The Corporate Transparency Act was enacted in 2021. With the passing of the a bipartisan CTA, domestic entities created by a filing with a state secretary of state and foreign entities that registered to do business in the U.S. are required to submit Beneficial Ownership Information (BOI) about the entities true owners to the Financial Crimes Enforcement Network or FinCEN.  The Act aims to combat illicit financial activities, including money laundering, by preventing the misuse of anonymous shell companies and closed loopholes by requiring transparency in corporate structures, making it harder for criminals to hide behind front companies or offshore entities.

How It Helps Combat Money Laundering in the Art Market:

Identifying Beneficial Owners – The CTA required certain U.S. businesses to disclose their true owners (beneficial owners) to the Financial Crimes Enforcement Network (FinCEN). This reduced the availability of anonymous shell companies which could be used to buy or sell high-value artworks as a way to launder money.

Closing Loopholes – The art market has long been an attractive space for criminals due to its anonymous transactions. By requiring transparency in corporate structures, the CTA made it harder for criminals, or sanctioned individuals, to hide behind front companies or offshore entities.

Enhancing Law Enforcement Investigations – With a registry of beneficial owners, law enforcement agencies could better trace illicit funds and investigate suspicious art transactions tied to money laundering, terrorism financing, or sanctions evasion.

Deterring Criminal Actors – Knowing that corporate ownership records are accessible to regulators and enforcement agencies created a deterrent effect, making it riskier for bad actors to use the art market for financial crimes.

Aligning with Global Anti-Money Laundering Efforts – The CTA brought the U.S. closer to international AML standards, reinforcing Financial Action Task Force (FATF) recommendations that called for greater transparency in high-value transactions, including art.

Recent Developments Under the Trump Administration:

On 2 March 2025, the U.S. Treasury Department, with endorsement of President Donald Trump's administration, announced that FinCEN will not take action against companies that miss BOI reporting under the CTA until further notice, suspending penalties and fines and that revisions to the deadline and reporting requirements are on the way.  This decision effectively halts the enforcement of the act's requirements, with plans to seek public feedback on potential modifications to the BOI reporting rules later in the year. 

Less than 24 hours after the Treasury Department's announcement, Judge Robert Jonker of the U.S. District Court for the Western District of Michigan declared beneficial ownership information reporting requirements unconstitutional and granting summary judgment to the Small Business Association of Michigan finding the Corporate Transparency Act violates the Fourth Amendment which prohibits unreasonable search.

After the announcements anticorruption and financial transparency advocates in the US and Europe were dismayed by the decision.

Implications for Money Laundering in the Art Market:

As mentioned above, the art market has historically been susceptible to money laundering due to high-value transactions and a lack of close financial oversight. The suspension of BOI reporting enforcement may have severe implications:

Increased Anonymity: Without mandatory BOI disclosures, individuals operating in bad faith can more easily use anonymous entities to conduct art transactions, making it challenging to trace the true ownership of artworks and by proxy the transfer of funds from one geographic region to another as works of art are bought and sold internationally. 

Regulatory Gaps: The lack of enforcement creates loopholes that will be exploited for illicit financial activities within the art market. 

Challenges for Law Enforcement: The absence of BOI data hampers the ability of authorities to investigate and prosecute transnational money laundering cases involving art transactions.

In 2020 two Russian oligarchs Arkady and Boris Rotenberg, who are close to President Vladimir P. Putin, exploited the opaqueness of the art world to buy high-value art.  Bypassing U.S. sanctions, a report by the U.S. Senate’s Permanent Subcommittee on Investigations stated that the brothers purchased of works at auction houses and through private art dealers in New York totalling $18.4 million in value after the pair came under United States sanctions in 2014.

In April 2023 Nazem Ahmad, a collector, was accused by U.S. authorities of being a key financial supporter of Hezbollah, a Lebanon-based organisation designated as a terrorist group by the U.S. government. His indictment alleged that Ahmad circumvented U.S. sanctions, placed on him in 2019, by operating through a network of businesses to obscure multimillion-dollar transactions involving art and diamonds. Additionally, eight other individuals faced charges in connection with the case.

Eric Allouche, whose Allouche Gallery did business with Ahmad stated he had no clue he was dealing with an entity affiliated with the Lebanese collector, indicating that his American-owned gallery dealt with a representative of an entity who he knew to be someone who had bought art previously from artists he handles. 

While the stated aim in the suspension of enforcement and potential repeal of this financial transparency law is purported to be to reduce the regulatory burdens on American-owned  businesses, weakening the CTA simply reapplies the veil of secrecy which the CTA had sought to remove.  If repealed, or left unenforced, it will again enable the concealment of identities, making it easier to clean dirty money through art transactions, and making art world an increasingly elastic haven for hiding criminal transactions. 

By:  Lynda Albertson

In the months leading up to the start of the programmes, this year’s lecturers are being interviewed about their courses and teaching with ARCA in Italy.  In this interview we meet Dr. Saskia Hufnagel, a Visiting Professor at Queen Mary, a Professor at the University of Sydney Law School and Co-Director of the Sydney Institute of Criminology. Her research concerns global law enforcement cooperation, transnational and comparative criminal justice and art crime. She lectures on the Art, Business and Law LLM (CCLS).  Her particular interests are international and regional legal patterns of cross-border policing as well as the detection, investigation and prosecution of art crimes in the UK, Germany and Australia. Saskia is a qualified German legal professional and accredited specialist in criminal law.

Can you tell us something about your background?

I started off as a German Criminal Lawyer in a little town close to the Dutch border and in my practice I got very interested in cross-border crime and law enforcement dealing with it.  As luck would have it, I received a scholarship funded jointly by the European Commission and the Australian National University to pursue a PhD in the area of international law enforcement cooperation.  After my PhD, I spent some time as a researcher in Queensland and then moved to Queen Mary University of London to teach criminal law, policing, and comparative criminal justice.  In 2023 I was offered a Professorship in Australia and am now teaching and researching at the University of Sydney Law School.

