Summary of CPAC Meeting to Discuss Proposed Cultural Property Agreement with Cameroon, Renewals of Cultural Property Agreements with Colombia and Türkiye, and a Renewal of Emergency Import Restrictions for Afghanistan

 On September 15, 2025, the US Cultural Property Advisory Committee (CPAC) met in a virtual public session to accept comments regarding a proposed Cultural Property Agreement  (CPA) or Memorandum of Understanding (MOU) with Cameroon, Renewals of current CPAs with Colombia and Türkiye, and a renewal of current “emergency” import restrictions with Afghanistan.

The Bureau of Educational and Cultural Affairs’ (ECA’s) website describes these requests as follows:

https://www.state.gov/cultural-property-advisory-committee-meeting-september-15-17-2025/  (last visited September 15, 2025).

Cameroon

The Government of the Republic of Cameroon seeks protection for archaeological and ethnological materials from 100,000 B.C. to the 19th century A.D., from the following time periods and cultures: Paleolithic (circa 100,000 – 2,000 B.C.), Neolithic (circa 9,000 – 500 B.C.), Metal Age (circa 3,000 – 300 B.C.), Historic Period (circa 1500 A.D.), Ethnological Period (circa 1,000 B.C. – 19th century A.D.), including objects made from stone (tools and weapons), ceramic (pottery and vessels), metal (jewelry, weapons, tools), fossil and bone (human and animal remains). The ethnological materials requested include objects made from wood (masks, statues, furniture), metal (jewelry, weapons, tools), textiles (ceremonial clothing, tapestries, embroidery), animal skins (clothing, drums, ritual objects), and bone (jewelry, tools, ritual objects).

Afghanistan

Extending emergency import restrictions unilaterally imposed by the United States on archaeological and ethnological material from Afghanistan would continue import restrictions on categories of archaeological material ranging in date from the Paleolithic Period (50,000 B.C.) through the beginning of the Durrani Dynasty (1747 A.D.), and ethnological material ranging in date from approximately 800 A.D. to 1920 A.D.

Colombia

Extending the Colombia MOU would continue import restrictions on categories of archaeological material ranging in date from approximately 1500 B.C. to 1530 A.D., and ecclesiastical ethnological material of the Colonial period ranging in date from approximately 1530 A.D. to 1830 A.D.

Türkiye

Extending the Türkiye MOU would continue import restrictions on categories of archaeological material ranging in date from approximately 1.2 million years ago to 1770 A.D., and ethnological material ranging in date from the 1st century A.D. to 1923 A.D.

The CPAC members did not introduce themselves before the public session, but CPAC currently includes the following individuals, all  appointed by President Biden: (1) Alexandra Jones (Chair, Represents/Expertise Archaeology, Anthropology, related fields, CEO Archaeology in the Community, Washington, DC); (2) Alex Barker (Represents/Expertise Archaeology, Anthropology, related fields) Director, Arkansas Archeological Survey, Arkansas); (3) Mirriam Stark, Represents/Expertise Archaeology, Anthropology, related fields, Professor of Anthropology, University of Hawaii); (4) Nii Otokunor Quarcoopome (Represents/Expertise Museums, Curator and Department head, Detroit Museum of Art); ( (5) Andrew Conners (Represents/Expertise Museums, Director, Albuquerque Museum, New Mexico); (6) Michael Findlay (Represents/Expertise: International Sale of Cultural Property, Director, Acquavella Galleries, New York); (7) Amy Cappellazzo, Represents/Expertise: International Sale of Cultural Property, Principal, Art Intelligence Global; (8) Cynthia Herbert (Represents/Expertise: International Sale of Cultural Property President, Appretium Appraisal Services LLC, Connecticut); (9) Thomas R. Lamont (Represents Public, President of Lamont Consulting Services, LLC, Illinois);  (10) Susan Schoenfeld Harrington  (Represents Public, Past Deputy Finance Chair, Democratic National Committee, Past Board member, China Art Foundation); and, (11) William Teitelman (Represents General Public, Legislative Counsel to the PA Trial Lawyers Association, Attorney (Retired)).

There were also Bureau of Educational and Cultural Affairs (ECA) Cultural Heritage Center staff present, presumably including Glen Davis, Director of the Cultural Heritage Center and Andrew Zonderman, who is serving as CPAC’s Executive Director.  Messrs. Davis and Zonderman are new to their positions.  

The meeting was conducted entirely on Zoom.  None of the CPAC or ECA staff identified themselves to the speakers, so it was difficult to ascertain who attended the meeting.

The Chair, Alexandra Jones, welcomed the speakers.  She thanked the speakers for attending, indicated that all comments had been read, and that speakers should try to limit themselves to under five minutes each given the number of presenters. 

Dr. Ömür Harmanşah spoke as the Vice President for Cultural Heritage, Archaeological Institute of America (“AIA”).  Given time constraints, he focused his comments on Türkiye and Afghanistan.  He stated that Congress chartered the AIA in 1906 and that today it has over 100,000 members which includes professionals and members of the interested public.  Dr. Harmanşah argued that all four countries suffered from looting which is a global phenomenon. He praised Türkiye’s hosting of American archaeologists at long-term digs in places like Sardis.  He noted that the Afghan National Museum had partnered with the University of Chicago to document continued looting in the country after the Taliban took power.  Dr. Harmanşah himself has helped document looting in Türkiye.  Türkiye has taken strong measures to protect its own cultural heritage, including enforcement, repatriation efforts, the creation of museum inventories and the creation of a new “Red List” of Turkish archaeological materials at risk from looting.   Türkiye has also sent exhibitions to the US, including one about the Golden Age of Midas that was displayed at the University of Pennsylvania. 

The AIA’s written comments about the proposed renewal of emergency import restrictions for Afghanistan can be found here:  can be found here:

https://www.regulations.gov/comment/DOS-2025-0203-0088

The AIA’s written comments on the proposed MOU with Cameroon can be found here:

https://www.regulations.gov/comment/DOS-2025-0203-0089

The AIA’s written comments about the renewal with Colombia can be found here:

https://www.regulations.gov/comment/DOS-2025-0203-0086

The AIA’s written comments about the renewal with Türkiye can be found here:

https://www.regulations.gov/comment/DOS-2025-0203-0085

Peter Tompa spoke as executive director for the International Association of Professional Numismatists (IAPN).  He indicated that IAPN opposed renewals for Afghanistan and Türkiye and takes no position on a MOU for Cameroon or a renewal for Colombia as long as coins are not included.  He focused his comments on Afghanistan and Türkiye, stating that both renewals raised fundamental contradictions that could not be reconciled.  He referenced the Taliban’s past destruction of historic statues and current blessing of a Chinese copper mine that will swallow up an important Buddhist site.  He further stated that ongoing looting with the full knowledge of local warlords who have pledged allegiance to the Taliban cannot be considered an “emergency.”   As for Türkiye, he noted that its government’s aggressive repatriation efforts abroad must be contrasted with its encouragement of treasure hunting on Jewish and Christian sites at home as well as its conversion of historic churches into mosques.   He further stated that extensive “designated lists” that cover coins that circulated regionally and internationally only hurt legitimate trade.  As a solution, he suggested that the Trump Administration apply the Administrative Procedure Act to the creation of designated lists and the Civil Asset Forfeiture Reform Act to enforcement. 

