals only with selling practices and does not make any presumption to prohibit the import of coins that were illegally exported or excavated.

A number of the ACCG’s donating ‘patrons’ actively import ancient coins in bulk and often sell them in bulk without any record of provenance. In fact, one ancient coin dealer and patron of the ACCG is also, curiously, the president of a customs clearing company in New York and is one of the more important suppliers of bulk lots of uncleaned coins in the U.S. This individual also deals in other types of antiquities, many of which appear to be of Balkan origin and has online storefronts on VCoins.

Despite the rhetoric and token “Codes of Ethics” subscribed to by some groups of antiquities dealers, it is clear that antiquities and ancient coins are being systematically looted from historical and archaeological sites at an alarming rate in order to supply for market demand. This activity is destroying valuable contextual and historical information in the process, harming not only archaeological and historical inquiry, but also – in the case of ancient coins – the “science of numismatics” (for further discussion see the article “Why Coins Matter…,” which should be made available on the SAFE website within a week).

REFS:

Cook, B.F. 1991. “The Archaeologist and the Art Market: Policies and Practice,” Antiquity 65.248: 533-537.

Karich, S. 2006. “Der Bundesverband Deutscher Kunstversteigerer hat einen neuen Verhaltenskodex für seine Mitglieder aufgestellt. Transparenz ist bisher nicht immer vorhande,” Frankfurter Allgemeine Zeitung 180 (05 Aug.): 47.