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Illegal Archaeological Excavations, Damage Assessment, and Illicit Trade in Ukrainian Cultural Objects: Legal and Traceability Challenges
By Dr. Andris Kairiss
Ukraine, Kyiv and Kyiv Oblast, 20-29 May 2026
1. Scope and activities
The Short-Term Scientific Mission (STSM) examined legal and traceability challenges connected with illegal archaeological excavations, damage assessment, and the illicit circulation of Ukrainian cultural objects. The work was carried out in Kyiv and Kyiv Oblast, hosted by the Institute of Archaeology of the National Academy of Sciences of Ukraine (NASU) and supervised by Dr. Evelina Kravchenko. The detailed agenda of the mission is not reproduced in this summary.
The activities included an introductory meeting at the Institute of Archaeology of NASU, research in the NASU Scientific Archive, a field visit to Moshchun, Ivankiv, and Vyshhorod, a visit to the NASU Archaeological Museum, independent review of websites and online platforms connected with the circulation of archaeological objects, and an expert meeting on heritage protection, illicit trafficking, illegal excavations, enforcement, and recovery practice. This summary omits the detailed agenda table and retains only the main findings and recommendations. [Field visit, May 23, 2026; NASU Scientific Archive research visit, May 22, 2026; NASU Archaeological Museum interview, May 25, 2026; Expert meeting, May 27, 2026]
2. Main findings
Ukraine’s archaeological heritage is highly vulnerable because many sites are located in open landscapes, agricultural zones, coastal areas, construction areas, and territories affected by military activity. Since Russia’s aggression in 2014, and especially since the full-scale invasion of 24 February 2022, archaeological sites, museums, archives, and collections have been exposed to destruction, damage, looting, unauthorized transfer, and illicit trafficking. The most serious risks concern occupied and frontline territories, where Ukrainian authorities and researchers have limited or no access.
The threats are interconnected. Military activity, shelling, fortifications, craters, trenches, illegal excavations, construction, agriculture, and erosion can damage archaeological layers. Once archaeological objects are removed from their context, both their scientific value and their legal traceability are weakened. This is particularly problematic for coins and small metal objects, which are portable, easily sold online or by post, and often presented as objects from old private collections. [Shydlovskyi et al., 2023; Expert meeting, May 27, 2026]
Occupation creates additional risks. Crimea is a particularly acute case: movable collections and immovable heritage, including Tauric Chersonesus and its chora, are affected by occupation-controlled interventions, ideological use of heritage, transfers of collections, and reduced Ukrainian oversight. Several waves of illicit circulation have been identified: objects appearing after the occupation of Crimea and Donbas in 2014; objects removed from museums after the 2022 invasion; and the continuing risk concerning millions of objects held in museums, scientific institutions, archives, libraries, and universities in occupied territories. [Kravchenko and Chaplian, 2025; Kravchenko and Reida, 2026]
Documentation is a central traceability issue. The NASU Archaeological Museum demonstrates careful practice, combining paper-based accounting with local digital tools. However, documentation across institutions remains uneven. Many museums still rely on paper records or local Excel and Word files; the central Museum Fund of Ukraine register contains limited information; and digitization is slowed by lack of equipment, unstable internet, insufficient digital skills, and limited institutional incentives. [NASU Archaeological Museum interview, May 25, 2026; Register of the Museum Fund of Ukraine]
The NASU Scientific Archive is especially important because field reports, transfer acts, collection descriptions, photographs, and archival records may be the only remaining evidence for objects removed from occupied museums or sites. Older reports are often scientific rather than object-identification records, and photographs may be black-and-white, single-angle, or insufficient for reliable identification. More recent collection-description forms, such as those connected with the National Preserve of Tauric Chersonesus, provide stronger identification data but are not part of a unified digital register. [NASU Scientific Archive research visit, May 22, 2026]
Damage assessment is developing but remains fragmented. The instruction and form prepared by UNESCO Antenna in Ukraine and the Institute of Archaeology of NASU provide a structured method for documenting damage to archaeological heritage, including remote monitoring, field inspection, photographic and video recording, mapping, analysis of causes and risks, and submission to competent bodies. However, the reviewed materials do not show the existence of a unified central register specifically for completed archaeological damage-assessment forms. This may weaken monitoring, legal qualification, prioritization of rescue work, and future claims for compensation or restitution. [UNESCO Antenna in Ukraine and Institute of Archaeology of NASU, Instruction; Expert meeting, May 27, 2026]
