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Diplomacy in Action

ICE Homeland Security Investigations: Efforts to Combat Illicit Trafficking in Stolen Art, Antiquities, and Cultural Property

HSI Special Agent Thomas Mulhall, U.S. Immigration and Customs Enforcement (ICE)'s Homeland Security Investigations (HSI) Cultural Property, Art and Anitquities Investigations and Repatriations Program (CPAA); and HSI Office of International Affairs CPAA Program Manager Deborah Hardos
Washington, DC
September 6, 2013

11:00 A.M. EDT


MODERATOR: Good afternoon, and welcome to the Washington Foreign Press Center. Today’s briefing is on U.S. efforts to combat illicit trafficking in stolen art, antiquities, and cultural property. Our two speakers today are Special Agent Thomas Mulhall with the U.S. Immigration and Customs Enforcement Homeland Security Investigations, and our second briefer is HSI Program Manager Deborah Hardos. They will speak to us today about the cultural property, art and antiquities investigations, and their repatriation program.

MR. MULHALL: Thank you. Good morning. My name is Thomas Mulhall. I’m a special agent with Homeland Security in New York. I currently supervise a group of special agents that focus on investigations involving cultural property, art, and antiquities.

To begin, I just wanted to briefly define cultural property as – Homeland Security is focused on the – I apologize – the definition we’re using currently is “movable or immovable property of importance to a cultural heritage, society, or nation.” That’s a fairly universal definition you’ll find throughout the world. Examples of these items are monuments, architecture – monuments of architecture or art or history.

These are all images of items that Homeland Security has recovered. Again, in the photographs are an Egyptian sarcophagus that was recovered in Miami, and a set of earrings from the 8th century, B.C., that was recovered in Chicago by our agents.

Again, these are all examples of the artifacts and the antiquities that we’re encountering and that we are seizing through both our efforts internally, within HSI, within the interior of the United States, and through cooperation with Customs and Border Protection, which will do inspections at the border of inbound cargo and mail parcels and things of that nature, including persons, and they recover items which are subject to seizure and forfeiture.

A common question we do receive is: Why is Homeland Security Investigations involved in the enforcement of cultural property laws, and the enforcement of foreign laws related to the theft and looting of cultural property? Through our legacy organizations and powers, I guess you could say, granted by Congress to Homeland Security, we’re in a unique position at the border to enforce these laws, to enforce laws involving stolen property being imported, stolen property being trafficked.

Our footprint – HSI’s footprint internationally is 46 – we have agents in 46 countries. We work closely with our foreign counterparts in those countries, and this is commonly how we receive our referrals, through the victim country making us aware that there’s an item or antiquity that is present in the U.S. or present on the market that they have claim to, that they feel that was illegally removed from their country or was stolen.

Another reason why Homeland Security Investigations is involved is because the United States is one of the top three markets for illicit – well, for cultural property, art, and antiquities. The trade occurs primarily in Hong Kong, London, and the United States, New York being the focus. The – and this is for the entire market. This isn’t just for the illicit market.

Statistics from Interpol say that the trafficking of cultural property is the third-most profitable crime currently in existence. It’s a $6- to $8 billion a year industry. The type of organizations we see – I mean, they do – they vary from a large organization where the looter is involved with the smuggler, who’s involved with the vendor here in the United States, and there are smaller organizations where the looter will collect property overseas without any item – without – with the intention, but without an understanding of how it will be sold.

The program which I work in New York City, which is one of the largest offices working on these cases – the program is under our Office of International Affairs, again which helps with – focus the cooperation between foreign governments and the domestic offices of HSI.

These are just relevant laws that are being used. The unique – well, particularly, I guess on these two slides are that the U.S. law does not require a foreign law to enforce. The U.S. laws that we’re enforcing most commonly are the customs laws: smuggling of goods, entry of goods into the United States through false statements, and trafficking in stolen property. And these are laws that you can enforce for any commodity. They could be enforced for stolen cars, for drugs, or for cultural property.

