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January 20, 2018

Hobby Lobby turns over more artifacts to federal prosecutors in New York

Image Credit:  US Dept of Justice
According to documents released by the US Federal authorities, officials affiliated with Hobby Lobby, the American craft-supply mega-chain, have relinquished another 245 ancient cylinder seals (in some articles it has been misquoted that the forfeiture included cuneiform tablets), originating from ancient Mesopotamia, to a storage facility within the Eastern District of New York on Wednesday, January 17, 2018. 

According to the letter signed by United States Attorney Richard Donoghue and Assistant U.S. Attorney Karin Orenstein, the forfeited items, from the zone of modern day Iraq 

“constitute merchandise that was introduced or attempted to be introduced into the United States contrary to law, and are therefore subject to seizure and forfeiture to the United States, in accordance with 19 U.S.C. § 1595a(c)(1)(A),”

This new forfeiture was done by way of an earlier settlement and decree of forfeiture between the the United States of America and Hobby Lobby Stores, Inc., dating to June 29, 2017 related to "The United States of America v. Approximately Four Hundred Fifty (450) Ancient Cuneiform Tablets; and Approximately Three Thousand (3,000) Ancient-Clay Bullae"

As noted in documents related to that civil forfeiture agreement, Hobby Lobby president, and evangelical benefactor, Steve Green, through his designated buyers, began building a substantial private collection of antiquities in anticipation of the opening the the Green-sponsored $800 million, eight-story Museum of the Bible,  which later opened this past November.

According to the Museum of the Bible website, the Green's purchased their first biblical object in November 2009.   Since that time, their private collection has grown to an accelerated rate to an estimated 40,000 objects which includes Dead Sea Scroll fragments, biblical papyri, rare biblical texts and manuscripts, cuneiform tablets, Torah scrolls, and rare printed Bibles.  

On one of the Green's authorised purchasing trips in July 2010 to the UAE, in which Green himself attended, Hobby Lobby negotiated the purchase of
"5,548 distinct artifacts: 1,500 cuneiform tablets, 500 cuneiform bricks, 3,000 clay bullae, 35 clay envelope seals, 13 extra-large cuneiform tablets and 500 stone cylinder seals." [page eight]
paying $1.6 million despite the lack of accompanying legitimate paperwork and the likely plundered origin of the artifacts.  The procured antiquities were then shipped to the purchaser in multiple shipments via Federal Express to Oklahoma City to various different destination addresses affiliated with Hobby Lobby and its subsidiaries.  

Five of these shipments, however, were intercepted in transit between January 3rd and January 5th 2011 and were found to have been falsely labeled as "Ceramic Tiles" or "Tiles (Sample)" [pages 13-14] misidentifying the contents of the packages so that the  artifacts instead appeared to be simply arts and crafts items.

As the importation of cultural property into the United States in violation of a foreign country’s patrimony law (in this case Iraq) violates the National Stolen Property Act, codified at Title 18, United States Code, Section 2314, et seq. the objects were seized by federal authorities and an investigation was initiated. 

As an outcome of that US Federal investigation, Hobby Lobby agreed to hand over 5,548 smuggled artifacts in July 2017 and the firm was heavily criticized by both academics and the general public for supporting the illicit trade through its unethical purchase of antiquities.



The June 2017 stipulation of settlement between Hobby Lobby and the United States stated that:
"in the event that any of the Artifacts not included in the Defendants in rem were to “come into [Hobby Lobby’s] physical custody or control, whether inside or outside of the United States, [then] Hobby Lobby will immediately notify the Office and arrange for such Artifacts to be delivered to a place to be designated by the [United States] at Hobby Lobby’s sole expense." [page eight]
Where are the remaining 1709 objects Hobby Lobby has agreed to hand over? 

In 2017, according to documentation filed with the US Federal Courts in July 2017, Hobby Lobby relinquished 3,594 clay bullae, cylinder seals, cuneiform tablets and other Near Eastern artifacts out of a total of over 5,500 documented in the same purchase. This weeks additional 2018 forfeiture of 245 cylinder seals brings the total number of artefacts relinquished to date by Hobby Lobby to only 3,839 objects.  

Equally important, when will the Museum of the Bible answer scholars who have been posing questions for several years about the provenance and authenticity of additional key objects which remain part of, or are on display at the newly opened Museum of the Bible.  

One of these, a Galations coptic papyrus fragment, was once on sale in 2012 via a dubious seller on eBay before being spotted at the Green’s Vatican exhibit Verbum Domini II in 2014.  Until now, despite numerous requests from University of Manchester scholar Roberta Mazza dating as far back as 2014,  the Museum of the Bible has declined all requests to clarify how and from whom this trafficked fragment and ca. 1,000 papyrus fragments and the other Egyptian objects in the collection were acquired.

By:  Lynda Albertson

For more on the collection practices of the Green family and its former associates please see these previous ARCA articles. 


July 8, 2017

Thou Shall Not Covet thy Neighbor's Cuneiform

Op/Ed By:  Lynda Albertson

As the US press and social media came alive in condemnation as a result of the Hobby Lobby smuggling case, I couldn't help but notice that while the hashtag #HobbyLobbyisISIS is noticeably attention-grabbing, (as well as probably inaccurate), the more important facet of the "is-that-object-looted" puzzle was still being overlooked. 

I asked myself, instead of simply rewording the press release announcement released by the government, why hadn't US news organizations dug deeper into the development of the Green Collection in ancient art.  Especially since everyone now seems hellbent, (excuse the pun) on crucifying the fundamentalist Christian collector or finding some way to tie Hobby Lobby to Da'esh.

This is a case that has been widely publicized since 2015, and it's not the only time the Greens or their large collection have come under scrutiny or been accused of acquiring objects through untrustworthy channels with illicit ties.  

In June 2014 Dr. David Trobisch, Director of Collections for the Museum of the Bible even attended ARCA’s annual art crime conference where he heard concerns made by Dr. Roberta Mazza, a papyrologist and ancient historian from the University of Manchester about the Green Collection's unprovenanced papyrus fragments.  Those fragments however were not mentioned in this current civil complaint. 

While this US civil forfeiture case underscores that illicit traffic in cultural objects contributes to the despoliation of a country's ancient heritage and causes irreparable loss to the world's heritage knowledge, why is it then that the public only wakes up and takes notice when ISIS ties are tangentially inferred?

Are trafficked Middle East artifacts only worthy of the world's indignation when they are looted to fund terrorism?  


