COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS on the EU Action Plan against Trafficking in Cultural Goods
Date: 2022-12-13
Institutions: Directorate-General for Migration and Home Affairs, European Commission
Subjects: EU action, art trade, cultural object, fight against crime, heritage protection, illicit trade, international cooperation

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 13.12.2022  COM(2022) 800 final  COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS on the EU Action Plan against Trafficking in Cultural Goods  
 
 
1.  Introduction   

Trafficking in cultural goods is a lucrative business for organised crime, and in some cases 
for conflict parties and terrorists1. This is due in particular to the low risk of detection, the potential 
for  high  margins,  and  the  attractive  size  of  the  licit2  and  illicit  markets,  driven  by  a  stable  to 
increasing global demand from collectors, investors and museums3.  

Interpol counts over 850 000 artefacts seized globally in 2020, with more than half of these in 
Europe.4 Since 2016, the annual global Operation Pandora has led to 407 arrests and the recovery 
of 147 050 cultural goods.5 This data belies a more extensive problem – given that a large number 
of cases go undetected, the real scale of cultural goods trafficking is likely much larger.6 

Cultural goods are often of major cultural, artistic, historical and scientific importance. Therefore, 
cultural goods trafficking can have a devastating and irreversible impact on cultural heritage 
within and beyond the EU. It destroys parts of our collective memory and deprives humanity of 
testimonies of its history. Crisis and conflict zones are particularly at risk. This is illustrated for 
instance in the Near and Middle East (such as in Syria, Iraq or Libya) and most recently in Ukraine. 

Tackling  this  complex,  inherently  transnational  criminal  phenomenon  requires  a  tailor-made 
response at EU level, as laid down in the EU Security Union Strategy 2020-20257 and the EU 
Strategy  to  Tackle  Organised  Crime  2021-20258.  Therefore,  the  Commission  puts  forward  an 
action plan. It aims to maximise the potential of existing EU actions, highlight areas that require 
further efforts and indicate how to address remaining challenges.  

2.  A complex phenomenon requiring a tailor-made response 

The  three  main  illegal  activities  associated  with  trafficking  in  cultural  goods  are  (1.)  theft  and 
robbery, (2.) looting (the illicit removal of ancient relics from archaeological sites, buildings or 

See for example  UN  Security Council Resolutions 2199 (2015), 2253 (2015), 2322 (2016), 2347 (2017), 

Cf. Europol, 2021 Serious and Organised Crime Threat Assessment. 
Interpol, Assessing Crimes Against Cultural Property 2020, report. 
An  operation  part  of  the  European  Multidisciplinary  Platform  against  Criminal  Threats  (EMPACT).  See 

1  
2462 (2019) and 2617 (2021); G20 Culture Ministers Rome Declaration of 30 July 2021. 
2  
In 2021 the “licit” art and antiquities market was valued at USD 65 billion globally, up by 29% compared to 
2020, surpassing pre-Covid-pandemic levels; see Clare McAndrew, The  Art Market 2022  – An Art Basel & UBS 
Report. 
3  
4  
5  
https://www.europol.europa.eu/media-press/newsroom/news/total-of-52-arrests-in-operation-across-28-countries-
targeting-trafficking-in-cultural-goods. 
6  
See  European  Commission,  Illicit  trade  in  cultural  goods  in  Europe  -  Characteristics,  criminal  justice 
responses and an analysis of the applicability of technologies in the combat against the trade, final report, 2019, p. 81, 
159, 160. 
7  
Social Committee and the Committee of the Regions on the EU Security Union Strategy, COM/2020/605 final. 
8  
Communication from the Commission to the European Parliament, the Council, the European Economic and 
Social  Committee  and  the  Committee  of  the  Regions  on  the  EU  Strategy  to  tackle  Organised  Crime  2021-2025, 
COM/2021/170 final. 

Communication from the Commission to the European Parliament, the Council, the European Economic and 

1 

 
 
                                                           
monuments9) and (3.) forgery of cultural goods. Related crimes include fraud, disposal of stolen 
goods (fencing), smuggling, or corruption. Beyond trafficking, criminals can abuse even legally 
acquired  cultural  goods,  for  money  laundering,  sanctions  evasion10,  tax  evasion  or  terrorism 
financing. 

Crimes related to cultural goods have specific features, distinguishing them from other illegal 
activities. The identity,  authenticity, provenience11, provenance12, and legal  status  of a cultural 
good is rarely instantly visible, and often requires specific expertise to be established. Secondly, 
public and private collections, monuments and excavation sites are vulnerable to theft and looting, 
especially in conflict and crisis situations. Moreover, unregistered cultural goods, especially from 
excavation sites or uncatalogued collections, are hard to detect and track once they have become 
subject to trafficking. Thirdly, the market for cultural goods is subject to certain vulnerabilities 
attractive to criminals. These include acceptance of anonymity and secrecy13, price subjectivity 
and volatility, and the possibility to use items to store and move considerable amounts of money14. 
Criminals also benefit from the general lack of awareness of the harm that trafficking in cultural 
goods can bring.15 

In  addition,  criminals  have  been  profiting  from  the  increased  availability  of  online  sales 
channels to expand their customer base on the licit and illicit markets. This poses additional 
challenges  to  law  enforcement16,  due  to  the  volume  of  cultural  goods  to  be  checked,  data 
encryption and the number of jurisdictions potentially involved. 

Furthermore, law enforcement authorities observe a higher level of sophistication of organised 
crime groups active in cultural goods trafficking compared to other types of organized property 
crimes. Criminals deliberately operate across borders to maximise their profits, blur their trails, 
hide from apprehension and falsify provenance or provenience of trafficked cultural goods. 

Investigations  into  cultural  goods  trafficking  cases  are  therefore  complex.  They  require 
specific expertise on cultural goods, and a high number of authorities to be involved (such as the 

Including pillaging, i.e. looting in war, considered a war crime in customary international humanitarian law. 

