Dmitry Tamoikin


Counter-Terrorism Report


wakeup call to authorities worldwide

 2011 – 2015

Art and terrorism seem to be worlds apart, however what most people perceive as heritage and culture – criminal organizations see as cold hard cash. Cash that is hard to trace and very easy to move undetected through the borders of any country.

In the late 80s through early 90s, the international community and law enforcement agencies started a global crackdown on organized crime. Today that battle evolved into ‘The War on Terror’. Part of the original strategy was stopping illegal cash flow, especially money that was intended for the end user – a criminal on the ground within the country. A $10,000 dollar limit was set. Cash over $10,000 had to be declared at all border crossings. Banks had to report all incoming wire transfers exceeding this amount to law enforcement agencies. Contractual justification and detailed information about the sender and beneficiary became obligatory. The majority of the public however, didn’t really see many benefits from this new policy perceiving it as a nuisance and infringement on their rights. Then, a decade later, in 2001 the world witnessed the largest terrorist act conspired by man  September 11th attacks struck America. Behind the plot, strategy and execution … Al Qaeda money… funnelled from multiple global locations directly into the United States. No red flags went up until it was too late … .

The Financing of the 9/11 Plot

‘To plan and conduct their attack, the 9/11 plotters spent somewhere between $400,000 and $500,000, the vast majority of which was provided by al Qaeda. Although the origin of the funds remains unknown, extensive investigation has revealed quite a bit about the financial transactions that supported the 9/11 plot. The hijackers and their financial facilitators used the anonymity provided by the huge international and domestic financial system to move and store their money through a series of unremarkable transactions. The existing mechanisms to prevent abuse of the financial system did not fail. They were never designed to detect or disrupt transactions of the type that financed 9/11’.

UNT Libraries / US Government Documents Dept. {1}

The key phrase here is ‘unremarkable transactions’. This is where the art market comes into play. As one of the last unregulated markets on the planet it is a thriving haven for unremarkable transactions, under the table dealings, shady clientele, extreme privacy and big money.

First crucial point to understand is that when we are talking about art, we do not mean your local flea market ‘stuff’. Nor do we limit ourselves to just paintings. We are talking about high-end ‘movable cultural property’ consisting of art, antiques and collectibles … very expensive art, antiques and collectibles. Items that by far exceed the $100,000 dollars benchmark.

Second point to understand – there are lots of them, everywhere, in every country, city and town. In fact there will never be a shortage of them. With the latest modern art hype the market literally became a factory. These modern creations are breaking multimillion dollar records at top auctions around the world. Put supply and demand together and you get liquidity. More important however, you get extremely valuable, highly liquid, easy to make or buy, objects that are unrecognised by the majority of people, including customs and border protection officers.

Ugly monsters

Photo: AP

Jean-Michel Basquiat’s Dustheads

Sold at Christies, NY, for $48.4 Million US



Ugly picture 2

Kazimir Malevich, Suprematist Composition

Sold at Sotheby’s, NY, in 2008 for $60 Million US



The truth is, customs officers are not trained to identify valuable art and antiques from invaluable items, thus unknowingly giving these items a green light at all entry points. When a single antique item can easily be worth significantly more than ten kilograms of heroin one can comprehend the full extent of danger involved. Money gained from the sale of such artworks can support an entire al Qaeda terrorist group for a year. This money will be hard to trace and identify in time to prevent an incident.

Most common art smuggling schemes:

Scheme 1 – Freight containers: Large items that cannot be taken on board a plane, for example a painting or a sculpture, are shipped by a container that is rented and loaded with similar paintings or sculptures. Inexpensive copies are easily purchased in Asia. In between those copies lies the original artwork. At the country’s entry point smugglers present proper import documents for goods in the container, excluding the main object, pay taxes and enter.  The smuggled item is never detected, even upon inspection. Chances that customs will suspect fraud are slim to none. Smugglers themselves in most cases are nothing more than mailmen , who are unaware of the overall situation. {2} {3}

Scheme 2 – Mail Couriers. Small items that are light and compact, for example a small statuette, are shipped via regular or priority mail.  Such items are packaged and simply shipped to any address with a tracking number. On the declaration this item is described as a carved souvenir with a standard declared value of $100 dollars or less. The likelihood that customs will detect fraud is nonexistent. Safe arrival of the asset is 99 per cent guaranteed.