As the general public responded to the press coverage over the last two days most of the grumbling I've come across was either ISIS-funding related or centered on whether or not the punishment fit the crime.   I use the word "crime" here loosely because no criminal charges were filed for the looting and theft of the 450 ancient cuneiform tablets and 3,000 ancient clay bullae which ultimately were the subject of this civil forfeiture.  

In civil cases, the object of the law is the redress of wrongs by compelling compensation or restitution.  As those following this case closely are painfully aware, civil law deals with the disputes between individuals, organizations, or between the two, in which compensation can be awarded to the victim.  Criminal law is the body of law that deals with crime and the legal punishment of criminal offenses.

A civil fine is not a criminal punishment.  

Civil case fines are primarily sought in federal investigations in order to compensate the state for harm done to it, rather than to punish a wrongful conduct, something many like myself would have liked to have seen happen given the Green's less than stellar record when it comes to vetting antiquities for inclusion in their collection.   In this case, Hobby Lobby only suffers so much harm as is necessary to make good the wrong they have done (to the state). 

Civil penalties, in this case a $3M fine, do not carry any jail time or other legal penalties.  This fact illustrates why no one from Hobby Lobby was criminally charged, despite the large number of objects seized and subsequently forfeited.

This may also explain the absence of any noticeable public remorse on Hobby Lobby's part for their role in this antiquities smuggling affair.  The lack of regret can also be seen in the unrepentant statement by Hobby Lobby President Steve Green, in his company's press release after the federal civil ruling was publicized. 


Was new to the world of acquiring these items?  Did not understand the correct way to document and ship these items?

Let's look at his statements more closely.  

While Hobby Lobby, may be "new" to the world of acquiring antiquities, the fact that it has purchased more than 40,000 objects since November 2009 does not in any way make it a neophyte collector of ancient art.  

In addition to the cuneiform tablets seized in this well publicized case, the Green Collection already had in its possession the third largest holding of cuneiform tablets in North America (over 10,000 pieces). This means Green and Hobby Lobby by proxy had ample prior opportunity to explore what could and should go on any customs declaration for objects that contain writing first developed by the ancient Sumerians of Mesopotamia between 3500-3000 BCE.  

In 2010, a year before the seized cuneiform tablets arrived in Memphis, the Greens had also already consulted with Dr. Patty Gerstenblith, a cultural heritage law expert with DePaul University 's College of Law, about import restrictions for ancient antiquities who is reported to have advised them about their need for deeper due diligence in their collecting.   Given Gerstenblith's impeccable familiarity with the cultural heritage law, it can be assumed that the Greens as collectors were not as ignorantly naive to the road they were embarking down as the firm's press statement this week seems to imply.

But setting aside the intricacies of import and customs documentation specifically related to ancient antiquities coming from Iraq, Hobby Lobby itself has some 32,000 employees, 750 stores in forty-seven states, and $4 billion in yearly revenue, much of it based on imported items. 

It's corporate headquarters include a 9.2 million-square-foot manufacturing, distribution, and office complex in Oklahoma City.  Its warehouse has an hourly employee base of 2500+ employees with 80+ members of management, headed by an Assistant Vice President of Warehouse Operations, who reports to the Senior Vice President of Distribution.

When importing merchandise from foreign countries Hobby Lobby is fully aware there are certain trade laws and regulations, and that U.S. Customs oversees the compliance of those laws. They even have an international department responsible for training and compliance to ensure the import process go smoothly, not to mention a manual outlining laws and regulations, valuation, assists, and country of origin requirements which can be downloaded here

So to imply to the public that Hobby Lobby "imprudently relied on dealers and shippers who, in hindsight, did not understand the correct way to document and ship these items" seems a bit unapologetic coming from an apologist.   

Especially given Green's business thrives on supply-chain distribution members in its shipping department who would have to have, given the large scale operation of receiving imported cargo from across the globe in support of Hobby Lobby's national operations, sufficient knowledge of what the legal requirements are for import.  If they didn't, they certainly knew who to ask. 

As I have mentioned in a previous post, the estimated 40,000+ objects in the Green Collection equates to acquiring 6,666 objects per year or collecting a whopping 18 new objects per day.  Compare that acquisition rate to the number of employees working on the Green's or the Museum of the Bible's payroll who are tasked with historic object provenance and one can easily surmise that an object's ethical collection history has never been either group's overriding priority.  

Emphasis instead has been on filling the Museum of the Bible, Washington DC's about-to-be-opened 430,000-square-foot, eight story massive red brick museum located over the Federal Center SW Metro station.  To put that into perspective, one NFL football field is 57,600 square feet.  The Museum of the Bible has seven and a half football fields of space it needs to fill. 

Given the scale of archaeological theft in biblical area source countries and the number of objects with questionable origins which have already been identified by various researchers following the Green Collection prior to this forfeiture, it's time for Hobby Lobby's founders to do more than just open their wallets, purchase, and if caught, pay civil fines and forfeit the objects in question.

Opening their wallets has been the crux of the problem, as the Green's appetite for unprovenanced antiquities, and the profits to be had from this appetite, have likely been a motivating factor for others to loot, thereby destroying whatever context the objects may have had.

It's time for the Greens to fulfill the promise previously made by their employee. 

In 2014 the director of Collections at the Museum of the Bible, David Trobisch, informed Dr. Roberta Mazza that the Green Collection was going towards full digitisation and open access.  This has yet to happen. 

They should also make every effort, before making any further acquisitions, to ensure that the objects they are purchasing have been legally obtained and been legally exported from their country of origin.  

If the Greens truly want to make amends, they should fill their future Museum of the Bible with acquisitions collected ethically, and make the details of their past purchases open to researchers and investigators so that they can start to set things right by restituting any objects previously purchased without sufficient moral and ethical consideration. 

Exodus 20:15 and 17 King James Version (KJV): 

“Thou shalt not steal." 

“Thou shalt not covet thy neighbour's house, thou shalt not covet thy neighbour's wife, nor his manservant, nor his maidservant, nor his ox, nor his ass, nor any thing that is thy neighbour’s.”

I think that includes cuneiform tablets, clay bullae, incantation bowls and papyrus fragments.

March 28, 2020

The Museum of The Bible's Chairman's letter leaves many unanswered questions


Issued on 26 March 2010 and uploaded quietly to the Museum of the Bible website here

Statement on Past Acquisitions Published: Mar 26, 2020 

Museum of the Bible’s Chairman of the Board, Steve Green, makes the following statement on past acquisitions: 

In 2009, when I began acquiring biblical manuscripts and artifacts for what would ultimately form the collection at Museum of the Bible, I knew little about the world of collecting. It is well known that I trusted the wrong people to guide me, and unwittingly dealt with unscrupulous dealers in those early years. One area where I fell short was not appreciating the importance of the provenance of the items I purchased. 