Legal protection exists but is fragmented in practice. Ukraine has relevant criminal, export-control, museum, archival, urban-planning, and cultural-heritage legislation, as well as international treaty commitments. The key difficulties concern unclear ownership and chronological status of movable archaeological objects; the need to prove an object’s connection to a specific site; the absence of clear criteria for special cultural value; weak control of private collections; lack of specialized law-enforcement structures and training; incomplete registers; and insufficient practical implementation of some international instruments. [Criminal Code of Ukraine; Law of Ukraine ‘On Export, Import and Return of Cultural Values’; Kravchenko and Pidhorna, expert opinion, 2024; Expert meeting, May 27, 2026]
At the same time, digital tools are also being used to document, protect, and support the future recovery of Ukrainian cultural heritage. The Museum Portal provides remote virtual access to museums, while the ARGO Project focuses on Ukrainian cultural and historical heritage, including artworks, historical artifacts, archaeological finds, jewels, bibliophile rarities, and other objects that have fallen into enemy hands. A related Google Form allows information to be submitted about material-culture objects seized or removed by Russia, with the aim of supporting documentation, identification, and future return efforts. These initiatives do not remove the underlying risks, but they demonstrate the importance of digital tools for documentation, public visibility, and future restitution work. [Museum Portal; ARGO Project; Google Form for submitting information about material-culture objects seized by Russia]
Non-material harm should also be considered. Damage to cultural heritage affects identity, memory, community belonging, historical continuity, access to culture, and scientific knowledge. Borodyanka illustrates this dimension: damage to the local history museum and the monument to Taras Shevchenko affected not only physical objects but also the symbolic and emotional landscape of the community. The Banksy murals created on damaged buildings further show how destroyed places can become internationally recognized symbols of civilian suffering, resilience, and solidarity. [Field visit, May 23, 2026; Expert meeting, May 27, 2026]
3. Most significant immediate recommendations
Rapid contact point: Create a single rapid contact mechanism for foreign law-enforcement, customs, postal, museum, auction, and restitution requests concerning detained or suspicious Ukrainian archaeological objects.
Emergency expert response: Establish a verified pool of Ukrainian experts able to identify seized objects quickly, especially coins, metal objects, ceramics, weapons, ornaments, architectural fragments, and materials potentially from Crimea, southern Ukraine, or occupied territories.
Access to reference data: Provide Ukrainian law-enforcement bodies, customs authorities, prosecutors, and authorized experts with free access to scientific databases, archaeological publications, museum records, and image repositories needed for identification and comparison.
Evidence handling: Adopt a protocol requiring high-quality photographs, measurements, descriptions, and chain-of-custody records for detained objects. Soil and corrosion should not be removed before expert examination because they may support provenance analysis.
Legal clarification: Clarify the state ownership and chronological scope of archaeological objects and distinguish site-related offences from offences involving movable archaeological artifacts, so that proceedings do not fail solely because an object has already been removed from its context.
Postal, customs, and online controls: Strengthen postal and customs screening and systematic monitoring of online platforms, auction sites, social-media groups, and collectors’ forums where Ukrainian archaeological objects may circulate.
No legitimization of doubtful objects: Promote a European professional rule that experts, museums, universities, auction specialists, restorers, dealers, and consultants should not attribute, authenticate, appraise, restore, publish, or otherwise legitimize archaeological objects of unknown or doubtful provenance, except for confidential work requested by law enforcement, customs, courts, museums, or restitution authorities.
Military guidance and digitization: Prepare short, practical guidance for military personnel, demining teams, engineers, and civil-military cooperation units on archaeological sites and chance finds. At the same time, prioritize digitization of the records most useful for identification and restitution: inventory books, acts, photographs, field reports, collection descriptions, restoration and exhibition records, and materials from occupied or frontline territories.
4. Strategic follow-up
Longer-term work should strengthen coordination between the Ministry of Culture, the Institute of Archaeology of NASU, museums, archives, local authorities, law enforcement, customs, border authorities, military structures, and foreign competent authorities. A dedicated Heritage Agency or permanent inter-institutional coordination unit could improve urgent responses, register development, and international cooperation.
Ukraine should continue practical implementation of relevant international instruments, including the 1999 Second Protocol to the 1954 Hague Convention, the Nicosia Convention, the 1970 UNESCO Convention, the Valletta Convention, and related standards. Implementation should be translated into amendments to criminal, customs, museum, archival, planning, and heritage legislation, as well as investigative guidelines, training, and expert procedures.
Archaeological expertise should become a mandatory and operational stage in planning, construction, infrastructure development, and post-war reconstruction. Preventive archaeological assessment, emergency damage assessment, and rescue archaeology should be treated as related but distinct procedures. Completed damage-assessment forms should be stored in a secure centralized repository or register.