And how did you get involved with ARCA? 

After I had finished my PhD, one of my examiners, Prof Duncan Chappell, asked me whether I would write with him about a German forger's case (Beltracchi) that also included international law enforcement challenges and, at the time, a lot of the reports on it were mainly available in German.  This is how I got into art crime and visited ARCA for the first time in 2011.  

It was such a great multidisciplinary hub for art crime research and it was so exciting to be exchanging ideas with both academics and practitioners specialising in fields much more interesting than my own, such as archaeology, art history, criminology, economics, forensic sciences and countless others.  People were so friendly and welcoming and happy to work even with boring lawyers that in the past 14 years, I only missed two of the conferences.

What is the purpose of the course you are teaching this summer?

My part of the teaching is a necessary evil as knowing the legal foundations of cultural heritage law is really important for many areas of art crime research.  I will go through the international legal set up of cultural property protection with students, discuss the differences between such protection in times of war and peace, look at the protection of moveable and immoveable cultural heritage and go through some basics of criminal law comparatively between various jurisdictions to highlight criminal law issues in relation to fraud, theft, vandalism, money laundering, tax-, import- and export-offences and many other crimes.

What is it like in Amelia?

Amelia is like a picture book Italian village with wonderful restaurants, bars and shops. The people are very friendly and forgiving with silly foreigners like me who do not speak a word of Italian. The longer you stay in Amelia, the more you will love it!

What is so special about this program?

There is no other program like ARCA.  University programs will situate a course mainly within one discipline, so you rarely get the same variety of interdisciplinary knowledge taught within this program elsewhere.  Also, ARCA has contacts to some of the most knowledgeable academics and practitioners in the field and brings them together from all around the world to teach the programme.

Which course would you like to follow yourself?

I would love to do Lynda Albertson’s course and discover more about data sets and data interpretation and how to harness art crime databases! Students were always gushing about it and telling me about all the possibilities for research they discovered in her course. It made me so jealous!

Any advice for the participants that come to Amelia?

Work hard and play hard! Amelia is a once in a lifetime opportunity to study with a very diverse group of students, people you would otherwise never – or not very likely – meet in your life. Make friends, support each other studying, have fun, enjoy the wide variety of teachers and subjects and take home a great deal of knowledge and a new little family.

In closing I would add that Dr. Hufnagel has co-edited a marvellous book in the field titled The Palgrave Handbook on Art Crime featuring articles from many people working in this important field.  If you would like to learn with her directly, there is still time to apply for the ARCA program and speak with her directly this summer. 

By:  Edgar Tijhuis

By Edgar Tijhuis*

This year, ARCA’s Post Lauream I on Art and Antiquities Crime will be held from 23 May through 20 July 2025, followed by ARCA’s Post Lauream II in Acquisition & Interpretation of Cultural Property. Both programs can be taken separately or together and are held in the beautiful heart of Umbria in Amelia, Italy. 

In the months leading up to the start of the programmes, this year’s lecturers are being interviewed about their courses and teaching with ARCA in Italy. In this interview we meet Dorit Straus, who is a specialist in art insurance and an independent art and insurance advisor. Previously, Dorit Straus was Vice President and Worldwide Specialty Fine Art Manager for Chubb & Son, a division of Federal Insurance Company and member of the Board of Directors of AXA Art Americas Corporation.

Can you tell us something about your background?

I am originally from Israel - I come from a musical family- my father was from Vienna and was a child prodigy studying violin with the great violinist Bronislaw Huberman.  When the Nazis came to power Bronislaw Huberman in 1936 founded what is today the Israel Philharmonic Orchestra and brought some of the best musicians from Europe to what was then the British controlled Mandatory Palestine - my father was among those musicians that Huberman saved and brought to the orchestra. 

All told Huberman saved over 1000 musicians and their families from the Nazis.  My father met my mother in Israel because her three brothers were also in the orchestra, and my father became the concertmaster of the orchestra, so my childhood was full of music and  I met many of the most famous musicians who came to perform in Israel. 

I used to go to concerts and take my autograph book with me - I have autographs from musicians like Arthur Rubenstein, Leonard Bernstein, Igor Stravinsky, Dmitri Dmitriyevich Shostakovich, Pablo Casals, and many many more. Although I studied piano and still play today, mostly chamber music, I pursued a different vocation - I studied Middle Eastern archeology at the Hebrew University in Jerusalem and participated in digs at Hazor with professor Yigael Yadin noted for his work on the Dead Sea Scrolls and the excavations conducted at the Judean desert rock-fortress of Masada.

I came to the US in 1970 and worked at several museums including the Jewish Museum in NY and the Peabody Museum of ethnology at Harvard University at Cambridge Mass.  Some years later I switched to a business career with Chubb  group of Insurance companies where I trained as a property and casualty underwriter Although Chubb did insure fine art, at the time there was no specialisation in that area, so eventually I created a Fine Art specialty within the company, as well as a special program for museums and cultural institutions.

And how did you get involved with ARCA?

I came to the attention of Noah Charney who was organising a conference at Cambridge University about art and crime as an academic subject and he invited me to speak,  which I did. Some years later when he created ARCA's in person training programming,  he invited me to come and teach a course about art and crime and its implications for the insurance industry and I have been teaching this course for over 12 years now.

What is the purpose of the course you are teaching this summer?

Many private art collectors and museums are insured - while many are not - in either case there are so many misconceptions about how insurance is purchased, what is covered and what isn't etc.  The purpose of the course is to explain the whole process through actual case studies and show how the insurance industry is a major participant working in the art trade. 

Any advice for the participants in your course?

At least in my course, I like to have heavy class participation - I realise that most people don't have any experience in insurance and so I tell everyone that there are no stupid questions.

What is special about ARCA's programmes?

ARCA offers an opportunity to learn from real practitioners in the art world about  their area of expertise.  Small class size allows for meaningful discussion and networking.  Also the participants come from all over the world and this affords more opportunities for different world views, as well as consensus building about the issues in are important within the art world.