9  
See https://ihl-databases.icrc.org/customary-ihl/eng/docs/v1_rul_rule52.   
10  
See for example United States Senate, Permanent Subcommittee on Investigations, Committee on Homeland 
Security  and  Governmental  Affairs,  The  Art  Industry  and  U.S.  Policies  that  Undermine  Sanctions  Staff  Report 
Permanent Subcommittee on Investigations United States Senate, 2020. 
11  
In situ location of an object at the date of its archaeological discovery. 
12  
The "origin-to-present" chain of custody details of an object. 
13  
Such as use of cash transactions, anonymity of buyers and use of shell companies and free ports. 
14  
See  for  example  on  the  vulnerabilities  of  the  art  market  to  money  laundering  and  terrorism  financing, 
TRACFIN (Traitement du renseignement et action contre les circuits financiers clandestins), La lettre d’information 
de TRACFIN, number 16, June 2018. 
15  
See the report quoted in footnote 7, p. 70, 81, 158 - 160. 
16  
If  not  further  specified,  the  term  law  enforcement  authorities  as  used  in  this  document  refers  to  police, 
customs, border control and other relevant authorities carrying out tasks for the prevention, investigation, detection or 
prosecution of criminal offences. 

2 

 
 
                                                           
police, customs, border guards, ministries of culture, financial intelligence units, and the judiciary), 
often involving various jurisdictions due to the cross-border scope of many cases. 

3.  An EU action plan against Trafficking in Cultural Goods  

In line with recommendations for stepping up global action against cultural goods trafficking in 
various areas17, this action plan aims to deter criminals effectively, to address evolving security 
threats and to protect cultural heritage.18 The action plan focuses on four strategic objectives, 
for an effective and comprehensive response: 

I. 

Improving prevention and detection of crimes by market participants and cultural heritage 
institutions; 

II. 

Strengthening law enforcement and judicial capabilities; 

III.  Boosting international cooperation; 

IV.  Gaining the support of other key stakeholders to protect cultural goods from crime. 

The action  plan uses a broad definition of cultural  goods that includes artefacts  of a historical, 
artistic,  scientific,  or  ethnological  interest,  as  mentioned  in  the  United  Nations  Educational, 
Scientific  and  Cultural  Organization  (UNESCO)  Convention  on  the  Means  of  Prohibiting  and 
Preventing  the  Illicit  Import,  Export  and  Transfer  of  Ownership  of  Cultural  Property  of  1970 
(“UNESCO 1970 Convention”).19  

3.1.  Prevention  and  detection  of  cultural  goods  trafficking  by  market  participants  and 
cultural heritage institutions 

Cultural goods market participants20, collectors and cultural heritage institutions are well 
placed to help prevent and detect crime related to cultural goods, since they are at particular 
risk  of  encountering  trafficked  cultural  goods  or  of  becoming  victims  of  property  crime.  It  is 

17  
See in particular UN Security Council Resolutions 2199 (2015), 2253 (2015), 2322 (2016), 2347 (2017), 
2462 (2019) and 2617 (2021), UN General Assembly Resolution A/RES/69/196 (International Guidelines for Crime 
Prevention  and  Criminal  Justice  Responses  with  Respect  to  Trafficking  in  Cultural  Property  and  Other  Related 
Offences), Report of the Conference of the Parties to the UN Convention against Transnational Organized Crime on 
its  tenth  session,  UNTOC  COP/2020/10  Resolution  10/7,  UN  Educational,  Scientific  and  Cultural  Organization 
(UNESCO)  Convention  on  the  Means  of  Prohibiting  and  Preventing  the  Illicit  Import,  Export  and  Transfer  of 
Ownership of Cultural Property of 1970, UNIDROIT Convention on Stolen or Illegally Exported Cultural Objects of 
1995,  G20  Ministers  of  Culture  Rome  Declaration  of  30  July  2021,  Interpol’s  report  “Assessing  Crimes  Against 
Cultural Property 2020”, “The Safety and Security of Cultural Heritage in Zones of War or Instability” published 
under the North Atlantic Treaty Organisation (NATO) Science for Peace and Security series 2021, Declaration of the 
UNESCO World Conference on Cultural Policies and Sustainable Development – MONDIACULT 2022. 
18  
19  
20  
further cultural goods dealers (including online sales platforms), free ports, art storage facilities, cultural goods 
experts, businesses involved in the financing of cultural goods transactions, as well as accountants, auditors, tax 
advisors and legal professionals involved in cultural goods transactions. 

See also UN General Assembly Resolution A/RES/69/196. 
Article 1 of the UNESCO 1970 Convention. 
Including various participants involved in art market transactions, such as buyers, galleries, auction houses, 

3 

 
 
                                                           
essential that these stakeholders are aware of the applicable legislation and other non-legislative 
tools that aim to prevent and detect such crimes21. The Commission is in regular dialogue with 
cultural  heritage  institutions,  notably  through  the  Cultural  Heritage  expert  group22.  The 
Commission has also cooperated with UNESCO to deepen the understanding of the art market and 
cultural heritage institutions of due diligence and ethics rules.23 UNESCO is currently working on 
a  revision  of  the  International  Code  for  Dealers  in  Cultural  Property  in  order  to  address  the 
challenges that have arisen since its adoption in 1999, as well as strengthen and clarify the ethical 
principles that should govern the art market. 

As cultural goods trafficking is typically a cross-border crime, EU trade legislation plays an 
important role in preventing and detecting such cases. The export of cultural goods from the 
Union customs territory is subject to an export licence requirement, to ensure that exports undergo 
uniform  controls  at  the  EU’s  external  borders.24  The  import  of  cultural  goods  falls  under 
Regulation (EU) 2019/880. It prohibits importing cultural goods illegally exported from a third 
country, and subjects the import of certain cultural goods in the Union to requirements for import 
licences or importer statements. The Regulation also introduces a centralised electronic system to 
store and exchange information between Member States and to accomplish import formalities by 
operators. This system will become operational by June 202525. It is paperless, and will ensure the 
interconnection between relevant customs, cultural authorities and existing databases. Moreover, 
it  has  the  potential  to  reduce  cases  of  document  forgery,  and  eliminates  the  need  to  verify  the 
authenticity  of  paper  licences.  The  Commission  is  also  considering  a  future  extension  of  this 
system to export licences under Regulation (EC) 116/2009. Legislation on import and export of 