Selected references
- ARGO Project. Return of Ukrainian Cultural Heritage. Online documentation initiative concerning Ukrainian cultural and historical heritage, including artworks, historical artifacts, archaeological finds, jewels, bibliophile rarities, and other objects that have fallen into enemy hands. Available at: https://argo.page/. Link last checked June 7, 2026.
- Civil Code of Ukraine, No. 435-IV, adopted by the Verkhovna Rada of Ukraine on January 16, 2003.
- Criminal Code of Ukraine, No. 2341-III, adopted by the Verkhovna Rada of Ukraine on April 5, 2001.
- Expert meeting with Dr. Evelina Kravchenko, Andrii Lutsyk, Yaroslava Sementsova, and Dmytro Shevchenko, Kyiv, May 27, 2026.
- Field visit to Moshchun, Ivankiv, and Vyshhorod and expert discussion with Dr. Evelina Kravchenko and Dr. Ivan Zotsenko, May 23, 2026.
- Google Form for submitting information about material-culture objects seized by Russia. Online submission form for reporting information on cultural and historical objects, archaeological finds, artworks, jewels, bibliophile rarities, and other material-culture objects seized or removed by Russia. The submitted information is intended to support documentation, identification, and future return efforts. Available at: https://docs.google.com/forms/d/e/1FAIpQLSeB7nqODJDfRx44DqvMI7MTymfddLrskAxylrxyxqLmo1g2Gg/viewform. Link last checked June 7, 2026.
- ICOM. Emergency Red List of Cultural Objects at Risk – Ukraine. Paris: International Council of Museums, 2022.
- Interview with Dr. Larissa Kulakovska and Dr. Oksana Votyakova, NASU Archaeological Museum, Kyiv, May 25, 2026.
- Kravchenko, Evelina, and Daryna Pidhorna. Current State Management and Control in Sphere of Archaeological Field Researches, Sites and Finds in Ukraine. Expert opinion, 2024.
- Kravchenko, Evelina, and Roman Reida. ‘The Ancient City of Tauric Chersonesus and Its Chora: A World Heritage Site under Threat.’ Acta Archaeologica 96, no. 1 (2026): 42-58. https://doi.org/10.1163/16000390-12341027.
- Kravchenko, Evelina, and Serhii Chaplian. ‘The War in Ukraine and the Evidence of the Illegal Traffic of Cultural Heritage Objects Stolen from Ukraine.’ In Artefacts, Roots, Networks, 107-109. Athens: ANCHISE Project, 2025.
- Law of Ukraine ‘On Export, Import and Return of Cultural Values,’ No. 1068-XIV, adopted by the Verkhovna Rada of Ukraine on September 21, 1999.
- Law of Ukraine ‘On Museums and Museum Affairs,’ No. 249/95-VR, adopted by the Verkhovna Rada of Ukraine on June 29, 1995.
- Law of Ukraine ‘On Protection of Archaeological Heritage,’ No. 1626-IV, adopted by the Verkhovna Rada of Ukraine on March 18, 2004.
- Museum Portal. Virtual museum portal providing remote access to Ukrainian and international museums. Available at: https://museum-portal.com/. Link last checked June 7, 2026.
- NASU Scientific Archive research visit and materials examined, May 22, 2026.
- Register of the Museum Fund of Ukraine. Online register of museum objects and museum collections belonging to the state part of the Museum Fund of Ukraine. Available at: https://museum.mincult.gov.ua/. Link last checked June 7, 2026.
- Shydlovskyi, Pavlo, Ian Kuijt, Viacheslav Skorokhod, Ivan Zotsenko, Vsevolod Ivakin, William Donaruma, and Sean Field. ‘The Tools of War: Conflict and the Destruction of Ukrainian Cultural Heritage.’ Antiquity 97, no. 396 (2023): e36, 1-7. https://doi.org/10.15184/aqy.2023.159.
- UNESCO Antenna in Ukraine and Institute of Archaeology of the National Academy of Sciences of Ukraine. Instruction: Form for Assessing Damaged Archaeological Heritage Objects. Methodological instruction, n.d.
- UNESCO. ‘Damaged Cultural Sites in Ukraine Verified by UNESCO.’ Continuously updated online resource on verified damaged cultural sites in Ukraine. Available at: https://www.unesco.org/en/ukraine-war/damaged-cultural-sites. Link last checked June 7, 2026.
- Violity. Online collectors’ and sales platform reviewed in connection with the circulation of archaeological and collectible objects. Available at: https://violity.com/. Link last checked June 7, 2026.