The role of Interpol on these investigations is really – it’s the center of the cases we work. Interpol is coordinating with overseas entities. They’re creating a database where a victim can go and report an item either looted or stolen. They have photographs. They have descriptions, which we rely on heavily to match items when they are recovered here on the United States.

And this is just a brief example of one of the cases we were working. This is a tomb that was uncovered, I think, in the early ’80s. This is a picture of as it was discovered. A short time later, in 2000, a – this item was brought up for sale in the United States. It’s a carved relief, which was valued at between $400- and $500,000. HSI was contacted through our overseas offices by the Government of China, who informed us that they believe this item was illegally removed from a tomb and exported before being brought to the market in New York.

These are just some of the questions that are – some of the hurdles that have to be overcome in order to be successful in one of these investigations. The – on this particular case, the question was: Can we confirm that the item was illegally removed, and where it will – was it present in China in 1980? And fortunately, there was photographic evidence which actually depicts where the item was removed from the wall. You could see there’s a small void. It looks like a doorway on the right and left. And this is where the relief – this relief that was offered and the second relief was also removed. And here I just included this photo for scale.

This was included – these are ruins. These are present, I believe, in India. One’s in India and possibly Pakistan. And this is just to illustrate that there is a market for the property, even if fragmented.

There is a – the next we’ll show, this is a auction that was in New York this year. And the portion of the foot there was sold for $20,000, and the portion of the Egyptian limestone relief was $6,200. So it really presents an incentive for even a small or independent looter to do work, as we saw earlier, to take portions of antiquity, to break it off, and to move it into the United States, because the market is that strong.

This is an ongoing investigation in New York involving a statue that was looted from Cambodia. It’s presently being prosecuted by the Southern District of New York. Again, this is a – the questions that come about with this investigation, the hurdles that need to be overcome, to be successful and to return this to Cambodia are – they’re two-fold. Really, it’s the question of the law, and when was Cambodia was under French rule and when Cambodia was under independent rule and which laws would apply during the looting – or during the removal, we should say, of this item – and the inventory, where it was in Cambodia.

And these were discovered – these are the feet that belong to the statue. So the question of where it came from was – has been answered, but there’s still – the question remains of when it was removed and what laws applied in that country when it was exported.

And this is a successful investigation we’ve had in New York. It was – we dubbed it Operation Mummy’s Curse. It resulted in four indictments and three arrests. There’s currently one fugitive in the Middle East.

And this I include just to show the market. This is a target’s home. He was arrested. We conducted a search warrant. And this is the attic, I believe, of his home. These are the items. He was purchasing and displaying them. The purchase price of each sarcophagus was in the $300- to $400,000 range.

So it’s a tremendously profitable venture, because when you consider the cost of living, I guess you could say, in the countries where these items are coming from, and the thought that you could excavate, you could recover an item, and with it changing hands two or three times, it could be worth half a million dollars in the United States.

Another fossil – another investigation we are just wrapping up is a Tyrannosaurus – a Tar (ph) – was seized also in New York. The – that investigation was initiated when we received a notification that a fossil was being offered in New York that was extremely rare. There was only five known in existence. And this fossil came about – it was an online auction. It came to the market relatively recently. There was no history, or a limited history, on how – who owned it prior and how many hands it changed through. When we encountered it, this is how it was packed. It was being shipped, I think, in five crates.

The – I think it’s safe to say, or (inaudible) safe to say that the fossil was obtained for roughly $20,000. And there was $100,000 in investment in restoring the fossil. It’s about 80 percent complete. The sale price was $1 million. And the auction was successful. The target did sell the fossil. We intercepted it before it changed hands. And the – this is the repatriation ceremony which occurred within the last six months. We returned it to the (inaudible), Mongolia.

