Hipster Internet Art Newsletter Raises Alarm About Antiquities being "Weaponized" for Political Purposes

"Hyperallergic,"  an Internet "forum for playful, serious, and radical perspectives on art and culture in the world today" has joined the Committee for Cultural Policy in taking on fantastical claims about ISIS funding itself with looted antiquities, albeit from a far different perspective.  Tellingly, the post by archaeologist Michael Press -- though well researched-- avoids the elephant in the room.  Who was responsible for "weaponizing" antiquities in the first place?  The ISIS killing machine was bad enough to justify military intervention, particularly given its terror threats not only in the region but to Europe and the US as well.  

Of course, the answer is quite apparent to those who represent the interests of collectors, museums and the trade.  It is the State Department's Cultural Heritage Center, which worked along with ASOR, the  State Department contractor mentioned in the article, and the Antiquities Coalition, a well-funded archaeological advocacy group with ties to ASOR, the Archaeological Institute of America, as well as authoritarian Arab regimes. These groups were quite successful in laundering their dubious narrative not only through mainstream media (NY Times, Washington Post, Wall Street Journal, CBS, etc.) but through the foreign policy establishment as well (think tanks and Foreign Policy Magazine).  The goal was threefold.  First, getting Congress to pass permanent import restrictions on Syrian cultural goods (which was achieved through these scare tactics).  Second, creating and funding an "Antiquities Czar" position that would elevate these groups' influence even further within the US Government.  (A goal that was not realized.)  Third, convincing Congress to lower the bar for criminal prosecutions based on foreign cultural patrimony laws.  (Another  goal that was not realized.) Meanwhile, those representing the interests of collectors, museums and the trade that raised the exact same issues about the credibility of these fantastical numbers early on have become targets for abuse from some of the very same individuals Press acknowledges for their contributions in exposing the truth.  

Special Report on Grossly Overstated Claims that ISIS Funds itself with Antiquities Sales.

The Committee for Cultural Policy has issued a report demonstrating how news media and advocacy groups associated with the archaeological lobby have spread disinformation (including some from Russian and Syrian sources) about the value of artifacts looted by ISIS.  A must read.

"Emergency" Restrictions on Libyan Cultural Goods Imposed

U.S. Customs has announced so-called "emergency" import restrictions on Libyan cultural goods.  Once again, grossly over-hyped fears of illicit antiquities funding terrorism appears to be the primary  justification for rushing through this dubious request, even though it meets few, if any, of the statutory criteria and it is doubtful the militias running the country will protect any artifacts that may be repatriated under the agreement. 

The sheer breadth of the "designated list" also raises concerns.   The Cultural Property Implementation Act contemplates that any “emergency restrictions” will be far narrower than "regular" ones.  They focus on material of particular importance, but no “concerted international response” is necessary.  The material must be a “newly discovered type” or from a site of “high cultural significance” that is in danger of “crisis proportions.” Alternatively, the object must be of a civilization, the record of which is in jeopardy of “crisis proportions,” and restrictions will reduce the danger of pillage. 


Yet, here, import restrictions have been imposed on virtually all Libyan cultural goods.   And despite the lack of "cultural significance" all coin types that were made or circulated within Libya down to 1750 A.D. are now potentially subject to restrictions.   At least in a bow to the CPIA's wording limiting such restrictions to items "first discovered" within Libya, the regulations contain some belated acknowledgement any restricted coins must also be "found" there.  (Previous import restrictions on coins have improperly equated where they are found with where they are minted, though they are items of commerce that typically circulated widely.)

CCP Welcomes Global Heritage Alliance

The Committee for Cultural Policy has a new sister organization, the Global Heritage Alliance.  Global Heritage Alliance will act as an advocacy organization.  GHA has already submitted Congressional testimony and testimony before CPAC.  GHA hopes to provide decision makers in the Administration and Congress with a much needed pro-museum, pro-collector prospective. 