https://ec.europa.eu/transparency/expert-groups-register/screen/expert-

21  
Art markets and cultural institutions are subject to rules and other norms regarding due diligence, due care 
or  reporting  regarding  customers,  provenance  of  cultural  goods  or  transactions.  These  rules  and  norms  stem  from 
market practice, codes of conduct (such as UNESCO’s International code of ethics for traders in cultural property or 
the International Council of Museums Code of Ethics for Museums), case law or legislation (such as Directive (EU) 
2015/849 on preventing the use of the financial system for money laundering or terrorist financing as amended by 
Directive (EU) 2018/843, OJ L 156, 19.6.2018, p. 43–74; Directive 2014/60/EU of the European Parliament and of 
the Council of 15 May 2014 on the return of cultural objects unlawfully removed from the territory of a Member State, 
OJ L 159, 28.5.2014, p. 1 – 10, or national requirements to record sales in registers.). 
22  
groups/consult?lang=en&do=groupDetail.groupDetail&groupID=3204. 
23  
See for more details: https://en.unesco.org/fighttrafficking/eu-cooperation. 
24  
Council  Regulation  (EC)  No  116/2009  of  18  December  2008  on  the  export  of  cultural  goods,  OJ  L  39, 
10.2.2009,  p. 1  –  7,  and  Commission  Implementing  Regulation  (EU)  No  1081/2012  of  9  November  2012  for  the 
purposes of Council Regulation (EC) No 116/2009 on the export of cultural goods, OJ L 324, 22.11.2012, p. 1–24. 
25  
See  Regulation  (EU)  2019/880  of  the  European  Parliament  and  of  the  Council  of  17  April  2019  on  the 
introduction  and  the  import  of  cultural  goods,  complemented  by  Commission  Implementing  Regulation  (EU) 
2021/1079 of 24 June 2021. Regarding Syria and Iraq, see Article 3 of Council Regulation (EC) No 1210/2003 of 7 
July  2003  concerning  certain  specific  restrictions  on  economic  and  financial  relations  with  Iraq  and  repealing 
Regulation (EC) No 2465/96 (OJ L 169, 8.7.2003, p. 6–23) and Article 11c of Regulation (EU) No 36/2012 concerning 
restrictive measures in view of the situation in Syria as amended on 13 December 2013 by Regulation 1332/2013, OJ 
L 16, 19.1.2012, p. 1–32. 

4 

 
 
                                                           
cultural  goods  is  complemented  by  Directive  2014/60/EU  on  the  return  of  cultural  objects 
unlawfully removed from the territory of a Member State.26 

To further streamline implementation of EU import and export legislation, the Commission holds 
regular exchanges with Member States’ customs and cultural affairs authorities through the Expert 
Group on customs issues related to cultural goods, the Cultural Goods Committee established by 
Regulation  (EC)  116/2009  and  Regulation  (EU)  2019/880  and  the  Project  Group  on  the 
Digitalisation of Cultural Goods.  

However, scrutiny and control of trade in cultural goods can vary widely within the single 
market27. This leaves significant loopholes for criminals to hide their tracks and disguise an item’s 
origin.  In  line  with  the  UNESCO  1970  Convention28  and  as  raised  by  law  enforcement 
stakeholders consulted, measures to increase traceability29 of the transfer of property in cultural 
goods within the single market could significantly contribute to detect trafficking cases and deter 
criminals  from  infiltrating  the  cultural  goods  market.  Furthermore,  establishing  provenance  for 
cultural goods falling within the scope of Directive 2014/60/EU would improve the functioning of 
the  return  mechanism  provided  by  the  Directive  itself.30  Many  Member  States  have  already 
implemented  sales  registers  for  cultural  goods  categories.  Implementing  similar  measures 
throughout the EU would help boost crime prevention and detection in cross-border cases, and 
would help establish a comprehensive picture of illicit trafficking of cultural goods in the single 
market. Moreover, the effectiveness of existing sales registers could be improved, for example by 
ensuring that information is stored digitally and that registers are interconnected.  

Steps can also be taken to make public and private cultural goods collections less vulnerable 
to property crime. Europol31 reports that in the EU, many cases of trafficking concern cultural 
goods stolen from places of worship, cultural heritage institutions, museums,  as well as private 
homes  and  collections.  Public  and  private  collections  need  to  develop  awareness  of  their 
vulnerabilities to property crime, train their staff in applying protection measures, and invest in 
protection tools. 

Similarly,  the  owners  or  managers  of  public  and  private  collections  can  take  voluntary 
measures to protect themselves better from property crimes. One key action is to keep up-to-
date  inventories  and  databases  of  collected  cultural  goods.  Such  inventories  facilitate  the 
identification and search of stolen objects. Even for private collections, there are available tools 

Outside of areas harmonized by EU legislation, such as Directive (EU) 2015/849, Directive 2014/60/EU, or 

Directive 2014/60/EU of the European Parliament and of the Council of 15 May 2014 on the return of 

26  
cultural objects unlawfully removed from the territory of a Member State, OJ L 159, 28.5.2014, p. 1–10. 
27  
national requirements to record sales in registers. 
28  
29  
30  
of 15 May 2014 on the return of cultural objects unlawfully removed from the territory of a Member State and 
amending Regulation (EU) No 1024/2012 (Recast), COM/2021/705 final, 18 November 2021. 
31  

Article 10 (1). 
On support for increased traceability measures see actions under strategic objective 2. 
See First report on the application of Directive 2014/60/EU of the European Parliament and of the Council 

Cf. Europol, 2021 Serious and Organised Crime Threat Assessment. 

5 

 
 
                                                           
recommended  by  law  enforcement  authorities,  such  as  the  International  Council  of  Museum’s 
(ICOM) Object-ID.32 The reporting of property crime cases to the law enforcement authorities is 
another means to detect and prevent crimes. This helps ensure that stolen cultural goods appear in 
national  stolen  art  databases  and  Interpol’s  Stolen  Works  of  Art  Database.  Registering  stolen 
cultural  goods  increases  their  visibility,  and  reduces  the  possibility  for  traffickers  to  find  sales 
channels in the legal economy. 

The EU already has specific legislation in place to tackle cultural goods trafficking online. 
The  Digital  Services  Act33  increases  the  responsibilities  of  providers  of  intermediary  services, 
including  online  platforms  that  connect  consumers  with  providers  of  goods  and  services.  The 
Digital Services Act also regulates the reporting of illegal content, such as on suspicious sales,34 
introduces the possibility for public authorities to send cross-border removal orders to providers 
of intermediary services established in other Member States, and increases traceability obligations 
for traders. The Commission also supports digitisation and digital preservation of cultural heritage 
through  the  common  European  data  space  for  cultural  heritage35  and  the  upcoming  European 
Collaborative Cloud for Cultural Heritage. 