Peter Tompa’s oral statement can be found here: 

https://culturalpropertyobserver.blogspot.com/2025/09/renewals-for-afghanistan-and-Türkiye.html

IAPN’s written comments on proposed renewal of emergency import restrictions for Afghanistan can be found here:

https://www.regulations.gov/comment/DOS-2025-0203-0035

IAPN’s written comments on renewal with Colombia can be found here:

https://www.regulations.gov/comment/DOS-2025-0203-0032

IAPN’s written comments on the renewal with Türkiye can be found here:

https://www.regulations.gov/comment/DOS-2025-0203-0038

Peter Tompa’s personal comments can be found here:

https://www.regulations.gov/comment/DOS-2025-0203-0059

Dr. John Hoopes (University of Kansas) spoke in support of a renewal of the MOU with Colombia.  He has excavated in the country for 30 years.  Pottery and gold artifacts are sought by looters, making the renewal of the current MOU to be essential in helping to protect Colombia’s cultural heritage.  There are many sites yet to be excavated, just being discovered with the help of modern imaging techniques. 

Kate FitzGibbon spoke as Executive Director of the Committee of Cultural Policy (CCP) against the renewal of the current emergency import restrictions on behalf of Afghanistan. FitzGibbon has a special interest in the country after living there for 30 years working primarily with Afghan women who make textiles.  FitzGibbon raised four main points.  First, any renewal is inconsistent with statutory intent.  The Cultural Property Implementation Act (CPIA) § 2603 only authorizes narrow, time-limited, exceptional measures when there is an immediate crisis—targeted to clearly defined categories that meet an evidentiary emergency standard—so that US border controls can actually reduce the incentive for pillage. Congress did not design § 2603 to function as a rolling, multi-year embargo across whole civilizations. Second, the destination problem is real and unavoidable. Under the CPIA’s return rule, designated material forfeited in the US must first be offered back to the State Party. Today that means return to the Taliban and their Interior Minister, Sirajuddin Haqqani, a US-wanted terrorist.  Third, the policy is mis-aimed.  The Afghan government, not the US art market, is the problem.  The most acute threats to Afghanistan’s heritage today are state-sanctioned or militia-enabled extractions and earthmoving, most notably the destruction of the important Buddhist site of Mes Aynak to mine copper.  Finally, the emergency standard has been stretched past recognition. A catch-all designated list spanning 70,000 years of culture through A.D. 1920, renewed in five-year blocks, is not what § 2603 authorizes.  Such a broad designated list only hurts legitimate trade and threatens to sweep up and repatriate the personal property of Afghan refugees.  Instead, the US Government should prioritize diaspora protection and safe-haven pathways and create custodial trusteeship options with US museums and libraries for Afghan materials until a legitimate government exists.

Testimony opposing the Afghan renewal submitted on behalf of the CCP and its sister organization, the Global Heritage Alliance (GHA), can be found here:

https://www.regulations.gov/comment/DOS-2025-0203-0091

FitzGibbon also submitted written testimony on behalf of the CCP and GHA that opposed or questioned aspects of new or renewed MOUs with Cameroon, Colombia and Türkiye.  

The CCP’s and GHA’s written testimony on a proposed new MOU with Cameroon can be found here:

https://www.regulations.gov/comment/DOS-2025-0203-0079

The CCP’s and GHA’s written testimony on a proposed renewal of a MOU with Colombia can be found here:

https://www.regulations.gov/comment/DOS-2025-0203-0080

The CCP’s and GHA’s written testimony on a proposed renewal of a MOU with Türkiye can be found here:

https://www.regulations.gov/comment/DOS-2025-0203-0083

Randy Myers spoke as a board member on behalf of the Ancient Coin Collectors Guild (ACCG). He also spoke on behalf of the American Numismatic Association (ANA).  He touched on several points related to the renewals for Afghanistan and Türkiye.  First, he indicated the time provided to comment of 31 days is inadequate; instead a full 60 days should be provided as set forth in the Administrative Procedure Act.   Second, Myers noted that current import restrictions on coins ignore the statutory provisions that limit them to archaeological objects of “cultural significance” that were “first discovered within” and “subject to export control” of a given country.  He emphasized that unlike many ancient artifacts, coins are mass produced, with dies used to strike 13,000 coins each.  This large production of coins combined with their wide dispersion means that one cannot assume that particular coin types are found in a given country.  For example, coins on the current designated list for Türkiye are found as far West as Spain and as far East as India.  Finally, he notes that the State Department has produced no information to suggest that the MOU with Türkiye has been effective.

The ACCG’s and ANA’s written comments regarding the renewal of emergency import restrictions for Afghanistan can be found here:

https://www.regulations.gov/comment/DOS-2025-0203-0030

The ACCG’s and ANA’s written comments regarding the renewal of the CPA with Türkiye emergency can be found here:

https://www.regulations.gov/comment/DOS-2025-0203-0031

Elias Gerasoulis spoke as executive director of the GHA and also as a board member of the American Hellenic Institute to oppose the Turkish renewal.  The Turkish CPA should not be renewed because it will only further encourage Türkiye to erase the cultural heritage of its displaced minority Christian and Jewish populations. Türkiye has tried to rewrite the histories of its historic churches.  It has licensed looting of Christian and Jewish sites.  It has precluded Christian religious orders from owning their own property.  It has occupied a significant part of Cyprus, looting and destroying numerous churches.  It’s government actively works against religious freedom. 

Lucy Varpetian appeared on behalf of the Armenian Bar Association.  The Armenian Bar Association submitted comments, but Ms. Varpetian used her time to read a letter to CPAC from Congressman Gus Bilirakis (R-Florida) opposing a renewal of the MOU with Türkiye.   Congressman Bilirakis wrote CPAC as a co-chair of the Congressional International Religious Freedom Caucus.  That letter noted that Türkiye had failed to protect the cultural heritage of its religious minorities, most notably by converting historic churches into mosques.  The asking that the MOU not be renewed, Bilirakis concludes that, “[t]he government that destroys its minorities’ historical property should not have the right to repatriate them at their pleasure.” 

The Armenian Bar Association’s written comments can be found here: 

https://www.regulations.gov/comment/DOS-2025-0203-0072

After this presentation, one CPAC member (William Teitelman?) noted he was Jewish and indicated to Ms. Varpetian that the concerns of religious minorities would be considered. 