Another Dubious Seizure of an Artifact Long on Display

NY Prosecutors Vance and Bogdanos have seized a fragment of a relief said to be from Persepolis from a London dealer who set up at a New York City Art Fair.  The relief in question had been put on display at a Canadian museum back in the 1950’s.  The seizure raises serious legal questions about whether the Iranian statute used as the basis for the seizure really vests title of the artifact in Iran, whether at the time such artifacts were given to excavators so they may not, in fact, be “stolen,” and whether laches would apply to defeat such a stale claim.  There is also the obvious question whether Vance and Bogdanos should be using New York taxpayer’s money to take private property to award it to the Islamic Republic of Iran, a state sponsor of terrorism whose top officials at times have threatened to bulldoze pre-Islamic sites like Persepolis and the tomb of Cyrus the Great.  But the real question is whether the dealer will fight the seizure, particularly given the costs and potential criminal liability involved.  

Virtual CPAC Meeting on Cambodian MOU Renewal Request

On October 23, 2017, the U.S. Cultural Property Advisory Committee held a “virtual” meeting where CPAC members and all speakers were linked via an internet based video platform.  According to my notes, at least the following CPAC members were in attendance:  (1) John Frank (Trade); (2) Karol Wight (Museum); (3) Lothar von Falkenhausen (Archeology); (4) Nancy Wilkie (Archaeology); (5) Rosemary Joyce (Archaeology); (6) Dorit Straus (Trade); (7) James Willis (Trade); (8) Shannon Keller O'Loughlin; and (9) Jeremy Sabloff (Public-Chair).

There were six (6) speakers:  (1) Tess Davis (Antiquities Coalition); (2) Kate FitzGibbon (Committee for Cultural Policy); (3) Mitch Hendricksen (University of Illinois). (4) Josh Knerley (Association of Art Museum Directors); (5) Katie Paul (Antiquities Coalition); and (6) Peter Tompa (Global Heritage Alliance).

Tess Davis- Speaks on her own behalf.  Katie Paul will speak for Antiquities Coalition.  She unequivocally supports renewal of the MOU.  She has worked in Cambodia since 2004.  Davis has never received pay from the Cambodian government and she has worked for the New York prosecutor’s office pro bono.  [She presumably is on salary from the Antiquities Coalition and/or otherwise receives funding.]  The MOU brings tremendous benefits and protects collectors from buying recently looted materials.  She is dedicated to the cause of fighting looting.  She has read the letters of those opposed to the MOU and finds them misguided.

Kate FitzGibbon- There has been an ongoing embargo on Cambodian artifacts for 18 years.  This embargo was put in place as an administrative matter without complying with Congressional limitations.  For instance, after a prior CPAC only supported emergency restrictions on Cambodian statuary in 1999, restrictions were expanded administratively in 2003 without CPAC’s knowledge or consent.   The issue that CPAC should be asking is whether Cambodia is undertaking all the self-help measures it can.  One issue is whether there are adequate museum inventories.  Renewing the MOU will only help legitimize Hun Sen’s repressive government.

Mitch Hendricksen- He supports the MOU.  He works in Cambodia.  NGOs such as Heritage Watch have helped educate local people that looting hurts their heritage.  Now, economic development is the greatest threat to cultural heritage.  The MOU has helped relationships between the government and American archaeologists. 

Lothar von Falkenhausen asks about looting.  Hendrickson says most of temple complexes were stripped clean of statues years ago.  A new road has been built to the temple complex of Preah Khan.  It has brought tourists and police patrols that make looting less likely.

Nancy Wilkie asks about local museums.  One was built near a police station which makes it less likely that it will be looted.  Heritage Watch has done a good job educating locals not to loot.

Josh Knerly- The AAMD supports a renewal of the MOU, but requests that benchmarks be applied to assess self-help.   The US Government and other foreign donors have given generously to Cambodia’s cultural heritage establishment, but the CPIA requires some action on behalf of the Cambodian government.  There needs to be more cultural exchange, not just in situations where an American museum has repatriated an artifact. 

Rosemary Joyce wants to know if the MOU has been responsible for loans.  Knerly says you cannot make that assumption. 

Dorit Straus asks about inventories.  There is a good inventory for artifacts in the National Museum, but not for regional and local museums. 

Lothar von Falkenhausen states that the National Museum collection is on-line.

