Robbery during the Holocaust: The Language of Robbery and the States Allied to Nazi Germany

Abstract

The systematic robbery of European Jews was a crucial aspect of the Holocaust. While it is undisputed that Nazi Germany was the principal initiator and organiser of the Holocaust, this article examines the robbery of Jews in countries that joined the Tripartite Pact of the Axis powers, using Italy, Hungary, Romania, Slovakia, Bulgaria and Croatia as examples. Was there a shared pattern in the widespread robbery of Jewish property? To what extent was the term ‘Aryanisation’ applied in the states that were allied to Nazi Germany? Through an exploratory approach that combines different methodological perspectives, this article traces the language of robbery used to frame and justify the robbery of Jews during the Holocaust. This framing, emanating from Germany and Austria, also played a key role in the institutionalisation of robbery in the states allied to Nazi Germany. By examining these states from a comparative perspective, the article highlights the similarities in the institutionalisation of robbery, its framing and the competition for booty. Focusing on these commonalities, this approach seeks to explain more fully the phenomenon of robbery on a European scale. The article adopts an integrated history approach, emphasising a European perspective. Primary sources for this study include the 16-volume edition of The Persecution and Murder of the European Jews by Nazi Germany 1933–1945.

The systematic robbery of Jews was an integral aspect of the Holocaust. ¹ This robbery did not occur in isolated, spectacular incidents but rather as a widespread practice within the broader context of National Socialism. For Jews facing persecution, the disposal of their property became a matter of survival. ² While Nazi Germany was the principal force behind the Holocaust and the plunder of the Jewish population, the support from accomplices in occupied and allied countries contributed to the reach of Nazi rule. ³ Given that the phenomenon of the robbery of Jews also occurred in sovereign states allied to Nazi Germany, ⁴ this article seeks to explore whether there was a common pattern in the widespread robbery of Jews in those states. To what extent was ‘Aryanisation’ implemented in these states allied to Nazi Germany? Can ‘Aryanisation’, its institutionalisation and framing, be compared with terms like ‘Romanianisation’, ‘Bulgarisation’ or ‘Slovakisation’?

To answer these questions, I will first introduce my sources and methods, adopting an exploratory approach that combines various methods. While ‘Aryanisation’ is well-researched in the context of Nazi Germany, ⁵ I will contextualise it further by outlining the language of robbery, which was part of the broader linguistic framework of National Socialism. This language has been analysed in depth by scholars such as Victor Klemperer, Nachman Blumental, as well as in subsequent studies. ⁶ Next, I will compare the robbery of Jews in the states allied to Nazi Germany, focusing first on the institutionalisation of robbery and its ideological framing, and second on the competition for booty between these states and Germany. I will examine this through the examples of Italy, Hungary, Romania, Slovakia, Bulgaria and Croatia, following the order in which they joined the Tripartite Pact with the original Axis powers. ⁷ In the conclusion, I will elaborate on the extent to which the language of robbery can help to explain the phenomenon on a European scale, and what insights can be gained into the understanding of National Socialism from this perspective.

1. Sources and methods

To investigate the phenomenon of robbery from a European perspective, the edition The Persecution and Murder of the European Jews by Nazi Germany 1933–1945 (VEJ) ⁸ served as the main source material. ⁹ It provides scientifically annotated documents from the entire social spectrum of the states occupied by and allied to Nazi Germany – based on Raul Hilberg's classification of perpetrators, victims and bystanders ¹⁰ – available in both German and, in part, English translation. Noting that Hilberg identified at least 20 ‘languages of Holocaust research’, ¹¹ this edition allowed a transnational approach without the immediate obstacle of language barriers. ¹² In my research, I assumed that the volumes were representative of the available sources. The edition enabled me to adopt a cross-border approach focused on the states that joined the Tripartite Pact, while also pursuing an integrated history of the Holocaust as suggested by Saul Friedländer. ¹³ Using the potential of this Europe-wide source edition, I analysed the documents with a specific focus on robbery. The documents from the volumes were searched for their relevance to robbery and then examined for similarities and differences, structures and narratives. Simultaneously, I traced the phenomenon of robbery along temporal and spatial axes of analysis. This approach builds on the work of Hilberg, who argued that Germany had tried, practiced and slowly radicalised the persecution and robbery of the Jewish population over time. With Germany's attack on the neighbouring countries, particularly with the invasions of Poland, the Kingdom of Yugoslavia and the Soviet Union, the Nazi regime spatially extended the practices rehearsed in Germany and in Austria after the ‘Anschluss’, but in an increasingly accelerated and intensified manner. ¹⁴ The Axis powers and their allies introduced similar antisemitic measures, especially concerning the practices of robbery. Whereas Hilberg identified chronological stages of persecution – ‘definition’, ‘expropriation’, ‘concentration’, ‘destruction’ – this article, following Dan Michman and Martin Dean, ¹⁵ assumes that robbery was present throughout all these phases of National Socialist rule.