Rabbi Eric Fusfield is Deputy Director, International Center for Human Rights and Public Policy, Director of Legislative Affairs, B'nai B'rith International. He argues that there should be a carve out from current import restriction for Türkiye for ritual and ceremonial objects.   These are currently found on the designated list for Türkiye, but they really belong to Jewish and Christian communities, not the Turkish state.  Rabbi Fusfield holds up a Kiddish cup as an example.  His wife’s family comes from a Middle Eastern country, and they were not allowed to take such items with them when they were forced to flee.  If these items remain on “designated lists,” he thinks such items that may be seized by US Customs should be turned over to the communities in exile, particularly whereas in Türkiye there are so few members of the Jewish faith still living there these days.

Dr. Peri Johnson is an archaeologist teaching at the University of Illinois Chicago.  She supports a renewal of the CPA with Türkiye because looting is still a major problem there.  She has seen instances where heavy machinery was brought in to help loot sites.  Around 50% of the archaeological digs in Türkiye are meant to rescue items before they can be taken by looters. 

Dr. Elizabeth Prodromou is a visiting professor in the international studies program at Boston College.  Prodromou served a diplomatic appointment on the US Commission on International Religious Freedom (2004-2012), and she was a member of the US Secretary of State’s Religion & Foreign Policy Working Group (2011-2015).  Dr. Promdmou believes that the current agreement is in violation of Article 9 of the UNESCO Convention because it can be seen as “green lighting” Türkiye’s erasure of minority cultures, most recently the conversion of the Cathedral of Ani into a mosque. The renewal of the MOU should be rejected, but if it is renewed, there should be an individualized provenance review for contested items to determine whether the object was originally created by a community that no longer exists in modern Türkiye or whose property rights have not been acknowledged.

Dr. Prodromou’s written testimony, joining the comments of the Armenian Bar Association, can be found here:

https://www.regulations.gov/comment/DOS-2025-0203-0078

Dr. Simon Maghakyan is a postdoctoral fellow at the University of Oxford. He indicates his support of the comments of the Armenian Bar Association.  He indicates that another reason the MOU should be rejected is on account of Türkiye’s support for Azerbaijan in its war to erase Armenian culture heritage in Nagorno-Karabakh.  He also notes that he has studied and written a Newsweek article about state-sanctioned treasure hunting of former Armenian areas in Türkiye.  This article is cited in the Armenian Bar Association’s comments at page 3. He urges CPAC to adopt the 6 safeguards proposed in the Armenian Bar Association’s comments.  These safeguards are discussed in depth at pages 6-7 of those comments.

Dr. Brian Rose is the James B. Pritchard Professor of Archaeology at the University of Pennsylvania in the Classical Studies Department and the Graduate Group in the Art and Archaeology of the Mediterranean World. He is also Peter C. Ferry Curator-in-Charge of the Mediterranean Section of the Penn Museum.  He supports the renewal of the MOU with Türkiye believing that it is essential to help combat continued looting in the country.  Türkiye has taken adequate measures to protect its own cultural heritage.  These include the use of drones to surveil sites and an active repatriation program, with the help of the Manhattan DA’s office.

One CPAC member (William Teitelman?) asks Dr. Rose about Türkiye’s aggressive efforts to erase minority cultures.   Dr. Rose can only say he has not personally seen any such activities and that the Turkish colleagues he deals with respect all cultures.  He also indicates that he is aware of Türkiye’s efforts to turn Hagia Sophia into a mosque but offers no other comments. 

Cultural Property Agreement Renewals for Afghanistan and Turkey Raise Unreconcilable Contradictions

This is what I said at today's CPAC hearing:  

Thank you for this opportunity to speak on behalf of the International Association of Professional Numismatists.  IAPN opposes renewals for Afghanistan and  for Turkey.  IAPN takes no position on a new MOU for Cameroon or a renewal for Colombia, but opposes any import restrictions on coins.  The coins that circulated in these two countries simply don’t meet the criteria for either archaeological or ethnological objects.  Historical coinage that circulated in Colombia was also US legal tender before 1857 and the first official issues of Cameroon were late 19^th century coinage of the German Empire.

I would like to focus my comments today on Afghanistan and Turkey.  Both renewals raise fundamental contradictions that cannot possibly be reconciled.

Proponents argue that import restrictions promote cultural heritage preservation and are only directed against keeping recently looted material off the market.  However, such claims are misleading at best given the reality on the ground in both countries and the way US Customs enforces  import restrictions as embargoes on material imported from legal markets abroad, chiefly in Europe.  

Afghanistan’s Taliban rulers blew up the  Bamiyan Buddhas and smashed statuary at the Kabul Museum.  More recent efforts at bribing them into caring with money for “conservation projects” can’t compete with Chinese business interests which are in the process of destroying a major Buddhist site at Mes Aynak to mine copper.   Moreover, any looting has been going on for decades, all under the watchful eyes of local warlords.  The only difference now is that they pledge allegiance to the Taliban.  Such long term looting with the full knowledge of government authorities simply does not qualify as an  “emergency.”   Finally, despite the AIA’s claims to the contrary, Section 1216 of the National Defense Authorization Act is no safe harbor provision because it only covers institutional loans.  In fact, US law requires repatriation to the Taliban once diplomatic relations are restored, and  any decision will be made on a basis other than the safety of the objects.

Meanwhile, Erdogan’s aggressive repatriation efforts abroad must be contrasted with his government’s active promotion of  “treasure hunting” at former Jewish and Christian sites at home.  This is just another provocation directed at minority religious groups like the conversion of Hagia Sophia and the Cathedral at Ani into mosques. 

For coins, extensive “designated lists” which cover coins that circulated regionally or internationally only hurt legitimate trade.  Efforts to limit such lists to coins “sourced” to Afghanistan or which “circulated primarily” in Turkey are meaningless since US Customs seizes coins based on their  “type” alone.  That means pretty much all ancient and early modern coins are now at risk unless the importer can prove the “negative” that they were out of a given country before the effective date of the governing regulations or for at least 10 years    While  enforcement has been spotty, it does occur with the results being that collectors have their property taken with little, if any, “due process.” 

Going forward, the best solution would be for the Trump Administration to make  preparing designated lists  subject to the Administrative Procedure Act and for any detentions, seizures and forfeitures of cultural property to be subject to the Civil Asset Forfeiture Reform Act of 2000.  The former would require the government to justify the inclusion of specific coin types in the designated lists and the latter would help  ensure that import restrictions only apply in situations where there was some evidence that the coin in question was illicitly exported from a country with a MOU or emergency restrictions after the date of the governing regulations.

Thank you for your consideration of the views of the micro businesses of the numismatic trade.

Time Again to Tell the Cultural Property Advisory Committee What You Think About Import Restrictions on Coins for Taliban Afghanistan and Erdogan’s Türkiye

 The State Department has announced a Cultural Property Advisory Committee (CPAC) Meeting to consider renewals of current “emergency” import restrictions on behalf of Taliban Afghanistan, and the renewals of current cultural property memorandums of understanding (MOUs) with Erdogan’s Türkiye and Colombia.  CPAC will also consider a new MOU with Cameroon.