Guennol Lioness
Year: 3rd millennium BC
Type: Limestone
Size: 8.3 cm (3.25 in)
Location: Private collection
Price: $57.2 Million USD

The Guennol Lioness is a 5,000-year-old Mesopotamian statue found near Baghdad, Iraq. Depicting a well-muscled anthropomorphic lioness, it sold for $57.2 million at Sotheby’s auction house on December 5, 2007. {4}

Note the miniscule size and astronomical value of this historic piece. If smugglers (terrorists) wish to be 100 per cent sure an item like this will arrive safe and sound they will make nineteen copies and send four priority packages containing five statues each.

Scheme 3 – Airport. Items that are visually perceived as too expensive to be sent by mail, primarily gold and diamond jewellery, are put on as regular jewellery and very openly pass through all airport security and customs checkpoints. A male and female smuggler (working for a client) can literally walk out of the most secure airport’s front door – easily wearing up to 10 million dollars worth of extremely expensive bracelets, necklaces and rings. This scheme is used when expedited funding is needed.

 7 The Chopard Blue Diamond RingValued at $16.26 Million {5}

Scheme 4 – Copy Switch.  For this scheme, the method of delivery is not important. What is important is documentation. An item is shipped officially into a country under a temporary import permit. Once in the country an identical copy is made. This copy is exported as an original while the true original never leaves the country. Six months later customs’ copy of that import permit is buried in a vast border service archive that gives priority to large shipments and more notable cargo. Now this item can be openly sold.  Auction houses and galleries are neither connected to customs offices nor do they perform extensive background checks. While all information is there the dots are not connected, since no unified database exists. When money, gained from the sale of this item, is used for terrorist funding within that country, law enforcement officials will put the scheme together – unfortunately after the incident.

8 {6}

The extreme danger of terrorists over criminals is that terrorists do not plan to get away after committing the crime. They understand that governments are slow to respond and detect fraud only after internal audits – something that does not happen often. This gives them a window of opportunity and an ability to use certain financial systems, like the art market, much more openly, quickly and boldly without concern for the aftermath. Authorities now know how September 11th was organized but were not able to prevent it.

Option 5 – Auction Shipping. This is an option and cannot be called a scheme as it is a completely legal way to ship an item. This is not smuggling. However, it is a viable option that can be used by people associated with terrorism. A buyer working through a representative, asks the auction house/gallery to ship a purchased item to the very same auction house or its affiliate in the country of preference, where it will be picked up by a representative. The buyer pays extra for shipping and handling fees as well as import taxes. The auction house does the rest. Purchased item can even be sold at the same auction house or its affiliate in the country of destination, six months to a year later. To the customs, the shipper and recipient is a well-recognized auction house or gallery. No flag would go up.

 Web site extract : {7}


 Web site extract : {8}


To date, customs and border protection services associate art smuggling only with lawless collectors, thieves and avoidance of import taxes; however, they do not understand that art is money in transit, money that can be used to fund terrorism. Even more concerning is that the majority of customs officers perceive valuable art, antiques and collectibles through the Hollywood version where expensive treasure is depicted as mountains of gold coins, sparkling fist-size rubies or magnificent eight feet Renaissance paintings and statues. Reality however is much different. Here is an example:

This is what customs officers are looking for. This is what sells for $37 Million US Dollars at an Auction.
11 12
David, by Michelangelo (The Accademia Gallery, Florence) is an example of high Renaissance art. {9}
Madame L.R.
Sold in 2009 for: $37,623,104 {10}


Question: What customs official, looking straight at the carved statue will associate Constantine Brancusi’s Madame L.R. with an item worth almost 40 million US Dollars? 

There are dozens more ways to smuggle items into a country from outright bribery to using political mail of corrupt foreign diplomats however, smuggling is not the real problem. Although it is easy to put the blame solely on border protection authorities, smuggling is an age-old business so the tighter our borders become the more innovative smugglers will be. Naturally customs have to react to this threat, starting with additional art education for their personnel, but that is only a part of the solution. To understand this problem authorities have to go to the source where it all starts and ends – places of purchase and sale. There, with proper regulations, they can effectively stop almost all incidents from developing any further.