Katie Paul- Her presentation was difficult to follow given technical problems.  In any event, Paul showed charts that appear to suggest that the United States remains the dominant market for undocumented archaeological objects.  Paul identified 231 artifacts for sale on a web based auction sales platform that were Khmer archaeological artifacts.   There are currently another 46 items on eBay.   The values range from $200-500 Euros to $65,000.  Some of the listings do have provenance information.

Peter Tompa- Notes that the State Department can no longer ignore the self-help requirement.  The House Appropriations Committee has required CPAC to quantify annual national expenditures on securing and inventorying cultural sites and museums.  CPAC should also consider other concrete self-help measures in a revised Article II.  For instance, it is not clear whether foreign archaeological missions pay their workers a fair living wage or take advantage of modern electronic surveillance systems to monitor their sites for looting in the long off season.  CPAC should also question Cambodian authorities about persistent allegations that elements within the Cambodian military continue to loot out of the way temple complexes.  Finally, CPAC should advocate that Cambodia investigate the creation of a portable antiquity reporting scheme for minor objects found on private land.  Tompa's complete comments may be found here.

Nancy Wilkie asks why there is an embargo if restrictions allow in documented material.  Tompa states the CPIA limits restrictions to artifacts illicitly exported after the date of restrictions, but Customs applies the restrictions to all artifacts on the designated list.  Documentation is frequently unavailable for items of modest value. 

Lothar von Falkenhausen launches into a monologue in response to Tompa’s suggestion that redundant artifacts could be sold after being recorded.  He states that even minor artifacts have critical context.  Tompa states that the CPIA distinguishes between archaeological interest and cultural significance.  He also indicates that the PAS helps record context.

James Willis asks Tompa to respond to the contention that Cambodia is a poor country that cannot spend money on heritage.  Tompa states that ticket sales at Angkor archaeological park have become a cash cow and that some should be spent for heritage purposes.  He also notes Congress has required CPAC to provide information about expenditures and it up to others to decide their significance.  

Global Heritage Alliance Comments on Proposed Renewal of MOU with Cambodia

Here are my comments more or less on behalf of Global Heritage Alliance regarding a proposed renewal of a MOU with Cambodia:

          I am speaking for the Global Heritage Alliance, an advocacy organization representing the interests of collectors, the museums and the trade in cultural artifacts.  I will focus my comments today on the required findings of 19 U.S.C. Section 2606 (b) and (c).  These include the need for self-help measures and the requirement that less onerous alternatives than import restrictions be considered first.

            There have been import restrictions in place on Cambodian cultural artifacts in some form since 1999.   Such import restrictions hurt legitimate collecting here in the United States because they effectively embargo “designated” material legitimately sold abroad. 

            While import restrictions have certainly damaged collecting here in the United States, it is unclear what Cambodia has been doing for all those years to protect its own cultural patrimony, particularly when elements within its own military stand accused of carting off tons of statuary from out of the way temple complexes with the help of government-issue heavy equipment.

            The CPIA has always required a finding that Cambodia has been doing its part to protect its cultural patrimony and that alternatives to embargoes be considered first, but these and other statutory requirements have been glossed over time and again to  provide a “deliverable” for the State Department to serve up to Cambodia’s authoritarian government. 

            Now, however, Congress has determined that such “business as usual” is no longer acceptable.  Recently, Congress added the following directions to CPAC in a report accompanying appropriations of State Department funds:

Cultural Property.--The Cultural Properties Implementation Act (CPIA) requires countries participating in MOUs restricting cultural property take significant self-help measures. The Committee urges the Cultural Property Advisory Committee to consider the annual national expenditures on securing and inventorying cultural sites and museums in its annual reviews of the effectiveness of MOUs, as well as during the reviews required by the CPIA for extension of an MOU. The Committee also requests the Secretary of State review the feasibility of collecting and reporting on the cost of measures taken by partner countries in support of their cultural property MOU with the United States and be prepared to report on such review during the hearing process on the fiscal year 2019 budget request.

House Report 115-253 at 11. 

            Here, although Cambodia has made an astounding $76 million from ticket sales just for the Angkor archaeological park in the first nine months of 2017 alone, it is unclear how much money the Cambodian government (as opposed to foreign donors) spends annually on securing and inventorying cultural sites and museums.   Given Congress’ direction, CPAC should ascertain this information from the Cambodian government and allow it to help guide its deliberations.