The State Department’s announcement can be found here:  https://www.state.gov/cultural-property-advisory-committee-meeting-september-15-17-2025/

The State Department is soliciting comments here:  https://www.regulations.gov/document/DOS-2025-0203-0001

Comments are due on or before September 8, 2025.

The renewals for Afghanistan and Türkiye should be controversial because they prioritize soft power efforts directed at a terrorist state (Afghanistan) and an authoritarian one (Turkey) over the interests of American collectors, museums, and the trade in cultural goods.  For coin collectors, the big issue is the grossly overbroad designated lists for both countries that cover coins that circulated regionally or internationally.   There are currently no import restrictions for coins for Colombia, and it does not appear that Cameroon is requesting any restrictions, likely because coins were not used there until recently.

The other big issue relates to enforcement.  Unfortunately, in the only case that addressed the issue, courts in the US Fourth Circuit gave Customs a “green light” to detain, seize and repatriate coins for no other reason that they were of types on a “designated list” for import restrictions.  This puts collectors importing such coins at risk because it is often difficult, if not impossible, to produce the documentation necessary for legal import under current “safe harbor” procedures.

For further details about these MOUs and emergency restrictions and how to comment see this solicitation from the Ancient Coin Collectors Guild https://accguild.org/news/13533301 as well as this critique from the Cultural Property Observer blog: https://culturalpropertyobserver.blogspot.com/2025/08/soft-power-love-for-taliban-trump-state.html  Again, comments are due on or before September 8, 2025, with the CPAC hearing to take place on September 15, 2025, via a Zoom video conference. 

What should you say? It’s better to write in your own words about how import restrictions hurt your ability to  access coins and learn more about other cultures or even get in touch with your own cultural heritage.  However, here is a model for you to consider:

Please do not renew current import restrictions that prioritize the interests of a terrorist state (Afghanistan) and an authoritarian one (Türkiye) over the rights of American coin collectors.  If you nonetheless renew these agreements, please ensure that the designated lists are rewritten so that it is absolutely clear that they do not impact coins legitimately imported from legal markets abroad, particularly those in Europe.  Coin collecting is a hobby that promotes cultural understanding and relationships with collectors abroad.  It is troubling that the State Department Bureau of Cultural Affairs is behind efforts that do considerable damage to a hobby that actually promotes the cultural understanding the Bureau supposedly aims to foster.

"Soft Power" Love for the Taliban: Trump State Department Continues to Prioritize the Interests of Foreign Despots and Archaeological Advocacy Groups Over Those of American Citizens

Collectors hoping Trump II would “make collecting great again" have been sorely disappointed.  Instead, giveaways in the form of Cultural Property Agreements or Memorandums of Understanding (MOUs) to foreign despots, their cultural bureaucracies, and US based archaeological advocacy groups that are dependent on foreign excavation permits continue to be approved at an accelerated pace. 

These MOUs impose confiscatory import restrictions on cultural goods.  They are justified as  "soft power" measures aimed at encouraging even "failed states" to "like us more."  Indeed, the push to complete as many agreements as possible has been so strong that the State Department has gone so far as to fund both foreign requests and "self-help" measures, both of which are supposed to be the responsibility of the foreign government.  Doge cuts or no, such funding in the form of cultural property implementation grants continues to appear on  the State Department Cultural Heritage Center website.  Of course, some of the prime beneficiaries are associated with the archaeological advocacy groups most identified with protecting the current status quo. For example, according to a federal grant tracking database, the Antiquities Coalition, one of the most active, has received over $3.3 million in grants from the State Department and USAID for work that has included "strengthen[ing] the U.S. commitment to preventing illegal trafficking and sale of antiquities into the United States from Uzbekistan, Nepal, and India by supporting the development of bilateral Cultural Property Agreements."

Trump has sought to overturn many "woke" Biden initiatives, but his Administration has nonetheless implemented Biden era decisions to impose import restrictions on behalf of Hindu nationalist India, authoritarian Uzbekistan, and even Hezbollah dominated Lebanon.  The Trump Administration may have hit India with 50% punitive tariffs and approved Israel's continued bombing campaign in Lebanon, but that hasn't stopped the US government from seizing and repatriating cultural goods to these countries.  

Moreover, after a short regulatory pause, the Trump State Department has even expanded these "soft power" efforts.  In May 2025, the State Department held a Cultural Property Advisory Committee (CPAC)  Meeting to consider a new MOU with Communist Vietnam, and renewed agreements with Chile, Costa Rica, Italy and Morocco.  In so doing, the State Department denied a request from groups representing collectors and the trade to postpone the meeting to give time for Trump to appoint at least some CPAC members.  As it is, CPAC may be one of the last bodies in the federal government still  completely staffed with Biden political appointees.  

Now, at a time Congress is out of session and most of Washington, DC is enjoying summer vacation, the State Department has provided public notice of a September 2025 CPAC meeting to consider a renewal of even more controversial "emergency import restrictions" on behalf of Taliban Afghanistan, as well as a new MOU with authoritarian Cameroon, and renewals for Erdogan's Turkey and the Leftist government in Columbia.  

One preliminary question is whether the State Department has exceeded its statutory authority under the Cultural Property Implementation Act in considering renewals of import restrictions for Afghanistan, Columbia and Turkey.  The notice of the proposed extension for Afghanistan does not mention any request for a renewal or information received from the State Party that supports the determination that an emergency condition still exists. 19 U.S.C. Section 2602 (f) (2), 2603 (c) (1). The same issue arises with the notices of proposed extensions of MOUs for Columbia and Turkey.    Neither of those notices indicate that either country has requested a renewal of a current agreement or provide any information to justify it.  19 U.S.C. Section 2602 (a) (1), (a) (3), (e), (f) (2). Without any such request or supporting information  from a State Party, such restrictions can only be authorized by a special act of Congress as was done for post Saddam Iraq in 2001 and Assad's Syria in 2016.

Each of these proposals also raise important substantive concerns, but the renewal of "emergency import restrictions" on behalf of Taliban Afghanistan should be particularly troubling.  Why should the Trump  II Administration even consider repatriating cultural goods to the Taliban at all?  As was pointed out  by representatives of museums, collectors and the trade during a 2021 CPAC hearing to consider the initial request for import restrictions from the "former government of Afghanistan," the Taliban are far more known for dynamiting cultural heritage such as the Buddhas of Bamiyan than preserving it.  More recently, a Chinese mining company has moved forward with the blessing of Taliban officials on controversial plans to dig a copper mine under an important ancient Buddhist site at Mes Aynak.  Of course, the silence from archaeological advocacy groups that regularly condemn American collectors, dealers and museums as would be looters is deafening.  Indeed, the founder of the well-funded and politically connected Antiquities Coalition has gone so far as to praise Communist China's authoritarian, mercantilist, and nationalistic cultural heritage policy.   No matter the Chinese Communist's distinct lack of respect for Buddhist cultural heritage in Afghanistan as well as their promotion of Han cultural supremacy along with the state sponsored suppression and destruction of the cultural heritage of subject Tibetan and Uyghur cultures.  

