Please Comment on the Proposed Renewal of a MOU with Greece

The United States Department of State has proposed a renewal of its current Memorandum of Understanding (“MOU”) with the Hellenic Republic for another five (5) years.  Once again, individuals will be afforded an opportunity to comment on whether the MOU should be extended.  

Coin collectors in particular should comment to help protect the current exemption for ancient trade coins struck in Greece.  Such coins—which include Athenian Tetradrachms, Corinthian Staters and Tetradrachms and gold coins of Philip and Alexander the Great—are very popular with collectors. 

Further official information about a May 24, 2016 Cultural Property Advisory Committee meeting and how to comment by the May 9, 2016 deadline can be found here: 

https://www.federalregister.gov/articles/2016/03/14/2016-05671/notice-of-meeting-of-the-cultural-property-advisory-committee  

To submit comments electronically, go to the Federal eRulemaking Portal (http://www.regulations.gov), enter the Docket No. DOS-2016-0009, and follow the prompts to submit a comment. (for a direct link see http://www.regulations.gov/#!documentDetail;D=DOS-2016-0009-0001 )(Please note comments may be posted only UNTIL MAY 9, 2016 at 11:59 PM.)

Please also note comments submitted in electronic form are not private. They will be posted on the site http://www.regulations.gov. Because the comments cannot be edited to remove any identifying or contact information, the Department of State cautions against including any information in an electronic submission that one does not want publicly disclosed (including trade secrets and commercial or financial information that is privileged or confidential pursuant to 19 U.S.C. 2605(i)(1)).

 What should you say?  Provide a brief, polite explanation about why the renewal should be denied or limited.  Consider the following points:

• The governing statute requires that restrictions only be applied on artifacts "first discovered in Greece." But hoard evidence demonstrates that Greek coins circulated extensively outside the confines of the Modern Greek nation state.  Although smaller denomination silver and bronze coins have been restricted, the State Department and U.S. Customs have already recognized this fact for higher denomination coins and they may still enter the US without difficult to obtain documentation.  At a minimum, this finding protecting the collecting of Ancient Greek trade coins should be preserved. 
• The governing statute requires restrictions only be placed on artifacts of "cultural significance." But coins -- which exist in many multiples-- do not meet that particular criteria.
• The governing statute requires that less drastic remedies be tried before import restrictions. But Greece has not tried systems akin the UK Treasure Act before seeking restrictions.
• The governing statute requires that restrictions be consistent with the interests of the international community in cultural exchanges. But restrictions diminish the ability of American collectors (particularly Greek Americans) to appreciate Greek culture and greatly limit people to people contacts with other collectors in Europe.
• Restrictions are unfair and discriminatory to Americans. Collectors in the EU--including Greece-- have no similar limitations on their ability to import ancient coins.
• The Greek people are suffering from severe economic problems.  Commerce in common artifacts like coins that are available for sale throughout Europe should be encouraged.  The Greek economy can benefit from the legal sale of such coins to tourists and collectors who want to own a real piece of Greek History, which, after all, was originally designed to circulate. 

 Finally, you don’t have to be an American citizen to comment—you just need to be concerned enough to spend twenty or so minutes to express your views on-line.  Comments from collectors from Greece are particularly welcome!