CPO’s 2025 Year in Review- Repatriation on Demand Continues as Law of the Land

 The past year was another challenging one for collectors, the trade and museums.  Despite the Trump Administration’s “America First” rhetoric, repatriation on demand as a “soft power” measure pitched as a means to address “past wrongs” remains the default position of the US State Department, law enforcement, and increasingly US Museums. 

US Import Restrictions under the Cultural Property Implementation Act

The Cultural Property Implementation Act (CPIA) authorizes the executive branch to enter into cultural property agreements or CPAs with foreign governments conditioned on specific findings.  In all but emergency situations, these must be specific findings that the cultural heritage of a specific country is in danger, that the country has engaged in “self-help” measures, that any action is being taken in concert with other market nations, that there are no less drastic remedies available, and that the any action is consistent with the interchange of cultural property for scientific and educational purposes.  19 U.S.C. § 2602 (a) (1).  In “emergency” situations, these requirements are relaxed, but the material to be restricted must either be a “newly discovered type” of “importance,” site specific, or there is a "crisis" threatening the record of a particular culture that can be addressed temporarily by import restrictions. Id.  § 2603.  Once a CPA is signed, U.S. Customs and Border Protection (CPB) prepares “designated lists” of objects subject to repatriation that are published in the Federal Register.   Id.  § 2604.

Over time, however, the required findings designed to place significant substantive and procedural constraints on executive authority have devolved into a “check the box” exercise, and mission creep has repurposed and vastly expanded the program.  What thus started as a forward looking, focused effort to protect archaeological sites and artifacts of cultural significance abroad has now morphed into a comprehensive program to “claw back” and repatriate most archaeological and ethnological objects made or found in a given country from prehistory to the early 20^th century.   While the number of seizures under the CPIA are impossible to determine because CBP has consistently stonewalled FOIA requests, they probably number in the thousands of objects with far more to come as AI is increasingly used to sift through shipments.

Most significantly for the sheer number of American citizens impacted, restrictions now typically extend to common items like historical coins.  Generally speaking, such coins circulated regionally and internationally as items of commerce in the past and are widely collected today.   Yet, under current enforcement guidelines, CBP  can “assume” that any coins of a type that appears on multiple, overlapping designated lists are subject to detention, seizure and forfeiture.

In contrast, a fair reading of the CPIA instead suggests that there must at least probable cause that “designated material” was “first discovered within and is subject to export control by, the State Party”  and that it was exported after the effective date of any governing regulations before it can be seized, forfeited and repatriated.  Id.  §§ 2601, 2606.  However, the Fourth Circuit Court of Appeals rejected an effort at judicial review, holding instead that the issue was a “foreign policy” matter beyond full judicial review.

As a result, import restrictions under the CPIA are not applied solely to illegal exports made after the effective date of regulations under § 2606, but rather are now enforced far more broadly against any import into the US made after the effective date of regulations, i.e., as an embargo, not targeted, prospective import restrictions.  Such enforcement damages legitimate trade, particularly with Europe, because many common artifacts like coins simply lack the documentation necessary to take advantage of a limited “safe harbor” provision for artifacts proven to be outside the country with a CPA before the effective date of any implementing regulations.

Despite significant “disruption” elsewhere, the “soft power” status quo remains alive and well at the Trump State Department when it comes to CPAs and import restrictions on cultural goods. Just in 2025, the Trump II administration implemented Biden era requests for import restrictions on virtually all archaeological and ethnological objects  for India, war-torn Lebanon, and Uzbekistan with renewals being considered for  Taliban Afghanistan, Chile, Columbia, Costa Rica, Italy, Morocco, and Turkey, and new CPAs being considered for Cameroon and Communist Vietnam.

Of particular concern for coin collectors is the expansion of import restrictions to widely collected Roman Imperial coins.  Despite the tiny percentages of such coins found in Afghanistan, Pakistan and Ukraine, the Biden Administration added Roman Imperial coins to “designated lists” for such countries. Moreover, in 2025, the State Department held CPAC hearings to consider renewals of current CPAs with Italy and Turkey, which could be an excuse to expand current import restrictions to include such coins.  

In mid-December, the State Department again renewed its current CPA with Italy, but without any of the past fanfare.  That renewal means that another 5 years of import restrictions must be announced on or before the current ones expire on January 19, 2026.  That makes it likely that the Trump II Administration will at least extend current Obama era import restrictions on ancient Greek, Punic and early Roman Republican era coins as part of the renewal.  What remains uncertain is whether the Trump Administration will continue the Biden Administration’s efforts to place new restrictions on widely collected Roman Imperial coins.  During a State Department Cultural Property Advisory Committee hearing in May, CPO and other representatives of collectors and the trade opposed any such move, citing scholarly evidence proving that such coins circulated in quantity from Britain to Sri Lanka, with  less than 6% of the total number of validated Roman Imperial coin hoards comprising almost 7 million coins being found in Italy,  Under the circumstances, it should be impossible for CBP to assume that any  particular Roman Imperial coin was found in and illicitly exported from Italy as of the effective date of any regulations, but it remains to be seen if undisputed scholarly evidence matters  more than “soft power.”