So, why is the Trump Administration continuing on this same path?  It may simply be that the State Department bureaucracy has misled Administration officials about the true effect of MOUs and import restrictions on legitimate trade and collecting.  In an email announcing September's CPAC hearing, the State Department Cultural Heritage Center claims that import restrictions "bar trafficked cultural property from entering the United States while encouraging the legal exchange of cultural property for scientific, cultural and educational purposes."   What can be wrong with that!

In fact, plenty.  In reality, such import restrictions actually harm the legal exchange of cultural property because they operate as embargos on all cultural goods of "designated types," including those purchased on legal markets abroad, mostly in Europe.  Such a broad-brush approach is particularly damaging to the legitimate trade in historical coins.  Under it, once a coin is determined to be of a type that appears on a designated list, it may be detained, seized and repatriated based on nothing more than being one of many thousands of examples of such coins that may have circulated regionally if not internationally. 

Coin collectors continue to believe that the governing statute instead requires the government to at least demonstrate "probable cause" that a coin subject to detention, seizure and forfeiture was illicitly exported after the effective date of any governing regulations.  However, the State Department and US Customs convinced Judge J. Harvie Wilkinson and the US Court of Appeals for the 4th Circuit to provide US law enforcement with a "green light" to seize and repatriate collector's coins solely based on their “type” as a "foreign policy matter."   Fast forward to the present, mainstream media lauded Wilkinson as a champion for the due process rights of  illegal aliens who were also allegedly gang members.   But what about "due process" for collectors?

This lack of due process matters because the current "safe harbor" for those importing restricted cultural goods was meant for valuable objects with long paper trails.  Moreover, overlapping designated lists for multiple countries of coin types subject to such import restrictions now regularly include coins that circulated regionally or even internationally.  All this makes it difficult, if not impossible, to import increasing numbers of historic collectors coins from legal markets abroad. Most collector's coins simply do not have the provenance documentation necessary for legal import under the current "safe harbor" provision. Given the limited value of most collector's coins and the great numbers found in most collections, most are unlikely to have documentation "proving" a particular coin left a specific country before the effective date of governing regulations. 

So what can collectors do?  

First, collectors should still comment on the proposed MOU with Cameroon as well as the proposed renewals of import restrictions for Afghanistan, Columbia and Turkey.  While one may think their comments don't matter, silence will be taken as acquiescence to the status quo.  Coin collectors should focus on the fact that embargoes on import of collector's coins makes no sense, particularly because one cannot assume that a coin type was only found in a particular country.  They can and should also describe how there are far too many coins out there for them all to be cared for by cultural bureaucracies, particularly ones in places like Afghanistan.  

Second, coin collectors should contact their Representative and Senators and ask them to support HR 595, a bill to facilitate the lawful exchange in collector's coins.

Finally, all collectors should advocate for more fundamental legislative reform to protect our due process rights before any collectibles are detained, seized and forfeited to a foreign government.  In view of the State Department’s continuation of the anti-collecting status quo, only legislative action can help "make collecting great again."

W

Not MAGA: Trump Administration Implements Biden Embargo on "Indian" Cultural Goods

The Federal Register has announced long anticipated import restrictions on Indian cultural goods.  This is yet another wide-reaching Biden Administration  MOU implemented by the Trump Administration.

Following a trend that picked up steam under the Obama Administration and accelerated under Trump I and Biden, the announced restrictions are extremely broad, covering archaeological material dating as recently as 1770 and ethnological material dating as recently as the end of the Raj in 1947.

 Here is a link to the restrictions: 

https://www.federalregister.gov/documents/2025/07/28/2025-14114/imposition-of-import-restrictions-on-archaeological-and-ethnological-material-of-india

For coin collectors, the restrictions generally include all coins found in India, including Persian, Greek, Roman, and later issues with types struck in India specifically named as part of the designated list: 

 (5) Coins—Ancient coins include gold, silver, copper, lead, and copper alloy coins in a variety of sizes and denominations. Includes gold and silver ingots and commemorative coins. Coins may be circular, oval, square, or polygonal in shape, may be punch-marked, hammered, cast, molded, and/or gilded. Coins may include designs on one or both sides, including edges. Designs may include portraits, crests, deities, and animal, floral, architectural, geometric, and/or vegetal motifs, and/or may be inscribed in various languages and scripts. Includes depictions of symbols and figures from Buddhist, Jain, Hindu, Christian, Sikh, and Zoroastrian religious traditions, among others. Includes Roman, Persian, Greek or Hellenistic, Gandharan, Central Asian, and other coins found in India. Includes coins that were reused or converted into decorative objects or objects of personal adornment. Approximate Date: 600 B.C.E.-1770 C.E.

a. Early Historic Period includes punch-marked coins, discs, tokens, among others in gold and silver. May include depictions of animals, geometric, floral, and/or vegetal motifs.

b. Historic Period includes, but is not limited to, Mauryan punch marked coins ( karshapana) with various symbols such as suns, crescents, six-arm designs, hills, peacocks, human figures, animals, and others, and inscriptions in Brahmi script; Roman silver and bronze coins; Hellenistic and Gandharan drachms, tetradrachms, and gold staters featuring iconography of Hellenistic deities and human portraiture and inscriptions in Greek and Kharoshti; Kushan dinars, tetradrachms, and copper alloy denominations with iconography from Persian, Zoroastrian, Buddhist, and Hindu traditions; Western Satraps coins with bull-and-hill or elephant-and-hill images; Indo-Scythian coins; Satavahana coins with Prakrit inscriptions and animal, floral, geometric, star, Buddhist shrines or stupas, human, wheel, and/or maritime motifs; Ashokan stambha coins featuring a central pillar; Gupta dinaras and drachms and others with images of animals, human figures, mythological birds, archery, javelins, battle-axes, wheels and scepters, deities, and portraiture along with floral, geometric, and/or vegetal motifs, including inscriptions in Brahmi script.

c. Medieval Period includes, but is not limited to: Gurjara-Pratihara, Pallava, and other dynastic coins or tokens with portraiture and geometric, animal, and religious motifs; Chola coins with crests of animals and weapons, mythological icons, and inscriptions in the Nagari script; Vijayanagara pagoda coins featuring Hindu deities and related symbols; Delhi Sultanate tankas and jitals with animal, religious, floral, geometric, and/or vegetal motifs and calligraphic inscriptions in various languages and scripts such as Arabic.

d. Mughal Empire or Early Modern Period includes, but is not limited to, rupiya, dam, and mohur coins primarily featuring calligraphy and literary or religious verses, but also figures and portraits of rulers, zodiac signs, birds, animals, and other icons.