What is it like in Amelia?

Amelia is a charming picturesque town perched up in the hills surrounded by Neolithic walls.  It's quiet and very restful, away from the hustle bustle of big cities like Rome - yet its within an easy train ride to Rome and by car to other important towns like Assisi, Orvieto, Perugia, etc..

Which course would you like to follow yourself?

Marc Masurovsky's Provenance course is definitely one that I am interested in.  

_________

NB:  Late Applications are being accepted for both summer programs.  For a detailed prospectus and application materials or for general questions about this postgraduate program please contact us at: programmes [at] artcrimeresearch.org

*Edgar Tijhuis serves as the Academic Director at ARCA. He is responsible for the postgraduate certificate program and has taught criminology modules within the ARCA program since ARCA’s start in 2009.

The museum, which has featured the bronze in its collection since 1986, had challenged the order in court, arguing that there was insufficient evidence to prove the statue had been illegally exported.  In their lawsuit, the museum claimed that the headless sculpture, controversially named The Emperor as Philosopher, probably Marcus Aurelius, then renamed Draped Male Figure, had been lawfully acquired by the museum and that New York District Attorney Alvin L. Bragg’s office in Manhattan has no legal authority to seize it.  

In its prior federal filing, Cleveland Museum of Art v. District Attorney of New York County, New York (1:23-cv-02048),  Cleveland had opposed the return of this statue contending that its former curator Arielle P. Kozloff (Herrmann) believed that the Philosopher did not come from Bubon, and that any previously stated connection between Bubon and the Philosopher was mere conjecture, statements which completely contradict the museum's earlier findings. 

Vol. 74, No. 3, Mar., 1987 The Bulletin of the Cleveland Museum of Art

After its purchase, the Museum was so proud of its acquisition of unknown origin that it dedicated its entire its March 1987 edition of The Bulletin of The Cleveland Museum of Art to the statue and highlighted the bronze in a Year in Review exhibition.  Curator Kozloff wrote in the Introduction to that 62-page Bulletin that “[t]his entire issue of the Bulletin is devoted to the study of Cleveland’s newly acquired bronze.”  At page 133, she quoted English archaeologist and writer George Bean’s observations when he visited Bubon and described the difference at the site between his first visit in 1952 and his second visit in 1966:

“[T]he scene completely changed. The entire slope of the hill had recently been dug from top to bottom by the villagers in search of loot; their pits left hardly a yard of space between them. Of the ruins, such as they were, nothing now remains; but in the course of digging in the theater a large stone covered with writing was said to be found.” 

Kozloff also published photographs of her trip to Bubon, including one which she captioned “Figure 3. The photograph depicts the extent of the looting: giant holes scar the landscape and fragments of stone walls can be seen jutting out of the pits.”  Kozloff also included another photograph to illustrate the find spot of the looted statues:

On a longitudinal axis leading to the northeast (nearly parallel to the axis of the “agora”) from the theater are two structures, now pits, about 2 meters deep and mostly filled in with debris (Figure 3). The smaller of the two was pointed out by an Ibecik native as “the museum” where eight large statues were found. Our guide’s arm gestures indicated that the sculptures were found tumbled together, face down in the earth. Our guide remembered only human figures being unearthed and reported a quantity significantly less than what is claimed for the site.

Effectively, Kozloff admitted, in CMA’s own official publication, that the Sebasteion had been heavily ravaged “by the villagers in search of loot” between 1952 and 1966—all while trumpeting CMA’s newly acquired statue had originated from this very site.

At the time of its celebratory exhibit, the Cleveland Museum of Art issued a statement that it would be exhibited their new bronze with "one other sculpture supposedly found with it, a bronze bust of a lady, now in the Worcester (Massachusetts) Art Museum."  That identified object as already been returned by the New York District Attorney's Office, making it all the more outrageous, that on one hand the museum admitted to the statue's origins from Bubon, while in 2023 foot-dragging against the the realities they themselves had fully acknowledged years earlier. 

Today, the CMA formally filed a Notice of Dismissal Under FRCP 41(a)(1), electing to drop its opposition of the statue's seizure.  This now paves the way for the artefact's eventual return to its country of origin.  In opting to dismiss, the museum issued a statement published in the New York Times that the decision was predicated on the basis of scientific study, which only now allowed the museum to be “able to determine with confidence that the statue was once present at the site.”

Over the last several years, the Manhattan District Attorney's Office Antiquities Trafficking Unit, headed by Assistant District Attorney Matthew Bogdanos has been actively involved in the repatriation of stolen artefacts, including many bronzes identified as having been looted from the ancient city of Bubon in Türkiye.  In recent years, prosecutors and analysts with the ATU have worked closely with academics studying the bronzes and the Turkish authorities in order to seize, where possible and in accordance with the law, antiquities looted from this ancient site that were laundered through the black market.

By May 1967, law enforcement authorities from the Republic of Türkiye had uncovered their first lead which would help identify where the looted statues came from. A large, ancient bronze statue was found hidden in a looters house in the village of Ibecik, located in the mountainous region of the Gölhisar district, in the southern province of Burdur, less than 100 kilometers from the southwest Turkish coast.

This initial investigation, coupled with studies by Turkish archaeologist Jale İnan on behalf of the museum in Burdur, as well as notes gathered and seized from a local treasure hunter during investigations, helped to establish the find spot for the CMA bronze and other statues which once stood on the summit and slopes of Dikmen Tepe within the eastern Roman Empire city of Bubon.

According to the ancient Greek geographer Strabo, the city of Bubon formed a tetrapolis with its neighbouring cities of Cibyra, Oenoanda and Balboura.  Culturally diverse, at its pinnacle its inhabitants are said to have spoken as many as four languages: Greek, Pisidian, Solymian and Lycian. 