At this point I’m going to turn it over to Debbie Hardos, the program manager for cultural property, who handles the repatriation and the training of our agents.

MS. HARDOS: Thank you, Tom. My name is Debbie Hardos, and I am the program manager at headquarters here in Washington. And I am in charge of the repatriations, or the many happy returns, as we call them. I work with agents or group supervisors such as Tom and his staff of other agents, agents around the world, on bringing these investigations to a close and then getting these objects back to their rightful owner.

The most – well, the Tar (ph) was repatriated in New York in May. This was a collective effort by HSI, ICE, U.S. Attorney’s Office, definitely the Mongolian Government. They were with us every step of the way, and they really did help to move this along rather quickly. But the Tar (ph) was returned to the government. They took it back to Mongolia. And they have since set up in their capital a temporary museum to hold the skeleton. It was reassembled there, and it has commanded quite an audience since it opened several months ago.

We have many other fossils to return to Mongolia. It’ll take a little bit of time. The entire process doesn’t end at the conclusion of the investigation. There’s a forfeiture process which is very, very important for the U.S. Government to get title of this – of these items, and to make sure that there are no other owners out there – or claims, I should say, for any of this property.

The agents in the field are offered an opportunity to come to Washington and to meet with curators, academia, other agents at the Smithsonian twice a year. We have a small group of about 24 agents that come in as well as some – a couple prosecutors and some of our attorneys, and they get together for about three and a half days at the Smithsonian, and they actually get to do hands-on handling of the specimen’s identification, and then they go and they actually go to a practicum where they actually work on a case study themselves. So it’s some of the most in-depth training that we have. We thank our partners at the State Department and the Smithsonian for these opportunities. The program actually became more formalized in 2007 with the training. So we’re relatively young as a program, but we’ve – they really – the agents have really hit the ground running. They leave the training and they are ready to open investigations just about anywhere.

We have a list here of – as I said, when the program became formalized in 2007, then we started keeping more statistics. Prior to that, though, and since the beginning of Customs, we’ve always – they have done repatriations, but in a less formal way, and certainly not as often. Many of the countries here that are represented – I know there are some reporters here, and even if you don’t see a country listed up there, that doesn’t mean that we’re not working with or have an investigation, and that we will be working together at some point.

Some of the countries up there we’ve done more work with recently, definitely Peru. We had a – we have an Afghan repatriation on Monday, and we have many in the pipeline, as I said, that are not listed up there. The Mexico repatriation was one of the largest. That was last October in El Paso. And that was a culmination of about 11 different investigations and many, many seizures. A lot of property was returned at that repatriation. And again, this includes fine paintings, all kinds of pre-Colombian artwork, human skulls. Pre-Colombian skulls were returned to Peru. As Tom mentioned, the definition is quite vast.

This happened just this past week in Korea, and this was the work of agents in New York, Detroit, and Seoul working together to return this Hosan (ph) currency plate dated about in 1893. It entered this country illegally, and we were advised by the Korean Government. We were able to open an investigation and actually close it relatively quickly and smoothly. And it requires the entire forfeiture process, and it came to a happy conclusion on Monday of this week in Korea. Our attaché is represented there as well as the U.S. Ambassador and the Korean officials.

The cultural property program would not exist, I think, as it does in the media without the help of our public affairs people at – in Washington as well as in each of the offices. They are the ones responsible for bringing the media together to get the stories out, and we rely on them tremendously for that. We do have a – if you haven’t visited, we have a website set up, and it does list the – all the most recent news releases as well as videos and photographs as well.

So with that, that’s my presentation. Thank you.

MODERATOR: Thank you both. And with that, we will turn it over to questions. Please remember to state your name and a media organization, and we will start right here.

QUESTION: Hi. I’m Chida Rajghatta from the Times of India. A bunch of related questions: One is you mentioned that at 6-to-8 billion, this is the third most profitable industry. Third-most profitable after what?