 What are not included are the machine struck coins of the British Raj.

For further background on  the arguments for and against these restrictions, see this blog post about the Jan. 30, 2024, CPAC hearing related to this MOU: https://culturalpropertyobserver.blogspot.com/2024/02/public-meeting-of-us-cultural-property.html

Some of the issues raised by collectors and the trade (but completely ignored) are the fact that there is a huge internal market for items like coins within India itself, but with no working system for legal exports as contemplated under both the UNESCO Convention and the Cultural Property Implementation Act. 

There is also the important issue of the impact of these restrictions on the ability of Indian-Americans to own their own cultural heritage, including heirlooms brought from India. 

Given the breadth of these restrictions and their enforcement as embargoes, there needs to be Congressional intervention to rein in the State Department and US Customs.  For a modest proposal which would accomplish just that, see here:  https://culturalpropertynews.org/time-to-make-collecting-great-again/

 For coin collectors, it’s also important to support HR 595, legislation which would facilitate the lawful exchange of collector's coins already subject to cultural property MOUs.  For more, see here:  https://accguild.org/HR-7865

Summary of CPAC Meeting to Discuss Proposed Cultural Property Agreement with Vietnam and Renewals of Cultural Property Agreements with Chile, Costa Rica, Italy and Morocco

 On May 20, 2025, the US Cultural Property Advisory Committee (CPAC) met in a virtual public session to accept comments regarding a proposed Cultural Property Agreement or Memorandum of Understanding (MOU) with the Socialist Republic of Vietnam as well as renewals of current agreements with the Republics of Chile, Costa Rica, and Italy and the Kingdom of Morocco.  The meeting was rescheduled from an earlier date of February 4-6, 2025, pursuant to President Trump’s regulatory freeze, which has now been lifted.  The Ancient Coin Collectors Guild, the Global Heritage Alliance, and the International Association of Professional Numismatists all sought an additional postponement to allow time for the Trump Administration to appoint its own CPAC members and decision-maker, but this request was denied.

The Bureau of Educational and Cultural Affairs’ (ECA’s) website describes these requests as follows:

Vietnam

Vietnam seeks protection for archaeological and ethnological materials from ca. 75,000 BCE to 1945 CE, from the following time periods and cultures: Paleolithic (c. 75,000 BCE – 10,000 BCE), Neolithic period (c. 10,000 BCE – 2,000 BCE), Bronze Age (c. 2,000 BCE – 1,000 BCE), and Iron Age (c. 1,000 BCE – 200 CE), the Ancient period (2,879 BCE - 179 BCE), Northern domination period (179 BCE – 939 CE), and the Dynasty and Monarchy period (939 – 1945 CE) including objects made from gold, silver, ceramic, stone, metal, copper, bronze, iron, bone, horn, ivory, gems, silk and textiles; lacquerware and wood; bamboo and paper; glass; coins; and painting and calligraphy.

Chile

Extending the Chile MOU would continue import restrictions on categories of archaeological material ranging in date from approximately 31,000 B.C. to 1868 A.D.

Costa Rica

Extending the Costa Rica MOU would continue import restrictions on categories of archaeological material ranging in date from approximately 12,000 B.C. to the time of the establishment of Hispanic culture in Costa Rica (approximately 1550 A.D.).

Italy

Extending the Italy MOU would continue import restrictions on categories of archaeological material ranging in date from approximately 900 B.C. to 400 A.D.

Morocco

Extending the Morocco MOU would continue import restrictions on categories of archaeological material ranging in date from approximately one million B.C. to approximately 1750 A.D. and certain ethnological material from the Saadian and Alaouite dynasties, ranging in date from approximately 1549 to 1912 A.D.

Cultural Property Advisory Committee Meeting, May 20-23, 2025, Bureau of Educational and Cultural Affairs Media Center (amended May 1, 2025) available at  https://eca.state.gov/highlight/cultural-property-advisory-committee-meeting-may-20-23-2025  (last visited May 21, 2025).

The CPAC members did not introduce themselves before the public session, but CPAC currently includes the following individuals appointed by President Biden: (1) Alexandra Jones (Chair, Represents/Expertise Archaeology, Anthropology, related fields, CEO Archaeology in the Community, Washington, DC); (2) Alex Barker (Represents/Expertise Archaeology, Anthropology, related fields) Director, Arkansas Archeological Survey, Arkansas); (3) Mirriam Stark, Represents/Expertise Archaeology, Anthropology, related fields, Professor of Anthropology, University of Hawaii); (4) Nii Otokunor Quarcoopome (Represents/Expertise Museums, Curator and Department head, Detroit Museum of Art); ( (5) Andrew Conners (Represents/Expertise Museums, Director, Albuquerque Museum, New Mexico); (6) Michael Findlay (Represents/Expertise: International Sale of Cultural Property, Director, Acquavella Galleries, New York); (7) Amy Cappellazzo, Represents/Expertise: International Sale of Cultural Property, Principal, Art Intelligence Global; (8) Cynthia Herbert (Represents/Expertise: International Sale of Cultural Property President, Appretium Appraisal Services LLC, Connecticut); (9) Thomas R. Lamont (Represents Public, President of Lamont Consulting Services, LLC, Illinois);  (10) Susan Schoenfeld Harrington  (Represents Public, Past Deputy Finance Chair, Democratic National Committee, Past Board member, China Art Foundation); and, (11) William Teitelman (Represents General Public, Legislative Counsel to the PA Trial Lawyers Association, Attorney (Retired)).

The meeting was conducted entirely on Zoom.  None of the members identified themselves to the speakers so it was difficult to ascertain who attended the meeting.

There were also Bureau of Educational and Cultural Affairs Cultural Heritage Center staff present, including  Glen Davis, Director of the Cultural Heritage Center and Andrew Zonderman, a Foreign Affairs Officer who is serving as CPAC’s Executive Director.  Messrs. Davis and Zonderman are new to their positions.   

The Chair, Alexandra Jones, welcomed the speakers.  She thanked the speakers for attending, indicated that all comments had been read, and that speakers would be given five minutes each to present their oral comments. 

Dr. Ömür Harmanşah spoke as the Vice President for Cultural Heritage, Archaeological Institute of America (“AIA”).  Given time constraints, he focused his comments on Italy and Morocco and the new MOU with Vietnam.  He stated that the AIA was chartered by Congress in 1906 and that today it has some 200,000 members which includes professionals and members of the interested public.  Dr. Harmanşah argued that all three countries suffered from looting which is a global phenomenon. He praised the work of the Carabinieri, noting that had successfully dismantled two looting networks recently. He indicated that the French government had repatriated 35,000 objects to Morocco seized from and illicit collection. He further indicated that bronze and iron age sites suffered from looting in Vietnam.   He further indicated that all three countries had taken self-help measures to protect their own cultural patrimony.  The work of the Carabinieri and their cooperation with the Manhattan DA’s office and Homeland Securities Investigations is well known.  Harmanşah  also highlighted loans being used for cultural exchange purposes.  He mentioned that Morocco loaned materials to Northwestern University’s Block Museum of Art for the exhibition, “Caravans of Gold, Fragments in Time: Art, Culture, and Exchange across Medieval Saharan Africa.”

