The Armenian Bar Association has prepared and submitted a comprehensive public comment to the U.S. Department of State’s Cultural Property Advisory Committee (CPAC), urging CPAC to deny the proposed renewal of the United States–Turkey Memorandum of Understanding (MOU) on cultural property. The CPAC will convene on September 15–17, 2025, to review Turkey’s renewal request as well as the effectiveness of other cultural property agreements, pursuant to the Cultural Property Implementation Act (CPIA) (90 FR 38196).
If the U.S.-Turkey MOU is renewed without the addition of the Armenian Bar’s suggested checks and balances, Turkey may be further emboldened to assert illicitly that Armenian archaeological and ethnological materials dating back hundreds and thousand of years, even those materials with a provenance before the arrival of Turks in the Armenian homeland, belong to Turkey. Equally perverse, Turkey may be heard to argue that Armenian cultural property currently located in the United States, but which originated on the land mass of current-day Turkey, belongs to Turkey as well and, therefore, must be repatriated.
Concerns Over Turkey’s Cultural Stewardship
The Armenian Bar and its co-signatories maintain that Turkey’s request is not consistent with the intent or standards of the CPIA, which was designed to curb illicit trafficking while ensuring public access to cultural heritage for education, research, and preservation. Turkey seeks sweeping import restrictions on virtually all categories of archaeological material dating from 1.2 million years ago to A.D. 1770, and ethnological objects from the 1st century A.D. to 1923. This, presumably, would include all items of cultural property which are purely Armenian, Greek, Assyrian, Christian or Jewish in nature because the items happen to be located in what is now known as Turkey.
“In the case of the MOU, import restrictions have been implemented without adequate mechanisms to distinguish between cultural property belonging to the Turkish state or Turkish heritage and property originating from persecuted religious and ethnic minority cultural communities,” the Association’s comment states.
The comment criticizes Turkey’s track record of cultural destruction and appropriation, citing the patterns of inaccurate attribution and misappropriation are not mere academic abstractions and that state preservation policies routinely exclude Armenian, Greek, and Assyrian narratives, often reframing sites to obscure their origins. This troubling pattern aligns with recent actions—such as the restoration of the 11th century Christian Cathedral of Ani excluding Armenian narratives—raising concern that Armenian cultural property returned under the MOU could be subject to policies that fail to acknowledge or involve the source communities.
Turkey’s Cultural Imperialism vs. Armenian Heritage Protection
“The United States should not be in the business of enforcing authoritarian cultural policies abroad,” said LucyVarpetian, Chair Ex-Officio of the Armenian Bar Association. “Turkey’s cultural property law systematically denies minority communities—Armenians, Greeks, Jews, Assyrians, and Kurds—access to their own sacred heritage, while using international agreements to legitimize this exclusion.”
The Armenian Bar’s submission also exposes Turkey’s tolerance of domestic looting, particularly the widespread online promotion of definecilik (treasure hunting), often targeting Armenian and Greek heritage sites. Despite this, Turkey presents itself as a protector of antiquities, seeking U.S. enforcement power to block the lawful importation of objects long part of global scholarly, museum, and collecting networks.
Implications for U.S. Museums, Scholars, and Communities
The current MOU and its expansive Designated List have had chilling effects on:
- Academic freedom, as entire categories of research materials become inaccessible
- Museum exhibitions, which are stalled or canceled due to provenance concerns
- Diaspora communities, who are prevented from recovering sacred objects tied to their heritage
- Small businesses, including dealers in textiles, coins, and calligraphy, who face criminal penalties for trading in items with centuries of legal circulation
The Armenian Bar Association’s letter proposes a more effective and balanced approach, including targeted enforcement against actual trafficking routes, transparency in museum collections, and diaspora pathways for restitution and stewardship of cultural items.
A Call for Accountability and Fairness
The Armenian Bar Association urges the Cultural Property Advisory Committee to reject the renewal of the U.S.–Turkey MOU in its current form, and to demand accountability, transparency, and cooperation from Turkey as preconditions for any future agreement.
“Cultural protection must not become cultural erasure,” the letter concludes. “To honor the spirit of the CPIA, the United States must not reward states that destroy heritage at home while demanding protection abroad.”
The Armenian Bar’s letter is supported by a broad coalition of legal, academic, interfaith, and human rights organizations, including:
- Armenian National Committee of America
- Churches for Middle East Peace
- Hellenic Law Society of California
- In Defense of Christians
- International Christian Concern
- National Council of Churches
The letter is also co-signed by prominent scholars:
- Prof. Bedross Der Matossian (University of Nebraska–Lincoln)
- Prof. Barlow Der Mugrdechian (Fresno State University)
- Profs. Ann Karagozian and Taner Akçam (UCLA Promise Institute of Armenian Studies)
- Prof. Christina Maranci (Harvard University)
- Prof. Elizabeth Prodromou (Boston College)
Join the Virtual Open Session
The virtual open session of the Committee meeting will be held on September 15, 2025, at 2:00 p.m. (EDT) using Zoom.
To Observe: Anyone may observe the open session virtually, but they will not be able to speak. It is not necessary to pre-register to observe. If needed, please request reasonable accommodation by email to [email protected] no later than September 8, 2025. It may not be possible to fulfill requests made after that date.
Zoom Information: https://statedept.zoomgov.com/j/1614319681?pwd=lfeXSjBwzy3JNfyOPcqxS9GkgAmp4G.1