More evidence that the status quo has not changed can be seen in the lack of turnover in the Cultural Property Advisory Committee (CPAC) and continued State Department funding of archaeological advocacy groups, notably the American Society of Overseas Research (ASOR).    CPAC is an advisory committee that makes recommendations to the Executive Branch about entering into and renewing CPAs.  Its current membership, which is to represent the separate interests of the public, the trade, archaeology and anthropology, and museums, remains completely comprised of Biden appointees. Not surprisingly, based on their interactions with representatives of collectors and the trade at CPAC meetings, most, if not all these Biden political appointees seem to share the Biden State Department’s views that prioritized CPAs and “soft power” over protecting American  collectors and fostering legitimate trade.

State Department funding of ASOR and related archaeological groups is largely directed at conservation programs within countries with CPAs, but part of that funding has also been used to draft reports to help justify more controversial CPAs, like the one with one of the armed factions running Libya.  There is a built-in conflict of interest here because these groups represent archaeologists who can only excavate in these countries with the permission of their governments.  As a result, these groups are reluctant to criticize local corruption and mismanagement or laws that declare state ownership and/or control of most anything “old.”  Nor does the State Department have any incentive to rein in such practices.  The selective “evidence” these groups provide at CPAC hearings helps the State Department bureaucracy “check the box” on the CPIA’s statutory requirements and hence justify further “soft power” CPAs.  

In the past under Biden,  this “collaboration” went so far as to bypass CPAC review and public comment for the renewal of a CPA with a Saudi supported faction in Yemen.  Instead, the new CPA was signed at an “invitation only” event sponsored by the Antiquities Coalition, another advocacy group that has received substantial past State Department funding.  

With the Trump II Administration going into its second year, there remains only a fleeting hope that there will be a major “rethink” of the State Departments prioritizing “soft power” over the private property and due process rights of American collectors. no matter how damaging current import restrictions are to American collectors and lawful cultural exchange, primarily with Europe. 

Threats of Criminal Liability to Force Repatriations

Even more concerning than ever more expansive CPAs are the hard ball tactics of Alvin Bragg’s Manhattan District Attorney’s office (the same office that prosecuted President Trump for falsifying business records).   Matthew Bogdanos, an assistant DA in that office, has gained notoriety by utilizing threats of criminal prosecutions under New York law to “encourage” museums and collectors into “voluntarily” repatriating objects to countries as diverse as Communist China, Italy, Greece, the Islamic Republic of Iran, Libya, and Turkey.   As far as Bragg and Bogdanos are concerned, any object claimed by a foreign country under its own laws will also be treated as “stolen” under New York law even if it left that country decades ago.  The object need not be located in New York today as long as the artifact itself or any transaction related to that artifact, passed through New York at some point in the past.  Furthermore, limitations periods do not apply because each new day of possession a “stolen” object starts the statute of limitations running over again.

Forced repatriations of bronze statues traced to a Roman Imperial era sanctuary in Boubon, Turkey, illustrate some of these issues.  The statues in question apparently were illegally excavated by townspeople and smuggled from Turkey in the 1960s before the 1970 UNESCO Convention provided a legal basis for repatriation.  These statues were openly sold and displayed for decades until archaeological activists gained Bogdanos’ ear after which he demanded that the Cleveland Museum of Art repatriate one of them prominently displayed in its collection.  The Museum initially contested the claim but reconsidered once scholarly evidence suggested that the statue was indeed from Turkey. 

Since then, Bogdanos, with the help of archaeological activists, has been tracking down other statues from the same group.  Most recently, Bogdanos made a claim for another statue from a collector in California.  That collector initially fought the claim by bringing his own case in federal court only to dismiss it and capitulate after being indicted by the Manhattan DA’s office.  Obviously, any rational collector would give up whatever the merit of their own legal arguments given the threat of jail time. 