With the unregulated nature of the entire art market this is a true uncharted Wild Wild West. There are virtually no regulations to abide by and the ones that do exist are vague or unenforceable. A thriving heaven for criminal and terrorist organizations to launder and move large sums of money, legally, openly and without risk. One simply needs to type ‘Unregulated Art Market’ in Google to experience the full extent of the problem and the amount of public complaints. Here is one such example:

Time To Reform The Art Market?

For the last few years, the media have trumpeted contemporary art as the hottest new investment. At fairs, auction houses and galleries, an influx of new buyers many of them from the world of finance have entered the fray. Lifted by this tidal wave of new money, the number of thriving artists, galleries and consultants has rocketed upwards. Yet amid all this transformative change, one element has held stable: the art market’s murky modus operandi [mode of operation].In my experience, people coming from the finance world into the art market tend to be shocked by the level of opacity and murkiness’, says collector Greg Allen, a former financier who co-chairs MoMA’s Junior Associates board. … ‘The art trade is the last major unregulated market’, points out Manhattan attorney Peter R. Stern, whose work frequently involves art-market cases. {11}

Transparency and art are like two polar opposites and yet it is the single most effective tool to stop criminal abuse of this market.  All auction houses, galleries and dealers including the largest and most prominent in the world permit complete anonymity of the buyer and the seller, under the pretext that they value their client’s privacy. This single act creates a very favourable situation for terrorists to exploit. Those who have read about or seen articles of expensive art being sold at auction may have noticed that 90 per cent of the time the buyer and the seller are never revealed. At the very bottom of the article it would say something like this: ‘item sold into a private collection’. Many times even the auction does not know who the real buyer and seller of the items are. If one watches a live, high-class auction, they will notice a number of agents next to the telephones at a specially designated area, these people are placing bids on the buyer’s behalf.

In the end what we have is a very expensive item sold from one private collection to another with auction houses in the middle. Auction houses are loyal to money and will not easily release information about their high-net-worth clientele or even their representatives without a court order, an order that will consume precious time to get, especially if there is an urgent investigation taking place.

Do auction houses really know the Seller of every item they sell? The answer is no. Auction houses sell a lot of art, antiques and collectibles. It is not cost-effective to do a thorough background investigation on each item they sell. One may argue that auctions pay close attention to provenance of the item. Yes, art may have spotless provenance which is a pass for any auction. What no one is concerned about is the immediate owner with multiple foreign representatives and lawyers. As long as the item has decent provenance and is not in any stolen art database it is accepted for auction – this constitutes a formal background check.


Do auction houses really know the Buyer of every item they sell? Again the answer is no, they do not. Yes, they may know the name and banking information of the person on the other end of the phone, who is making the bid – however that person, almost always, is not the actual buyer. In case the item, that is being bid on, is intended for terrorist purposes, that person will not even be the buyer’s representative. Most likely that person will be an unsuspecting law-abiding lawyer who is contracted to place a bid. If this sounds too far-fetched so were the early pre 9/11 reports of a complex large-scale terrorist attack that could involve 19 terrorists and 4 passenger jets. In fact, to purchase an item, terrorists may create a chain of multiple representatives some of whom would not even suspect in what they are really involved.


Put everything together and a very alarming picture comes to light.



Anonymous / Untraceable





It is evident that very expensive and mobile art can be anonymously purchased, transported and sold … completely avoiding all preventive mechanisms and barriers set in place by authorities. Again re-quoting the earlier mentioned article:


The Financing of the 9/11 Plot

‘The existing mechanisms to prevent abuse of the financial system did not fail. They were never designed to detect or disrupt transactions of the type that financed 9/11’.

UNT Libraries / US Government Documents Dept. {1}

It is evident that the financial backers of a terrorist group like al Qaeda are not illiterate, misguided or brainwashed combatants that do not fully comprehend their actions. On the contrary it is clear these people are extremely wealthy, well-connected and quite sophisticated. It may be the case that these people not only have access to high-end art, but already have large private collections themselves. If so, then transport and sale is their only concern. Above that, many of these top Middle-Eastern buyers have diplomatic passports which means they and their luggage can pass any border without being searched or even x-rayed.

Without bias or prejudice, it is necessary to mention factual correlation between the regional/national background of 9/11 terrorists and the fact that Middle-Eastern collectors are becoming some of the biggest art buyers and investors in the world {16}. Qatar and UAE, for example, became massive international art hubs, with all the top auction houses, like Sotheby’s, Christie’s, and Bonham’s, being present there for years. Even the Guggenheim Museum is being built in Abu Dhabi! And while it is obvious that the majority of such organizations and buyers use art for lawful and culturally beneficial purposes, it is unavoidable that some of these items can be redirected towards very different goals, under the pretext of art and culture.

