GLOBAL HERITAGE ALLIANCE ADVOCATES IN FRONT OF THE THREE BRANCHES OF THE US GOVERNMENT AND INTERNATIONALLY
Before the Legislative Branch
Our Accomplishments
- The sole industry advocate to engage bi-partisan Senate Banking Committee staff on extreme Anti Money Laundering (AML) provisions in House National Defense Authorization Act (NDAA).
- Succeeded in Senate dramatically limiting Anti Money Laundering (AML) provisions included in Section 6110 of HR 6395, the FY21 NDAA Conference, to antiquities and rejecting the House’s plan to impose Bank Secrecy Act requirements on art. Instead, the Senate replaced that provision with a study to determine if there really was a need to impose AML report on art, which the report ultimately determined it was not needed.
- Successfully blocked S 3449, the Terrorism Art and Antiquity Revenue Prevention Act of 2016 (“TAAR”), legislation introduced by the archaeological lobby. That bill would have dramatically lowered the bar for criminal prosecutions based on other nations’ cultural patrimony laws. TAAR empowered federal prosecutors to charge individuals for possession of any object valued over $50 illegally removed from another country. As proposed, the bill would have turned millions of collectors, many businesses that trade in art and antiquities, and hundreds of museums into criminals overnight.
- Notified industry players on FINCEN developing report determining the need for imposing AML restrictions on art. We organized and guided industry input to FINCEN with resulting FINCEN Report indicating no need for AML on industry.
- Testified against bilateral Cultural Property Memorandums of Understanding (MOU) agreements which act as embargoes on cultural goods.
- Engaged and provided testimony to Jewish organizations, B’nai B’rith and JIMENA, to oppose Libya MOU resulting in removal of direct reference to Jewish religious and ceremonial items in that MOU.
- Engaged and provided testimony above Jewish organizations to oppose Algeria MOU.
- Engaged and provided testimony above Jewish organizations to oppose Yemen MOU.
- Engaged and provided testimony to Jewish and Greek (AHI) organizations to oppose Turkey MOU.
- Obtained language in House version of State Authorization to expand the reach of the Commission to Preserve America’s Heritage Abroad to include the Middle East and North Africa.
- In July 2019, during the 116th Congress, obtained burden-of-proof CAFRA language in Section 410 of S. 2066, Senate Saudi/Yemen legislation.
- Global Heritage Alliance led a successful coalition congressional lobbying effort, in conjunction with the Art Dealers Association of America (ADAA), to remove legislative language from the Enablers Act (H.R.5525) which would have made art subject to the Bank Secrecy Act and its money laundering provisions. More specifically, GHA convinced Congressman Joe Wilson, to amend his own amendment and remove art related provisions. The removed provisions would have also required substantial record keeping and the collection of intrusive information that would be available to the U.S. government which could then be shared with a host of foreign governments.
Before the Executive Branch
Before the Judicial Branch