And related to that, what other principal countries of origin in terms of – which are the countries which lose – which are losing their heritage or where you have complaints or requests – most complaints or requests?

And thirdly, what is the market here? Who buys this stuff? Particularly something like the Tyrannosaurus. I mean, that’s not something you can hide in a closet. So who would be in the market to buy a million dollar worth of Tyrannosaurus? Would it be museums? Are they individual collectors? How does that work?

MR. MULHALL: Well, the market – and I think part of the reason – I apologize – the market, I think, is based on means. The market is based on the ability to purchase. And I think that’s part of the reason why New York is such a prominent office in working these cases. It’s – we see them in New York, Miami, California.

Who’s buying them? It’s – there are all kinds of millionaires, pretty much, who want to decorate their home with the most expensive and exotic item they could find. That’s what we’ve been seeing.

The countries we’ve been dealing with or that we get the most referrals from, I could say I think are Rome, or from Italy, and that’s the main – our main partner on these investigations. I think that’s probably just because of the relationship that’s built, that has been built over the last few years. We don’t deal with them under any exclusive agreement, but they – we’ve been working with them probably for 15 years or so. So that is where we receive a majority of our leads.

And for the first most – two most profitable criminal ventures, narcotics trafficking is number one, and number two escapes me right now.


MR. MULHALL: Arms trafficking, I apologize. Arms trafficking is the number two, and then culture property, trafficking in art antiquities is the third.

QUESTION: And specifically about the Tyrannosaurus, can you tell us what is the market for it, where was it going?

MR. MULHALL: It was going to stay in New York. It was 24 feet long, eight feet tall, and it was – $1,050,000 was the purchase price.

QUESTION: And the potential buyer was?

MR. MULHALL: That name I honestly --

MS. HARDOS: Somebody with a big house.

MR. MULHALL: Somebody with a big foyer. (Laughter.) But that name, I – honestly, I don’t have it in front of me right now and I don’t think it’s something that was released publicly, because the sale was never complete. The auction house kept the fossil.

MODERATOR: We’ll go right here.

QUESTION: Hi. Ekaterina Katracheva, Focus News Agency at Radio Network Bulgaria. I saw my country in this list, and most recently, over 500 ancient monies were returned – coins were returned to Bulgaria. And my question to you is: Could you share some information about the investigation? Have you traces leading to the perpetrators? And what is the summary of the cooperation with the Bulgarian authorities in this area? Thank you.

MR. MULHALL: Well, the investigation is ongoing. There is a criminal investigation being worked out of Newark, New Jersey. The coins were intercepted in the mail. They weren’t smuggled on a person. They were being shipped via mail, and a hub for the mail is in Newark, based on the port. So that’s why the case is being prosecuted there, and it’s ongoing.

For cooperation, we have a great level of cooperation with Bulgaria. We recently had an agent from New York – I believe two agents from our agency went over to Bulgaria and attended a coordination and a training conference. That was within the last six months.

MODERATOR: Go in the front and then the back.

QUESTION: Hello. Irena Gelevska, I’m correspondent with the Macedonian TV. I’ve been in the United States for a year, a little bit over a year. Since then I’ve tracked three stolen artifacts from Macedonia. One is the bronze (inaudible), which is, or at least was, in the Houston Museum of Fine Arts. And here in D.C. there is Byzantium center of George Washington University which holds icon from Macedonia. It’s St. Paul, or St. Pablo (ph), as we call it. And also the silver collection of George Soros in New York of silver coins.

The problem is when these items are displayed publicly, their country of origin isn’t known. My question is: What do you do in such cases? Do you open an investigation or do you need the proof from the country of origin?

MR. MULHALL: Well, we open investigations when we receive a lead. There’s never a lead that we receive that we throw our hands up and we don’t open an investigation. We open investigations with all leads. The issues with some of the cases are the time of theft and what laws apply when the item was removed. And the country of origin is a strong concern because some of the items we are – involved here predate the nations, they’re from a period in time where maybe a country where the laws were – that applied over that item have since either fallen or there are a new – there’s a new nation in those boundaries.