Drawing on Friedländer's concept of an integrated history, I analysed both sources of perpetrators and of the persecuted. In analysing testimonies of the Jewish population, this approach takes into account criticisms of subsuming varied written legacies – such as diaries, farewell letters or reports – under the term ‘testimonies’; the inherent logic of autobiographical text forms, as well as the context of text production, should not be ignored. Nevertheless, the testimonies were used as sources of information, ¹⁶ for example by identifying argumentation patterns, narratives and topics. ¹⁷ In analysing the perpetrators’ language, this article does not aim to conduct a linguistic analysis but instead draws on the ‘Jüdische Sprachkritik’, ¹⁸ the historical reflection on the language of the Nazi era in early Holocaust literature by Survivor Scholars, such as the historian and member of the Jewish Historical Commission in Poland, Blumental. According to Nicolas Berg, Elisabeth Gallas and Aurélia Kalisky, this analysis of the perpetrators’ vocabulary has become a method of historical cognition. ¹⁹ These approaches highlight the significance of language in understanding National Socialism, showcasing language analysis as a historical method. They emphasise the active element of language, which Berg, Gallas and Kalisky refer to as the ‘Agentivität’ of language. ²⁰ The article seeks to apply this approach in an exploratory manner. To trace the trajectories of the language and the phenomenon of robbery into the states allied to Nazi Germany, I will also employ a comparative approach. Rather than focusing on differences, my analysis will concentrate on similarities and general patterns. ²¹ Acknowledging the challenges that comparing states may present, such as the risk of overlooking national differences ²² and the complex relationships between states, ²³ this comparison seeks to emphasise the similarities in order to better describe and understand ²⁴ the phenomenon of robbery in Europe. By comparing the institutionalisation of robbery, its ideological framing and interstate competition, I aim to explore the extent to which similar patterns can be found in the states allied to Nazi Germany. In this comparison, Germany is present in an asymmetrical manner. ²⁵ It serves as the starting point and functions as a backdrop for the analysis. While the sources primarily come from the VEJ edition, the article also builds on important case studies that already exist for the different countries.

2. The language of robbery

Antisemitic justification strategies accompanied acts of robbery, not only those carried out by Germans but also those perpetrated by their non-German accomplices across Europe. This antisemitism has deep roots in the centuries-old antisemitic traditions in Europe, which were firmly embedded in cultural imagery, especially in Germany. The economic persecution of Jews in other European regimes was similarly based on this very tradition. ²⁶

Constantin Goschler and Philipp Ther have pointed out that the historical terms for material persecution, such as ‘Aryanisation’, are imprecise and have racist connotations. However, since, in their view, there were no alternatives, they suggested using these terms in order to consider the different levels of ‘legality’ and of direct and indirect violence. Depending on the context, they therefore suggested speaking of ‘Aryanisation’, ‘liquidation’, ‘expropriation’, ‘plundering’ or ‘robbery’. ²⁷ In contrast to this proposal, but nevertheless building on their work, I subsume all these practices under the term of ‘robbery’. In light of the critique and the ‘Agentivität’ of language, the term ‘language of robbery’ is intended to emphasise how the imposition of particular linguistic expressions, along with the creation of neologisms, shapes and frames the possibilities for thinking and acting while anchoring ideologies. ²⁸ The language of robbery concealed the expulsions, deportations and murders, while also providing legal and moral guidance and a framework for predatory practices.

The pillars of the semantic universe of robbery were terms such as ‘Jewish assets’, ‘Jewish money’ and ‘Jewish property’. ²⁹ All these terms are preceded by the antisemitic definition that first created the racially defined figure of ‘the Jew’ and made it tangible for National Socialist politics. ³⁰ The same applies to ‘ownerless’, ‘available’ and ‘abandoned Jewish property’, which framed looted property as a chance discover that consequently ‘had to’ be ‘secured’, rather than the product of violence. ³¹ In his publication on the language of Nazi Germany, Blumental listed numerous terms that refer explicitly to the practices of robbery, including ‘Beschlagnahme’, ³² ‘Beschlagnahmungsurkunde’, ³³ ‘jüdische Bestände’ ³⁴ , ‘Goldjuden’, ³⁵ ‘Gut, jüdisches’ ³⁶ , and even a term like ‘Armbanduhr’, ³⁷ which was a coveted object of the pursuers. The language of robbery converged on antisemitic narratives, such as that ‘the Jews’ were rich and that they had taken this wealth from ‘national property’. According to this logic, the state and the non-Jewish population were called upon to ‘take back’ this property. ³⁸ In Austria, party members called the wild ‘Ayanisations’ ‘Wiedergutmachung’. ³⁹ This idea persisted after liberation. Looking at post-liberation terms such as the German word ‘Rückerstattungsgeschädigte’, ⁴⁰ translated as ‘victims of restitution’, meaning profiteers who demanded ‘restitution’ because they were required to return stolen property, a continuity is evident. The war was over, yet profiteers still lived in the homes and among the belongings of the dead and deported and refused to return them. ⁴¹ The language of robbery also rested on the belief that those robbed would soon be ‘gone’ and would never come back to reclaim their property. Many of those affected recognised this desire in the behaviour of their neighbours who had profited from robbery or had directly participated in persecution. ⁴²