A  key  component  of  the  fight  against  cultural  goods  trafficking  is  the  detection  of  illicit 
financial  flows.  Furthermore,  the  prevalence  of  money  laundering  or  terrorism  financing  with 
legally acquired cultural goods requires particular attention. Concerns that the arts and antiquities 
sector  may  be  abused  by  criminals  to  launder  the  proceeds  of  their  crimes  have  led  to  calls  to 
extend the EU anti-money laundering and counter-terrorism financing regulatory framework. The 
Anti-money Laundering Directive36 now applies to art and antiquities market participants, such as 
galleries and auction houses, which trade or act as intermediaries in the trade of works of art, as 

Also supported by Interpol’s ID-Art App. See https://www.interpol.int/Crimes/Cultural-heritage-crime/ID-

32  
Art-mobile-app. 
33  
Regulation (EU) 2022/2065 of the European Parliament and of the Council of 19 October 2022 on a Single 
Market For Digital Services and amending Directive 2000/31/EC (Digital Services Act) (Text with EEA relevance), 
OJ L 277, 27.10.2022, p. 1–102. 
34  
Introducing mechanisms to enable the reporting of suspicious dealings or sales on the internet is listed as 
guideline 3 (d) in the International Guidelines for Crime Prevention and Criminal Justice Responses with Respect to 
Trafficking in Cultural Property and Other Related Offences, UN General Assembly, A/C3/69/L7. 
35  
See Commission Recommendation C(2021)7953 of 10 November 2021 on a common European data space 
for cultural heritage; European Commission, Directorate-General for Research and Innovation, Brunet, P., De Luca, 
L., Hyvönen, E., et al., Report on a European collaborative cloud for cultural heritage : ex – ante impact assessment, 
Publications Office of the European Union, 2022, https://data.europa.eu/doi/10.2777/64014. For more information 
about Europeana and the creation of a European Competence Centre for the conservation of cultural heritage (4CH) 
see https://www.europeana.eu/en and https://www.4ch-project.eu. 
36  
See  Directive  (EU)  2015/849  of  the  European  Parliament  and  of  the  Council  of  20  May  2015  on  the 
prevention of the use of the financial system for the purposes of money laundering or terrorist financing, amending 
Regulation (EU) No 648/2012 of the European Parliament and of the Council, and repealing Directive 2005/60/EC of 
the European Parliament and of the Council and Commission Directive 2006/70/EC (Text with EEA relevance), OJ 
L 141, 5.6.2015, p. 73–117 amended by Directive (EU) 2018/843 of the European Parliament and of the Council of 
30 May 2018 on the prevention of the use of the financial system for the purposes of money laundering or terrorist 
financing, and amending Directives 2009/138/EC and 2013/36/EU (Text with EEA relevance), OJ L 156, 19.6.2018, 
p. 43–74. 

6 

 
 
                                                           
well  as  to  free  ports  for  transactions  above  a  certain  threshold.  Market  participants  have  an 
obligation to include risk assessments and ‘risk-based’ approaches to the prevention and detection 
of money laundering and terrorist financing, risk mitigating and risk managing measures, effective 
customer  due  diligence  and  identification  of  customers  and  their  beneficial  owners,  and  report 
suspicious transactions and activities to the national Financial Intelligence Units. Moreover, the 
proposal for a new Anti-money Laundering Regulation37 sets an EU-wide limit of EUR 10 000 for 
cash  payments.  This  can  reduce  the  attractiveness  of  the  cultural  goods  market  for  money 
laundering.  

Public  authorities  need  a  sufficient  level  of  understanding  of  money  laundering  and 
terrorism financing risks and vulnerabilities in the cultural goods sector so that they can act 
accordingly when necessary. To this end, national risk assessments conducted by Member States 
under  the  anti-money  laundering  legislation38  provide  the  adequate  setting.  Member  States  can 
also  issue  guidance  to  relevant  private  sector  entities  on  how  to  spot  relevant  transactions  and 
comply with obligations to prevent money laundering and terrorism financing.39  

Finally,  the  Commission  supports  the  Financial  Action  Task  Force  project  on  money 
laundering and terrorist financing associated with art, antiquities and other cultural objects. 
Its objectives include helping countries, competent authorities and the private sector to understand 
how criminals and terrorists can abuse trade  in  such objects, and  to  develop  best  practices  and 
recommendations to mitigate these risks.40 Moreover, the Commission continuously assesses the 
risks of money laundering and terrorist  financing affecting the  single  market  when it relates to 
cross-border  activities.  In  the  context  of  the  supra-national  risk  assessment41,  the  Commission 
assesses and monitors the specific risks of the art and antiquities market and further related sectors, 
such as free ports and art storage facilities.42  

Key actions 

The Commission will: 

  Launch a dialogue with the art market, in close cooperation with UNESCO, on the issues 
related to  the protection and trade of  cultural  goods  in  the single market,  including  a 
High-Level event in 2023; 

Proposal for a Regulation of the European Parliament and of the Council on the prevention of the use of the 

37  
financial system for the purposes of money laundering or terrorist financing COM/2021/420 final. 
38  
See Article 7 of Directive (EU) 2015/849. 
39  
See Directive (EU) 2015/849. 
40  
For further information: FATF Annual Report 2020-2021, page 32. 
41  
See Article 6 of Directive (EU) 2015/849. 
42  
Report from the Commission to the European Parliament and the Council on the assessment of the risk of 
money  laundering  and  terrorist  financing  affecting  the  internal  market  and  relating  to  cross-border  activities, 
COM/2022/554  final,  27  October  2022  and  the  Commission  staff  working  document  accompanying  that  report, 
SWD/2022/344 final.  

7 

 
 
 
                                                           
  Support exchange of information between cultural heritage professionals and  relevant 

authorities through a series of workshops and peer-learning activities43; 

  Explore  the  extension  of  the  electronic  system  for  regulating  the  import  of  cultural 

goods to handle the export of cultural goods, through a feasibility study; 

  With the aim of helping Member States establish sales registers to improve traceability 
of cultural goods within the single market (including online sales), the Commission will 
launch a study, and on this basis issue guidance to Member States in 2024; 

  Cooperate with the ICOM to promote the ICOM Code of Ethics for Museums, improve 
capacities and provide trainings to staff in museums and cultural heritage institutions 
in several Member States, in order to better record and protect their collections. 