Osama Bin Laden came from one of the wealthiest families in Saudi Arabia. Almost every member of the Saudi Royal Family, as well as, Qatar and UAE for that matter, collects expensive art, in one form or another. Considering that the Saudi Royal Family consists of approximately 15,000 members, a number of whom are associated with extremists {15}, it is reasonable to conclude that such individuals may use art as a means to fund terrorism, especially when their bank accounts can be monitored – their art however, cannot!

This report is not intended to cause ethnic discrimination in the art market but rather show the reality of the situation to date and push authorities to regulate this market so all participants, regardless of their skin colour or religious believes can transact openly and freely.


Wiring, shipping, moving, storing



  1. Expansive art 80 per cent of the time does not look expensive at all.
  1. Cash always looks like cash.
  1. Art can be small and mobile:

The 1933 double eagle (United States 20-dollar gold coin) sold at auction for

$7.59 million USD.

Mass: 33.431 g

Diameter: 34.1 mm  (1.34252 in) Thickness 2.0 mm  (0.07874 in) {12}


  1.  Cash is big and hard to move:

7.5 Million USD in 100-dollar bills is roughly: 165 lb (75 kg) assorted in 23 packages that are 23.6 inches (60cm) high. {13}

‘Mexican military seizes $26m in cash’

16Photo: AFP/GETTY {14}

  1. Moving/Shipping Art is risk-free. Upon inspection or x-ray art looks like any other item, especially when located among similar items.
  1. Moving/Shipping cash poses high risk. If container/carrier is inspected or x-rayed cash will be detected.
  1. Art can be shipped from Auction house to Auction house or Gallery to Gallery without revealing owners’ and buyers’ names, addresses and bank accounts to authorities.
  1. Wiring cash electronically Bank to Bank poses high risk of detection, especially with modern tracking technology and post 9/11 regulations.
  1. Money gained from sale of art is automatically justified. Seller (terrorism financier) remains unexposed. One side risks exposure.
  1. Sender and receiver of wired cash require contractual justification and run the risk of exposing themselves. Two sides risk exposure.
  1. Storing art is virtually risk free. Art can be stored at any location (offices, luxury living quarters, with acquaintances, storage units …) without suspicion or incrimination.
  1. Storing large amounts of cash poses risk from authorities as well as other criminals. It requires warehouses, hidden locations and security.

There are many other cons and pros but these are the top six worth mentioning.


METRO NEWS | Canada | Monday, May 11, 2015

Putting it all together

This hypothetical scenario describes stage by stage unfolding of a possible terrorist act, from beginning to the end, involving art as its primary funding source. The main purpose of this simulation is to show how harmless works of art, as well as deregulated conditions of the market, can play a fundamental role in a very destructive event.

terrorist plan is set in action  – 3-year timeline
Stage 1 Terrorism financier, working through a line of representatives and brokers invests $5 million US in art. Purchases are done at various major auction houses in London, Amsterdam and Paris.
Stage 2 Buyer’s lawyer requests all items to be shipped to the auction’s offices in major US city, where they will be picked up. Taxes and shipping fees are paid.
Stage 3 All items arrive, are picked up by a legal representative, and disappear into a private collection. Future funding for arriving or home-grown terrorist groups is established and secured.
Stage 4 Suicide bombers start training in camps within Pakistan, Afghanistan and other known locations – or within the nation by other means.
Stage 5 Year passes. Terrorists are prepared. Purchased art is ready to be sold.
Stage 6 Terrorists arrive to a major US city through work, tourism, student and immigration visas (or as travelling citizens).
Stage 7 Art is submitted for sale at same auction houses. Reason for liquidation given by seller’s representative – owner has financial trouble and needs funding.
Stage 8 Three to six month later auctions are held – art is sold under value. From original $5 million US invested, after import taxes and shipping $3 million US is recovered. However this $3 million is in the United States, legally justified and tax free. No red flags go up. Funding is established.
Stage 9 Funding of and preparation for terrorist act on U.S. soil begins. Year passes.
Stage 10 Unless other intelligence agencies (FBI, CIA, INTERPOL …) prevent this from happening – this hypothetical terrorist act will be executed.