            CPAC should also consider other concrete self-help measures in a revised Article II.  For instance, it is not clear whether foreign archaeological missions pay their workers a fair living wage or take advantage of modern electronic surveillance systems to monitor their sites for looting in the long off season.  For that reason, consistent with Congressional directives, GHA requests CPAC to seek information on these issues and to condition any further renewals on Cambodia setting ascertainable benchmarks in these areas. 

            CPAC should also question Cambodian authorities about persistent allegations that elements within the Cambodian military continue to loot out of the way temple complexes.  At a minimum, Cambodian officials should be required to report on what efforts are being made to ensure military discipline directed at discouraging looting by members of the Cambodian armed forces.

            Finally, CPAC should advocate that Cambodia investigate the creation of a portable antiquity reporting scheme for minor objects found on private land.  Once objects reported under that scheme are registered, land owners and/or finders acting with the permission of the landowner should be allowed to retain or sell common objects not necessary for state museums. Such a program, which has been quite successful in the United Kingdom, should be a model for countries such as Cambodia, at least as far as common, redundant objects found on private land are concerned. 

            Thank you for this opportunity to speak.  

Little Public Support for Renewed MOU with Cambodia

Low numbers of comments to CPAC suggest low public support for a renewed MOU with Cambodia.  Indeed, though most of the twenty-one (21) comments were supportive of the renewed MOU, virtually all these came from archaeologists who depend on Cambodian excavation permits or their associated archaeological advocacy groups.  Meanwhile, it is finally dawning on some in Congress that MOUs have devolved into special interest programs for archaeologists.  Significantly, Congressional appropriators have required CPAC to report on the expenditures MOU partner countries make in securing their own cultural patrimony.  Hopefully, this will help change a culture that has vilified collectors to help divert attention away from poor stewardship of archaeological resources by source countries. 

Archaeologists for Assad?

UNESCO's Bulgarian Ex-Communist Director-General has praised Syria's Director-General for Antiquities and Museums in glowing terms.

“'When history books teach children about those who contributed to conserving Syrian heritage during the devastating conflict in Syria, Dr Maamoun Abdulkarim will be at the top of the list, along with all others who have been so dedicated and deserving of the world’s respect for their relentless, humanist commitment', said UNESCO Director General, Irina Bokova."

What appears lost on UNESCO and members of the archaeological lobby who have also sung Abdukarim's praises is the fact that the Assad regime, which Abdulkarim serves, itself has been responsible not only for mass murder, but for the looting and the intentional destruction of Syrian cultural patrimony.  Indeed, Assad, like other Arab Strongmen, appears all too willing to use and abuse archaeology for his regime's own political purposes.  So, why should Abdulkarim be praised at all?

Ancient Coin Collectors Guild Files a Reply Brief

The Ancient Coin Collectors Guild has filed a reply brief in the long running forfeiture action related to the coins the Guild imported for purposes of a test case.  Due process requires the government to make out each element of its case before private property may be forfeited.  Simple, no?  For more, see here.

Eurocrats Find Little Evidence Terrorist Artifacts Entering Market, But that Does Not Stop Calls for Draconian Legislation

Ivan Maquisten writes that EU bureaucrats believe the absence of evidence that ISIS looted material is entering the market is reason for more draconian controls, not fewer.  The bureaucratic thinking is that vast amounts of looted material must be entering the market unnoticed under current customs regimes.  Of course, those who seek to justify draconian regulation will not consider the distinct possibility the extent of ISIS looting has been greatly overstated by Russian and Syrian propagandists and archaeological advocacy groups for their own purposes.  Moreover, it does not help that the EU cultural bureaucracy-- like its US counterpart-- only considers archaeologists and foreign governments legitimate stakeholders in the issue.  No wonder the cultural bureaucracy is so distrusted by collectors and the small businesses of the antiquities and numismatic trade. 