As an ideological term and euphemistic slogan of Nazi propaganda, ‘Aryanisation’ – to make something ‘Aryan’ – contained a direct call to turn words into deeds. Analysed as a social process and as a state project, ⁴³ the term reflects the interaction between ‘wild Aryanisations’ carried out by party members and non-Jewish citizens, and the state's aim to centralise, control and profit from the robbery. ⁴⁴ It encapsulates the process of institutionalising robbery, which had its precedents in Nazi Germany from the 1930s ⁴⁵ but intensified and accelerated with the so-called Anschluss of 1938. ⁴⁶ In Austria, new institutions were established to connect expulsion and robbery and to centralise these processes, including the ‘Zentralstelle für jüdische Auswanderung’ ⁴⁷ and the ‘Vermögensverkehrsstelle’ ⁴⁸ to regulate the ‘wild Aryanisations’ and later to oversee the trustees of the robbed businesses. In addition, the ‘Regulation on the Registration of Jewish Assets’ ⁴⁹ was issued during this period. These processes were accompanied by corruption and nepotism. ⁵⁰ From 1938 onwards, the Axis states likewise radicalised the robbery and its framing. Institutions for robbery emerged based on the concept of ‘Aryanisation’ but were adapted to fit each state's nationalist traditions and used for their own purposes, such as the pre-existing terms ‘Romanianisation’ ⁵¹ , ‘Bulgarisation’, ⁵² ‘Slovakisation’. ⁵³

The language of robbery provided profiteers with a vocabulary and framing that enabled them to label their actions so that they did not consider themselves thieves, even though robbery remained a criminal act under National Socialism. The regime only referred to such acts as robbery when it did not directly benefit from them, ⁵⁴ especially in the countries it invaded. This attitude was recognised by many of the persecuted. ⁵⁵ When non-Jews plundered their Jewish neighbours, they were deemed to have stolen state property and were threatened with punishment. ⁵⁶

The extent of robbery is also evident in languages other than German. The Polish expression ‘pożydowski’ ⁵⁷ meant ‘post-Jewish’, illustrating that parts of the population knew about the robbery and were able to recognise former Jewish assets decades after the liberation. ⁵⁸ The Dutch verb ‘pulsen’, named after the moving company Puls, stood for emptying out Jewish apartments after deportation. ⁵⁹ The term ‘Bewarians’ ⁶⁰ is likewise Dutch and describes a phenomenon mentioned frequently in the testimonies of the persecuted from other countries: neighbours who pretended to take over Jewish belongings to save them but in fact kept them for themselves. ⁶¹

Contrary to the language of robbery, there have always been voices opposing it; voices that did not use the Nazi language but named events as robbery and consequently fought against it. These voices came from those affected, from governments in exile and from resistance groups. For example, in the 1930s/40s, organisations like the American Jewish Joint Distribution Committee and the Institute of Jewish Affairs sought to collect evidence of the robbery in Germany and Europe to prepare plans for restitution. ⁶² Following their liberation in the winter of 1942, Algeria and Tunisia were among the first countries in which questions of the ‘change of ownership under German rule’, ⁶³ and thus of restitution, were discussed. Likewise, affected Jews documented individually in reports, letters and diary entries how they experienced and analysed the robbery. ‘The robbery of Jewish assets began,’ ⁶⁴ wrote the Viennese doctor David Schapira about the annexation (‘Anschluss’) of Austria to Germany in 1938. The author addressed the language of robbery by putting the relevant terms in quotation marks: ‘From the very first days, uniformed and non-uniformed Nazis began to plunder Jewish shops, sorry - to ‘requisition’ them. (…) Soon the legal robbery began by the commissioner-managers, who had the task of ‘liquidating’ or ‘Aryanising’ the Jewish shops’. ⁶⁵ Other examples were the legal resistance strategies of individual Jews as well as Jewish communities, which were described by Ionescu using the example of Romania ⁶⁶ but can also be extended to the Axis powers. The persecuted addressed letters of complaint to state authorities to obtain exceptions or to demand an end to the robbery and expulsion. ⁶⁷ Their voices show that the language and policies were always contested.

3. ‘Aryanisation’ in the Axis powers?