When I purchased items in those early years, dealers would make representations about an item’s provenance, which the consultants I employed would say was sufficient. As I came to understand taking a dealer at his or her word was not good enough, I cut ties with those consultants. When I engaged with new advisors, I acquired a better understanding of the importance of verifying provenance and we developed a rigorous acquisitions policy that would help avoid repeating those early mistakes. 

For the past several years, the many dedicated curators at Museum of the Bible have quietly and painstakingly researched the provenance of the many thousands of items in the collection. That work continues. 
While this research was proceeding, beginning in late 2017, we also engaged with officials in several countries, including Egypt and Iraq, to open a dialog regarding items that likely originated from those countries at some point, but for which there was insufficient reliable provenance information. Those discussions have been fruitful, and continue to this day. 

I long ago made the decision that when our research revealed another party had a better claim to an item, I would do the right thing and deliver such items to that party. We have already proactively made several such returns. 

Today, I am announcing that we have identified approximately 5,000 papyri fragments and 6,500 clay objects with insufficient provenance that we are working to deliver to officials in Egypt and Iraq respectively. As discussions with officials in Egypt and Iraq continued, we also engaged with officials in the U.S. government to determine the best way procedurally and logistically to make the deliveries, and are appreciative of their assistance. We are working to finalize the deliveries in the near future. We also hope to finalize agreements with organizations in Egypt and Iraq that will allow for us to provide technical assistance, and support the ongoing study and preservation of their important cultural property. 

These early mistakes resulted in Museum of the Bible receiving a great deal of criticism over the years. The criticism resulting from my mistakes was justified. My goal was always to protect, preserve, study, and share cultural property with the world. That goal has not changed, but after some early missteps, I made the decision many years ago that, moving forward, I would only acquire items with reliable, documented provenance. Furthermore, if I learn of other items in the collection for which another person or entity has a better claim, I will continue to do the right thing with those items. 

I understand established museums, universities, and other institutions have evolved over the years and developed sound protocols for dealing with cultural property with insufficient provenance. I intend to continue to learn from the collective efforts and wisdom of those institutions, and support every person and organization possessing such items to continue their research into the provenance of their items. 

Steve Green Chairman of the Board Museum of the Bible

Takeaways:

This letter and these restitutions do not adequately address the negligence of the museum's management or the indiscretions of its philanthropists.  Nor do statements like these erase the indelible blemish on the museum's founding history.

Green claims to have unwittingly dealt with unscrupulous dealers without appreciating the importance of the provenance of the items he purchased. Does he want us to believe that HAD he appreciated the importance of provenance he would have walked away from the many once-in-a-lifetime pieces dangled before him?

Green explains that the consultants he employed were overly trusting of dealers, which is why he made mistakes and why he "cut ties" with those consultants. Emphasis on the word cut ties.  Fired? Let go? Contract not renewed? Swept under the rug? Who and When? What does "cut ties" mean exactly?

When he relates only his own story of events, it seems more like he is trying to control the narrative than do anything to actually make amends.

If we look back in the history of this scandal, it took Green an exceedingly long time to "cut ties" and when he did, we didn't see a great deal of improvement in the museum's operational model, purchasing due diligence, or its transparency.

January 3-5, 2011 is when US Customs inspected Five Federal Express antiquities-filled packages shipped bearing air waybills:


  • No. 7286 2809 6729 from the UAE Dealer to the “[President] or [Executive Assistant]” at Hobby Lobby's Mardel’s address.
  • No. 7286 2809 6751 from the UAE Dealer to the “[President] or [Executive Assistant]” at Hobby Lobby’s principle address. 
  • No. 7286 2809 7162 from the UAE Dealer to the “[President] or [Executive Assistant]” at Hobby Lobby's Crafts, Etc!’s address. 
  • No. 7286 2809 7173 from the UAE Dealer to the “[President] or [Executive Assistant]” at Hobby Lobby's Mardel’s address. 
  • No. 7286 2809 7162 from the UAE Dealer to the “[President] or [Executive Assistant]” at Hobby Lobby's Crafts, Etc!’s address. 

But despite this embarrassing faux pas, by May 16, 2011 Hobby Lobby was still sticking to their guns that the plundered material was rightfully theirs.  To substantiate that claim, they had their attorney file an administrative petition with the CBP seeking the return of their seized property, which one can assume by all the lawyer fees that would have entailed, that at least on paper, Hobby Lobby still felt their claim to the ancient objects, was legit. 

As spring turned eventually to autumn, on September 7, 2011 Hobby Lobby was still defending its honor, submitting a supplemental petition to the CBP trying to satisfy the governments concerns about the payment methodology used in the purchase of the antiquities contained in these shipments.

The Supplemental Petition stated that the reason the payments for the order were made through “separate wire transfers was that various original owners were to be paid directly.” This explanation however proves inconsistent with the fact that Israeli Dealer #3’s provenance statement covered almost the entire order and Israeli Dealer #3 was not one of the payees. It was also inconsistent with representations made to Hobby Lobby about listing Israeli Dealer #3 in the purchase agreement “because the invoice is from [Israeli Dealer #3’s] family and the collection is the [Israeli Dealer #3] family collection.”

Two days after the Supplemental Petition on the problematic shipment, on September 9, 2011, still-consulting "Director" of the Green Collection, Scott Carroll, was out destroying mummy masks at Baylor University with washing up liquid.

Nine months after the problematic shipment, on October 15, 2011, still-consulting Carroll took the last flight out of Heathrow bound for Israel to retrieve still more "unknown, significant Hebrew biblical manuscripts", where upon arrival he poured over 1100+ scrolls spanning 700 years, and spent the day looking at someone's private collection of papyrus.



Such were the Green's buying power that on November 27, 2011, and despite an open investigation into their previous purchases, Carroll set off yet again on another international buying trip.  A voyage which would take him from West Africa, to Istanbul, and then on to London, where in addition to making purchases, he met with people in Oxford, in all probability, Dirk Obbink, regarding the Green Scholar Initiative.