So it’s something we work at. It’s not – we never really throw up our hands and give up. So I’m sure – I don’t know anything about those specific items; I can’t really comment on them. But I – speaking for New York and for the contacts we’ve had with referrals, cases have gone on for years. We’ve had cases that have taken 8 to 10 years, items are still in storage, and we still are pursuing criminal investigations.

QUESTION: Inga Czerny from Polish Press Agency. I wanted to ask you about the investigation of objects stolen during the Second World War. I wonder if 70 years after the end of the war you can still find some objects. And as I am from Poland, I actually wanted to ask you if you have some current investigation of some objects from Poland. As you know, Poland lost thousands of objects both during the German and Russian occupations. Thank you.

MR. MULHALL: Well, yes, we are still finding items. The currency plate that was just repatriated was removed from Korea, it doesn’t involve Poland, but it was removed from Korea during the Korean conflict, and it came from the market when the servicemen who removed it passed away. And that’s commonly when we see these items enter the market. Servicemen will remove the item as a keepsake or a war trophy, keep it in their home, and then when they pass away the – whoever inherits the item brings it to market, just naturally not knowing where it came from, and that’s when we begin to discover these artifacts. As we approach 70 years, most of the owners, they’re changing hands now.

And Poland – investigations ongoing with Poland, we have one in New York where we’ve been successful in recovering two paintings. One is a modern work and one was looted during the Second World War. And we are still – it’s an ongoing investigation. We’re still making headway in recovering other paintings; I guess we could say that.

QUESTION: My name is Reasey Poch from Voice of America Khymer News Service. Cambodia is definitely on your list, and what – and recently you have returned two important pieces to Cambodia. Could you tell us how many artifacts you have in stock from Cambodia? And is there any immediate plan to return more?

MR. MULHALL: Do you know how many? I apologize.

MS. HARDOS: There are – yes. That’s the short answer. The long answer, though, is that it takes tremendous amount of time to coordinate the right people and the right – and making sure that the forfeitures are complete on these objects before they are returned. So yes, there are returns planned. One of the largest Cambodian investigations going on right now is with the athlete that Tom talked about, and that is – that’s ongoing. So our hope is that this does get – it does come to a closure and that that athlete is returned to its rightful place. But yes, we have plans to return to Cambodia other objects once all of those processes are complete.

QUESTION: How many pieces (inaudible)?

MS. HARDOS: Not off the top of my head.

MODERATOR: Okay. We’ll come up here in the front and then we’ll go in the back.

QUESTION: Good morning. I am Fabienne Faur from Agence France-Presse news agency. I’ve got several questions. What are the most looted countries? We were talking about the buyers, but what about the sellers? Is there real other – really seasoned professionals? Are there gangs, very well organized and so on?

To go back to the buyers again, are they private persons? Do they know usually that they are trying to buy something illegally or not? You said a number of times we have been notified. Who will notify you? I mean, are – do you have connections with art galleries, with auctioneers, that when they suspect something illegal just call you and – okay.

MR. MULHALL: Well, it’s difficult to say the most looted country or region, because the looting may be ongoing now and we’re not aware of it or we’re not enforcing the laws related to that country because we have yet to begin. That’s part of the reason why I think we have a strong relationship with Italy. And then you’ll see there will be an increased activity with Cambodia, because it’s uncharted territory. And the – once the laws are established and once we have success with one investigation, other investigations will follow, because the law will become precedent and you’ll see items – you’ll see a spike in recoveries or a spike in enforcement in a certain region.