Travellers to Bubon as late as the mid-19th century described finding a walled acropolis, a small theatre of local stone, and the remains of tombs, temples, and other large structures in what remained of the ancient city.  Few of these survive today.  Decimated by a large-scale looting operation conducted during the mid-20th century, the unprotected ancient city's movable cultural heritage fell victim to poverty and art market greed, with much of what had survived throughout history, being dug up and hauled away for profit.

The Sebasteion at Boubon

In 1967, the archaeological museum of Burdur undertook the first legal excavation at what remained of Bubon.  During these emergency excavations, where some of the explored sites were reburied after exploration to afford more protection, site archaeologists documented a Sebasteion near the centre of the terrace close to the Agora.  This complex is believed to have been devoted to the worship of the imperial cult, honouring members of the Imperial family.  It is thought to have been in use for a period of over two centuries from the 1st to the middle of the 3rd century CE. 

Inside this Sebasteion, archaeologists discovered two inscribed podiums along the north and the east walls of the room, as well as four free-standing bases along the west wall.  Here, statues of emperors and members of the Imperial household were once on display.

The majority of the dedications found at the Sebasteion date the cult sanctuary from the half century beginning with the joint reign of Marcus Aurelius and Lucius Verus (161-168 CE) to the ending of the sole reign of Caracalla (211-217 CE).  Unsurprisingly, by the time archaeologists set about documenting the site, only one single headless statue remained.  

All the others had been clandestinely excavated and illicitly exported out of the country.

As part of this documentation, Jale İnan assigned names to seven of the missing bronze statues, based on seven of the 14 dedicatory inscriptions found in situ at the Sebasteion.  According to the researcher's reconstruction, patrons or visitors entering this room in the middle of the 3rd century CE, would have seen bronze statues of Nerva, Poppaea Sabina, Lucius Verus, Commodus, Septimius Severus, and lastly, Marcus Aurelius who would have stood on a podium or plinth facing the entrance.

One of three inscriptions discovered during J. İnan's excavation, on stones forming the top course of the north pedestal (blocks E 10 and 11), documented in his 1990 excavation notes, reads:

[Μ.Αυρήλιο]ν Άντωνεϊνον

The Emperor as Philosopher Image Credit: Cleveland Museum of Art

At the time of sculpture's purchase, the CMA's press releases and follow-up publications openly admitted that the bronze was part of a “group of Roman bronze figures and heads, believed to have come from Turkey” that represented various emperors and empresses, which had been created for a structure honouring the imperial cult in the mid-2nd century.  All details which perfectly aligned with the details of the statues which once filled the Sebasteion in Bubon.

Before mandating the statue's seizure, DANY's Antiquities Trafficking Unit, with the assistance of officials from the Republic of Türkiye, were able to locate and interview one of the individuals who actually looted and smuggled this statue and determined that the bronze had been smuggled into Switzerland by Robert Hecht then circulated onward via Charles Lipson, first via the exhibition at the Museum of Fine Arts in Boston, and later loaned long term to the Metropolitan Museum of Art via a private collector before ultimately being purchased by the Cleveland museum.

Yet, despite the evidence presented at the time of its seizure and its earlier stance that the object had been lawfully acquired, the museum somewhat lamely cited only the forensic evidence in its late-in-coming decision to relinquish the Marcus Aurelius statue.  It indicated that analysis of soil samples taken from within the body of the statue, as well as lead from a plug in its foot used to attach the statue to a plinth, which matched evidence obtained from the Sebasteion in Bubon proving the bronze had once stood there.  

While these laboratory findings provide the scientific nail in the coffin, proof linking this beautiful statue to its original site, this testing merely strengthens the preponderance of evidence accumulated in Manhattan's preexisting case for restitution.  The evidence of the object's trafficking from Türkiye, didn't rest on scientific analysis, which in this case, was miraculously made possible because the find spot remained relatively undisturbed.  

The case was weighted on multiple elements, including the first-hand testimony of farmers who told investigators that men from a nearby village found the bronzes buried on a hillside, beginning in the late 1950s and year by year, working in teams, removed the artefacts from the Sebasteion, many of which were sold to “American Bob,” absence of legal export permits and then unlawfully smuggled out of Türkiye.

Lest we forget, in 1962, the infamous American ancient art dealer Robert "Bob" Hecht was detained in Türkiye after he was seen inspecting ancient coins returning to Istanbul on a flight from heavily plundered Izmir, the same city where the intermediary dealer in this case operated.  As a result of that incident, Hecht was declared persona non grata in the country.  A friend of notorious Turkish antiquities smugglers, such as Fuat Üzülmez and Edip Telliağaoğlu, Hecht mediated the purchase of a large number of ancient artefacts which were smuggled from Turkey, before he turned his sights on Italy.

To date the ATU has restituted 14 antiquities, valued at almost $80 million, looted from the ancient site of Bubon. This Marcus Aurelius, headless though he be, is the 15th, and one I am sure the citizens of Türkiye will warmly welcome home.  

In closing, it will be interesting to see the CMA's own published statement as to why it ultimately elected to close its Federal folly to keep an obviously looted statue in its collection, rather than come to terms with what was already widely known for more than a decade.  I suspect they will mention their scholar's “subsequent research,” and her change of heart as to the statue's origins. 

But before they do so, I would remind ARCA's readers that the CMA's now-retired curator, Arielle Kozloff Herrmann, of Shaker Heights, who led the purchase of this Marcus Aurelius bronze in 1986, had longstanding interactions with problematic dealers in the ancient art market.  Those include the following, who have repeatedly tied to the illicit antiquities trade: 

Robert Hecht, who ravaged Turkey and Italy and who Kozloff thanked for information in the bulletin's acknowledgments on this purchase.

Sicilian Gianfranco Becchina, who she and her husband, John Herrmann, corresponded and met with.  

Edoardo Almagià, who currently has an outstanding arrest warrant in New York and who she was introduced to by the problematic Princeton curator, Michael Padgett. 

Edward Merrin the dealer who sold this statue to the CMA and whom she later worked with,

Lawrence Fleischman, George Zakos, Brian Tammas Aitken, and Robert Haber.   