Three and a half months later, on March 12, 2012, Carroll, still consulting for the MoTB, is quoted in the Toledo Blade saying:

“I tell the Greens that I trust them to know where to put a store, and they need to trust me to stock the shelves,”
Carroll goes on further to add:
“We’ve been extremely careful to vet everything acquired and are fully aware of the issues and problems,” declaring “I work closely with international and national agencies reporting suspicious items that come our way.” 

The Greens eventually cut ties with Carroll only in May 2012, yet the continued to put their trust in Dirk Obbink, whom they had purchased from since 2009.  Despite terminating their relationship with Carroll, by January 17, 2013 the Museum, had arranged to purchase four early gospel papyrus fragments from the Oxford-based scholar via a private sales agreement.  These turned out to be stolen from the EES Oxyrhynchus collection.  By November 2019, a total of 13 stolen fragments from the EES collection had been identified as having been purchased by the Museum of the Bible through various buying channels. 

Given all that, the fact that Green's press release statement yesterday, relays that they did not get around to speaking with the source countries of the looted material until 2017 is not surprising.  In an earlier Wall Street journal article, also by Crow, the Museum of the Bible's Vice Chairman of the board Robert E. Cooley indicated that the museum's board itself only learned about the government’s six-year smuggling investigation involving Hobby Lobby when the craft company was close to signing the settlement... so again, the year 2017.

Green purportedly did not tell the museum's board sooner because he considered it a Hobby Lobby matter which brings into question Green's statement yesterday about having "acquired a better understanding of the importance of verifying provenance... we developed a rigorous acquisitions policy that would help avoid repeating those early mistakes."

So this more vigorous acquisitions policy applies to the problems in Green's private collection or to the objects from that collection he donated onward to the Museum?

That said, it was around 2017 that the Museum's board hired cultural-heritage lawyer, Thomas Kline, to vet the pieces remaining in the museum’s collection.  One question which remains is whether or not they hired anyone else besides one busy lawyer, who does not have manuscript provenance experience.  If not, then that might explain why it took an additional three years for this next, and I suspect not last, round of at a snail's pace restitutions.

The final interesting statement is Green's letter is his hope that Egypt and Iraq will allow the Museum of the Bible to provide technical assistance, and support the ongoing study and preservation of their important cultural property.

Having (possibly) worn out their welcome with the EES, and having hooked their dreams on folks like Carroll, Obbink and company, Green now hopes that the very source nations their purchases robbed will see their better late than never restitutions and a single carefully-worded, reputation management letter from the Museum's principle donor as a sincere and real attempt at righting several wrongs.

For me it doesn't even start. 

It should not have taken this many years for Mr. Green to own up to his and his buyers indiscretions. He may have been blindsided by his consultants in the beginning, but throughout this process he has been the one to control the narrative.

If he truly wants to earn my trust, and really make meaningful amends, he could start by addressing the degrees of his own culpability, both for his actions (wantonly and  heedlessly purchasing objects without any due diligence consideration) and his inaction, (to get ahead of this, to his refusal to answer researchers questions about where and from and in what time frame he or his consultants purchased suspect material) from 2009 to present.

For now I remain skeptical and as unconvinced as my venting yesterday further explains.

Lynda Albertson

July 6, 2017

Civil Complaint requires forfeiture of thousands of cuneiform tablets and clay bullae, but is that enough?

Cuneiform Tablet - Image Credit U.S. Attorney's Office for the Eastern District of New York
By: Lynda Albertson


At the heart of the investigation, were import irregularities related to ancient artifacts shipped to Hobby Lobby, Mardel, Inc. and Crafts, Etc! The firms Mardel, Inc. and Crafts, Etc! were affiliates of Hobby Lobby and both maintained their principal corporate offices adjacent to Hobby Lobby’s headquarters in Oklahoma City.  

The antiquities were shipped to Hobby Lobby and their associates by dealers in Israel and the United Arab Emirates (“UAE”), all of whom have been left unnamed in the civil complaint.  The objects were shipped without required customs entry documentation being filed with the U.S. Customs and Border Protection (CBP) and bore shipping labels that falsely and misleadingly described their contents and their value, in some cases as “ceramic tiles” or “clay tiles (sample).” In truth, the mislabeled objects were ancient clay and stone artifacts that originate from the area of modern day Iraq, which had been smuggled into the United States after their contracted purchase in the Middle East. 

Hobby Lobby's growing Green Collection is purported to be the largest private collection of rare biblical texts and artifacts worldwide and is estimated to be made up of more than 40,000 biblical-related antiquities, purchased and assembled by the Green family, who are founders of the national arts and crafts chain.  The bulk of this collection is intended to be displayed in their 430,000-square-foot Museum of the Bible, which is scheduled to open in Washington DC in November of 2017.

As is often the case with illicit antiquities smuggled around the globe, the intercepted packages, destined eventually to join the museum's collection, had their shipping labels intentionally mislabeled, stating the country of origin as imports from Turkey and Israel, not Iraq.  The shippers also used multiple shipping addresses for objects destined for a single recipient.  This too is a technique used by smugglers of all types, not just illicit antiquities, as it is a means of avoiding scrutiny by customs authorities. 

In the DOJ press release Bridget M. Rohde, Acting United States Attorney for the Eastern District of New York, and Karin Orenstein, Assistant United States Attorney, of counsel, announced that Hobby Lobby Stores has agreed to pay a $3 million federal fine and forfeit thousands of ancient Iraqi artifacts believed to have been smuggled in 15 shipments, 5 of which were stopped by the CBP on their way to the Greens.   

Hobby Lobby had executed an agreement to purchase the objects, despite their likely illicit origins, in 2010 for $1.6 million.  They paid for the antiquities via wire payments to seven personal bank accounts held in the names of five individuals.  This despite noticeable suspicious irregularities in the objects purported provenance and no direct contact with the objects' "owner.  The civil complaint also outlines conversations related to the purchase and import which indicate intentional changes to invoices and shipment to disguise the objects' value, and in some cases to change to purported seller. 

As DOJ documents state Title 19, United States Code, Section 1595a(c)(1)(A) provides that “merchandise which is introduced or attempted to be introduced into the United States contrary to law . . . shall be seized and forfeited if it . . . is stolen, smuggled, or clandestinely imported or introduced.”

Legal measures specific to Iraq also make it a violation of U.S. law to import any cultural objects removed from Iraq since August 1990, unless exported with the permission of Iraqi authorities.  Illegally importing objects that meet this criteria are subject to criminal penalties and fines.