The concept and the practice of ‘Aryanisation’ became integrated into the respective nationalist projects of the Axis powers. By using ‘Aryanisation’ for their own purposes, these countries found themselves in a competitive situation with Germany over the profits. What they shared was the desire to minimise Germany's influence on their national economies while simultaneously viewing the property of Jewish residents as national assets to be claimed against Germany and German minorities. ⁶⁸ As in Germany, the states allied to Nazi Germany enacted laws to define Jewishness and institutionalise robbery, particularly from 1938. Several institutions and laws, created specifically for this purpose, administered robbery within the states that joined the Tripartite Pact. ⁶⁹ They employed similar framing when they confiscated Jewish property for the benefit of the state, often using antisemitic rhetoric such as ‘taking back’ property. ⁷⁰ At the same time, they promoted a racist social policy, ⁷¹ arguing that the wealth should be ‘returned’ to the non-Jewish population. This article does not quantify this policy, but focuses on the argument as propaganda, serving as both a promise and justification. The Axis powers aimed to create a supposedly homogeneous ‘nation’ based on the exclusion of minorities and rooted in antisemitic and racist ideas. ⁷² As in Germany, expulsion from professions, taxes, the registration of assets, blocked bank accounts, trusteeship, forms and regulations and auction lists – numerous institutions were tasked with locating, calculating, collecting, moving, redistributing and keeping ‘Jewish wealth’, accompanied by corruption and nepotism. ⁷³ There was active exchange and open communication about robbery and persecution: officials travelled to Germany and German ‘experts’ advised the Axis powers. Germany served as an example and a model, and, through its deadly expansion policy, it created a space for inspiration, resonance and pressure to implement antisemitic measures. ⁷⁴ The similarities are demonstrated here by comparing the institutionalisation of robbery and its framing as well as the competition over booty using the examples of Italy, Hungary, Romania, Slovakia, Bulgaria and Croatia. ⁷⁵

4. Institutionalisation of robbery and its framing

Italy enacted antisemitic laws from the summer of 1938 – partly modelled on Germany and partly on its own racist system in the East African colonies ⁷⁶ – accompanied by numerous decrees. One of these legislative decrees in February 1939 announced the establishment of ‘the Real Estate Management and Liquidation Agency’, the ‘Ente gestione e liquidazione immobiliare’ (‘Egeli’), which worked closely with the ‘Department for Jewish Property’ in the Ministry of Finance. ⁷⁷ The regime campaigned to render ‘Jewish capital’ available to the ‘nation’ ⁷⁸ and adopted the term ‘arianizzazione’ ⁷⁹ from the German context. Until 1943, the ‘Egeli’ and other ministries issued an increasing number of decrees, expanding robbery and other discriminatory measures. ⁸⁰ The robbery in Italy was not linked to deportation until the establishment of the so-called ‘Republic of Salò’, the fascist rump state under Mussolini in 1943, where the ‘Egeli’ continued its business. ⁸¹

While Italy robbed its Jewish population within Italy and framed it as a way to benefit ‘needy citizens’, as a fascist newspaper wrote, ⁸² it nonetheless protected its Jewish citizens in countries such as Croatia, Greece and Tunisia. ⁸³ Sara Berger has explained this behaviour by reference to the different strategies of Mussolini and certain Italian diplomats, who saw themselves as acting in an aristocratic tradition. ⁸⁴ Unlike other states allied to Nazi Germany, Italian diplomats not only claimed the property of Jewish–Italian citizens abroad but also stressed that these citizens represented state interests in trade and finance, to the great annoyance of the Germans. ⁸⁵

In 1920, the Hungarian Parliament was the first in Europe to pass a ‘Numerus Clausus Law’ directed at Jewish students. ⁸⁶ But it was only in 1938 that the Hungarian government under Miklós Horthy began to issue antisemitic laws at regular intervals, almost all of which contained paragraphs regulating the robbery of the Jewish population. In May 1938, the ‘First Jewish Law’ restricted access to the labour market; in May 1939, the ‘Second Jewish Law’ defined who was to be considered a ‘Jew’ and again restricted access to various professional groups. The ‘Third Jewish Law’ further extended the practice of robbery. ⁸⁷ Institutions like the Hungarian ‘Institute for the Research of the Jewish Question’ in Budapest, ⁸⁸ together with the government and sections of the non-Jewish population, shared the antisemitic narrative that it was necessary to ‘return’ the ‘wealth of the Jews’ to the ‘nation’ from which the Jews had stolen it. ⁸⁹ The Hungarian government, which referred to Germany as a ‘model,’ ⁹⁰ gradually pushed the Jewish population out of the economy and workplaces. In contrast to the other Axis powers, Hungary did not create institutions of robbery until 1944 but instead empowered several ministries to impose antisemitic measures. ⁹¹ The term ‘Magyarisation’ played a role in Horthy's politics, but it referred more to a language policy; for example, he spoke of the ‘Magyarisation’ of Slovak or ‘Ruthenian names’. He insisted that ‘Jewish names’ should only be converted into a Hungarian version in individual cases. ⁹²