Look into any of these fellows, most of whom have been featured on ARCA's blog, and then tell me if you think Arielle's latter indecision was unbiased, without motivation, and should have been a deciding factor in the museum's filings against this forfeiture. 

By:  Lynda Albertson

Upon arriving at John F. Kennedy International Airport on January 22, 2020 from an international flight from Egypt, Eldarir had submitted a customs declaration form to U.S. Customs and Border Protection agency (CBP), as required for all travellers entering the United States.  On that form, he had stated that he was bringing in merchandise and agricultural products worth $300.  However, when CBP officers inspected his luggage, instead of finding low value business related products, they discovered three suitcases filled from top to bottom with antiquities wrapped in protective packaging. 

Inside Eldarir's careful bubblewrap and foam padding were a total of 590 Egyptian artefacts.  Some of these still had sand and soil adhering to them, a telltale sign which underscored their recent excavation, and, in the words of the agents examining his luggage, still smelled of wet earth. 

Along with the antiquities, CBP agents found documents "written in Arabic on watermarked paper with stamps affixed on the top right of the documents, and two-hole punches along the left-hand side" along with blank paper resembling that of the purported provenances, with the same watermark and two-hole punches along the left-hand side and thirteen loose stamps similar to the ones used on the provenances.  When asked if he had ever sold historical artefacts previously, Eldarir replied that he had sold "a few in the last few years", a statement which would turn out to be a gross understatement.

Given that he was unable to provide the customs agents with sufficient proof that the packaged artefacts he was importing into New York had legally been exported from Egypt prior to the enactment of the country's 06 August 1983 Law No. 117 "on the Protection of Antiquities, CBP seized the antiquities pending further investigation.

Eldarir was subsequently arrested on 28 February 2020 and charged in the United States District Court, Eastern District of New York, on two counts of smuggling, under Title 18 U.S. Code § 545, 2 and 3551 et seq.  As part of that investigation, the United States also sought forfeiture of the following antiquities in accordance with: (a) Title 18, United States Code, Section 982(a)(2)(B):

forty-one (41) ancient Egyptian gold artifacts;

nineteen (19) ancient coins;

two (2) Greco-Roman rings;

thirty-one (31) ancient Egyptian talismans (Ptolemaic period);

fourteen (14) ancient beads;

twenty-six (26) ancient Egyptian wooden figures;

four hundred (400) ancient Egyptian faience ushabtis;

three (3) ancient Egyptian wooden panels with painted figures;

one ( I ) ancient Egyptian large stone face;

two (2) Egyptian wooden masks;

two (2) Egyptian stone panels with hieroglyphics; 

three (3) ancient Egyptian canopic jar lids;

two (2) ancient Greco-Roman stela;

one (1) ancient Greco-Roman terracotta headless torso with robes;

seven (7) ancient Greco-Roman terracotta statues; 

three (3) ancient Egyptian large terracotta vases; 

two (2) Egyptian smalIterracotta vases;

two (2) Egyptian alabaster artifacts;

two (2) ancient Egyptian Osiris headpieces/crowns; 

twenty-six (26) ancient Greco-Roman oil lamps; 

one (1) Greco-Roman terracotta pilgrim's flask;

one (1) ancient Egyptian polychrome relief.

For years prior to his arrest, Eldarir had been successfully laundering plundered artefacts onto the licit ancient art market.   Often his pieces carried with them a fabricated provenance claiming that the pieces were part of "The Ashraf Eldarir Private Collection of Ancient Art, New York, USA", or "Acquired by Izz al-Din Tah al-Darir Bey in Egypt December 1946 from Salah al-Din Sarmali Bey" or that they had been inherited through the trafficker's grandfather. 

To disguise their illicit origins, and to cosmetically claim that the pieces were derived from a collection which predated Egypt's ban on export, Eldarir's trafficked artefacts sometimes mentioned that his grandfather or "Ezeldeen Eldarir," was a friend of Prince of Egypt, Omar Tosson, with whom he shared a passion for archaeology or that the collection had been formed during the 1930s-1940s, mostly as gifts from Prince Tosson, which he claimed had been moved to the United States "in 1948 where it remained with the family until the present day."

With no export licenses, and no factual proof which supported his vague claims of long term ownership for the pieces he handled, aside from what would turned out to be self-made documents giving a cosmetic overhaul of legitimacy, Eldarir's smuggled antiquities circulated among US and Europe's prestigious ancient art galleries from 2012 until shortly after his arrest was announced publicly.  After which ARCA published a list of material it had identified as being linked to the suspect trafficker.  This compilation of suspect Egyptian antiquities was made public on 8 July 2020, and can be found here.

One of the more interesting high value pieces was this portrait head of a man, sold first through Christies New York in 2012 for $52,500.  Despite the trafficker's arrest in the US, this piece was still up for sale during the COVID-affected TEFAF Maastricht art fair in 2020, at the stand of Swiss dealer, Jean David Cahn.  Here the piece was called "a Portrait Head of the Emporer Severus Alexander" with a price on request. 

On June 15, 2023, a federal grand jury in the Middle District of Pennsylvania indicted Nicholas Dombek, Damien Boland, Joseph Atsus and his brother Alfred Atsus for their alleged involvement in a widespread art and memorabilia theft ring that spanned over two decades and targeted 19 museums and other venues in six states and the District of Columbia.

The charges against the men included conspiracy to commit theft of major artwork, concealment or disposal of cultural artefacts, and interstate transportation of stolen property.  Each defendant also faced additional counts related to the theft and concealment of significant cultural objects, with Dombek receiving an extra charge for transporting stolen property across state lines.