Equally important Under Article 3 of Iraq’s Antiquities Law No. 59 of 1936 (as amended in 1974 and 1975), all antiquities found in Iraq, whether movable or
immovable, on or under the ground, are considered property of the state. Under Article 16 of Antiquities Law No. 59, private persons generally cannot possess antiquities. Article 26 of the same antiquities law prohibits the export of Iraqi antiquities and defines “antiquities” as movable possessions which were made, produced, sculpted, written or drawn by man and which are at least 200 years old.  Southern Mesopotamian objects definitely fall into this category as any collections management expert in Near East antiquity would be aware of.


Is a $3 million fine and the forfeiture of 450 ancient cuneiform tablets and 3,000 ancient clay bullae enough?

As a result of this investigation, Hobby Lobby has agreed to adopt internal policies and procedures governing its importation and purchase of cultural property, provide appropriate training to its personnel, hire qualified outside customs counsel and customs brokers, and submit quarterly reports to the government on any cultural property acquisitions for the next eighteen months.


So much for remorse. 

NB: No one has faced criminal prosecution (read: jail time) for their actions. 

October 27, 2015

America’s Museum of the Bible - Hobby Lobby Owners Under Federal Investigation for Possibly Trafficked Assyrian and Babylonian Cuneiform Tablets

For years various academics have questioned the collecting and conservation practices of billionaire collector Steve Green, the philanthropist behind the $800 million, eight-story Museum of the Bible.  Slated to open in 2017, the museum will occupy a historically protected warehouse built in 1923 just minutes away from the National Mall and the US Capitol in Washington DC.  But Green's collection raises more questions than it answers.

Where are the thousands of antiquities coming from that have been purchased to supply this expansive museum?   And as a private museum, has the largest evangelical benefactor in the world cut corners in formulating his museum's acquisition policy, forgoing the standards propounded by museum associations and those dictated by international treaties?

Most of the general public are more familiar with the Green family via their landmark case against the US government objecting to the Patient Protection and Affordable Care Act which required that corporations above a certain size provide medical insurance benefits to their employees, including coverage for certain contraceptive methods.  In approving an exemption as a result of the case, Burwell v. Hobby Lobby, 573 U.S. (2014), the US Supreme Court decided in Hobby Lobby's favour stating that the Affordable Care Act's mandate requiring that for-profit corporations supply their employees with access to contraceptives at no cost to the insured employee could be opted out of by commercial enterprise owners who are opposed to contraceptive coverage based upon their religious beliefs.

GC.MS.000462, a papyrus fragment sold
on eBay in 2012 which has a text from
Galatians 2:2-4, 5-6 in the New Testament
But the Green's success in rulings over contraception has now been overshadowed by a federal investigation into the museum's collection practices regarding antiquities from ancient Assyria and Babylonia, what is now Iraq.

According to the Museum of the Bible website, the Green's purchased their first biblical object in November 2009.   Since that time, their collection has grown to an estimated 40,000 objects including Dead Sea Scroll fragments, biblical papyri, rare biblical texts and manuscripts, cuneiform tablets, Torah scrolls, and rare printed Bibles.   That's 6,666 objects per year or a whopping 18 objects purchased per day. Compare that to the number of employees currently working for the Greens in relation to their new museum and one can surmise that an object's collection history has not been a principle concern among the staff or consultants vetting historic items for inclusion in the museum's collection.

In April of 2014 Italian papyrologist Roberta Mazza, a lecturer in Classics and Ancient History at University of Manchester, pointed out her concerns surrounding a papyri fragment in the Green's collection. Mazza identified a small papyrus codex page containing lines from Galatians 2 in Sahidic Coptic during a visit to the exhibition, Verbum Domini II, organized by the Green Collection in Vatican City, Rome.  As might be expected, the fragment had a less than stellar collection history.

Belonging to the Green Collection, the fragment was first identified back in October 2012 by Dr. Bryce C. Jones, then a PhD student at Concordia University's Department of Religion.  The Galatians 2 papyrus had previously been listed for sale on the online auction site eBay that same year through an irreputable dealer using the name “mixantik”.  “Mixantik”, who also has used the names "ebuyerrrrr" and "Yasasgroup", is/was an Istanbul-based trader with a seemingly inexhaustible supply of ancient Coptic and Greek papyrus fragments from Egypt, all with little or no provenance.  This seller was also someone whom academics like Dr. Dorothy King and archaeologist Paul Barford had openly reported for trading contrary to Turkish and International law.

Concerned about the provenance of this piece of papyrus as well as other Green Collection practices, Roberta Mazza asked David Trobisch, the current director of the Museum of the Bible, both publicly and privately for more information on the acquisition circumstances of two specific pieces in the family's collection, GC.MS.000462 (Galatians 2) and P. GC. inv. 105 (the Sappho fragments). 

From the Green's employee she learned that the Galatians 2 Coptic fragment was purchased in 2013 by Steve Green from someone referred to as "a trusted dealer".   Records in the Museum of the Bible/Green Collection archives attest that the papyrus was part of the David M. Robinson collection which was sold at a Christie’s auction in London in November 2011.   

The fact that the auction sale records give no mention of the eBay seller, and conveniently does not contain a photographic record or detailed description of what the 59 packets of papyri fragments contain is suspect to say the least.  This lack of detailed documentation on auction sales involving antiquities makes it difficult to ascertain if any given object's origin is either licit or illicit.  This easy loophole leaves the door open for both buyers and sellers to slide suspect objects into the stream of international commerce undetected.  In a nutshell this method may be used to effectively launders smuggled cultural contraband and give an illegitimate object a plausibly legitimate collection history. 

Speeding forward to today, The Daily Beast has reported that the Greens have been under federal investigation for the illicit importation of cultural heritage from Iraq over import irregularities related to 200 to 300 clay cuneiform tablets seized by U.S. Customs agents in Memphis on their way to Oklahoma City from Israel.  The jointly-written article was written by Biblical scholars Joel Baden, professor of Hebrew Bible at Yale University and Candida Moss, professor of New Testament and early Christianity at the University of Notre Dame.

Cary Summers, president of the Museum of the Bible, spoke with Daily Beast reporters exclusively on Monday and stated that a federal investigation was ongoing and that “There was a shipment and it had improper paperwork—incomplete paperwork that was attached to it.” 

In 2008, the U.S. imposed an emergency import restriction on any archaeological and ethnological materials defined as "cultural property of Iraq. This import restriction was imposed to protect items of archaeological, historical, cultural, rare scientific or religious importance at risk of trafficking as the result of unrest in the country.  This import restriction continues additional restrictions already in effect continuously since August 6, 1990.

