The U.S. Bureau of Land Management (BLM) is steward to vast cultural resources across public lands and in museum collections. Like other land-managing agencies, its resource protection strategy includes Federal enforcement of cultural property laws. Between 2007 and 2013, a case code-named Operation: Cerberus Action recovered more than 100,000 objects, mainly consisting of artifacts from the American Southwest, through undercover operations, evidence gathering, seizure, and forfeiture. Prized by collectors and stockpiled as part of illicit ventures, most of the artifacts have little-to-no provenience. To address the immense quantity of material and best meet the public interest, the BLM developed a decision-tree with criteria to determine appropriate disposition options. This process involved three intensive phases: (1) identification; (2) return or repatriation; and (3) assessment of the remaining items to inform disposition based on specific criteria. In this third phase, artifacts are categorized for curation, education, conveyance to tribes beyond the scope of NAGPRA, another public use, or ultimately, destruction. This paper summarizes the case, addresses the legal foundations for determining ownership, presents the significance criteria for disposition, and concludes with a reflection on the opportunities and challenges of this endeavor, which may guide similar efforts in the future.

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