This entire scenario can be prevented purely by regulatory measures that demand transparency and accountability at points of purchase and sale. However what is needed is the complete overhaul of the entire art market, setting new laws, regulations, systems and departments. Interesting enough is that these actions will not only prevent terrorism, but will generate new income streams and create jobs in North America, Europe or wherever else such reforms are implemented.

That said, auction houses and galleries are not the only weak link in the above equation. In fact, as unregulated as these businesses are, they don’t even come close to the private art buyers and sellers. That’s because most reputable auctions and galleries don’t often pay someone in cash so there’s some level of accountability. In the realm of private collectors – cash is king! All want it, and often demand it, since it allows them to evade taxation and generate even higher profits. Needless to say that a lot of collectors, especially the wealthy ones, are very secretive by nature and thus want complete privacy, anonymity and to be untraceable. Again, this is also accepted as business as usual in the art world.

Back in the day, I personally have done art transactions where we were paid in hard cash for more than $200,000 US. We since stopped this practice and became advocates for transparency in the art world. However, such cash-for-art culture is normal between collectors, and when someone requests a hard-cash transaction, no eyebrows are raised – only smiles. Again, this is considered standard practice, even now in the modern digital world.

Many would argue that private art buyers need such a high degree of privacy and security because the art world is a dangerous place. We couldn’t agree more. In fact this is our spot-on case in point. The art world is a dangerous place with very dangerous people. There are bound to be terrorists among them, who are looking to exploit the fear of buyers, sellers and owners for their own benefit.



Virtually all objects of substantial value available to the public require proper government documentation and registration. A house, a car, a yacht or a plane, these are some of the most expensive investments people make in their lifetime. And yet a single art, antique or collectible can be more valuable than all of those things put together while having zero paperwork, zero registration and no accountability.

Expensive art, antiques and collectibles have to be treated no different than an automobile – with proper registration, documentation, appraisal and identity management, all from a specific government department. Most important of all, a government department must be designed to oversee all aspects of such movable cultural property from the moment these items are created, appear on the market, come up for sale, imported, transferred or sold. National and international art databases have to be created. Strong collaboration with other countries has to be established. If expensive art (items valued over $10,000 USD) starts to be managed as motor vehicles are, by a specific department – 90 per cent of the work would be done, and the art market would be that much safer!

All technologies, tools and methods necessary to effectively stop misuse of the art market by terrorist and criminal organizations – exist. Very little has to be developed from scratch. The majority of needed technologies and systems are already being implemented independently from one another by private and government organizations, some have been on the market for over a decade. Take a look:


Knowledge, Educational Materials, Classification Systems exist ✔
Sophisticated Technology, Databases and Operating Systems exist ✔
Art Tracking Technology exist ✔
Object Recognition Technology exist ✔
Universal Auditable & Transparent Appraisal Technology exist ✔
Identity Management Technology exist ✔
Authenticity Management Technology exist ✔
Technical Support exist ✔
Tools, Materials & Hardware exist ✔
Trained Professionals and Labour Force exist ✔


Now the time has come to tie them all together into one unified body. This is only possible if government officials, law enforcement agencies, border protection services and cultural departments take strong immediate action now, before it’s too late! The art market has to be regulated. Transparency has to be established. Market-specific rules and regulations have to be set in place. Law enforcement authorities and border protection officials need to understand and get better training in matters involving cultural property. Auctions, galleries, dealers and owners that are interested in a fair and stable art market need to step up, speak up and make a genuine effort towards collaboration between themselves and government bodies. Art, antiques and collectibles need to be recognized for what they truly are – a unique, valuable and highly liquid commodity that requires just as much legal attention as a gold bullion, stocks or cash. This is the only lasting solution that will effectively stop the finance of terrorism through art, antiques and collectibles. Art must be used to develop culture – not destroy it.

