IAPN and PNG join 88% of the public comments posted on the regulations.gov website that express concerns about the MOU’s restrictions on ancient coins. The cumulative effect of these restrictions has already damaged private and institutional collecting, the preservation of coins, the study of the history they represent, the appreciation of other cultures, and the people to people contacts collecting brings. And, of course, it has hurt the ability of Greek Americans to get in touch with their own culture.
Greece—which is still trying to dig out of a terrible sovereign debt crisis that has been exacerbated by an influx of Syrian refugees—needs our help, but import restrictions on coins are not the way to go. As applied by US Customs to coin types made in Greece rather than exclusively found in Greece, they do nothing but hurt legitimate collectors who want to obey the law. In this regard, I would like to commend Carmen Arnold-Biucchi for recognizing the wrong-headedness of an approach that focuses on where a coin is made rather than found. However, her proposal that all coins found in Greece be designated will just sow more confusion and further damage legitimate coin collecting UNLESS Customs is directed only to detain and seize coins WHERE there is specific proof that they were illicitly exported from that country. And, really, who is going to do that?
Restricting all Greek coins merely because some coins of the same type have been found in Greece would make a mockery of the plain meaning of the Convention on Cultural Property Implementation Act. It requires that objects of “archaeological interest” must be first discovered within Greece and subject to Greek export control before they can be restricted.
Let me also comment on some of the statements made by Dr. Nathan Elkins. Elkins now suggests the designated list should include all coins “commonly found” in Greece. However, Elkins previously advanced a different standard in his Journal of Field Archaeology article that attacks the Ancient Coin Collectors Guild and its test case. There, Elkins claims that the current designated list is proper because it is limited to coins that “primarily circulated there.” Such shifting positions totally ignore the statutory mandate and for that matter the past Greek Ambassador’s promise made on the record at the last MOU hearing that Greece only seeks restrictions on artifacts that are exclusively found there.
Elkins (and Prof. Jane Evans) also point to an increase in applications for metal detectors as a reason for restrictions, but isn’t that instead a reason for Greece to be either more careful in issuing such permits or adopting something akin to the PAS in the UK?
Next, Elkins suggests that a seizure of valuable Greek coins from Peter Weiss, a former ANS Trustee back in 2012 justifies restrictions. However, he fails to mention that a number of the coins had old provenances from the early 20th and late 19th century. If anything, the seizure and repatriation of coins with such old provenances should raise serious questions about overreach by NY State authorities.
Finally, Elkins points to a change in the ANS acquisition guidelines, but fails to note the ANS’ “cultural property” statement continues to recognize, “because most coins in private collections have been traded and held without any provenance, it is unreasonable to assume that a coin is stolen, illegally exported, or illegally imported merely because the holder cannot establish a chain of custody beyond receipt from a reputable source.”
Rather than overbroad restrictions that adversely impact Americans interested in Greek culture, let’s consider modest steps archaeologists can take—like ensuring their sites are monitored in the long off-season and ensuring local people they employ are paid a fair living wage so they don’t have an incentive to loot to help make ends meet—instead.
Simple steps like these could do far more to help protect Greece’s cultural patrimony than prohibitions on imports that only hurt legitimate collecting and people to people contacts and appreciation of Greek culture it engenders. Thank you.