The selling of ancient Iraqi artifacts is absolutely prohibited under UN resolution 1483 from 2003, as you may find in paragraph 7 of the link here. 

A source familiar with the Hobby Lobby investigation told reporters at the Daily Beast that the cuneiform tablets were described as samples of “hand-crafted clay tiles” on their FedEx shipping label and were valued at under $300.   If true, this seems less like an simple oversight on the part of the shipper and more like direct falsification, not just of these objects' value but of their historic significance and origin as its doubtful that cuneiform tablets will be showing up in the Wall Decor section of Hobby Lobby anytime soon. 

American imports of art, collections and collectors' pieces, and antiques from Egypt, Iraq, Lebanon, and Syria increased sharply between 2011 and 2013. Is a pattern developing?  Is this how heritage artifacts from source countries plagued by conflict are being folded into legitimate museum and private collections?

David Trobisch has stated that the Green Collection has one of the largest cuneiform tablet collections in the country.

In selecting antiquities, individual collectors and museums have choices. They can choose to focus exclusively on the historic, aesthetic and economic benefits of their acquisitions in formulating their collections or they can add ethical and moral criteria to their purchase considerations and not purchase conflict or blood antiquities.

By Lynda Albertson 

Excerpt from ICOM Code of Ethics for Museums
©2013


March 26, 2024

Judgment entered in favor of Plaintiff (Hobby Lobby Stores, Inc). against Defendant (Dirk D. Obbink)


In early June 2021 Hobby Lobby Inc, owned by craft store mogul, David Green,  filed a Civil Complaint for fraud against former professor Dirk Obbink.  According to Civil Docket No. 21-CV-3113, the craft conglomerate alleged that as many as 32 items that it had purchased between 2010 and 2013 from the Oxford professor, to be featured in the Museum of the Bible (MOTB), were not his to sell.  

Instead, the papyrus fragments the scholar sold them via Private Sale agreements had been stolen from Egyptian Exploration Society's collection.  The textual artefacts  were identified as having come from the Grenfell and Hunt excavations in the late nineteenth and early twentieth centuries at the site of Oxyrhynchus and were removed from the EES collection while Obbink still had access to the Sackler Library of the University of Oxford.

During the period of Obbink's commercial relationship with the MOTB philanthropists he served as the General Editor of the Oxyrhynchus Papyri for the EES (until August 2016).  He was also a renowned Lecturer in Papyrology and Greek Literature in the Faculty of Classics at Oxford.  That position ended in a fall from grace in February 2021 just as his life as a part time dealer began to unravel.  

The seven Hobby Lobby-purchase transactions were itemised as:

    Purchase #1 - February 6, 2010: Papyri fragments for $80,000 
    Purchase #2 - February 15, 2011: Papyri fragments and other antiquities for                $500,000
    Purchase #3 - July 22, 2010: Papyri fragments and other antiquities for $350,000 
    Purchase #4 - November 20, 2010: Papyri fragments and other antiquities for            $2,400,000
    Purchase #5 - July 20, 2011: Papyri fragments and other antiquities for                       $1,345,500 
    Purchase #6 - March 7, 2012: Papyri fragments and other antiquities for $609,600
    Purchase #7 - February 5, 2013: Papyri fragments and other antiquities for                 $1,810,000

Obbink had represented to Hobby Lobby that the 32 items he was selling all came from private collectors. 

In September 2023 Hobby Lobby asked the Magistrate Judge, overseeing the case at the US District Court for the Eastern District of New York to grant their request to transfer their fraud and breach of contract case to the US District Court for the Western District of Oklahoma, where the company is headquartered. On October 5, 2023, their request was granted and on October 17th an amended complaint against Obbink was filed with the court in Oklahoma City which was served on the scholar on 4 November 2023. 

Throughout the proceedings, Obbink has failed to appear, plead, or otherwise respond to the unfolding US-based court case, and on January 29, 2024 Hobby Lobby filed a motion seeking a Clerk's Entry of Default.  As a result, on March 11, 2024 Senior Judge of the United States District Court for the Western District of Oklahoma, David L. Russell entered a motion for Default Judgment in favour of Hobby Lobby Stores, Inc., awarding them the eye popping sum of $7,085,100.00, with prejudgment interest from February 5, 2013, at the rate of 6% per annum. 

Yet despite this scandal of Biblical proportions, Dirk Obbink was last seen on his houseboat, self-destructively ignoring the US and UK legal drama swirling around him. 

To recap the last eight years. 

In the Spring 2016 the Egyptian Exploration Society realised that the much rumoured "First Century Mark" papyrus that had been the subject of so much speculation was in fact their own papyrus fragment (P.Oxy. 5345).

By August 2016 the EES decided to not re-appoint Obbink as the General Editor of the Oxyrhynchus Papyri primarily because of unsatisfactory discharge of his editorial duties, but also because of concerns, which he did not allay, about his "alleged involvement" in the marketing of ancient texts, especially the controversial Sappho and Gospel of Mark fragments.  

By December 2017, according to court documents, Obbink had admitted to Hobby Lobby that he had “mistakenly” sold the Gospel Fragments in Purchase #7 (for  $1,810,000) and that they were, in fact, owned by his employer, the Egyptian Exploration Society.

By January 2018 the Museum of the Bible formally severed ties with the Oxford-based scholar. 


On 16 April 2019 Obbink's UK-based antiquities sale's enterprise, Castle Folio Limited was dissolved.

By June 2019 the Egyptian Exploration Society took a harder stance against their former colleague and banned Obbink from any access to its collection pending his satisfactory clarification of the 2013 contract. 

On 2 March 2020 Obbink was "detained" briefly by officers from Thames Valley police on suspicion of theft and fraud. Unnamed at the time by the British authorities, he was released after questioning. 

By February 2021 Obbink no longer held his position as Lecturer in Papyrology and Greek Literature in the Faculty of Classics at Oxford University and had retreated to his houseboat where he was served in relation to the US court case. 

Yet, to date, and despite the ongoing investigation by the Thames Valley Police, Dirk Obbink has inexplicably still not been charged with any crime in the United Kingdom.


By:  Lynda Albertson

March 27, 2020

Steve Green to return another 11,500 antiquities to the Iraqi and Egyptian governments, but let's not forget the past.


Journalist Kelly Crow, in a Wall Street Journal exclusive, reports that Hobby Lobby magnate Steve Green has agreed to return an additional 11,500 antiquities to the Iraqi and Egyptian governments.  Consisting mostly of papyrus fragments and ancient clay objects, the collection pieces, originally destined for the philanthropist's museum project, are being relinquished to their source country because they all lack ownership histories.  

