This thesis examines and compares the State's ownership of archaeological heritage in Switzerland and Turkey: two countries with different political structures and archaeological contexts. The comparative analysis (Part I and II) is later used to formulate general recommendations applicable to other countries (Part III). The recommendations are built on the Model Provisions on State Ownership of Undiscovered Cultural Objects elaborated by UNESCO and UNIDROIT. This thesis proposes the States to go further than the Model Provisions by (i) explicitly mentioning in their laws the specific duties related to archaeological heritage protection (Provision 1) and by (ii) reinforcing their ownership regime with respect to both archaeological objects and sites (Provision 3). Regarding objects under public ownership, it is recommended to States to prohibit their sale in the open market. Regarding sites under public ownership, States can adopt conservation strategies to properly guide public authorities in the balance of different public interests.