The networks are very organized. There is an understanding that the item is relatively easily obtained. It’s difficult to excavate and to uncover, but you’ll see networks that will piggyback or follow a academic excavation that’s going on. And when the students, university students, when they returned from the dig to go back to study, a local population will go into the dig and recover items. And they’ll trade them through a network, knowing that the United States is the strongest market, one of the strongest markets. This is where you’ll recover the most for the item.

And the notifications, really, the agents who work these cases are well trained. The training we receive is outstanding. But we’re not really an expert in all things of art and antiquities in all nations. So really we depend on the victim country, who has the intimate knowledge of the artifact and knows the history and where it belongs and where it come from to contact us and let us know that that item is suspect and we – they have a strong belief that it was illegally removed.

So that’s how the notifications come in. They come in from law enforcement. Law enforcement from overseas will see an auction in New York, and they’ll have just a few questions. They won’t have probable cause to seize that day, but a few questions, and we’ll follow up and make sure those questions are answered.

QUESTION: About the buyers, are they private persons, usually or --

MR. MULHALL: Usually buyers are private. Another issue that we’ve come across is if an item is difficult to sell, it may be donated. That’s when a museum or a university will acquire an item that – this isn’t in all cases, but there are cases where a smuggler will have something, and it’s not quite acceptable for sale in a public market, and in order to relieve themselves of it they’ll donate it to a university, and then we recover it from that university or museum.

MODERATOR: The young lady in the back.

QUESTION: My name is Diana Castaneda from NTN24. It’s a Spanish TV from Colombia. And I want to know if you have more information about how those items entered to U.S., if you have information of how many enter throughout airports, talking about small items.

And I saw that more of those items came from Argentina, Brazil, South America countries, Central America countries, and I want to know how – which one it’s the most common or what kind of items came to U.S. from those countries?

MR. MULHALL: Can you, since it’s like initial, most --

MS. HARDOS: With my experience, and it’s been about three years, there’s a tremendous amount of pre-Colombian pottery, earthenware and things like that from Central America and South America. And it’s just a – there’s a very vast cultural – I can’t think of all of the different cultural names to attach to all of that, but there’s been quite a bit of recovered and repatriated pottery – oh, and the textiles and things like that. So my understanding is that these objects – even mummies are considered now the – an item – items to collect. And you can find websites that sell mummies. So it’s – there’s a tremendous amount of that going on as well. Did that – I’m sorry, did that answer the question? Okay. Okay.

MODERATOR: Okay. (Inaudible.)

QUESTION: Hi. Is there a statute of limitation in terms of time of how you take a case? And also, since you mentioned time of theft and country of origin, can you talk about what legitimate, well-known museums – I mean, they could be having artifacts which they have hosted for many years – for instance, the Hope Diamond. If the country of origin of the Hope Diamond laid claim to it, would that come within your domain to pursue an investigation of how it was acquired?

MR. MULHALL: I can’t comment on the Hope Diamond. I’m not sure about that investigation. But the reason we’re concerned about the theft, the date of theft, is because the enactment of, I guess, the UNESCO Convention, which is in the ’70s. And then the signing of a bilateral agreement between the United States and the victim country is important. That isn’t really – it’s not going to limit the case, but it provides an easier solution. If the country is a signatory to UNESCO and there’s a bilateral agreement between the two nations, that helps us in enforcing cultural property law.

But the customs laws, the smuggling and the entry of goods by false statements, those apply whether UNESCO is involved or not. And it involves importing an item that is stolen. So it could be stolen some time ago, but if it’s imported – the statute of limitations on the smuggling is five years. So if it’s recently imported, it restarts the clock, and it is subject to enforcement. So that’s when you’ll see an item that might have been stolen during the Second World War, but we would seize it here in the United States in 2000 because it was imported for sale through a New York auction house or a West Coast auction house, and it’s a separate crime.

MODERATOR: We have time for two questions. Let’s go to the gentleman in the back first.