Once again, the narrative planted in the press only told part of the story.  While the collector apparently capitulated after evidence was disclosed that he knew it was smuggled from Turkey, important questions about the Manhattan DA’s jurisdiction over the object that had been in California for decades remained.  Another important issue here is that while Turkey’s authoritarian government likes to paint itself as a historic “victim,” reality is quite different.  Ottoman Turkey was an Imperial Power that enriched its own palaces with cultural goods taken from its oppressed, foreign subjects.  Moreover, Recep Tayyip Erdoğan’s Turkey of today has similar Imperialist pretentions.  The Turkish government has encouraged looting and destruction of cultural heritage abroad in places like Cyprus and Syria.  It has converted historic churches like Hagia Sophia into mosques.  It has also encouraged treasure hunting in former Christian and Jewish areas.  This should raise a basic question.  Should Turkey really benefit from repatriations of objects removed decades ago and openly displayed since when it has such “unclean hands” today?

Voluntary Repatriations from Museums

The past year was also another banner year for voluntary repatriation from museums.  While such voluntary repatriations may make sense in given circumstances (particularly when they relate to indigenous communities or individual victims), the problem is that returns made on “ethical considerations” to nation states or other governmental powers are all too often based on a selective review of the facts.

Museums are public institutions and Museum Trustees have a duty to retain and preserve the objects in their collections for the public.  After all, most objects in museum collections were donated by private citizens with the expectation that they would be displayed for the American public, not repatriated abroad.

Some years ago, activists with the the Archaeological Institute of America helped convince the Association of Art Museum Directors to adopt new acquisition guidelines.  These state that member museums should not acquire an object unless provenance research substantiates that the work was outside its country of probable modern discovery before 1970 or was legally exported from its probable country of modern discovery after 1970.  At the time, this 1970 date was pitched as a safe harbor for current and future acquisitions.  However, as we have seen,  all that has gone down the Orwellian memory hole as far as the Manhattan DA is concerned.  Moreover, despite the Trump Administration’s “war on woke” at museums, the 1970 Rule has increasingly been replaced with a much more subjective one calling for “ethical returns."  Such ethical considerations are increasingly being applied, particularly where it is alleged that the object in question is the product of “colonial exploitation.” 

Ethics are fine but “provenance research” must tell the whole story, not simply half-truths designed to justify repatriation.  Recent repatriations from the Smithsonian and other Institutions such as the Museum of Fine Arts, Boston ,of Benin “bronzes” come to mind.  The return of these objects to the Oba, a traditional ruler in Nigeria, have been justified as righting the colonialist wrongs perpetrated during a punitive British colonial military expedition that took the bronzes as war prizes.  What is all too often left unsaid, however, is that the Oba’s own wealth derived from the slave trade and that the bronzes themselves are made up of melted “manilla” currency used to buy and sell slaves.   Shouldn’t that be relevant to repatriation decisions, particularly when it deprives Americans who descended from slaves taken by the Oba of tangible evidence of their own undeniable victimization?

Legislative Initiatives

It is not all gloom and doom, at least for coin collectors.  Last term, Congresswoman Beth Van Duyne (R-Texas) introduced a technical correction to the CPIA, H.R. 7865, towards the end of the 118^th Congress in April 2024.  This same bill was reintroduced in the 119^th Congress on January 21, 2025, as H.R. 595. The bill currently has fourteen cosponsors, including ten Republicans and four Democrats, making it bipartisan. 

The legislation’s “safe harbor” language allows for the import of coin types on “designated lists” with evidence the numismatic material was acquired lawfully, is of a known type, and is not the direct product of illicit excavations within a UNESCO State Party after the effective date of any import restrictions on coins. The hope is that the bill will be attached to a larger trade bill that is typically passed each Congress.  However, there is some concern that given the month-long government shutdown, there will be no such legislation this year, and it will be necessary to try to get H.R. 595 reintroduced again next term. 

While H.R. 595 would help protect the legitimate trade in collector’s coins, far more ambitious legislation also is necessary to rein in the State Department and Manhattan DA’s office and protect the due process and private property rights of collectors. 

For Further Reading

For coverage of 2025 CPAs, CPAC hearings and import restrictions Under the CPIA, see the Cultural Property Observer Blog, Blog Archive 2025, available at   https://culturalpropertyobserver.blogspot.com/2025/ (last visited January 2, 2026).

For a discussion of the ACCG’s past effort to seek judicial review of the decision to impose import restrictions on coins, see An Epic Battle: U.S. v. 3 Knife-Shaped Coins, Cultural Property News (October 15, 2018), available at https://culturalpropertynews.org/an-epic-battle-u-s-v-3-knife-shaped-coins/ (last visited January 2, 2026).

For a discussion of State Department funding of archaeological advocacy groups, see Peter K. Tompa, Careful Collector No. 22-Your Tax Dollars at Work, Cultural Property News (December 28, 2023), available at https://culturalpropertynews.org/careful-collector-no-22-your-tax-dollars-at-work/ (last visited January 2, 2026).

