The painting will already be familiar to readers of the ARCA blog.  In July 2025, we wrote about Operation Altarpiece following the restitution to Spain of the 62 cultural objects recovered through a two-year investigation involving Spain’s Guardia Civil, Italy’s Carabinieri Command for the Protection of Cultural Heritage, the Spanish Ministry of Culture, and judicial cooperation facilitated through Eurojust.  The investigation began in June 2023 after information transmitted through Europol’s SIENA system alerted Spanish authorities to the seizure in Italy of a sixteenth-century carved, polychrome, and gilded wooden altarpiece depicting scenes from the Passion of Christ.  Spanish authorities had previously refused permission for that object to be exported, yet it subsequently appeared in Italy without its required authorisation.

Under Spanish law, cultural properties of this nature—i.e., artworks over 100 years old, included in the General Inventory of Movable Property of Historical Heritage, or valued above specific monetary thresholds (ranging from €15,000 for drawings, engravings, and photographs to €150,000 for paintings)—require a definitive or temporary export permit.  The seized altarpiece in question lacked any of these necessary authorisations.

As investigators followed the movement of the altarpiece, they discovered that the case extended considerably further.  More than 90 cultural objects had been transported out of Marbella using a non-specialised removal company.  They included Renaissance panel paintings, triptychs, sculpture, furniture, tapestries, ceramics, and works attributed to artists including Amedeo Modigliani, Auguste Rodin, and Pieter Brueghel the Younger.  Many of the objects were subsequently located by the Italian investigators at a villa in Lesa, on the shores of Lake Maggiore, belonging to the late controversial German garbage magnate, Günter Hans Ludwig Kiss, who, as a side note, was in the midts of coordinating a deal to sell his palace in Morocco to Jeffrey Epstein shortly before the paedophile was taken into custody.  Others illegally exported artworks owned by the now-deceased Kiss had been consigned to Italian galleries and sold onward in Genoa and Milan, while others had circulated farther afield, to third countries.

Among the works ARCA highlighted at the time of their recovery in Italy were two paintings that had been consigned for sale to Cambi Casa d'Aste for their Old Masters sale held at Castello Mackenzie in Genova (Italy) on 16 December 2021.  One was a sixteenth-century Antwerp School triptych depicting the Holy Family and angels.  The other was an early sixteenth-century Antwerp School panel catalogued by Cambi as Madonna con il Bambino e Sant’Anna.  Neither auction entry provided provenance information.

It is this latter painting that has now re-emerged publicly in a very different setting.  The latest information released by the Spanish authorities identifies the subject more fully as The Virgin and Child with Saint Anne and Saint Joseph. 

Spain's Ministry has distributed other recovered works among public institutions including the Museo de León, Museo de Málaga, Museo de Bellas Artes de Valencia, Museo Nacional de Escultura in Valladolid, Museo Reina Sofía, Museo Nacional de Antropología, and Museo Nacional de Artes Decorativas.

An especially revealing new detail has emerged concerning the paperwork accompanying this particular panel.  Guardia Civil commander Fernando Delgado stated during the presentation in A Coruña that investigators found, together with the painting, a document issued by the Spanish Ministry of Culture declaring the work inexportable.  According to Delgado, an earlier export request submitted through an auction house had been denied.  The discovery of the painting in Italy alongside documentation demonstrating that it could not legally leave Spain was one of the circumstances that alerted investigators to this smuggling offence.

That detail brings the central issue raised in ARCA’s original article sharply back into focus.  Export permits for protected cultural property are not bureaucratic formalities.  They are one of the mechanisms by which States determine whether historically significant objects may permanently leave national territory.  Where permission has expressly been denied, the subsequent appearance of the same object abroad should be an obvious warning sign to anyone handling it.

The outcome also reinforces the lesson at the centre of ARCA’s earlier coverage: due diligence needs to happen before an object changes hands, not after police discover that it should never have crossed the border in the first place. Asking where an artwork came from, whether it was legally exported, and whether documentation exists to support its movement is not an optional courtesy and the dealers who sold pieces of the Günter Kiss collection onward should already have been aware of these details.