No a big surprise there.  It is something academics have been worriedly asking the collector and his museum about for years.

Seemingly apologetic, the billionaire behind the $800 million, eight-story Museum of the Bible, told the Wall Street Journal “One area where I fell short was not appreciating the importance of the provenance of the items I purchased,” adding when he started collecting biblical-era antiquities in 2009 he  “knew little about the world of collecting.”

I'd like to remind ARCA's readership that by the time we published our first article on Green's buying antiquities like hotcakes, in October 2015, the Hobby Lobby craft store giant had already purchased an estimated 40,000 objects for their collection, in just six years.  These included Dead Sea Scroll fragments, biblical papyri, rare biblical texts and manuscripts, cuneiform tablets, Torah scrolls, and rare printed Bibles.  

That's 6,666 objects per year or a whopping 18 objects purchased per day. 

Looking at that from a transactional basis, I would say that Mr. Green's excuse of knowing little about the world of collecting rings a bit hollow.  Green's purchasing power, and avarice, meant his collective team knew a lil more than the average joe when it comes to the world of ancient art dealers and collectors. It is not like they made one or two wrong newbie purchases.  

According to US law enforcement documents, by 2010, just one year after he had started collecting, Green, himself made a trip to the United Arab Emirates to eyeball some 5,548 artefacts reportedly worth millions. This same law enforcement complaint states that the objects “were displayed informally...” “spread on the floor, arranged in layers on a coffee table, and packed loosely in cardboard boxes, in many instances with little or no protective material between them.” 


For a man known to watch his financial line to the level Green does within his craft store empire, for me it is inconceivable to believe that an individual of this billionaire's stature would fork out millions, buying ancient objects without at least a tacit knowledge that he might need to ask questions of the dealers and suppliers he was buying material from. 

For years now I have been saying that if the Greens truly want to make amends, they should fill their future Museum of the Bible with acquisitions collected ethically. In addition they should also make the details of their past purchases open and searchable to external researchers and investigators not just relinquishing batches of suspect objects purchased without sufficient moral and ethical consideration. 

During the first handover of antiquities Green said “We should have exercised more oversight and carefully questioned how the acquisitions were handled.”  Unfortunately it took him another five whole years to muster up the gumption to admit that these additional 11,500 objects were also likely purchased in the same haphazard manner as the ones relinquished earlier.  

I don't know about most folks but if I had the capability of writing million checks dollar checks, and had already once had my feet held to the fire for purchasing antiquities that didn't pass muster, I think that I would likely remember all the other occasions when I wrote eye-popping checks for astronomical sums for equally suspect, not fully-thought out, purchases from individuals who were not completely transparent about where their merchandise was coming from. 

Why it took Green five years to do the right thing on this other set of objects is therefore not to be applauded.  The people in Egypt and Iraq who loot to feed the collecting appetites of Westerners spend years in jail when caught.  But big dollar collectors like Steve Green, who incentivise that very plunder, seem to think that showing remorse in a financial journal or a Hobby Lobby press release should suffice.   

For me it isn't.

Put your collection on line Mr. Green.

Then I will truly believe that you are sincerely sorry for what you have done.  Help researchers, who can connect dodgy dealers put a dent in the illicit supply chain.   Just giving back boxes and boxes of pretty baubles to the countries your dollar has plundered doesn't undo the damage you have done.   

Op/Ed: Lynda Albertson

May 19, 2020

Prosecutors file a civil forfeiture complaint for the Gilgamesh Dream Tablet which they say was looted from Iraq.

The Gilgamesh dream tablet, Iraq, c. 1600 BCE
while on display at Museum of the Bible

“Strange things have been spoken, why does your heart speak strangely? The dream was marvelous but the terror was great; we must treasure the dream whatever the terror.”  ― The Epic of Gilgamesh, N.K. Sanders translation. 
Authorities in the United States have filed a civil forfeiture complaint for a 1600 BCE cuneiform tablet featuring a dream sequence from the Epic of Gilgamesh. Acting as the Plaintiff in the case, the US authorities brought an action in rem for the tablet pursuant to 19 U.S.C. § 1595a(c)(1)(A).  Under this section, US law authorizes the forfeiture of any "merchandise" that is "introduced or attempted to be introduced into the United States contrary to law." In this case, that's when it is believed that the property was stolen in a foreign country and imported into the United States illegally.  

In the complaint, Special Agent John Paul Labbat with the United States Department of Homeland Security, Homeland Security Investigations, cited that the object was stolen Iraqi property introduced into the United States contrary to 18 U.S.C. § 2314, the stolen property act.  This act serves as an independent basis for the forfeiture of any stolen property that moves in interstate or foreign commerce and which is utilized whether the object in question was stolen overseas or inside the United States.

The ancient clay object, originally part of a larger six-column tablet, contains seventy-four lines of Middle Babylonian cuneiform text, and is known to be one of only thirty known surviving fragments from the Epic of Gilgamesh created during the old and middle Babylonian periods.  Written almost 4,000 years ago, the Epic of Gilgamesh is one of the oldest known literary works in the world. The earliest parts of the poem were first discovered in the ruins of the library of the Assyrian King Ashurbanipal, in Nineveh, Iraq in 1853. 

Based upon the facts as set out in the Verified Complaint in Rem, on July 30, 2014, Hobby Lobby wired $1,674,000 to an unnamed auction house as payment for the Gilgamesh Dream Tablet, having purchased the artifact for donation or display at the Museum of the Bible in Washington DC.  This was the same year that the company's fundamentalist president, Steve Green, persuaded the United States Supreme Court that it deserved a religious exemption from a federal requirement under which employers in the country are made to provide their workers with access to contraceptives.  It is also the same month that the Egyptian Exploration Society gave Dirk Obbink an ultimatum: cut ties with the Green family or lose his editorship of the Oxyrhynchus Papyri, several fragments of which are now part of a separate ongoing investigation into another illegal sale in the United Kingdom.

Three months earlier, in April 2014 Manchester-based papyrologist Roberta Mazza had already published a blog post after visiting the Green's exhibition Verbum Domini II in Rome, Italy.  There, Professor Mazza recognized that another ill-advised Green purchase, a papyrus fragment of the Coptic codex of Galatians 2:2-4, 5-6, was one which had earlier been identified by Brice Jones and Dorothy L. King as having passed through the hands of a middleman trafficker on eBay, a gentleman going by the pseudonym Ebuyerrrrr, Yasasgroup, and later Mixantik.  As the investigations into the Green's buying habits progressed, Mazza, would be integral in determining that the Turkish middleman was Yakup EkÅŸioÄŸlu, a name kept discreetly amongst researchers while investigations were undergoing.