Member States are encouraged to: 

  Strengthen effective cooperation and information sharing among  customs authorities 
and with the Commission44 through the Customs Information System in order to fight 
cultural goods related fraud; 

  Take  measures  to  ensure  that  public  and  private  collections  duly  register  their 
possessions in databases and report property crime cases to law enforcement, with 
help from internationally agreed standards and tools (such as the Object ID standard or 
Interpol’s Stolen Works of Art Database; 

 

Identify, assess and understand the risks of cultural goods trafficking, money-laundering 
and terrorism financing as part of their national risk assessment under the anti-money 
laundering legislation, and to adopt adequate measures to mitigate these risks; 

  Raise awareness and issue guidance to the private sector on how best to comply with 
their  obligations  to  prevent  money  laundering  and  terrorism  financing  in 
cooperation with the competent authorities;45 

 

Improve  the  cooperation  between  obliged  entities  from  the  art  and  antiquities 
market, financial sector and Financial Intelligence Units by sharing knowledge and 
training on risks and types of illegal activities related to cultural goods, while taking into 
account the cooperation possibilities between public and private entities; 

  Promote the UNESCO International Code of Ethics for Dealers in Cultural Property and 

the ICOM Code of Ethics for Museums. 

3.2. Strengthen capabilities of law enforcement and the judiciary  

Due to the complex nature of cultural goods trafficking, law enforcement and the judiciary face 
specific  challenges.  Further  action  is  needed  to  boost  their  capacity  to  handle  cases  of  cultural 

43  
See Council Resolution on the EU Work Plan for Culture 2023-2026. 
44  
See Council Regulation (EC) No 515/97 of 13 March 1997 on mutual assistance between the administrative 
authorities  of  the  Member  States  and  cooperation  between  the  latter  and  the  Commission  to  ensure  the  correct 
application of the law on customs and agricultural matters, OJ L 082, 22/03/1997, p. 1 – 16. 
45  

See in particular Directive (EU) 2015/849. 

8 

 
 
                                                           
goods  trafficking  effectively,  in  accordance  with  the  authorities’  respective  tasks  and 
responsibilities under EU and national law.  

Currently,  the  available  intelligence  picture  does  not  adequately  reflect  the  prevalence  of 
cultural goods trafficking. One of the reasons for the lack of data on cultural goods trafficking is 
that  trafficking  cases  are  not  appropriately  registered.  A  major  impediment  to  gathering  a 
comprehensive  EU-wide  intelligence  picture  is  that  there  is  neither  a  uniform  data  collection 
methodology, nor a uniform categorisation of cultural goods related crimes. To facilitate uniform 
categorisation, the comprehensive catalogue of cultural property crimes set out in the Council of 
Europe’s Convention on Offenses relating to cultural property (“Nicosia Convention”)46 contains 
guidance on categories of crimes that Member States’ authorities can use.  

Public  authorities  need  to  have  an  adequate  understanding  of  the  modus  operandi  of 
criminals,  and  share  information  with  each  other  to  be  able  to  maximise  the  use  of  their 
resources.  Such  an  understanding  should  notably  cover  the  regional  differences47  between 
traffickers, for instance in terms of organisational set-up, cultural goods at risk, trafficking routes 
or  methods  to  launder  money  and  falsify  the  provenance  and  provenience  of  goods.  This 
knowledge  can  facilitate  more  targeted  searches  and  an  effective  use  of  available  resources. 
Operational  actions  of  the  European  Multidisciplinary  Platform  Against  Criminal  Threats 
(EMPACT) can also contribute to a better understanding of traffickers’ practices and the scope of 
cultural goods trafficking.  

Public  authorities  also  need  to  be  aware  of  intra-  and  inter-agency48  cooperation 
requirements, as well as cooperation options in a given case. To support public authorities in 
their capacity building efforts, UNESCO has published the toolkit “Fighting the illicit trafficking 
of cultural property: a toolkit for European judiciary and law enforcement”, developed as part of 
EU-UNESCO  cooperation.  The  Commission  supports  UNESCO  in  translating  its  toolkit  into 
further languages of relevant countries. Secondly, UNODC has developed a Practical Assistance 
Tool49, to assist in the implementation of the International Guidelines.50 

Public  authorities  need  specific  expertise  and  tools51  to  detect  and  investigate  trafficking 
cases. In line with Interpol recommendations, this involves the adequate recording of stolen items 

Council of Europe Convention on Offences relating to Cultural Property, adopted on 3 May 2017 (Council 

Cf. Interpol, Assessing Crimes Against Cultural Property 2020, page 6. 
Intra-agency cooperation can mean for example cooperation within one authority (e.g., between various 

46  
of Europe Treaty Series no. 221). 
47  
48  
police units specialized in different forms of crime, or between various regional police units). Inter-agency 
cooperation means cooperation between different authorities, such as police, customs, judiciary, etc. 
49  
Prevention and Criminal Justice Responses with Respect to Trafficking in Cultural Property and Other Related 
Offences (2016). 
50  
See footnote 18. 
51  
Such as Interpol’s Stolen Works of Art database and the corresponding ID-Art App, or the Red Lists of the 
International Council of Museums, describing cultural goods categories at risk of trafficking from various regions of 
the world.  

UNODC Practical assistance tool to assist in the implementation of the International Guidelines for Crime 

9 

 
 
                                                           
at  national  and  international  level,  and  competent  authorities  having  the  necessary  skills,  in 
particular  through  the  creation  of  specialised  units  at  national  level  exclusively  dedicated  to 
cultural  goods  trafficking  investigations52,  as  stipulated  by  the  UNESCO  1970  Convention. 
Specialised pools of prosecutors have also proven to be effective in deepening the scope of the 
investigations.  Another  important  factor  is  timely  access  to  expertise  from  art  historians, 
archaeologists or other cultural goods experts, to identify seized cultural goods, determine their 
authenticity, or quantify the possible damage occurred at sites that have been or risk being looted.  

Technology is crucial in supporting law enforcement authorities and in protecting cultural 
goods from being trafficked. This includes software to register stolen items and detect illegal 
cultural  goods  on  the  market,  air  surveillance  technology  to  protect  sites  at  risk  or  online 
investigation tools, including those based on artificial intelligence. In particular, law enforcement 
authorities need specific detection tools to effectively tackle the volume of items to be checked in 
online investigations, for example for systematically scanning the internet for images and other 
data of cultural goods illegally on sale. 