The objects taken during the series of breakins included:

Those objects included:

A Christy Mathewson jersey and two contracts signed by Mathewson stolen in 1999 from Keystone College in Factoryville, Pennsylvania;

“Le Grande Passion” by Andy Warhol and “Springs Winter” by Jackson Pollock stolen in 2005 from the Everhart Museum, Scranton, Pennsylvania;

Nine (9) World Series rings, seven (7) other championship rings, and two (2) MVP plaques awarded to Yogi Berra, worth over $1,000,000 stolen in 2014 from the Yogi Berra Museum & Learning Center, Little Falls, New Jersey;

Six (6) championship belts, including four awarded to Carmen Basilio and two awarded to Tony Zale stolen in 2015 from the International Boxing Hall of Fame, Canastota, New York;

The Hickok Belt and MVP Trophy awarded to Roger Maris, stolen in 2016 from the Roger Maris Museum, Fargo, North Dakota;

The U.S. Amateur Trophy and a Hickok Belt awarded to Ben Hogan, stolen in 2012 from the USGA Golf Museum & Library, Liberty Corner, New Jersey;

Fourteen (14) trophies and other awards worth over $300,000 stolen in 2012 from the Harness Racing Museum & Hall of Fame, Goshen, New York;

Five (5) trophies worth over $400,000, including the 1903 Belmont Stakes Trophy, stolen in 2013 from the National Racing Museum & Hall of Fame, Saratoga Springs, New York;

Eleven (11) trophies, including 4 awarded to Art Wall, Jr. stolen in 2011 from the Scranton Country Club, Clarks Summit, Pennsylvania;

Three antique firearms worth a combined $1,000,000 stolen in 2006 from Space Farms: Zoo & Museum, Wantage, New Jersey;

An 1903/1904 Tiffany Lamp stolen in 2010 from the Lackawanna Historical Society, Scranton, Pennsylvania,

“Upper Hudson” by Jasper Cropsey, worth approximately $500,000, and two antique firearms worth over $300,000, stolen in 2011 from Ringwood Manor, Ringwood, New Jersey;

$400,000 worth of gold nuggets stolen in 2011 from the Sterling Hill Mining Museum, Ogdensburg, New Jersey;

Various gems, minerals, and other items stolen in 2017 from the Franklin Mineral Museum, Franklin, New Jersey;

An antique shotgun worth over $30,000 stolen in 2018 from Space Farms: Zoo & Museum, Wantage, New Jersey;

Various jewelry, and other items from multiple antique and jewelry stores in New York, Rhode Island, and Pennsylvania.

The prosecution's case relied heavily on the testimony of Thomas Trotta, 49, a former resident of Moscow, Pennsylvania, who law enforcement identified as the ringleader behind the theft operation.  Prior to pleading guilty, state police had used newly acquired DNA evidence to link Trotta to several burglaries which ultimately resulted in him cooperating with state police and the FBI, informing detectives of the extent and scope of the gang's activities.

During his testimony, Trotta spoke of the destruction of the memorbilia for its base metal price, despite the fact that the objects were symbols of legacy.  In providing detailed accounts of the thefts during the trial of his associates, Trotta's testimony highlighted how the group of museum thieves stole the nine World Series rings, trying them on before they set about prying the gemstones out of them, then melting them down, along with the metal on the plaques in his garage.   His cooperation, although controversial, was pivotal in securing the convictions. 

Unfortunately, as this one described incident details, many of the items stolen are not recoverable as the were converted into metal discs or bars which the theft ring then sold in New York for the raw metals. 

Despite this, the trial's outcome has been met with a sense of justice by the numerous law enforcement agencies who worked on this multi-state investigation, including the Federal Bureau of Investigation (FBI), the Pennsylvania State Police, the New Jersey State Police, the New York State Police, the New Jersey State Park Police, the Newport Police Department (Rhode Island), the Fargo Police Department (North Dakota), the Chester Police Department (New York), the Wyoming Regional Police Department (Pennsylvania), the Scranton Police Department, the Franklin Police Department (New Jersey), the Village of Goshen Police Department (New York), the Metropolitan Police Department (Washington, D.C.), the West Milford Township Police Department (New Jersey), the Montclair Police Department (New Jersey), the Saratoga Springs Police Department (New York), the Canastota Police Department (New York), the South Abington Police Department (Pennsylvania), the Bernards Township Police Department (New Jersey), the Salisbury Township Police Department (Pennsylvania), the Montclair State University Police Department (New Jersey), the Lackawanna County District Attorney’s Office (Pennsylvania), the Sussex County Prosecutor’s Office (New Jersey), the Essex County Prosecutor’s Office (New Jersey), the Orange County District Attorney’s Office (New York), and the Madison County District Attorney’s Office (New York).  

While stolen memorabilia may not hold immense financial value, their historical and cultural significance still makes their loss irreplaceable.  Many of the objects targeted in ring's museum thefts, such as the championship belts, or award rings, carry deep personal and societal meaning, a value which cannot be calculated simply, and which transcends their monetary worth alone. These sports-related objects serve as tangible connections to the past, preserving the stories and achievements of their respective award winners, and these individual's importance within their communities. 

When stolen and melted down, these pieces of history are lost forever—depriving future generations of their educational and cultural importance. 

To read more on this case, check out this article by Ariel Sabar. 

The Oracle at Delphi, 1881, by Camillo Miola

Sometimes the road from diplomatic agreement to restitution or seizure to restitution is a long and windy road like the lyrics of a Beatles song.  And in the announcement and publication of victories, which flash across the news, the general public sees only the superficial details, carefully curated to neutralise all the hard fought passages that allowed "Object A" to be returned to "Country B".   

Such is the case with The Oracle at Delphi (1881) by Camillo Miola, a neoclassical painting depicting the ancient Greek sanctuary of Delphi, where the Pythia, a high priestess of Apollo, delivered prophecies. The artwork portrays a dramatic scene within the grand temple, with the Pythia seated on a tripod, enveloped in mystical vapors, as she channels divine messages. A group of supplicants, including warriors and noble figures, eagerly awaits her pronouncements, their expressions reflecting awe, anticipation, and reverence. 