Not long after the payment for the Gilgamesh Dream Tablet was finalized, the firm affiliated with the sale shipped the Gilgamesh Dream Tablet to their New York branch and then arranged for one of their representatives to hand-carry the tablet to Hobby Lobby in Oklahoma City, in order to avoid incurring a New York sales tax. The cuneiform tablet was subsequently transferred to the Museum of the Bible in Washington DC, where it drew concerns with one of the Museum's curators, in the lead up to the museum's grand opening. This unnamed curator queried the parties involved in the object's history post-sale, looking for evidence that would establish the artifact's legitimacy; an act of due diligence that should have been done by the prospective buyer before the tablet was purchased, and not after.  Those involved were anything but helpful.

This likely explains one of the reasons why the cuneiform tablet, once on display on the 4th floor of the DC museum in the History of the Bibles Galleries, was displayed with no provenance information whatsoever.

On 24 September 2019, the Gilgamesh Dream Tablet was seized as part of this civil investigation.  As the complaint released demonstrates, the importance of export documentation, for potential owners and dealers, or the lack thereof is a useful tool for researchers, law enforcement, and customs agents who monitor and prevent the trafficking of cultural property, none of which was remotely in keeping with this particular object.

But where was the Dream Tablet before? 

As background to the case, the US document cites that the tablet was first seen by an unnamed antiquities dealer in 2001 on the floor of a London apartment belonging to antiquities dealer Ghassan Rihani originally from Irbid in northern Jordan.

Prior to Rihani's death as well as after, a substantial portion of his "collection" of Iraqi objects began appearing on the London ancient art market. Many were believed to have been illicitly exported out of Iraq during the Gulf War following the 2003 invasion of Iraq and then recycled as being part of the not well documented Rihani family collection, something his son has denied in an interview with the New York Times.

By March/April 2003 the same dealer returned to London with a cuneiform expert and again viewed the tablet, this time with members of Rihani's family.  It is at this visit, where the dealer agreed to purchase the cuneiform table along with other items for a total of $50,530.  These items were subsequently mailed back to the United States and sold onward to two other dealers in ancient art for $50,000 along with a preliminary translation of the inscription.

By March 2007, false provenance documents had been created which omitted any mention of Rihani or the United Kingdom transaction.  Instead, the would-be provenance documentation proclaimed that the tablet had been purchased at a 1981 Butterfield & Butterfield auction in San Francisco, listed as LOT 1503.  All of which was blatantly untrue, as was the claim that the tablet had been deaccessioned from a small museum.

The cuneiform table would eventually make its way into the hands of Michael Sharpe, who published the object in his Rare & Antiquated Books catalog, where the object's constructed pedigree took a back seat to it's highlighted importance.



Like many cases before it, the multiple transactions surrounding the sales of the stolen Gilgamesh Dream Tablet reflects the inadequacy of the due diligence performed by intermediary dealers, the auction house, and the Green family themselves.  A simple check of the Butterfield & Butterfield auction records would have noted that LOT 1503 does not match the description of a terracotta cuneiform tablet from Iraq.  That alone should have given someone reason to pause.

At best, all of these dealers' behavior, the auction house's behavior and the collector's continued nonchalant attitude towards the object agreed to he purchase should be characterized as negligent. At worst, it shows the complicity of market actors, including those anonymously helping law enforcement post-facto, in prioritizing profits and plausible deniability as a masquerade for stewardship and collecting ethics.

As a result of this case, never shy Hobby Lobby has deflected its own ethical responsibilities towards due diligence by filing suit against Christie's, alleging fraud and breach of warranty in connection with the private treaty sale allegedly after the Gilgamesh Dream Tablet's provenance failed to stack up. This move confirms the auction powerhouse as the intermediary auction house, unnamed in the civil forfeiture complaint. That case has been listed as Hobby Lobby Stores, Inc. v. Christie's Inc. (1:20-cv-02239) to be heard in the Eastern District of New York and names Georgie Aitken, Head of the Antiquities Department at Christie's in London from 2009-2016 and Margaret Ford, the Senior Director, International Head of Group, Books and Science at Christie's.

In closing, it is interesting to note that in the past Christie's has voiced a willingness to work closely with law enforcement agencies and ministries of culture to resolve issues when suspect antiquities passing through their organization, but reading the emails detailed in the civil forfeiture complaint for this cuneiform tablet show acting employees of the firm being anything but that. Instead, Christie's appears to have been trying to extract itself from the difficult situation it found itself in, having failed to so their advance homework prior to accepting the object for consignment or at any point up to the final sale.

Yet guarding our past for the future, is also going to be a tough sell for the Oklahoma-based retailer/donor.  In 2017 Hobby Lobby was fined $3 million after federal authorities alleged that the firm bought thousands of historical artifacts that were smuggled out of Iraq.  In 2019 the Museum of the Bible deaccessioned and restituted a number of stolen EES papyrus fragments removed illegally from the Oxyrhynchus Papyri housed at the Sackler Library in Oxford and in 2020 the museum relinquished 11,500 antiquities to the Iraqi and Egyptian governments, which had been acquired with a lack reliable provenance, or ownership histories.

Then there is that Galatians fragment Dr. Mazza has been asking about for years now, as well as many other pieces, have been tied back to Dr. Dirk Obbink and his private antiquities enterprises. 

At the time of the last restitution Mr. Green stated:

“One area where I fell short was not appreciating the importance of the provenance of the items I purchased.” 

One would question just how many legal entanglements it will take before Mr. Green starts to acknowledge that he is a significant contributor to the problem and not merely an innocent victim.  His failure to have engaged in serious due diligence of the artifacts he has purchased has already caused the Museum of the Bible to suffer by their own hands.  Likewise, due diligence of looted antiquities, especially those that could be from conflict-based countries, must be meaningful and not superficially plausible, in the furtherance of a sale's commission.  Partially-documented histories in an object's collection background, do not necessarily always point to fresh looting or illegal export but when an antiquity's background looks murky, as is the case with this important cuneiform tablet, the art market and wealthy donor collectors need to step up their game, by no longer participating in the laundering and by allowing researchers access to past sales details so that wrongs can be righted.

By:  Lynda Albertson