QUESTION: Thank you. My name is Oliver Grimm. I write for the Austrian newspaper Die Presse. And my first question is: How is it possible that auctioning houses like Sotheby’s or Christie’s would actually auction stolen, looted arts? In your view as law enforcement agents, are there loopholes in terms of the legal rules for auctioning houses, the way they should look into the providence of pieces of art? I know there’s a very strong lobbying effort by the New York art dealers scene to make sure that there aren’t any too strict rules, but I would be interested in your views on that.

And then secondly, on a concrete case, the theft of several paintings from the museum in Rotterdam, and this sort of really topsy turvy tale of the things turning up in Romania, do you help the Romanian authorities in making sure that these things aren’t being sold on the black market? Because there are rumors that they might have been sold to Russia or to any other post-Soviet place of – what is your role in making sure that these paintings are tracked down and they’re being recovered? Thank you.

MR. MULHALL: Your first question about the auction houses – we, at least in New York, have received outstanding cooperation from Christie’s and Sotheby’s. The current requirement is for a providence to be provided which can be attested to, I guess we could say. So if you were to come to Sotheby’s with a painting and the providence is documented, then they will accept the painting. If they – they do turn quite a few artifacts away in – they do turn away items, but the criminal really wants to create that providence. That’s what would – adds value to an item. You’ll see two very similar items with different histories have vastly different values, and one would be depicted in a photograph in the early 1900s and one will just have a paper providence of bills of sale but all the parties involved are either deceased, or there’s no further way of supporting that providence.

So that’s the level of evidence that they’re using and it’s – well, my personal opinion I really can’t share, but it’s been very successful in New York. It’s – for HSI as a whole for working in these cases, it is effective. And --

QUESTION: Sorry, do they, sorry – do they inform you when they turn down suspect pieces of – suspicious pieces of art?

MR. MULHALL: No. No. Sotheby’s and Christie’s do not inform us usually. We come to find the – in investigations it has been the case we found artwork or antiquities that are at a second auction house or a third auction house. We seize them as stolen, and then through the investigation we come to learn that it was brought to Sotheby’s, and that helps the investigation move along because it shows the person was made aware that the item was questionable. They bring it to a legitimate auction house and the auction house turns them away and says it’s not acceptable for public sale, and then they’ll go to a – they’ll shop it around, and they’ll go to a third and fourth auction house.

And I’m sorry, the – your second question --

QUESTION: Rotterdam, the Rotterdam case, the paintings that were stolen.

MR. MULHALL: We are – we receive alerts, regular alerts, sometimes daily from Interpol concerning thefts, and it’s something that we both alert the Customs and Border Protection at the border to the possibility of the item being imported, and then through our investigative efforts in New York, through sources and informants and people we speak to in the art world, try to determine if it’s in the New York art market. So that would be the level of support we really provide, but a transaction between Rotterdam and Romania, we really don’t have a mechanism to getting records or to find anything out about it.

MODERATOR: And we’ll take our last question from the gentleman in the black cap.

QUESTION: Hi, George Nunez, NTN24. Just two questions. One is, what’s the max legal stats (ph) for a person who is committing these crimes? And number two, is there a message to the people who are about to do such a crime?

MR. MULHALL: The sentence for the majority of the crimes is five years. That’s not to say the sentencing can’t be concurrent. You can be charged with multiple violations for a single criminal act involving the smuggling and the theft and the sale and then the money laundering of the proceeds that are made from the sale, so five years is not the limit that someone could receive.

The – I don’t know if I would have a message for anyone who is thinking of the crime. Again, the question was asked earlier – I don’t think the buyer really understands when – a lot of these cases, the majority of these cases, when we contact a buyer and explain to him that you’re holding something looted, you’re holding something that was stolen, they’re eager to give it back, unless it’s – in a rare case, they would fight the government’s case. But once you lay out the evidence and the details, they understand that it’s – the right thing to do would be to return it to the victim.

MODERATOR: Great. Thank you both for joining us today, and our briefing is now ended.

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