With the German invasion of Hungary in March 1944, the Jewish population was robbed by the occupying forces, and robbery was linked to the deportations. ⁹³ The new Hungarian government continued the robbery to its advantage ⁹⁴ and sought to involve multiple actors, such as municipalities and other authorities, in the process. ⁹⁵ The government authorised local authorities to distribute Jewish property to the local population at their own discretion. ⁹⁶ The institutionalisation of robbery, including the introduction of new terminology, is documented in a letter from the government commissioner Árpád Toldi to the Minister of the Interior Gábor Vanja in late January 1945, concerning the regulation on ‘former Jewish property’. The words ‘Jewish’ and ‘Jew’ were to be deleted from the name of the authority because, it was argued, there was no longer any ‘Jewish’ but only ‘national’ property. The authority should therefore be renamed ‘National Authority for Assets passed to State Ownership’, ‘Államraszállt Vagyonok Országos Hatósága’. ⁹⁷

In Romania, the Ministry of National Economy promoted and monitored the ‘Romanianisation’ of the economy. The Ministry of Health, Labour and Social Work ⁹⁸ housed the Central Romanianisation Office (Oficiul Central de Românizare) ⁹⁹ , established in 1939, and controlled the ‘Romanianisation’ of employment through inspectors. ¹⁰⁰ The National Romanianisation Centre (Centrul Naţional de Românizare) was subordinate to the State Under-Secretariat for Romanianisation, Colonisation and Inventory and was responsible for the expropriation of rural and urban property, the distribution of robbed goods to ‘ethnic’ Romanians and the transfer of assets to state property. ¹⁰¹ Antonescu promoted ‘Romanianisation’ and a nationalist Europe without Jews. ¹⁰² The regime sought to create a ‘Romanian’ middle class that defined itself through its non-Jewishness. Accordingly, ‘Romanianisation’ was directed against Jewish Romanians, as well as against Roma and, to varying degrees, other national minorities such as Bulgarians and Ukrainians. ¹⁰³ Romania attempted to implement a racist social policy by involving the non-Jewish population in the robbery. It distributed apartments, furniture and clothing, held auctions outside deportees’ houses and donated to ‘charity’ organisations. ¹⁰⁴ Even when the regime stopped the deportations in the autumn of 1942, it continued to pursue ‘Romanianisation’. ¹⁰⁵ In August 1943, Antonescu ordered that a portion of the money extorted from the Jewish population be handed over to the Committee of Welfare for Social Works, the foundation of his wife Maria Antonescu. Receipts, Antonescu emphasised, were not required. ¹⁰⁶

Slovakia, under Jozef Tiso and his party, Hlinka's Slovak People's Party, passed a series of ‘Aryanisation’ laws to regulate robbery from 1939. ¹⁰⁷ One of Slovakia's goals was to create a ‘Slovak middle class’, defined primarily as non-Jewish. ¹⁰⁸ Tiso's justification for enrichment followed an antisemitic pattern: he argued that the state was not carrying out ‘robbery’ but that the ‘Slovak nation’ was ‘taking back’ what ‘the Jew’ had previously taken away. ¹⁰⁹ The Central Economic Office was known as the ‘Aryanisation Office’ ¹¹⁰ and was set up by Prime Minister Vojtech Tuka in September 1940. His protege Augustín Morávek headed the office. The idea was initiated by Dieter Wisliceny, a so-called ‘Judenberater’ in the office of Adolf Eichmann, whom Germany sent to Slovakia as an advisor on robbery and murder. Also involved in the robbery and its connection to deportation was the ‘Judenzentrale’. ¹¹¹ The state, the Slovak population and the ‘Volksdeutsche’ benefited from this antisemitic policy, as did local administrations and members of the party and the Hlinka Guard. ¹¹² The Slovak turnaround in deportation policy in November 1942 ¹¹³ did not mean an end to the policy of robbery. Until after the Slovak uprising against the Tiso regime in August 1944, the state continued to rob the Jews. ¹¹⁴

The Bulgarian Prime Minister Bogdan Filov appointed Petăr Gabrovski, a member of the far-right party of the Ratnici, as Interior Minister in 1940. Already in the autumn of 1940, six months before joining the Axis in March 1941, Aleksandăr Belev – working at the Interior Ministry at that time – was drafting an antisemitic law based on the German model. It came into force in January 1941 with the approval of the National Assembly and the Tsar as the euphemistically called ‘Law for the Protection of the Nation’. ¹¹⁵ Belev then worked under Gabrovski in the ‘Commissariat for Jewish Affairs’, the ‘Komisasrstvo za evreiskite vuprosi’, also called the office for ‘Bulgarization’, which Filov established by decree in August 1942. ¹¹⁶ In the spring of 1943, this institution employed over 100 permanent and almost 60 temporary employees to register the Jewish population and their property and to draw up deportation lists. ¹¹⁷ The government also secured legal means to give the ‘Public Aid Organisation’, a state organisation oriented on the ‘National Socialist Peoplès Welfare’, access to the booty. ¹¹⁸