Just What One would Expect from a Military Dictatorship That Respects Neither Private Property Rights Nor Human Rights

Egyptian government officials have attacked an edict of a religious scholar approving of landowners keeping treasure found on their own land as long as part is given to charity.  Meanwhile, a member of the country's parliament seeks the death penalty for anyone caught with illicit antiquities.  Just what one would expect in a military dictatorship with a rump parliament that respects neither private property rights nor human rights.

A Repatriation Only the Most Ardent Repatriationist Could Love

One can only hope one of the few Trump political appointees at the State Department takes a close look at the Obama Administration deal to repatriate the Iraqi Jewish Archive.  Such a repatriation would seem to be against everything America stands for.  Some of the materials were originally confiscated from Iraqi Jews who were forced to leave their country under Saddam Hussein.  Others appear to be taken from schools and synagogues after they left. All the material was stored in the basement of Iraqi secret police headquarters, and became waterlogged after the building was bombed during the liberation of Iraq.  The US Government spent considerable time and money restoring and digitizing them.  This is yet another situation where UNESCO's repatriationist dogma has been allowed to take precedence over not only the facts, but what is right.  The archive should not be returned to sectarian Iraq.  Or, at a minimum, the entire contents of the archive should be publicized so that individual Iraqi Jews can make claims on what is rightly the property of their own families.

Preservationists Seek to Remove or Even Destroy Confederate Monuments

So-called "preservationists" have advocated for the removal or even destruction of Confederate war memorials as products of an inherently racist culture.  In contrast, CPO believes we should not erase history, but learn from it.

In a blog post on the subject, Obama Cultural Property Advisory Committee Appointee Prof. Rosemary Joyce justifies her views based on the assumption that

When you remove these statues to men who fought for slavery, you’re not destroying history – you’re making it.

Surprisingly, this 180 degree departure from archeology's mantra of preservation of objects in context appears to be based on little more than reductionist reasoning, i.e., the statues must be symbols of  "white supremacy" because they were produced in a racist South.  Indeed, efforts to draw attention to the fact that their iconography is virtually identical to monuments erected in the North at around the same time when the politically powerful Civil War generation was passing from the scene elicited little more than condenscending responses. It seems furthering "white supremacy" not commemoration of sacrifices on the battlefield must be the prime motivator in the South, but not the North (despite similar racist sentiments there at the time).

In any event, justifying the removal or even destruction of historical monuments by designating them as "racist" should be even more troubling given recent events in Iraq and Syria.   Indeed, there are distinct parallels between ISIS destroying "idolatrous" statues and monuments and efforts here to topple "racist" ones, not the least the motivation to deprive certain groups of artifacts deemed important to their culture (there Shia, Assyrian Christians and Yazhdis and here poor White people (who must be racist!)).  At least here, we have processes in place to allow localities and States to make the decision what to do with our Confederate monuments.  What must be avoided at all costs is another Durham, N.C., where a mob was allowed to take matters into its own hands.   

Collectors Contest Lawless Seizure

The art law firm of Pearlstein, McCullough & Lederman LLP has brought an action to contest the seizure of an artifact on loan to the Met.  The New York Times has covered the seizure here.   Lost on the Times, however, is the concern that the NY District Attorney has lawlessly used a search warrant to seize and repatriate an artifact purchased in good faith.  

The lawyers for the collectors describe their action to quite title as follows.  

Beierwaltes v. Directorate General of Antiquities of the Lebanese Republic and the District Attorney of New York County is an important test case for the art market in general and the antiquities market in particular.

Our clients, Bill and Lynda Beierwaltes, bought an Archaic Greek marble Bull’s Head in 1996 from a London dealer who made representations about its provenance. In 2006, the Bull’s Head was exhibited publicly in Paris at a major art fair and published in a dealer’s catalogue. In 2016 the Bull’s Head was loaned to and exhibited by The Metropolitan Museum of Art. From excavation records published in Switzerland in 2005, the Museum concluded that the Bull’s Head was excavated at the Temple of Eshmun in Lebanon in the 1960s.

After Lebanon demanded restitution, the Beierwaltes filed a complaint in U.S. District Court for the Southern District of New York seeking declaratory judgment to clear title to the Bull’s Head. Although the Department of Justice declined to pursue a claim for civil forfeiture, the District Attorney of New York County seized the Bull’s Head pursuant to a search warrant and is now seeking to turn the Bull’s Head over to Lebanon. We thereafter amended our complaint to include DANY as a defendant in the federal case.