The AIA’s written comments about the Proposed MOU with the Socialist Republic of Vietnam can be found here:  https://www.regulations.gov/comment/DOS-2024-0048-0181

The AIA’s written comments on the Renewal with the Republic of Chile can be found here:

https://www.regulations.gov/comment/DOS-2024-0048-0178

The AIA’s written comments about the Renewal with the Republic of  Italy can be found here:

https://www.regulations.gov/comment/DOS-2024-0048-0179

The AIA’s written comments about the Renewal with the Kingdome of Morocco can be found in the 2024 docket here: 

https://www.regulations.gov/comment/DOS-2024-0048-0180  

Peter Tompa spoke as executive director for the International Association of Professional Numismatists (IAPN).  He indicated that the Trump Administration’s emphasis on promoting American business and scaling back regulations require CPAC to consider a new paradigm, one which facilitates the lawful trade in common items like coins, particularly where they are already legally available for sale in countries seeking restrictions.   With regard to the Italian renewal, there should be no further expansion of the current designated list to include late Roman Republican and Roman Imperial coins.  One cannot assume that Roman Imperial coins are found in Italy.  Scholarly evidence demonstrates that only 5.24% of the 15,000 coin hoards containing 6 million coins are found there.  Larger denomination Greek era coinage that circulated in international trade should be delisted.  Given Italy’s large internal market, issuance of export certificates should be mandated and US Customs should also recognize legal exports from Italy’s sister European Union countries as legal imports under the MOU.  There should be no new restrictions placed on coins for Vietnam. Coins are openly sold there at a gift shop at the Hue UNESCO World Heritage site.  It would be confusing to place restrictions on cash coins that are inconsistent with those for China, given the fact that many more times such coins are found in China. There should be no restrictions on machine struck coins of the French protectorate, minted in France or in the US, as they do not fit the definitions of either archaeological or ethnological objects. The Moroccan designated list should be scrapped because it is so broad that importers lack fair notice of what particular coins are actually restricted. Spanish colonial and early Republican era coins that circulated in Costa Rica and Chile circulated in far greater quantities elsewhere, including as US legal tender until 1857 and should remain unrestricted.

Peter Tompa’s oral statement can be found here:  https://culturalpropertyobserver.blogspot.com/2025/05/its-time-for-reset.html

IAPN’s written comments seeking an additional postponement can be found here: https://www.regulations.gov/comment/DOS-2025-0003-0014

IAPN’S written comments on the Proposed MOU with the Socialist Republic of Vietnam can be found here: https://www.regulations.gov/comment/DOS-2025-0003-0019

IAPN’s written comments on Renewal with the Republic of Chile can be found here: https://www.regulations.gov/comment/DOS-2025-0003-0017

IAPN’s written comments on the Renewal of the MOU with the Republic of Costa Rica can be found here, https://www.regulations.gov/comment/DOS-2025-0003-0013

IAPN’s written comments on the Renewal with the Republic of Italy can be found here: https://www.regulations.gov/comment/DOS-2025-0003-0018

IAPN’s written comments on the Renewal with the Kingdom of Morocco can be found here:  https://www.regulations.gov/comment/DOS-2025-0003-0020

Peter Tompa’s personal comments as supplemented can be found here: https://www.regulations.gov/comment/DOS-2025-0003-0041

Elias Gerasoulis spoke as executive director of the Global Heritage Alliance (GHA) and also on behalf of the Committee for Cultural Policy (CCP). Gerasoulis indicated each request failed to meet the four requirements for either a new or extended MOU. He also noted that the number of MOUs issued by CPAC has more than doubled in recent years. Over thirty countries are now covered. Import restrictions now extend over virtually all cultural material dating from prehistory to the early 20th century, lacking any connection to actual looting or risk.  Gerasoulis indicated that a MOU with Italy is no longer necessary given the Carabinier’s successful efforts to bring looting under control.  Gerasoulis indicated that Morocco has prioritized tourism over archaeological preservation and that there is no credible evidence of serious looting. Gerasoulis also indicates that there is no evidence of serious current looting in either Chile or Costa Rica.  He also mentions that the Director of Costa Rica’s national museum was previously arrested for looting.  Gerasoulis then commented on the proposed MOU with Vietnam. Vietnam has a strong, public domestic legal market, and is clearly focused on tourism rather than archaeological protection – yet it seeks restrictions up until the mid-20^th century.  The MOU request is about asserting national branding and control over diaspora heritage.

CPAC member Andrew Connor disputed Gerasoulis’ statements about looting arguing that proponents of the MOUs have all produced evidence of looting.  [CPO Comment: One of the findings before a MOU can be completed is that “the cultural patrimony of the State Party is in jeopardy from the pillage of archaeological or ethnological materials.”  19 USC Section 2602 (a) (1) (A).  Proponents and opponents argue about the extent and timing of the looting necessary to justify a MOU.  Is historic looting with some continuing looting enough as proponents maintain or must there be serious current looting to justify an agreement as opponents argue?  Given the State Department’s desire to reach agreement on as many MOUs as possible as “soft power” measures a lower bar for looting seems to have won out, at least for the present.]

CCP’s and GHA’s written comments on the Proposed MOU with the Socialist Republic of Vietnam can be found here: https://www.regulations.gov/comment/DOS-2025-0003-0011

CCP’s and GHA’s written comments on the Proposed Renewal of the MOU with Chile can be found in the 2024 docket here: https://www.regulations.gov/comment/DOS-2024-0048-0092

CCP’s and GHA’s written comments on the Proposed Renewal of the MOU with Costa Rica can be found here: https://www.regulations.gov/comment/DOS-2025-0003-0108

CCP’s and GHA’s written comments on the Proposed Renewal of the MOU with Italy can be found here: https://www.regulations.gov/comment/DOS-2025-0003-0010

CCP’s and GHA ‘s written comments for the Renewal with the Kingdom of Morocco can be found here: https://www.regulations.gov/comment/DOS-2025-0003-0009

Frances Hayashida, the Director of the Latin American and Iberian Institute at the University of New Mexico, spoke in support of  the MOU with Chile.  She stated artifacts were still being looted from Chilean sites despite the best efforts of Chilean authorities.  She specifically pointed to a sale of textiles being stopped in 2021.  She stated that import restrictions create a chilling effect on the market.  She further stated that the current MOU has helped stimulate cultural exchanges between scholars in Chile and the U.S. 