When the Bulgarian regime in 1943 stopped preparing deportations from so-called ‘core Bulgaria’, ¹¹⁹ the state within its borders after World War I, it nevertheless continued the robbery as part of the ‘Bulgarisation’ project, aimed against the Jewish, as well as the Serbian, Greek and Roma parts of its population. ¹²⁰ At the same time, the Bulgarian authorities handed over the Jews in the newly conquered territories in Macedonia, Thrace and Pirot to the Germans for deportation, ¹²¹ robbed them of their possessions and redistributed these to the non-Jewish population. ¹²²

In Croatia, the fascist party under the dictator Ante Pavelić immediately began to implement a German-style programme of robbery and murder at a rapid pace, issuing decrees modelled on the Nuremberg Laws. ¹²³ In the German-controlled part of the ‘Independent State of Croatia’, founded in April 1941 with German and Italian support after the Nazi regime's invasion of the Kingdom of Yugoslavia and Greece, ¹²⁴ the Ustaše regime created the euphemistically called ‘State Office for Renewal’, ‘Državno ravnateljstvo za ponovu’ (‘Ponova’), also known as ‘Office for Aryanisation’, in June 1941, which reorganised itself several times in order to administer the robbery of the Jewish, as well as the Serbian and Roma, population under a single authority. ¹²⁵ In the ‘State Office for Renewal’, lists of the robbed property of the Jewish population were compiled, as were lists of the ‘trustees’ of shops, companies and apartments. Before the deportation, it sent out forms in which the Jewish population were required to provide precise information about their property. Further instructions were intended to regulate into which local bank or cooperative the robbed goods were to be deposited. ¹²⁶ The ‘State Office for Renewal’ also demanded the broad participation of the non-Jewish population: Teachers, professors, court staff, tax and financial officials, civil servants, police, district personnel, the Ustaše, the army – all were to become accomplices by organising the robbery and receiving a share of the booty. ¹²⁷ At the same time, the Pavelić regime demanded that inhabitants hand over all possessions that they had already taken from their Jewish neighbours, on the grounds that the profit belonged to the state. ¹²⁸ While the German term ‘Arisierung’ can be found in the German documents, ‘Arizacija’ rarely appears in the Croatian documents, and ‘Croatisation’ does not appear at all. Instead, the term ‘nationalisation’ is used in the sources, as well as phrases such as ‘the economy should pass into Croatian hands’. ¹²⁹

5. Competition for the booty and negotiations of ‘Aryanisation’

In Italy, the competition for a share of the spoils became acute with the German occupation of the northern parts of Italy in September 1943. With the occupation also arrived the T4 Reinhardt men, the mass murderers from the extermination camps in Poland, who had set up a complex robbery network and had become ‘experts’ in murder and robbery there. ¹³⁰ Mussolini then enacted a law that declared all Jewish property to be state property and set up new offices in the remaining state territory to administer the robbery. ¹³¹ At the same time, the Germans declared ‘the Jewish assets’, ‘das jüdische Vermögen’, in the ‘Operationszone Adriatisches Küstenland’, as they called this part of northern Italy, to be their property. ¹³² Although the ‘Operationszone’ did not coincide with the territory conceded to Mussolini, competition between the Germans and Mussolini arose over the question to whom the robbed property belonged. ¹³³ In April 1944, for example, the Italian Foreign Ministry [Ministero degli Affari Esteri] complained to the German Embassy that the German authorities continued to ‘confiscate’ ‘Jewish assets’. It stressed that this behaviour was contrary to Mussolini's instructions to carry out ‘confiscations’ of real estate and assets for the benefit of the Italian state and to hand them over to the EGELI. ¹³⁴ The EGELI was to be responsible for the use of ‘former Jewish furniture and property’, of ‘mobili ed immobili ex ebraici’. ¹³⁵ This dispute about the Jewish property continued until liberation. ¹³⁶

In the North African countries such as Tunisia, there was another state, with which Italy negotiated over the robbery: Vichy France, which wanted to maintain colonial rule and had the Vichy regime's instructions implemented there. With the aim of protecting ‘Italian interests’ against France, the Italian Foreign Ministry defended Italian Jews in Tunisia against Vichy's antisemitic laws. ¹³⁷ Also in Tunisia, the SS-man and German ambassador Otto Abetz complained about the ‘Aryanisation’ in a letter to the Foreign Office. He was upset that the Vichy Regime would have ordered ‘Aryanisation’, but that Italian Jews then had acted as buyers. He asked the Foreign Office to intervene with the Italian government to ensure it would accept the ‘Aryanisation’ of Italian companies and to prevent Italian Jews from acting as buyers in ‘French Aryanisations’. ¹³⁸