On August 11, 2022, ahead of their agreed upon negotiations, The J. Paul Getty museum made a widespread public announcement that it would be returning a number of objects in their collection to Italy including:

Orpheus and the Sirens (inv. 76.AD.11) acquired in 1976 from Bank Leu in Zurich,

Colossal Head of a Divinity (inv. 72.AL.96) acquired in 1996 from scandalous UK art dealer Robin Symes,

an Etruscan bronze thymiaterion (inv. 96.AC.253) acquired in 1996 from the Fleischman collection, It was sold to the Fleischmans in 1987 by Italian art dealer Edoardo Almagià.  A while back New York Assistant District Attorney Matthew Bogdanos, who heads the Manhattan Office's Antiquities Trafficking Unit was quoted in an interview with the Princeton Alumni Weekly, saying: 

“If Almagià is the first name on your provenance, it is stolen.” 

a Mold for Casting Pendants, (75.AA.35) about 2nd century CE, donated by collector Lawrence A. Fleischman and his wife;

and lastly, a rather fanciful oil painting entitled The Oracle at Delphi, 1881 by Camillo Miola (72.PA.32), a neoclassical painting depicting the ancient Greek sanctuary of Delphi, where the Pythia, a high priestess of Apollo, delivered prophecies.  

This artwork portrays a dramatic scene within the grand temple, with the Pythia seated on a tripod, enveloped in mystical vapours, as she channels divine messages. A group of supplicants, including warriors and noble figures, eagerly awaits her pronouncements, their expressions reflecting awe, anticipation, and reverence. Miola’s use of rich colours, classical architecture, and meticulous detail captures the spiritual intensity and grandeur of the sacred ritual, emphasising the oracle’s central role in guiding ancient Greek society.

In their announcement they stated that the impetus for the return of the Sculptural Group of a Seated Poet (Orpheus) and two Sirens is evidence presented to them of their looting.  Their announcement fails to make mention of the fact that the artefacts had been seized earlier pursuant to a court order and no other details were presented for the remaining pieces going home but as we know by the names of the dealers that circulated them, they propensity for being problematic was high. 

But what about the Miola painting nothing was stated as to why this artwork was coming home?

While Orpheus and his two friends came home in 2022, its taken two years and five months after the Getty's initial and somewhat lacking announcement, for Camillo Miola's painting to arrive back in Naples, along with the oil painting Portrait of Vittorio Emanuele III, 1902 by Achille Talarico.  

We know that Miola's painting depicting Pythia was stolen from the San Lorenzo Institute of Aversa between 1943 and 1946.  But not much has been written in public records which elaborates upon its exit from Italy.  We know only that the painting left Italy at some point after the close of World War II arriving to America.  It was then consigned to Parke-Bernet in New York as coming from "a Private Collection", and sold on 24 February 1972 to Ira Spanierman, who operated the eponymous Spanierman Gallery (1961-2014).   He in turn sold it to the J. Paul Getty that same year.

According to the museum's accession record the provenance for this painting is:

Open source records show us that following a meeting of Italy's Committee for the Recovery and Restitution of Cultural Heritage, chaired by Minister Alberto Bonisoli Italy's Ministry of Cultural Heritage formally asked the J. Getty Museum on 9 May 2019 to consider the country's claim for the Victorious Youth bronze (no progress there yet) and to also evaluate the provenance of four objects in the museum's collections that were also stolen or exported without permission from Italy. 

Those four objects were:  

Camillo Miola "The Oracle of Delphi" stolen from the San Lorenzo Institute in Aversa between 1943 and 1946; 

two marble lions from the Roman era that were in the Palazzo Spaventa in Preturo (Aquila) and 

a Mosaic with Medusa stolen from the National Roman Museum. 

This request was signed by the secretary general Panebianco and emphasised Italy's ministry's full willingness to keep alive the consolidated relations with the Getty,  blah blah blah, and considers cultural diplomacy a priority, blah blah blah, and stated that the writers would like to identify a suitable date for a meeting between the two parties to further discuss the Italian request for the restitution of The Victorious Youth, or the Athlete of Fano, the bronze statue that was fished out in 1964 in the waters of Fano in the Marche region and was subsequently illegally exported from Italy as determined by Italy's courts.

From the museum's side, the Getty replied that it would start their verification with the technical staff and that a response will be sent "as soon as possible", which, given the presentation of Miola's painting back in Italy has happened five and a half years later, and two years after the museum acknowledged that they were in agreement to relinquish the artwork, one has to marvel at the almost glacial pace of restitutions. 

And while ARCA is more than pleased that these artworks have actually come home through mutually beneficial agreements between museums and ministries and law enforcement officers and art researchers doing diligent work, we do wish there was a little more information than just somber, happy, formal, tight-lipped presentations stating these works are once again home. 

Transparency in restitution agreements between museums and source countries is crucial for ensuring accountability and ethical stewardship of cultural heritage. Not to mention it also builds public trust.  

Too often, repatriation deals are negotiated behind closed doors, with mutually agreed upon formal announcements which are carefully worded and often vague, leaving out key details about the provenance research, legal considerations, and the conditions of return.  All facts which could help us learn why one object makes it home and another doesn't. Or why certain objects are returned home quickly, while others take years after a restitution is announced, delaying justice for affected communities. 

This lack of openness can fuel skepticism, and invites speculation and negative interpretation, where the length of delays from announcement to homecoming can be misinterpreted foot dragging on the museum's part.    

By committing to clear, public disclosure of restitution decisions—detailing the origins of looted works, the justification for their return, the collaborative efforts between museum staff and source nations, and the complex mechanisms that often delay repatriation—museums can demonstrate a genuine commitment to ethical responsibility and cooperation. Transparency in these processes not only fosters trust but also ensures that institutions are seen as proactive stewards of cultural heritage rather than merely responding to external pressure.

Greater transparency would not only strengthen international cooperation—providing provenance researchers with valuable roadmaps from successful restitution cases—but also help rebuild public trust in museums as institutions committed to rightful ownership and historical justice. Rather than treating returns as mere footnotes with minimal explanation, museums should fully articulate the reasons behind their decisions, reinforcing their role as ethical stewards of cultural heritage.