Authorities could also consider broadening the scope of investigations beyond the recovery 
of the trafficked goods, to encompass the criminal networks and illicit money flows behind 
the  individual  trafficking  cases.  Scoping  investigations  this  way  is  in  line  with  international 
recommendations (e.g., Interpol), the EU Organised Crime Strategy 2021-2025 and the EMPACT 
common horizontal strategic goals. At EU and international level, investigations can be supported  
by  Europol53,  the  EU  border  management  agency  Frontex,54  and  the  European  Agency  for 
Criminal Justice Cooperation (Eurojust) in accordance with their respective mandates, or through 
the involvement of partners such as Interpol, United Nations Office on Drugs and Crime (UNODC) 
or the World Customs Organization. In addition, cooperation can be set up in the context of other 
relevant  law  enforcement  and  judicial  cooperation  instruments.55  The  European  Public 
Prosecutor’s  Office  (EPPO)  could  investigate  and  prosecute  specific  cultural  goods  trafficking 

See Interpol, Creating a national cultural heritage Unit. The value of a national unit dedicated to fighting 

52  
crimes against cultural heritage and the illicit traffic of cultural property, January 2019. 
53  
In  particular  information  exchange  via  the  Secure  Information  Exchange  Network  Application  (SIENA), 
hosting of operational meetings, operational support during investigations (including online investigation training in 
the  context  of  EMPACT’s  Pandora  operations),  analytical  support,  strategic  support  (e.g.,  threat  assessment),  or 
technical support through the Europol Innovation Lab. 
54  
E.g., the use of Frontex’s Eurosur Fusion Services Catalogue for the detection of cross-border crimes. 
55  
Such as  EMPACT cooperation, joint investigation  teams,  use  of joint coordination centers (with possible 
involvement  of  non-EU  countries),  including  support  of  Eurojust  and  the  European  Judicial  Network  in  criminal 
matters, possibilities of mutual legal assistance including under Article 6 of Directive 2014/60/EU, European Arrest 
Warrant, European Investigation Order, cooperation based on Directive (EU) 2018/1673 of the European Parliament 
and of the Council of 23 October 2018 on combating money laundering by criminal law (OJ L 284, 12.11.2018, p. 
22–30), Regulation  (EU) 2018/1805 of the European Parliament and of the Council of  14 November 2018 on the 
mutual recognition of freezing orders and confiscation orders (OJ L 303, 28.11.2018, p. 1–38), cooperation and mutual 
legal assistance in organised crime investigations based on the UN Convention against Transnational Organized Crime 
(UNTOC). 

10 

 
 
                                                           
related offenses  falling  within its competence.56  The Commission is committed to  ensuring the 
EPPO can effectively exercise its tasks conferred by Regulation  (EU) 2017/1939,  including by 
strengthening its cooperation with non-EU countries.   

As  an  inherently  cross-border  crime,  the  fight  against  cultural  goods  trafficking  can  be 
reinforced  by  better  exchanges  between  national  authorities.  To  improve  the  exchange  of 
strategic  information  and  best  practices,  as  well  as  to  foster  joint  efforts  in  cultural  goods 
trafficking,  the  Council  created  the  informal  network  of  Member  States  law  enforcement 
authorities, EU CULTNET, in 2012.57 This network has significant potential to support Member 
States’  law  enforcement  authorities  in  tackling  cultural  goods  trafficking,  in  particular  through 
cooperation on projects of common interest and the development of specific measures tailored to 
the needs of law enforcement authorities. The Commission will continue to work with Member 
States to facilitate and reinforce law enforcement cooperation via EU CULTNET. 

Cultural goods traffickers profit from an uneven criminalisation of relevant offences across 
the EU. The Council of Europe “Nicosia Convention”58 is the only international treaty specifically 
dealing  with  the  criminalisation  of  the  illicit  trafficking  of  cultural  property.  Implementing 
measures stipulated under the convention include criminalisation of theft, unlawful import/exports, 
illegal  excavations,  illegal  acquisition  and  placing  on  the  market,  as  well  as  falsification  of 
documents.  These  measures  would  help  disrupt  trafficking  activities  through  increased 
investigations as well as enhanced possibilities to recover and confiscate stolen cultural property. 
Moreover, in order to disrupt criminal business models, the Commission has recently proposed to 
step up the EU rules on asset recovery and confiscation59 which would require Member States to 
trace,  freeze  and  confiscate  property  stemming  from  trafficking  in  cultural  goods  where  such 
trafficking  is  carried  out  within  the  framework  of  an  organised  crime  group.  In  addition,  the 
Commission  is  working  on  ways  to  increase  criminal  accountability  of  individuals  and  legal 
persons involved in the violation of Union restrictive measures.60 This would also have an impact 

Trafficking in cultural goods may also result in damage to the Union’s financial interests or may be linked 

Draft Council Resolution on the creation of an informal network of law enforcement authorities and expertise 

56  
with criminal offences affecting such financial interests. The EPPO is competent to investigate and prosecute 
criminal offences affecting the Union budget as well as, offences that are inextricably linked to them. See Council 
Regulation (EU) 2017/1939 of 12 October 2017 implementing enhanced cooperation on the establishment of the 
European Public Prosecutor’s Office (‘the EPPO’), OJ L 283, 31.10.2017, p. 1–71.  
57  
competent in the field of cultural goods (EU CULTNET) of 4 October 2012, 14232/12. 
58  
of Europe Treaty Series no. 221). 
59  
25 May 2022, COM (2022) 245 final. 
60  
See Communication from the Commission to the European Parliament and the Council, Towards a Directive 
on criminal penalties for the violation of Union restrictive measures, 25 May 2022, COM(2022) 249 final; Council 
Decision (EU) 2022/2332 of 28 November 2022 on identifying the violation of Union restrictive measures as an area 
of crime that meets the criteria specified in Article 83(1) of the Treaty on the Functioning of the European Union, 
ST/10287/2022/REV/1, OJ L 308, 29.11.2022, p. 18–2. 

Proposal for a Directive of the European Parliament and of the Council on asset recovery and confiscation of 

Council of Europe Convention on Offences relating to Cultural Property, adopted on 3 May 2017 (Council 

11 

 
 
                                                           
on those individuals and legal persons involved in using cultural goods for circumvention of Union 
restrictive measures. 