CPAC member Andrew Connor commends Hayashida for her testimony that calls into question the statements about a lack of looting from another speaker.

Scott Palumbo, an anthropologist at the College of Lake County, Illinois, spoke in support of the MOU with Costa Rica.  He has observed significant looting in Costa Rica with sites looking like WWI battlefields.   He referenced the existence of a large archeological society in Costa Rica.  He suggested that enforcement of laws against looting has meant that the country is even running out of room to store recovered antiquities.   He added that the current MOU had helped stimulate cultural exchanges between scholars. 

CPAC member Andrew Connor praises Palumbo’s testimony about looting and further states that tourism and protection of cultural heritage are not mutually exclusive and can complement each other.

Randy Myers spoke as a board member on behalf of the Ancient Coin Collectors Guild (ACCG). He touched on several points focused on the MOU with Italy.  First, he indicated while the State Department is doing better providing notice, the time provided remains inadequate, making it difficult to solicit informed public comment.  Second, Myers noted that the State Department’s public notice indicates that the MOU is being treated as an extension of the current agreement with Italy, not an expansion of the current designated list.  He stated if an expansion of the current designated list is being contemplated, the State Department must provide the public with notice about this proposal and allow additional comment.  Third, he emphasized that unlike many ancient artifacts coins are mass produced, with dies used to strike as many as 10,000 to 15,000 coins each.  This large production of coins combined with their wide dispersion means that one cannot assume that late Roman Republican and Roman Imperial coins are found in Italy.  He then referenced the same analysis that IAPN did that only 5% of Roman Imperial coin hoards are found in what it today Italy.  For that reason, he concluded that one cannot assume that a Roman coin means  an Italian one.  He further indicated that he believes that the State Department should encourage Italy and other countries to implement programs akin to the Tresure Act and Portable Antiquities Scheme as the most effective self-help measures. 

 CPAC member Alex Baker asks a question, but it is difficult to hear.  Myers interprets it as a question about what is the best way to address looting to which Myers again reiterates the benefits of the UK’s system.   

The ACCG’s comments regarding the Renewal of the MOU with Italy can be found here: https://www.regulations.gov/comment/DOS-2025-0003-0042

Doug Mudd spoke on behalf of the American Numismatic Association (ANA), where he is the Curator of the Money Museum.  He focused his comments on the proposed renewal of the MOU with Italy.  As an archaeologist, he has seen the damaging effects of looting but he believes that because of the massive quantities that were produced coins should be treated  differently.   He reiterated Tompa’s and Myers’ statements that one cannot assume that a Roman coin was found where it was minted.  He asked that no new import restrictions be imposed on late Roman Republican and Roman Imperial coins.   He also asked that other widely circulating coins be delisted. Mudd believes that restrictions on bringing  coins into the US negatively impacts the education of our own people about our own cultural heritage.

The ANA’s comments regarding the Renewal of the MOU with Italy can be found  in the 2024 docket here: https://www.regulations.gov/comment/DOS-2024-0048-0089

Benjamin Utting is an archeologist and anthropologist specializing in the prehistoric cultures of  Southeast Asia.  He spoke in support of the new MOU with Vietnam.  He indicated that an MOU would stop the flow of black market antiquities into the U.S. and would also encourage Vietnamese authorities to take further protective steps and spur collaboration.

Notable Additional Written Comments

 CINOA’s comments, which can be found on the 2024 docket  here:

https://www.regulations.gov/comment/DOS-2024-0048-0063

The Oriental Numismatic Society’s comments regarding the proposed MOU with the Socialist Republic of Vietnam can be found here:

https://www.regulations.gov/comment/DOS-2025-0003-0015

The speakers finished 20 minutes early.  As there were no additional questions, the Chair thanked the speakers before closing the public session and continuing discussions in private.

It's Time for a Reset

Here is what I said, more or less, at yesterday's virtual Cultural Property Advisory Committee Meeting.  I hope to post a full report of that meeting shortly:  

            The Trump Administration’s emphasis on promoting American business and scaling back regulations requires this Committee to consider a new paradigm, one which facilitates the lawful trade in common items like coins, particularly where they are already legally available for sale in countries seeking restrictions. 

            There is no better place to start than Italy.  Since 2011 there has been an embargo in place on ancient coins of Italian types minted before 211 BC.   During this same period, Italy’s Carabinieri have mounted a successful campaign against looters without damaging Italy’s large, lawful numismatic market. 

            What does IAPN request?  First, we join hundreds of coin collectors to oppose expanding the current designated list past 211 BC  to encompass late Roman Republican and Imperial coins. 

Prior committees that considered the initial MOU in 2001 and subsequent renewals for 2005, 2011, 2016 and 2021 all came to the same conclusion buttressed by current research: One simply cannot assume that all such coins are “Italian cultural property” when only 5.24% of the 15,000 Roman Imperial coins hoards containing over 6 million coins are found within Italy itself. 

The current Italian designated list also needs to be reformed.  At a minimum—using the Greek designated list as a model—larger denomination coins which circulated in international trade should be delisted.

            We also request that any renewal be conditioned on Italy facilitating the export of any item legally available for sale within Italy itself.  Despite solemn promises, Italy has actually made it harder to export ancient coins.  Finally, this Committee should also require that US Customs accept legal exports from sister EU countries as legal imports of items on the Italian designated list.  Such a modification of the current MOU is not only consistent with the UNESCO Convention, but also with Italian law. 

            The proposed MOU with Vietnam raises similar issues.  A past IAPN President who visited the UNESCO World Heritage site of Hue (pronounced “Hugh”) earlier this week reports that cash coins up for restriction here are for sale to tourists at a gift shop there. 

More than that, any import restrictions will only cause confusion.  Chinese cash coins found in Vietnam also circulated in far greater numbers in China.  They should be restricted, if at all, under the current Chinese MOU.  No Vietnamese coins should be restricted. The earliest Vietnamese coins are virtually identical to Chinese prototypes from the post-Tang period which are not restricted under the MOU with China. Later Vietnamese coins, particularly the machine struck coins of the French protectorate struck in France or at the US Mint, do not meet the threshold requirements for either archaeological or ethnological objects.

As for the other MOUs, the designated list for Morocco does not provide fair notice to importers.  It simply recounts all the ancient and early modern civilizations whose coin types circulated within Morocco without naming specific types exclusively found there. Limiting restrictions to types that “circulated primarily” in Morocco fails to correct this problem, particularly where the vast majority  “circulated primarily” elsewhere. Accordingly, if restrictions are to continue, the current designated list must be limited to bronze coin types issued by Moroccan mints for local circulation.

Finally, there should be no new restrictions on coins for Chile or Costa Rica.  Spanish Colonial and early Republican era coinage that circulated in these countries also circulated in far greater numbers elsewhere, including as legal tender here in the United States until 1857.   They are as much part of US cultural heritage as they are of these nations. 

Thank you.