The heist, which occurred in the Netherlands on January 25, 2025, has been described by Drents Museum director Harry Tupan as the most significant incident in the institution's 170-year history.  Following the burglary, investigators discovered a bag containing clothing in Assen, which along with other investigative traces, led them to Wendersteyt and Zeeman.  Authorities have since released the names and two photographs of the two of the three suspects under investigation and are appealing to the public for any information regarding their whereabouts or activities in the days leading up to and immediately after the theft. 

In addition to Wendersteyt and Zeeman, the third individual, a woman, also from Heerhugowaard, has been arrested in connection with the case. Her identity has not been disclosed, but Dutch and Romanian news reports suggest that she and one of the male suspects are a couple with two young children. 

Image Credit: Safani Gallery TEFAF Maastricht advertisement

In terms of its history, DANY's court documents set out that the head was discovered during excavations of the Basilica Aemilia, located on the Via Sacra.  This is the ancient road between the Capitoline Hill and the Colosseum located within the Roman Forum in Rome. While little remains of the Basilica Aemilia today, it was considered by Rome historian Pliny the Elder to be one of the three most beautiful elements of the Roman Forum, this alongside the Forum of Augustus and the Temple of Peace. 

Looking across the remains of the Basilica Aemilia towards the Severan Arch, the Tabularium, and the Modern Senate House Image Credit: B. Dolan

The head was discovered at some point during Italian research excavations carried out by Drs. Professors Giacomo Boni and later by Professor Alfonso Bartoli which were carried out on the Palatine Hill between 1899 and 1939.  Documentation from the excavations suggest that the head belongs to one of the “Statues of Parthian Barbarians” which once adorned the Basilica.

After 20 BCE Roman art often portrayed the people of the Empire and during its restoration in 14 BCE, Augustus chose to line the Basilica with a series of Parthian figurines, perhaps in humiliation of Rome's ancient foreign enemy.  Representing individuals from the Parthian Empire (also known as the Arsacid Empire), these likenesses depicted the conquered Parthians as representatives of the Orbis Alter, subjects of Rome which were not considered to be part of the “civilised” world.  Stylistically, they differ from representations we have from the same period of people from the Orbis Romanus. 

According to court documents, the Italian Soprintendenza alle Antichità Palatino e Foro Romano began keeping archival photographic documentation of the objects discovered during the lengthy excavation starting in 1908.  Based on these records, the head of Alexander the Great, seized from the New York gallery, is believed to have been discovered during the second phase of these excavations which began after 1909. This dating is derived as the Italian authorities have no written, descriptive entries or photographic archival documentation of any marble head finds from the Roman forum of the Barbarian statues prior to 1909.   It was also not until September 1909 that Dr. Professor Bartoli's team began their explorations in the zone of the Basilica Aemilia.  As a result of this and other evidence described in the New York Court's Application for Turnover it seems most likely that the marble head was found sometime around 1910.

In this instance, the Alexander head has sold in the United States and in the United Kingdom on multiple occasions.

But where was the object bought and sold? 

While the documentation of this object's collection history is spartan, we know that on 22 November 1974 the head of Alexander sold for a mere $650, having been consigned by the Hagop Kevorkian fund to Sotheby Parke Bernet.  Sotheby’s Auction House acquired Parke Bernet Galleries in 1964 and adopted the name Sotheby Parke Bernet throughout the 1970s.  Today, this auction house is known simply as Sotheby’s.  The buyer at the time was listed only as "Altertum Ltd."

Sometime after that date the object was then purportedly purchased by Professor Oikonomides who indicated to others that he purchased the object while vacationing in Cairo, Egypt sometime between 1984 and 1986.  The object was then bequeathed to Dr. Miller by Oikonomides through his estate when he passed away in 1988.

Sotheby's Website Screen Capture taken 24 July 2018

On 08 December 2011 the object sold at Sotheby's for a second time during Sotheby’s Egyptian, Classical and Western Asiatic Antiquities sale .

At the time of this auction, the purported provenance for the object was listed as:

Hagop Kevorkian (1872-1962), New York, most likely acquired prior to World War II
The Hagop Kevorkian Fund (Sotheby Parke Bernet, New York, November 22nd, 1974, no. 317, illus.)
A.N. Oikonomides, Chicago

But with very little in the way of documentation to confirm this narrative.

The object sold to an unidentified buyer for $92,500 USD.

In May 2017, the head of Alexander surfaced across the Atlantic.  This time the ancient marble head went up for sale in the United Kingdom, having once been in the possession of former Qatari culture minister and cousin of the current ruler of the oil-rich Arab country, Sheikh Saud bin Mohammed Ali Al-Thani.  Before his death in 2014 Sheikh Saud Al-Thani was believed to have been the world's richest art collector.

Through Classical Galleries Limited, UK the Sheikh’s foundation sold the head of Alexander to Alan Safani of Safani Gallery for $152,625 on June 20, 2017.

Object Identified

Safani Gallery Booth - TEFAF 2018 Image Credit: L. Albertson

By an amazing bit of serendipity, on 19 February 2018 Dr. Patrizia Fortini, Director and Coordinator of the Archaeological Site of the Roman Forum and Palatine Hill chanced upon an advertisement which featured a photo of the stolen head in a publication for the upcoming 2018 Fine Arts Expo known as TEFAF.  In the dealer's documentation, a photograph of the marble head had been included highlighting Safani Gallery's offerings for the upcoming Maastricht sale scheduled to be held in the Netherlands from March 10 through 18 in 2018.

The photo in the advertisement and the old archival documentation photo of the head in the Museo Forense’s cloister were identified as one and the same object and as a result, Italy moved forward in requesting the object's seizure.

“[a] finding that the Manhattan DA violated the Constitution by seizing the Head without probable cause and without due process would not change the fact that only the state court can order the disposition of the Head.”

By:  Lynda Albertson