Key actions 

The Commission will: 

 

Identify  and  facilitate  more  uniform  categories  for  data  collection  with  support  from 
Europol, which could lead to EU-wide data collection via EUROSTAT in the future; 

  Explore measures for an EU-wide harmonisation and interconnection of Member States’ 
databases of stolen cultural goods – including a linkage to Interpol’s Stolen Works of 
Art Database; 

  Continue to fund the development of solutions to enhance traceability and detection 
of cultural goods for their protection from man-made threats (including crime), and to 
address  different  aspects  of  the  protection  of  cultural  goods,  including  traceability 
measures as well as detection and tracking of trafficked cultural goods61; 

  Add trafficking in cultural goods to the induction course for its standing corps officers 

for the detection of cross-border crime of Frontex; 

  Assess existing digital investigation tools (including those funded by the Commission) 
and foster Member States’ access to these, with support from Europol’s Innovation Lab; 

  Conduct  a  mapping  of  Member  States’  national  legislation  criminalising  the  illicit 
trafficking of cultural property and the implementation of the Nicosia Convention; 

Member States are encouraged to: 

  Set up and duly manage dedicated national databases of stolen cultural goods; 

  Report stolen cultural goods to Interpol via its Stolen Works of Art database; 

  Share  information  on  cultural  goods  trafficking  cases  with  Europol  and  Interpol  to 

improve the intelligence picture;  

  Maximise the potential of EMPACT for cultural goods trafficking cases, including on 

investigations on the criminal networks and illicit money flows involved; 

  Take full advantage of Europol’s as well as Eurojust’s support and expertise for cross-

border law enforcement and judicial cooperation; 

  Provide adequate capacity building of national law enforcement and judicial authorities, 
for  example  by  setting  up  and  training  specialised  law  enforcement  units  and 
specialised pools of prosecutors, and by providing a basic training for police, customs 
and border guard officers involved in routine checks; 

61  
Two  calls  for  proposals  were  already  published  under  the  first  work  programme  of  Horizon  Europe,  one 
under  Cluster  2  “Culture,  Creativity  and  Inclusive  Society”  (namely  HORIZON-CL2-2022-HERITAGE-01-07: 
Protection of artefacts and cultural goods from anthropogenic threats), the other under Cluster 3 “Civil Security for 
Society” (namely HORIZON-CL3-2021-FCT-01-08: Fight against trafficking in cultural goods). 

12 

 
 
                                                           
  Conclude memoranda of understanding between  relevant  law  enforcement  authorities 
and relevant cultural heritage institutions to ensure the adequate handling and storage 
of seized or confiscated cultural goods; 

  Support the reinforcement and the continuity of the network EU CULTNET to use 
its full potential, including by seconding appropriate staff to Europol for that purpose, 
and  by  developing  common  measures  such  as  improving  rapid  access  of  law 
enforcement to the necessary expertise from archaeologists or art historians62;  

  Sign, ratify and implement the Council of Europe “Nicosia Convention”.63 

3.3. Step up international cooperation  

An effective fight against cultural goods trafficking requires action beyond the EU’s borders. EU 
external action includes multilateral and bilateral cooperation, and focuses on measures in source, 
transit  and  destination  countries  outside  the  EU.  Actions  include  support  to  protecting  cultural 
heritage  and  archaeological  sites,  setting  up  national  cultural  goods  databases,  and  capacity 
building for law enforcement and the judiciary. 

The Commission services and the European External Action Service (EEAS) are continuing 
to support a global response to  cultural goods trafficking. They will further incorporate the 
protection of cultural heritage into the EU’s external action, ranging from crisis and emergency 
response to development cooperation, international and multilateral cooperation, and within the 
Common  Security  and  Defence  Policy.  The  Commission  services,  together  with  the  EEAS,  in 
accordance  with  their  respective  tasks  and  the  applicable  procedures  under  EU  law,  will 
furthermore  continue  to  strengthen  cooperation  with  international  and  regional  organisations64 
dedicated to fighting cultural goods trafficking, further encouraging development and adherence 
to relevant international legal frameworks and standards. 

Regarding bilateral or regional cooperation with non-EU countries, the EU has included the 
protection of cultural  goods against trafficking  in bilateral  cooperation agreements, such as  the 
Partnership Priorities with Egypt,65 or the Europe Latin America Programme of Assistance against 
Transnational  Organised  Crime  (El  PacCto).  This  has  resulted  in  the  establishment  of  new 
cooperation  tools  to  investigate  trafficking  in  cultural  property.66  Furthermore,  the  EU  has 
supported activities related to combatting trafficking in cultural goods in the Western Balkans, and 

Thereby taking into account the work of the EU-funded NETCHER project (NETwork and social platform 

62  
for Cultural Heritage Enhancing and Rebuilding). 
63  
See footnote 72. 
64  
Including  but  not  limited  to:  UNESCO,  the  Council  of  Europe,  ICOM,  WCO,  Interpol,  UNIDROIT, 
UNODC, ICCROM (International Centre for the Study of the Preservation and Restoration of Cultural Property) and 
ALIPH (Alliance Internationale pour la protection du patrimoine dans les zones en conflit).  
65  
2021–2027, 16 June 2022. 
66  

See Annex to Recommendation of the EU-Egypt Association Council on the EU-Egypt Partnership Priorities 

See https://www.elpaccto.eu/en/news/new-cooperation-tools-to-investigate-trafficking-in-cultural-property/ 

13 

 
 
 
                                                           
has provided financial support for cultural heritage protection to source and transit countries of 
cultural  goods trafficking such as  Mali,  Tunisia,  Lebanon,  Iraq, Syria,  Libya and Yemen.67 On 
capacity building, the Commission also supports partner countries in the field of asset recovery. It 
finances  assistance  measures  aimed  at  enhancing  cross  border  cooperation  for  the  tracing, 
investigation, seizure and confiscation of assets.68  

The EU also works globally to tackle illicit financial flows related to cultural goods. This is 
being  done  through  the  EU  Global  Facility  on  Anti-Money  Laundering  and  Countering  the 
Financing of Terrorism. The Global Facility aims to help countries adapt to Financial Action Task 
Force  standards,  which  ensure  a  co-ordinated  global  response  to  prevent  organised  crime, 
corruption  and  terrorism.  Actions  include  improving  investigations  and  facilitating  cooperation 
between partner countries’ relevant authorities, for example Financial Intelligence Units.  