To guide the government and the art market in the right direction we would like to introduce everyone to what we call the ‘Three Pillars’ concept:


Pillar 1: Unified Legal Dictionary & Terminology. It requires that all art market regulators (police, border service agency, ministry of culture, the legislative branch, as well as all other organizations and experts) possess and use the same terminology, rules, regulations and laws. In short, it’s a dictionary that permits everyone to understand one another. Pillar 2: National (or Intl.) Movable Cultural Property Database – integrated with art classification and coding technology. Because art, antiques and collectibles are so diverse, with over 180 thematic groups and thousands of subdivisions – unified national and Intl.  databases with integrated classification and coding capabilities are essential for real security and regulation. Pillar 3: Math-based, Transparent and Auditable Appraisal Technology that can valuate any art, antique or collectible based on factual data known about the item. Such appraisals must comply with the international valuations standards, be easily understood and verified by any auditor or trained gov’t official. Without this pillar art crime will continue.


The three pillars are just the tip of the iceberg when it comes to the necessary tools, systems and technologies required to bring order to the international art market. So not to bore the reader with all the technical details, I would like to just say the following. The Tamoikin Art Fund has developed, tested and perfected all necessary methods, systems and technologies that are mentioned in this report, as well as those that are so innovative that we have not released them to the public just yet. In light of this, I can say with full responsibility that any national or international art market can be completely and effectively regulated, right now – starting today. We possess the tools and the know-how to make the global art trade safe for all participants and nearly free of all major crime. If government and law enforcement agencies do what we strongly recommend (urgently and effectively regulate the art market), terrorists and criminals will not be able to use art, antiques or collectibles to fund their operations. A major global security loophole will be closed and the public will be much safer.

Lastly, to take away any speculation of fearmongering for financial gain on our part – I state that we offer our services free of charge to any government that is interested in working with us to make their public safe.


In light of the above said, I propose the following challenge to any law enforcement agency. With the permission and supervision of the authorities, my team and I are willing to demonstrate how easy it is to move large amounts of funds (up to $5 million dollars and more, if necessary), from one country to another, via movable cultural property (art, antiques, collectibles) while completely bypassing all law enforcement, border protection, and legal agencies as well as safeguards intended to stop (or at the very least detect) this type of financial transaction.


In 2012 our team was contracted by Ukrainian police to analyze and appraise 2500 artefacts, 13kg of which were rare gold antiques. All items were part of a national criminal case #18-458/1. We completed the job, submitting 24 volumes of reports to the Central Investigation Department of the Ministry of Internal Affairs of Ukraine. Recently we learned that all records of this investigation were deleted, and many of these items mysteriously appeared in Central Europe. In accordance with Ukrainian laws, such artefacts are considered as national treasure and cannot be exported. One of these items was a gold helmet from the era of Alexander the Great, worth over $30 Million US. In 2012 we held it in our hands in Ukraine. In 2015 it was offered to us by a 3rd party from the EU…



In 2009 I sent a letter to the Government of Canada (Ministry of Culture & Heritage), in which I clearly stated my concerns that art could be used to fund terrorism. Please read their reply below.

In 2011, I sent this report to offices of RCMP, FBI, CIA and INTERPOL. In 2012 it was presented, via my associates, to law enforcement officials from Germany, Luxemburg, Lithuanian, Japan, Russia, Ukraine and Kazakhstan.

In 2013 I sent it directly to the President and General Secretary of the International Police Association (Canada).

To date there has been no response…

The public must be aware of this security threat and demand action from their government officials. If this issue is not dealt with soon, we are not only permitting this unnecessary risk but are actually putting people’s lives in danger!



‘The Terrorist in the Art Gallery’
But it’s getting worse: in a modern-day version of the old ‘molasses to rum to slaves’ triangle trade of pious New England ship captains, the cozy cabal of academics, dealers, and collectors who turn a blind eye to the illicit side of the trade is in effect supporting the terrorists killing our troops in Iraq.

‘Terrorists raise cash by selling antiquities’ 2006

Terrorist organizations may be financing their deadly activities partly by dealing in the illicit trade of art and antiquities which come out of the Middle East and wind up in the homes of collectors who pay top dollar for ancient artifacts, experts have told GSN.

‘Terrorist Financing Risks and the Illegal Trade in Cultural Property’ 2013

There is sufficient anecdotal evidence to conclude that the illegal trade in cultural property may constitute a source of funding for terrorist networks … .

The report [National Money Laundering and Terrorist Financing Risk Assessment] also identifies art and antique dealers and auction houses as businesses ‘that may be useful [to include] in building a list of the ML/TF vulnerabilities that can be exploited in regulated entities…’ .

