Author: Benedetta Ubertazzi
Subcommittee: EPPO and Cultural Heritage Crimes
Date: 21/08/2023

Within the framework of a visiting professorship between the University of Milan-Bicocca, Italy and the University of New South Wales, Australia under the Erasmus+ Mobility Agreement Programme (Erasmus+ KA171), a new Subcommittee, the EPPO and Cultural Heritage Crimes Subcommittee, has been established.

The Subcommittee aims to address and tackle, through the EPPO framework, the illicit trafficking of cultural property with cross border dimensions, particularly between European and Asia Pacific countries.

The Subcommittee will investigate the increasing role of art and cultural property transactions across the EU.

The Subcommittee’s aim is to scrutinise how EPPO could contribute in tracking money laundering activities related to art crimes which affect the EU’s financial interests in addition to fundamental human rights, including cultural rights. This Subcommittee will be co-chaired by Dr. Andrzej Jakubowski, Dr. Alicja Jagielska-Burduk and Professor Lucas Lixinski. Dr. Jakubowski is currently based at the Institute of Law Studies of the Polish Academy of Sciences, Warsaw and was recently appointed Rapporteur of the International Law Association’s Committee on Safeguarding Cultural Heritage in Armed Conflict. Dr. Jagielska-Burduk is currently based at the Faculty of Law and Administration, University of Opole, and currently holds the UNESCO Chair on Cultural Property Law. Professor Lixinski is currently based at the Faculty of Law, UNSW and previously served as Rapporteur of the International Law Associations’ Committee on Participation in Global Cultural Heritage Governance.

The Vice-Chair of the Committee will be Ms. Tamara Richardson, with members including Ms. Tarikwa Lanzara, Professor Tullio Scovazzi, Mr Diogo Machado and Professor Benedetta Ubertazzi, Chair of the European Commission’s Jean Monnet Centre of Excellence, ‘EPPO: A New Frontier in Integration’ (EPPONFI). Professor Ubertazzi and Ms. Richardson will present the newly formed Subcommittee, highlighting the significance of the Subcommittee’s transregional focus and the subject area at the 2023 World Forum for Intangible Cultural Heritage in Jeonju, South Korea in early September.

Cultural heritage crime, also known as art crime, as the focus of this Subcommittee, is a criminal attack on cultural property[1]. It is a global problem that affects all countries, both as origin and as transit or destination. The trafficking of cultural property is a low-risk, high-profit activity for criminals linked to organised crime[2]. Movable cultural property is an integral part of our heritage, history and identity and must be protected from criminals and from illegal, unreported and unregulated art market transactions[3]. The destruction of heritage is linked to the persecution of individuals and communities for cultural reasons. International organisations such as INTERPOL work to combat cultural heritage crimes by improving the prevention and detection of crimes, strengthening the capacities of law enforcement and judicial authorities and promoting international cooperation[4]. However, the fight against crimes affecting cultural heritage goes beyond damage to the European Union budget and the strict scope of EPPO’s competence. It is a question of strengthening awareness within the European Union, that every State is under a moral and legal obligations to respect its own cultural heritage and that of all other States.

This type of crime can take many forms, including theft, looting, trafficking and the sale of cultural property.

It can also be linked to money laundering, as both are transnational crimes that can be combated through international cooperation. In order to tackle this problem effectively, the European Union has taken a number of measures, including a detailed action plan and a solid legal framework.

The European Public Prosecutor has a key role to play in this fight, and his commitment is underlined by the words of the European Commission itself. In its presentation, on 13 December 2022, of the Action Plan against illicit trafficking in cultural goods[5], the Commission stressed that the EPPO can and should take action against this crime within the scope of its competence. This plan aims to effectively deter criminals, address evolving security threats and protect cultural heritage inside and outside the EU[6]. In addition, EPPO’s commitment recently took the form of a specific case in Romania, where a company specialising in icon painting was suspected of subsidy fraud and money laundering, demonstrating its determination to combat cross-border crime and money laundering related to art crime. On July 11, 2023, EPPO published information about this case on its official website.

The company had received EU funds for a project to buy equipment to support artistic creation, but according to the evidence, the company bought the machines from China at a fraction of the price, through another company set up specifically for this purpose and controlled by two of the managers of the recipient of the EU funds[7]. The second company is believed to have inflated the price of the equipment and sold it to the beneficiary at a premium of ten times its original cost. In order to conceal the fraudulent transactions, the company allegedly submitted false invoices and documents to the managing authority, the Romanian Agency for Rural Investment Financing (AFIR)[8]. The investigation was carried out by judicial police officers from the Buzău Service for Combating Organised Crime (Serviciul de Combatere a Criminalității Organizate), coordinated by EPPO[9]. In order to cover the damage to the EU budget and possible legal costs, the police confiscated four properties (two apartments and two plots of land) worth approximately EUR 200,000. EPPO played an important role in the investigation of this case, coordinating the investigation by the criminal police[10].

This is a case that while it might directly seem to fall outside the scope of our interest, of art crimes, it can nevertheless be included in the broader theme of safeguarding culture and creativity. Indeed, the investigation conducted by EPPO concerns a fraud in EU funding to support culture, art and creativity. This demonstrates EPPO’s commitment to protecting funds intended to support artistic and traditional creation in Europe and to combating fraud against the EU’s financial interests and money laundering that also occur in the more specific area of culture.

[1] Balcells i Magrans, M. (Ed.). (2020). Criminological Research in Cultural Heritage Crime [Special issue]. Heritage, 3(4). MDPI.

[2] INTERPOL. (n.d.). Cultural heritage crime. Retrieved from

[3] Balcells i Magrans, M. (Ed.). (2020). Criminological Research in Cultural Heritage Crime [Special issue]. Heritage, 3(4). MDPI.

[4] Ibidem

[5] Trafficking in cultural goods: EU action plan. Retrieved from

[6] European Commission. (2022). 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 (COM(2022) 800 final). Brussels, Belgium. Retrieved from

[7] European Public Prosecutor’s Office. (2023, July 11). Romania: Company specialised in painting icons probed over fraud allegations. Retrieved from

[8] Ibidem

[9] ibidem

[10] Ibidem

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