In Hungary, too, German diplomats observed the robbing of the Jews. The ‘Volksdeutsche’ in Hungary wanted a share of the booty. Nazi Germany's diplomatic representation saw itself as an advocate for their interests. In a confidential report, an economic adviser to the Foreign Office in June 1941 explained how ‘Volksdeutsche’ could benefit from the ‘Aryanisation’ in Hungary. He insisted that the ministry should discuss the ‘Aryanisation’ with the Hungarian government soon and develop a strategy for securing the influence of the ‘Volksdeutsche’ and Nazi Germany. In order to collect the necessary information, the Germans deployed an informant, a ‘Gewährsmann’, who observed the distribution of the robbed goods in Hungary. ¹³⁹ The Undersecretary in the Foreign Office, Martin Luther, called for an agreement with Hungary on the question of who could keep the assets of Hungarian Jews in German territories and of German Jews in Hungarian territories. As a solution, he proposed the ‘territoriality principle’: each state could appropriate the assets in its territory. ¹⁴⁰ A delegation sent by Hungary in the spring of 1943 to discuss once again the assets of Hungarian Jews in the western occupation zones concluded that this ‘problem’ had remained unresolved. ¹⁴¹

Romania also competed with Germany for the robbed property of the Romanian Jewish population. ¹⁴² In September 1941, German diplomats were annoyed that ‘Aryanisation’ was being reinterpreted as ‘Romanianisation’ – and vice versa: Politicians close to Antonescu warned that the ‘Romanisation’ was at risk because the German minority, the ‘Volksdeutsche’ in Romania, claimed the property of the deported Jews for themselves. ¹⁴³ While they believed that they were entitled to a share of the ‘Romanian Aryanisation’, ¹⁴⁴ the Romanian state tried to prevent them from participating in the robbery, especially in relation to strategic companies. The German diplomats and the ‘Volksdeutsche’ in turn complained about a confusing legal situation, incompetent officials and simulated ‘Romanisation’ of companies. ¹⁴⁵ The Germans managed to plant an informant in the ‘Romanisation Ministry’. ¹⁴⁶

In Slovakia, the German envoy had already complained in 1940 that the Slovak government was changing ‘Aryanisation’ to ‘Slovakisation’. ¹⁴⁷ The German minority wanted a larger share of the booty and complained either to the German Foreign Office or directly to Himmler. Their demands led to disputes between the Slovak and German governments. ¹⁴⁸ To settle these disputes with the ‘Volksdeutsche’ and the German regime, the Catholic priest and president, Jozef Tiso, built mixed Slovak-German commissions. ¹⁴⁹ The German Foreign Office also negotiated with the Slovak ‘Central Economic Office’ about who could keep the booty of Slovak Jews abroad, in the territories ruled by Nazi Germany. The Slovak envoy wanted a guarantee that Slovakia's claims to the booty would not be endangered. ¹⁵⁰ Slovakia agreed to deport the Slovak Jews and agreed to pay Germany money for each deported person. In return, Germany had to promise that the Jews would never return. ¹⁵¹ At the same time, the Slovak government claimed the property of its deported citizens. ¹⁵² The Tiso regime, with the approval of the parliament, passed a law in 1942 to retrospectively legitimise the deportations and appropriate their property. ¹⁵³

There was less competition with Germany in the case of Bulgaria. There, the Foreign Minister Ivan Popov asked Ribbentrop in December 1941 to adjust the antisemitic legislation between the Axis powers. ¹⁵⁴ Bulgaria also agreed to let its Jewish citizens abroad be deported and didn`t forget to ask Germany for their possessions. ¹⁵⁵ Germany wanted to discuss deportations with Bulgaria again in October 1942. It is recommended that Bulgaria should be oriented towards the German antisemitic laws, like the ‘11. Regulation on the Reich Citizenship Law’ according to which all those who ‘left’ the country were to be denaturalised, and their property could be appropriated. Germany argued that Bulgaria would benefit from the ‘wealth of the Jews’, so the country should pay a certain amount to Germany for each deported person. However, it later instructed the German embassy not to insist on the amount if deportations were jeopardised as a result. ¹⁵⁶ Bulgaria agreed to pay Germany a sum of money per head for the deportations but sought to negotiate the sum down. ¹⁵⁷

Croatia also agreed to deportations and to pay a fixed sum to Germany for each deported person. ¹⁵⁸ In Croatia, too, the ‘Volksdeutsche’ negotiated with the Ustaše about the booty. To pacify the discussions between Germans and Croatians Pavelić divided the national territory into two areas for ‘Aryanisation’, into two ‘cooperatives’ as trustees, in March 1942. A representative of the ‘Volksdeutsche’ was appointed alongside the Croatian head of the robbery process to ensure a ‘fair’ distribution. If the representative of the Germans felt that they had been treated unfairly he could lodge a complaint directly to the Finance Minister. ¹⁵⁹ Nevertheless, there appears to have been a closer cooperation of the Ustaše and the ‘Volksdeutsche’ in some parts of the country: E.g. in May 1941, the Ustaše and the ‘Volksdeutscher Kulturbund’ in Vukovar took members of the Jewish community captive and blackmailed a large amount of money, framing their robbery as ‘collection campaign’ and ‘contribution’ for a ‘social fund’ in the town. After taking the money, they sent the hostages to Jasenovac and Auschwitz. ¹⁶⁰