‘Hillary Clinton announces program aimed at stamping out elephant poaching, ivory trade’ 2013

Clinton drew a direct link between terrorism and elephant poaching, citing growing evidence that terrorist groups in Africa are funding their activities in part by trafficking ivory. She said that includes al-Shabab, the group responsible for the recent attack at a shopping mall in Nairobi.

‘An Allied Effort to Save History’ 2014

Professor of Law, Georgetown University Mark Vlasic, former head of the Stolen Asset Recovery Initiative, noted: ‘Moreover after the post-9/11 crackdowns on terrorist financing, law enforcement has reported a marked increase in antiquities and other artworks being used to launder money (in fact, one agent told us that money laundering cases make up the bulk of their art investigations, not repatriations)’.

‘Money Laundering and the Trade in Cultural Property: Taking a Fresh Look at Federal AML/CTFs’ 2014

But anti-money laundering as well as counter-terrorism financing laws (AML/CTF) are often limited when it comes to the trade in cultural property. That is because the cultural property markets in art, antiquities, fossils, etc., are not explicitly covered under AML/CTFs … .

With respect to the art market, a 2012 Basel Institute on Governance report titled Basel Art Trade Guidelines, observes: In comparison with other trade sectors, the art market faces a higher risk of exposure to dubious trade practices. This is due to the volume of illegal or legally questionable transactions, which are noticeably higher in this sector than in other globally active markets. Far more serious than shady dealings in a legal grey area, the sector’s shadow economy encompasses issues ranging from looted art, professional counterfeiting and fake certificates to the use of art sales for the purpose of money laundering … .

Relics for rifles: Syrian rebels trade antique treasures for weapons (VIDEO) 2014

Not only is Syria’s future at stake as the civil war rages on, but now also its past. The black market flourishing in the conflict now sees relics – some as ancient as 1,200 years – traded by rebels for AK-47s … .

Mustafa says he looted Syria’s precious antiquities, some of which are several thousand years old, to trade them for money. He plans to use it to buy weapons and armoury to fight Syrian government forces … .

The rebel was planning to make nearly $3,000 – $6,000 out of the relics – enough to return to Syria with a couple of Kalashnikovs, or even a rocket-propelled grenade (RPG), an anti-tank weapon system … .

‘I receive every day four of five people from the Free Syrian Army and Al-Nusra Front to sell the relics to help the Free Syrian Army’, Abu Ghsein told RT.

His collection is now full of unique objects: gold, silver, bronze coins, stone – some of them dating back to the era of Phoenicia, an ancient Semitic civilization that lived 1,200-800 BC … .

Mooting the looting – Ft. George Richards, Senior Fellow at Iraq Heritage 2014

The trafficking of ancient artefacts looted from Iraq and Syria earns ISIS millions of dollars every month. And with such a significant economic incentive, the devastation of the world’s cultural heritage has become ubiquitous. Is looting the best hope for preserving antiquities in times of conflict, and how effective are international regulations at curbing the booming black markets? Oksana is joined by George Richards, ethnographer and Senior Fellow at Iraq Heritage, to sift through these issues.


 The frequency of such reports, and events that cause them, is increasing.

Do we really want to wait and see what the next few years will bring?

Or will we take action to stop this lawlessness once and for all?

The time has come to regulate the art market.

 – The End –

Dmitry TamoikinDmitry Tamoikin
President of the Tamoikin Art Fund
Founder of the Soviet Jewelry Project
Owner of the DMT Collection of Fine Art


  1. The Financing of the 9/11 Plot – UNT Libraries / US Government Documents Dept {1}
  2. {2}
  3. {3}
  4. {4}
  5.  {5}
  6. {6}
  7. {7}
  8.  {8}
  9. {9}
  10. {10}
  11. {11}
  13. {13}
  14. {14}
  15. {15}
  16. {16}
  17. {17}
  18. {18}


Further Sources:

  2. Los Angeles Times: Violating $10,000 Cash Limit Not a Crime, January 12, 1994| DAVID G. SAVAGE | TIMES STAFF WRITER
  13. Rethinking Money Laundering & Financing of Terrorism in International Law – ISNB 9789004207141 – Roberto Durrieu, Estudio Durrieu Abogado
  27. Museum of the Missing: A History of Art Theft Paperback, Simon Houpt, 2006, 192 pages, Black Walnut/Madison Press, 978-1897330449
  28. Border agency sees sharp rise in currency seizures – METRO NEWS | Canada | Monday, May 11, 2015

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