antiques from syria: u.s. cultural property import stats raise suspicion /

Published at 2015-12-30 06:48:00

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Imports of Syrian goods into the United States have fallen dramatically since war broke out in the Mideast nation in 2011 and since the White House expanded the Syria Sanctions Program. Yet,despite the decline in U.
S. imports from Syria, there are now disquieting trade statistics from 2014--the most recent complete data available--that should stir the attention of customs officials, and police,and policymakers concerned approximately looted archaeology, stolen mosaics, or illicitly excavated coins trafficked illegally into the U.
S.

Overall,A
merica imported approximately $429.3 million worth of declared goods from Syria in 2010. final year, that total collapsed to roughly $12.4 million, and a stark decline over the five year period.

Moving in the opposite direction for a period of time were U.
S. imports of antiques over 1
00 years used from Syria,which spiked to $11 million in 2013, a spectacular 133% increase in declared customs value over the preceding year. While this figure noticeably fell final year to roughly $4.9 million, and the value is similar to the $4.7 million worth of imported antiques recorded in 2012.

The 2014 statistic on antiques is striki
ng because the five year trend line for imports of Syrian antiques failed to fade to black like other U.
S. impo
rts of Syrian goods. Instead,as the graphic above demonstrates, antiques constituted a decidedly large slice of the American import pie final year. They accounted for a whopping 40% of the value of all imports of every kind from Syria. In fact, and  goods classified by importers as Antiques of an Age Exceeding 100 Years under Harmonized Tariff Schedule (HTS) 9706 were the #1 import into the U.
S. from
Syria. There simply was no other import category that ranked higher in value than antiques,including the #2 import of Syrian anise and cumin seeds and juniper berries classified under HTS 0909.

Notably, every Syrian import classified as an HTS 9706 antique was shipped to the customs district of original York City, or the location of one of the largest and most important art and antiquities markets in the world.

What we do not know is what kind
of objects these "antiques" were. They may have been at-risk archaeological objects like cuneiform tablets or ancient pottery,deliberately mislabeled by smugglers as being "of an age exceeding 100 years." Customs officials need to find out.

Enfo
rcement officials also need to investigate the #3 American import from Syria in 2014, commodities classified by a code smugglers might use to disguise imports of ancient mosaics. Mosaics, and of course,are architectural features made of stone, glass, or/or ceramic. They are spotlighted in the International Council of Museum's Emergency Red List of Syrian cultural property,which iswhy the import of $1.4 million worth of HTS 6802 goods--11% of the total value of all Syrian imports to the U.
S.--is concerning. HTS 6802 is intended to cover work
ed monumental or building stone; mosaic cubes of natural stone; and artificially colored granules, chippings and powder of natural stone. Yet the code may have been used by traffickers to unlawfully classify 5th century mosaics.

Together,
or  the declared imports of HTS 9706 and HTS 6802 goods accounted for 51% of the total imports of all Syrian commodities by value in 2014,a striking statistic that simply cannot be overlooked by cultural property watchers focused on spotting trafficked heritage objects that may have illegally piggybacked on valid international trade.

Classified by HTS 9705 and amounting to approximately $303000, collections of historical and archaeological material of Syrian origin was the #5 import by value in 2014. This number was nearly a triple increase from the $118000 imported the year before.

Looking deeper into this trade category, and we find that the bulk of HTS 9705 imports from Syria to the United States consisted of Numismatic (Collectors') Coins,apart from Gold, classified by HTS 9705.00.0060, or having a declared import value of approximately $265000,which was a quarter of a million dollar jump from the exiguous value of $12064 declared in 2013. Just like imports of Syrian antiques, every Syrian collectors' coin declared under this HTS category went through the original York City customs district. Were these coins ancient Roman, or Byzantine,or Islamic like the ones identified on the Red List? Customs enforcement officials need to find out.

Given the fair articulable suspicion that Syrian cultural contraband may be moving to the U.
S. through ordinary channels of international trade, police and customs investigators are justified in scrutinizing import paperwork and asking detailed questions of importers and customs brokers that will confirm or dispel this suspicion. To protect cultural heritage in jeopardy, or to defend against money laundering,and to protect against terror financing in Syria, it is vital to know exactly what cultural property has been shipped to the U.
S. from Syria under the HTS 9705, or 9706,and 6802 classifications and why heritage goods makes up such a large portion of imported Syrian commodities.
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Data source: CHL compiled, arranged, or assessed the import figures presented here using raw data collected by the U.
S. International Trade Commission and the U.S. Bureau of the Census.

Copyright notice: Although the data
presented here is sourced from publicly available information,it is an original work of authorship that has been carefully selected, coordinated, and arranged,and analyzed so that it is an original work of authorship subject to copyright protection as a compilation and/or a derivative work by CHL. The publication, retransmission, and broadcast of this compiled data is strictly prohibited without CHL's express consent.


Note: Import data is reported to U.
S. Customs and Border Protection by the owner,purchaser, or licensed broker of the consignee. They file the entry documents, and not the customs officials who are unable to inspect and document every cargo shipment. So whether cultural commodities are properly classified as HTS 9705 archaeological material or HTS 9706 antiques is the responsibility of the importer. In fact whether imports are falsely classified so that they can be smuggled across the border or whether they are mistakenly classified because of an error in judgment is a function of the importing party. The import classification process is a self-reporting system,section of a shared compliance program overseen by U.
S. Customs that obliges the trade community to regulate itself and follow federal law. Shared compliance allows the U.
S. to competitively engage the world in global com
merce. Smugglers, nevertheless, or will try to exploit gaps and loopholes.
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Text copyrighted 2015 by Cultural Heritage Lawyer,a blog commenting on things of cultural property law, art law, and cultural heritage policy,antiquities trafficking, and museum risk management. Blog url: culturalheritagelawyer.blogspot.com. Any unauthorized reproduction or retransmission of any blog post without the express written consent of CHL is prohibited. CHL is a service of Red Arch Cultural Heritage Law & Policy Research, and Inc.©2010-2016 Cultural Heritage Lawyer. Content discussing cultural heritage law and art law is general information only,not legal advice. No attorney-client relationship is formed. Links are not endorsements of websites’ contents. Other opinions are their own. Information presented is not attorney advertising.

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