Can you give us an introduction about yourself?

I’m honoured to be part of this interview and to share my journey in cultural heritage protection and the fight against the illicit trafficking of antiquities.  My background combines extensive experience in cultural heritage preservation with a strong focus on safeguarding archaeological sites and cultural assets in conflict zones.  Early in my career, I worked at the National Archaeological Museum of Aleppo and later at the Syrian Directorate-General for Antiquities and Museums (DGAM), where I engaged in efforts to protect heritage under various circumstances.

Over the years, I’ve collaborated with international organisations, including UNESCO, Europol, and the British Museum, as well as with law enforcement agencies on projects with the Italian Carabinieri TPC, and the Dutch National Police.  I also founded ArchaeologyIN, a social media network aimed at promoting cultural heritage awareness across ten countries.  This work remains close to my heart, particularly as we confront ongoing challenges to cultural heritage in the Middle East and North Africa region.

From Aleppo to Europe is quite a journey, can you tell us about that?

My journey into the world of cultural heritage protection began at the National Archaeological Museum of Aleppo.  I was fortunate to work at one of the region’s oldest and most prestigious institutions, which fuelled my passion for preserving Syria’s rich heritage.  My early days were filled with fieldwork, cataloguing artefacts, and collaborating with teams dedicated to archaeological research and preservation.  Later, I joined the Syrian Directorate-General for Antiquities and Museums in Damascus, where my knowledge and experience in project management and international cooperation increased.

With the outbreak of conflicts in the Middle East and North Africa region and in response to the emergence of new challenges, I launched ArchaeologyIN, a platform designed to raise public awareness about the importance of cultural heritage.  Over time, my work extended beyond Syria to encompass the broader MENA region.  My research and collaborations have focused on mitigating the risks to cultural assets in conflict zones, working with global institutions such as UNESCO and ARCA.  Each step of this journey has deepened my understanding of the complex network behind the illicit antiquities trade and strengthened my resolve to protect what remains.

How did you get involved with ARCA?

My connection with ARCA started through a shared passion for combatting art crime and protecting cultural heritage.  I first learned about ARCA’s work through its extensive publications and network of experts.  When I attended their postgraduate program as a Minerva scholar ten years ago, it became clear that this was more than an academic experience—it was a community of professionals committed to making a difference.  The program’s unique approach to blending practical case studies with cutting-edge research inspired me to stay involved.  I was later invited to join as a lecturer, an opportunity I gladly accepted.  Teaching at ARCA allows me to engage with dedicated professionals and students who share a passion for protecting cultural heritage and disrupting the networks that traffic antiquities.

Can you tell us about the purpose of the your course?

This summer, I’ll be teaching Unravelling the Hidden Market of Illicit Antiquities, a course that offers participants a deep dive into the international trafficking of antiquities. We’ll explore case studies from the past 50 to 60 years, focusing on how the trade has evolved.

The course is designed to be both informative and interactive. We’ll begin with a historical overview of the illicit trade, then move on to key players in the market, from prominent dealers to auction houses, museums, and galleries. We’ll uncover the intricate network behind this shadowy trade by examining the roles of source, transit, and market countries.  Our sessions will include practical discussions on the legal and ethical challenges of repatriation and the level of proof required to secure a successful claim.

Participants can expect a mix of lectures and interactive discussions, giving them the tools to better understand and confront this global issue.

Tell us life when you are in Amelia

Amelia is a hidden gem in the heart of Umbria, Italy.  Nestled atop a hill, this charming medieval town offers a serene escape from the hustle and bustle of modern life.  Narrow cobblestone streets wind through centuries-old buildings, leading to stunning views of the surrounding countryside.  Life in Amelia is peaceful yet vibrant, with a rich cultural history, making it the perfect setting for ARCA’s program.

For participants, Amelia becomes more than just a backdrop—it’s a place to immerse yourself in Italian culture, connect with fellow professionals, and reflect on the importance of preserving our shared heritage.

Can you tell us what makes ARCA's programmes special?

One of the most unique aspects of ARCA’s program is its emphasis on blending theoretical knowledge with real-world application.  Participants gain not only a deep understanding of the international art and antiquities crime landscape but also access to an extraordinary network of professionals.  This program creates an environment where scholars, law enforcement professionals, and cultural heritage experts from around the world come together to share insights and collaborate on solutions to some of the most pressing challenges in the field.

A highlight of the summer is The Amelia Conference – 2025, ARCA’s Annual Interdisciplinary Art Crime Conference, which will take place from June 20 to 22, 2025.  This conference is a rare opportunity for program participants to meet and engage with a wide range of experts in art crime and cultural heritage protection.  The conference offers participants the chance to learn from leading voices in the field, expand their professional networks, and gain practical insights that complement their studies.

By the time participants complete the program, they’re not only better equipped to address the complexities of art crime—they’re also part of a vibrant, global community dedicated to protecting cultural heritage.

If you could follow another professor's course, which one would it be? 

If I had the chance to take a course at ARCA, it would likely be “Discarded, Discovered, Collected: The Ethics of Antiquities Preservation and Publication” by Roberta Mazza.  This course offers invaluable insights into why are antiquities exchanged on the market and what drives price formation? It also covers grouond on what is special about antiquities with texts inscribed on them, and the sometimes vulnerable relationships between academics and actors in the art market who deal in this type of textual remains.

Do you have any advice for applicants and participants?

My advice for new participants is simple: embrace every opportunity this program offers.  Be curious, ask questions, and engage with the community.  The beauty of this program lies in its diversity—everyone brings a unique perspective to the table.

Also, take the time to explore Amelia and immerse yourself in its history and culture.  These experiences will enrich your understanding of cultural heritage in ways that go beyond the classroom.  Most importantly, remember that what you’re learning here has real-world implications. You’re joining a global effort to protect our shared history—an effort that is more important now than ever.

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