Advocacy
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.
Comments on UNESCO’s Draft Model Provisions on the Prevention and Fight against the Illicit Trafficking of Cultural Property
Nov 11, 2022
Submission to Cultural Property Advisory Committee, Bureau of Educational and Cultural Affairs, U.S. Department of State, on the Proposed Extension of the Memorandum of Understanding Between the Government of the United States of America and the Government of Libya Concerning the Imposition of Import Restrictions on Categories of Archaeological and Ethnological Material of Libya
Jul 26, 2022
Committee for Cultural Policy and Global Heritage Alliance on the Proposed Memorandum of Understanding (MOU) with the Islamic Republic of Pakistan Submission to Cultural Property Advisory Committee, Bureau of Educational and Cultural Affairs, U.S. Department of State
Apr 26, 2022
Cultural Affairs, U.S. Department of State, on the Proposal to Extend the Agreement Between the Government of the United States of America and the Government of the Republic of Mali Concerning the Imposition of Import Restrictions on Certain Categories of Archaeological Material and Ethnological Material of the Republic of Mali
Jan 25, 2022
Submission to Cultural Property Advisory Committee, Bureau of Educational and Cultural Affairs, U.S. Department of State, on the Proposal to Extend the Memorandum of Understanding Between the Government of the United States of America and the Government of the Republic of Peru Concerning the Imposition of Import Restrictions of Archaeological Material from the Pre-Hispanic Cultures and Certain Ethnological Material from the Colonial Period of Peru
Oct 5, 2021
Meeting of the Cultural Property Advisory Committee Regarding Proposed Memorandum of Understanding at the Request of the Former Islamic Republic of Afghanistan
Sep 21, 2021
Comments on FinCEN Advance Notice of Proposed Rulemaking Anti-Money Laundering Regulations for Dealers in Antiquities
Sep 21, 2021
Committee for Cultural Policy and Global Heritage Alliance Submission to Cultural Property Advisory Committee on the Proposed Request for a Memorandum of Understanding Between the United States of America and the Republic of Albania
Mar 3, 2021
Committee for Cultural Policy and Global Heritage Alliance Written Testimony on the Proposed Renewal of the Memorandum of Understanding Between the United States of America and the Arab Republic of Egypt
Mar 3, 2021
Written Testimony submitted to Cultural Property Advisory Committee, Bureau of Educational and Cultural Affairs, U.S. Department of State, on the Proposed Memorandum of Understanding Between the United States of America and the Republic of Tunisia
Jan 7, 2020
Written Testimony submitted to Cultural Property Advisory Committee, Bureau of Educational and Cultural Affairs, U.S. Department of State, on the Proposed Memorandum of Understanding Between the United States of America and the Republic of Turkey
Jan 7, 2020
Written Testimony submitted to Cultural Property Advisory Committee, Bureau of Educational and Cultural Affairs, U.S. Department of State, on the Proposed Memorandum of Understanding Between the United States of America and the Kingdom of Morocco
Oct 29, 2019
Written Testimony submitted to Cultural Property Advisory Committee, Bureau of Educational and Cultural Affairs, U.S. Department of State, on the Proposed Memorandum of Understanding Between the United States of America and the Republic of Yemen
Oct 2, 2019
Letter from GHA Executive Director Peter Tompa to Congressman Zeldin re HR 2194, the Protecting US Heritage Abroad Act
Apr 29, 2019
Written Testimony on the Proposed Memorandum of Understanding Between the United States of America and the Republic of Chile
Mar 25, 2019
Written Testimony on the Proposed Memorandum of Understanding Between the United States of America and the Hashemite Kingdom of Jordan
Mar 25, 2019
Request to Appear, Summary of Testimony and Prehearing Submission before USTR on China Tariff proposal
Jul 26, 2018
Letter from Global Heritage Alliance President Arthur Houghton to House Financial services on HR 5886
May 24, 2018
Testimony submitted to CPAC on MOU renewal request from Peoples Republic of China
May 2, 2018
Hearing Testimony of Peter K. Tompa, Executive Director, Global Heritage Alliance, Regarding the Revised Safeguard Tribal Objects of Patrimony Act of 2017
Nov 8, 2017
Amicus brief filed in United States of America v. 3 Knife Shaped Coins, No. 17-1625 (4th Cir.)
Jul 12, 2017