Financing terrorism: The billion-dollar blood antiquities art dealing

Palmyra isn’t the sole victim of ISIS. Syria’s six certified cultural heritage sites and three of Iraq’s cultural heritage sites have been subjected to the group’s bulldozers, hammers, and bombs in what is considered an unprecedented destruction in history. What is equally worrying is the massive amount of looted artifacts from those sites that have found their way into European art markets, both legitimate and illegal.

Known as “blood antiquities,” these artifacts are an important source of income for ISIS together with natural gas smuggling, ransom for hostages and abuse of charitable organizations.

Looting Artifacts, a Billion Dollar Business

The terrorist group has lost their final scrap of territory in Baghouz, Syria in March 2019 and has been reduced to a pocket in the Syrian desert, but ransacked artifacts are still appearing in European markets as well as other parts of the world. Despite the horrible videos of the destruction of Syria’s and Iraq’s cultural property, experts state that the temples and buildings are devastated before the camera to cover the evidence of what is being looted. In fact, ISIS had granted licenses for digging at the various historic sites as well as establishing a department of antiquities.



Europe is the biggest art market in the world with regards to sales made through dealers, private sales and auctions, with roughly $11.5 billion dollars of antiques and artworks being imported into its countries, naturally making it a desirable hub for ISIS.

EU’s Fight Against ISIS’ Pillaging

The European Commission, the European Parliament and Interpol have all taken important steps to counter the phenomenon through the creation of laws, directives, organizations, and task forces. Apart from the drafting of relevant policy frameworks, The European Union also works closely with international organizations including Interpol, the Council of European and the United Nations, and has supported UNESCO’s Action Plan for Syria, specifically concerning the trafficking of cultural goods.

The EU also included cultural goods crime as one of the EU’s priorities in the fight against organized crime for its 2022-2025 policy cycle of EMPACT (European Multidisciplinary Platform Against Criminal Threats) – a multidisciplinary and multiagency cooperation that fights organized crime at an EU level.


The most recent regulations, the 5th Anti-Money Laundering Directive and the EU Regulation on the Introduction and the Import of Cultural Goods, were created to disrupt the illegal trafficking of blood antiquities.

Art dealing and the 5th Anti-Money Laundering Directive

The 5th Anti-Money Laundering Directive (5AMLD) entered into force the 9th of July, 2018 and had to be implemented as national law by all member states by the 10th of January, 2020. It replaces the 4th Anti-Money Laundering Directive (4AMLD) and expands the Know Your Customer (KYC) requirements to include the art industry.

The new directive primarily requires art galleries and auction houses to:

• 1

  Verify the identity of any person purchasing a work of art of €10.000 euro or more, including linked transactions, and no matter the payment method. This prevents anonymous buyers from hiding their identity behind personal agents.

• 2

  Identify the source of client’s wealth as part of enhanced due diligence towards the buyer.



However, criticisms towards the new directive have already been displayed. Many art sellers believe that the amount of €10.000 euro is too low, hurting small businesses that may have trouble managing the extra steps needed to complete a purchase and burdening the dealers with too much administration. Enhanced due diligence will also compel art sellers to handle personal data of their clients, thus creating the need for policies and procedures to process such data as required under GDPR and increasing administrative tasks.

While not specifying cultural goods, stolen art of any epoch is included in the 7th of the 22 predicate offenses of the 6th Anti-Money Laundering Directive which concerns the illicit trafficking in stolen and other goods. A predicate offense is defined as a crime connected to a larger crime that generates monetary proceeds.



How Much Has Been Stolen by ISIS?

Around 40.635 artifacts are estimated to have been stolen from warehouses, places of worship, and museums in Syria since 2011. Items such as paintings, sculptures, Roman mosaics, statues, and Egyptian sarcophagi have appeared in international art markets over the years. Before reaching their destination, ISIS often ships the items through Turkey, Lebanon, or the United Arab Emirates to obscure their country of origin. At times they are held of years before selling them so to further complicate their tracing.











EU Regulation on the Introduction and the Import of Cultural Goods

Formally adopted on April 17, 2019 and entered into force June 27, 2019, the EU Regulation on the Introduction and the Import of Cultural Goods’ main objective is to preserve cultural heritage, prevent the loss of cultural goods and block the sale of looted artifacts to finance terrorism. Created to tackle the inconsistencies in laws between European countries regarding the importing of cultural heritage, particularly countries that had less stringent regulations which encouraged criminal activity, it establishes a uniform law applicable in all EU countries.

Here are a number of important points that the Regulation addresses:



• 1

  Cultural goods that are over 250 years old and that are elements or products of archaeological excavations or historical monuments will require an import license.

• 2

  Import licenses must be obtained from a “competent authority of the Member State in which the cultural goods are placed under one of the customs procedures” of the Regulation.

• 3

  All import information will be stored in an EU-wide electronic database set to go live by latest June 28, 2025.

• 4

  A new common definition is presented of what constitutes a cultural good covering a broad range of items having “great artistic, historical or archaeological value.”



Critics haven’t spared the new Regulation either. Many in the art trade and academia believe that the European legislators have misunderstood the issues at hand. Their main point of contention is a study ordered by the European Commission in 2017 called “Improving Knowledge on Illicit Trade in Cultural Goods in the EU” and published on July 12, 2019 – three months after the Regulation was first adopted. Many believe that the EU drafted the new law without the full knowledge of the findings of the study and the solutions it proposed.



On the 28th of December 2020, Article 3(1), which prohibits the importation of cultural goods removed from the territory of the country where they were created or discovered in breach of the laws and regulations of that country, will enter into force.




Online Market of Looted Artifacts

The EU legislations to disrupt the illegal market of cultural property are a step forward in the right direction but have little effect on the black markets that are present online.

Since the beginning of their reign of terror, ISIS has used social media to spread their propaganda and recruit criminals but have also utilized the likes of Facebook to sell their looted antiquities. Facebook groups created for the sole purpose of selling such artifacts were set up and maintained with ease for numerous years. Since the beginning of the Covid-19 pandemic, approximately 5 new Facebook groups were launched in the Middle East to traffic looted pieces with one group amassing 120.000 members in just one month.

Despite numerous attempts from authorities and institutions to urge Facebook to take serious action, the social media giant simply removed the groups throughout the years. It is only in June of this year that Facebook released a policy stating, “We now prohibit the exchange, sale or purchase of all historical artifacts on Facebook and Instagram.”


However, antiquities from heritage sites from Iraq and Syria have also been sold on anonymous black markets found on the Dark Web.

ISIS may have been reduced to a scrap but the high international demand for ancient artifacts and the relatively low risk of selling them compared to other illicit markets such as drugs or weapons will stretch the war against looted cultural property for more years to come.
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