EU  action  specifically  addresses  the  vulnerability  of  cultural  goods  to  criminal  harm  in 
conflict  and  crisis  regions.69  Its  progress  is  monitored  by  the  EEAS,  together  with  the 
Commission services and the Member States.70 This includes an informal task force of experts 
from the EEAS and relevant Commission services to exchange information and facilitate concrete 
new  actions.  Since  agents  deployed  in  missions  and  operations  can  play  a  major  role  in  the 
protection of cultural goods, cultural goods trafficking will be included in the dedicated Common 
Security and Defence Policy training modules on cultural heritage in conflicts and crises. Another 
notable example is support of countries at risk of looting by satellite and drone technology via the 
European Union's Earth observation programme Copernicus.  

Russia’s war of aggression against Ukraine calls for further action to safeguard Ukrainian 
cultural goods. The Commission services and the EEAS will continue to support safeguarding 
cultural goods in Ukraine by various means, including assistance to protect and evacuate cultural 
goods.71 To this end, Commission services and the EEAS regularly exchange in a dedicated task 
force on best practices, lessons learnt and possible new actions. Actions include financial support 
to protect buildings and collections, as well as support to cultural heritage professionals enabling 
them  to  continue  their  work  in  Ukraine,  in  cooperation  with  the  International  Alliance  for  the 
Protection of Heritage in Conflict Areas.72 Furthermore, for the first time, the EU Civil Protection 

For further examples see the European External Action Service’s “2022 Report on the progress in the 

Support is given through the EUROMED Police and EUROMED Justice programmes, led by CEPOL and 

67  
implementation of the “Concept on Cultural Heritage in conflicts and crises. A component for peace and security in 
European Union’s external action” and the dedicated Council Conclusions”, 14 September 2022, EEAS (2022) 
1556. 
68  
Eurojust. EUROMED Police aims at enhancing the capacity of the Southern Partner Countries (SPC) to fight serious 
and organised crime. EUROMED Justice brings together the most relevant stakeholders in the field of criminal 
justice. 
69  
2021. 
70  
71  
72  

See report mentioned in footnote 67. 
Ibid, p. 6 – 8. 
https://www.aliph-foundation.org/en/actions-country/UA.  

In line with Council Conclusions on EU Approach to Cultural Heritage in conflicts and crises of 18 June 

14 

 
 
                                                           
Mechanism  has  been  activated  to  provide  assistance  in  the  field  of  the  protection  of  cultural 
heritage.73 The House of Europe II programme, funded by the Neighbourhood, Development and 
International Cooperation Instrument, will include support to preserve and promote of Ukrainian 
cultural heritage.  

The Commission welcomes Member States’ existing support to non-EU source or transit countries, 
including in conflicts and crises, such as in the Middle East74 and Ukraine.  

Key actions 

The Commission services, in cooperation with the EEAS, and the Member States where 
appropriate,  will: 

  Monitor and report on the progress of the implementation of the Council Conclusions 

on EU Approach to Cultural Heritage in conflicts and crises 

 

Increase support to the protection of Ukrainian cultural goods from destruction by 
supporting evacuation and physical protection of collections; 

  Boost  third  country  capabilities  for  cross-border  cooperation  and  investigations  into 
money laundering related to cultural goods, notably by extending the scope of the EU 
Global Facility on Anti-Money Laundering to cover Asia and Latin America. 

3.4.  Increase  protection  of  cultural  goods  from  trafficking  by  maximising  stakeholder 
support 

Consultations  with  stakeholders,  including  UNESCO  and  UNODC,  have  shown  that  there  is 
limited  public  awareness  of  the  harm  that  trafficking  in  cultural  goods  can  bring.  It  is  vital  to 
generate awareness of the importance of cultural heritage and the damage done by the illicit trade 
in cultural goods beyond the law enforcement and cultural heritage communities. Target audiences 
include potential buyers of cultural goods, young people, journalists, individuals or entities able to 
influence public opinion on cultural goods, as well as communities in source countries that can 
influence the way local cultural goods are preserved and protected. 

To this end, the Commission supports several awareness raising projects. To raise awareness about 
cultural  heritage  protection  in  Ukraine,  the  Commission  supports  the  #ArtvsWar  campaign. 
Furthermore, the Commission works together with UNESCO and supports their campaign on ‘the 
Real Price of Art’, to raise awareness of potential buyers to the impact of trafficking on cultural 

73  
https://civil-protection-humanitarian-aid.ec.europa.eu/where/europe/ukraine_en. 
74  
For cooperation with countries in the Middle and Near East, action can also be built upon the results of the 
EU-funded “El HIWAR II” training and study on the protection of cultural heritage and fight against cultural goods 
trafficking in Egypt, Jordan and Lebanon. 

15 

 
 
 
 
 
 
                                                           
 
heritage. In order to reach a wider audience, the Commission supports the creation of teaching 
material  on  the  protection  of  cultural  heritage,75  and  its  EU-wide  promotion  via  the  School 
Education gateway. The EU also supports the involvement of youth. For example, the European 
Students' Association for Cultural Heritage, established on the occasion of the European Year of 
Cultural Heritage 2018, is part of a network project supported by the Creative Europe Programme 
"European  Cultural  Heritage  Agora:  Empowering  Europe’s  Civil  Society  Movement  for 
Heritage”.  

Key actions 

The Commission services, in cooperation with the EEAS where appropriate, will: 

  Provide  financial  support  to  the  ICOM,  to  upgrade  the  ICOM  Observatory,  which 
centralises and disseminates various instruments and materials for international public 
understanding and policy orientation to protect cultural goods; 

  Support UNESCO in creating a manual for journalists on reporting on cultural heritage 

related crimes;   

  Support youth engagement initiatives via the Creative Europe, the EU Solidarity Corps, 

and the Erasmus+ ; 

  Engage in a dialogue with relevant youth organisations in order to promote awareness 

on the need to protect cultural heritage from destruction, theft and looting.   

4.  Conclusion 

Cultural goods trafficking is not a victimless crime: it  not only fuels activities that threaten the 
safety of EU citizens, but can also cause irreparable damage to our cultural heritage and therefore, 
our  common  identity.  This  is  why  fighting  trafficking  of  cultural  goods  requires  additional 
common and sustained efforts from a large range of stakeholders within and beyond the EU. This 
action plan provides a comprehensive framework for the EU and the Member States to advance 
prevention, detection and criminal justice response to cultural goods trafficking and related crimes. 
The Commission calls on the European Parliament and the Council to endorse this action plan and 
support its implementation. 

75  
https://www.pitcher-project.eu/.  

For example through PITCHER (Preventing Illicit Trafficking of Cultural Heritage: Educational Resources), 

16