For a FOIA release related to the “invitation only event” to sign a CPA with a Yemeni faction, see The ACCG has secured important evidence about the extent of cooperation between the State Department and archaeological advocacy groups, most notably, the mysteriously well-funded Antiquities Coalition, Ancient Coin Collectors Guild Website, News, available at https://www.accguild.org/news/13420183 (last visited January 2, 2026).

For more on the Manhattan DA’s repatriation of a statute to Turkey, see Tom Mashberg and Grahm Bowley, Collector Surrenders ‘Nude Emperor’ Statue Identified as Looted, The New York Times (December 8, 2025), available at https://www.nytimes.com/2025/12/08/arts/design/nude-emperor-statue-met-marble-head-turkey.html#:~:text=But%20the%20Manhattan%20district%20attorney's,it%20too%20had%20been%20looted. (last visited January 2, 2026).

For more about the 1970 Rule, see 2013 Guidelines on the Acquisition of Archaeological Material and Ancient Art, Association of Art Museum Directors Website, Standards and Practices (January 29, 2013), available at https://aamd.org/standards-and-practices (last visited January 2, 2026).

For more about the Smithsonian’s ethical returns policy, see Shared Stewardship and Ethical Returns Policy, see Smithsonian National Museum of Asian Art, available at https://asia.si.edu/explore-art-culture/collections/collections-policies/shared-stewardship-and-ethical-returns-policy/ (last visited January 2, 2026).

For more about the legal complexities of the return of the Benin bronzes based on “ethical considerations,” see Channa M. Norman, Benin Bronzes Highlight Complexity of Repatriation Decisions, Shook, Hardy and Bacon Website, available at https://www.shb.com/intelligence/publications/2025/q4/norman-benin-bronzes (last visited January 2, 2026).

For more about H.R. 595, see HR 7865, a Bill to Facilitate the Lawful Trade in Collectors' Coins, Reintroduced as HR 595, Ancient Coin Collectors Guild Website, News, available at https://www.accguild.org/news/13463512 (last visited January 2, 2026).

For more about the legislative reform needed, see Peter K. Tompa, Opinion: It’s Time to Make Collecting Great Again!  Cultural Property News (April 3, 2025), available at https://culturalpropertynews.org/time-to-make-collecting-great-again/ (last visited January 2, 2026).

Repatriation of Late Roman Imperial Coins Raises Serious Questions about the Cultural Property Agreement with Turkey and the Private Property Rights of American Citizens

 Nazlan Ertan, writing for Al-Monitor, reports on the repatriation of 83 Late Roman Imperial coins struck at Anatolian Mints, under a 2021 Cultural Property Agreement (CPA)  between the United States and Turkey.  See Nazlan Ertan, Turkey boasts of antiquities' return, but faces scrutiny at home, Al Monitor (October 4, 2025), available at https://www.al-monitor.com/originals/2025/10/turkey-boasts-antiquities-return-faces-scrutiny-home (last visited October 16, 2025).

Ertan quotes Deputy Culture and Tourism Minister Gokhan Yazgi as stating, “The process was swift, transparent and efficient.”  The article then goes onto to portray the authoritarian government of President Recep Tayyip Erdogan as using “repatriation victories to project cultural authority abroad, an arena in which Turkey currently leads.”     

While the article also criticizes government mismanagement and the influence of short term political and commercial interests, Ertan completely ignores the serious critique of both Erdogan’s policies and the CPA levelled by  representatives of the trade, collectors and minority religious and ethnic groups at a recent U.S. State Department Cultural Property Advisory Committee meeting convened to discuss the CPA’s renewal. 

Indeed, the news of the repatriation of these Roman Imperial coins highlights these problems, at least for coin collectors.  First, it is unclear how the 2021 CPA and its implementing regulations can retroactively justify a seizure that took place in 2015, some six years earlier.  Second, it is highly questionable that the Roman Imperial coins that were seized are even subject to the import restrictions that implement the CPA.  Those regulations apply to Roman provincial coins, but not to Roman Imperial coins, which circulated well beyond the confines of modern-day Turkey as far as England in the West and Sri Lanka to the East.  Certainly, one cannot assume that such coins were found in Turkey, a prerequisite for them to be restricted under the governing statute, the Cultural Property Implementation Act. 

As it is, this looks like yet another case where the U.S. State Department and U.S. law enforcement have prioritized “cultural diplomacy” over due process rights for American citizens. As such, this seizure represents yet another reason for Congress to pass HR 595, a bill to protect coin collectors, as well as far more ambitious reform legislation to protect the private property rights of American citizens. 

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