6. Conclusion

As the comparative perspective seeks to show, the language of robbery is reflected in the institutionalisation and framing of robbery in the states allied to Nazi Germany. It also accompanied the competition over the booty. The Nazi regime took the antisemitic notion of ‘the wealth of the Jews’ to extremes, from which both the language oriented towards ‘Aryanisation’, and thus the framing of predatory practices, spread. Within the Axis states, Germany was able to build upon and reinforce centuries-old European antisemitic and nationalist traditions. Terms like ‘Romanisation’ or ‘Bulgarisation’ predated National Socialism and were embedded in nation-building processes, yet they developed a racist and antisemitic core in the 1930s and 1940s. Especially around the time of the radicalisation, acceleration and institutionalisation of robbery in Nazi Germany and Austria after 1938, there was a surge in robbery in states like Italy, Hungary and Romania as well. In their competition over ‘Aryanisation’ with Germany, the robbing of the Jewish population appeared to be an unquestioned premise. The controversies were not about whether the Jews should be robbed, but rather who would be able to keep the loot. The institutions of robbery were named after their ideological projects, like ‘Central Romanisation Office’ or were given nicknames like the ‘Office for Bulgarisation’, or ‘Aryanisation Office’. All of these states employed antisemitic arguments like ‘taking back’ property or ‘securing’ it for the ‘non-Jewish’ population. They appropriated ‘Aryanisation’ for their own purposes, interpreting it not just as valid for non-Jewish Germans, but also for the non-Jewish populations of Italy, Hungary, Romania, Slovakia, Bulgaria and Croatia. As a result, similarities in the argumentation and justificatory patterns, in the framing of the robbery, can be identified.

Even if economic reasons can be found for individual profiteers or states, these always presuppose a racist definition of ‘the Jew’, the belief that it is right to rob this particular group, and the assumption that those robbed would never be able to claim restitution. Regarding the well-known debate about ideological versus economic motives in explaining the Holocaust, the fronts today, compared to the discussions from the 1960s to the 1980s, have softened. While scholars may emphasise one aspect over the other, there is a general consensus that ideology and economics cannot be strictly separated from one another. ¹⁶¹ Consequently, it´s possible to argue that economic arguments in the context of robbery couldńt have existed outside an antisemitic frame. It´s possible to reject the often implicit assumption that some groups or states were more prone to respond to material incentives because they were poor. ¹⁶² It is also possible to adapt Götz Aly's ¹⁶³ thesis and to extend it, as Tönsmeyer does, arguing that Germany, and also other Axis powers, sought to pacify the population with the promise of welfare policies based on robbing the Jews, while emphasising that it was antisemitic ideas that explained why people responded to these incentives. This argument does not necessarily culminate in Daniel Goldhagen’s thesis, that an eliminatory antisemitism would inevitably have led to the murder of the Jewish population, ¹⁶⁴ applied to Europe. But the shared ideologies and interests regarding the robbing of the Jewish population seem to form an unquestioned agreement in the states allied to Nazi Germany. This is demonstrated by the competition over the booty. This raises the question about the stability of the Nazi regime in Germany and collaboration in Europe: to what extent did this unspoken agreement about robbing the Jews strengthen German power? In the context of the rise of nationalism and antisemitism in Europe, this aspect of European history is not merely of historical interest. The questions of complicity and antisemitism remain central to debates about how history is represented, especially as national cultures of remembrance are negotiated in relation to broader European narratives.

These examples also raise the question of whether, and to what extent, the robbery may have been connected with the death or survival rates and thus with the Holocaust. ¹⁶⁵ Robbery obviously reduced the chances of survival: exclusion from society meant that there were hardly houses available in which to live and hide outside the ghettos, no money for food or to organise resistance. Also, robbery strengthened the acceptance in the non-Jewish population for the ‘vanishing’ of their Jewish neighbours. Robbery seemed to have paved the way to mass murder, but – looking at Italy or so-called ‘core Bulgaria’ – not inevitably.

In contrast to the language of robbery, many who did not view National Socialism as a regime that would permanently secure property relations, but rather as a system that had to be overthrown, did not adopt the language of robbery either. Their voices demonstrate that the language, the policies and their framing have always been contested. Drawing on the perspectives of survivor scholars and their analyses of the language of National Socialism, this article also raises the broader historical question of how historical themes related to National Socialism can be conveyed without reinforcing the language of the perpetrators as an unintended side effect, but also without omitting the respective historical source terms.