The twin actions present a number of issues that have not previously been resolved.

First, we believe that DANY’s position is ill-founded and that New York law does not provide for in rem forfeiture. DANY disagrees and believes that it can first seize and then turn over property in the absence of a criminal case.

Second, the relationship between the Beierwaltes’ suit in federal court for declaratory judgment and DANY’s procedure in New York state court for turnover is unclear. Which decision governs if the Beierwaltes prevail in federal court and DANY prevails in state court?

Third, we believe that the Beierwaltes’ title claim is meritorious: even if the Bull’s Head was stolen from Lebanon, the statute of limitations under Lebanese law has expired; Lebanon has no claim under the Convention on Cultural Property Implementation Act; there are no grounds for seizure under federal law; and New York state law supports the Beierwaltes’ claim on several grounds, including statute of limitations and laches.

The Beierwaltes are bona fide purchasers with clean hands. By contrast, for more than 50 years, Lebanon has failed take any action domestically or internationally to report any theft of the Bull’s Head, file a claim for its return or list the Bull’s Head on any publicly-accessible, international database of stolen art.

Under these circumstances, DANY’s focus on restituting the Bull’s Head to Lebanon based solely on theft would be contrary to U.S. law and policy and New York civil law. It remains to be seen whether DANY’s expansive interpretation of New York’s search and seizure law will prevail

Congressional Appropriators Hold State Department, CPAC and Source Countries Accountable

The House of Representatives has used the appropriations process to highlight the need for the State Department and the Cultural Property Advisory Committee to hold countries with MOUs with the United States accountable for spending adequate sums to protect their own cultural patrimony as a precondition for receiving continued US assistance.  For more, see here.  It's long past time for such a message to be sent.  If source countries are poor stewards for what they already have, why repatriate more objects under the misapprehension they will be properly studied, preserved and displayed?

Virtual CPAC Meeting on Libyan MOU Request

On July 19, 2017, the U.S. Cultural Property Advisory Committee held its first “virtual” meeting where some CPAC members and all speakers were linked via an internet based video platform.  According to my notes, at least the following CPAC members were in attendance:  (1) John Frank (Trade); (2) Karol Wight (Museum); (3) Lothar von Falkenhausen (Archeology); (4) Nancy Wilkie (Archaeology); (5) Rosemary Joyce (Archaeology); (6) Dorit Straus (Trade); (7) Adele Chatfield-Taylor (Public); and (8) Jeremy Sabloff (Public-Chair).

There were six (6) speakers:  (1) Peter Tompa (International Association of Professional Numismatists/Professional Numismatist’s Guild; (2) Sue McGovern (Association of Dealers and Collectors of Ancient and Ethnographic Art); (3) William Wright (coin collector); (5) Kate FitzGibbon (Antique Tribal Art Dealers Association) and (6) Nathan Elkins (Baylor).  Due to a technical problem, Gary Vikan (Global Heritage Alliance) did not speak.

Peter Tompa- The request is a troubling one.  Libya has no government to speak of and anything repatriated cannot be protected from the militias running the country.  To the extent any restrictions are granted, they should be limited to site specific restrictions for material identifiable as from Libya’s 5 UNESCO World Heritage Sites as well as for coins identifiable as being stolen from public and private collections.   Restrictions cannot lawfully be placed on coins because they are not of cultural significance.  Moreover, hoard evidence proves that one cannot assume coins struck in Libya in ancient times were also found there.  (For more, see here.)

Sue McGovern- Libya’s chaotic governance means that it cannot undertake self-help measures or protect what cultural patrimony it has, let alone that which may be repatriated under a MOU.  Libya has no open museums.  It should be taken to task for opposing UNESCO’s efforts to list its World Heritage sites as endangered.  In a troubling episode, one powerful militia (supported by General Sisi’s Egyptian military government) burned 6,000 books.  Under the circumstances, any MOU is a bad idea.

William Wright- Wright is a teacher at a community college in Virginia.  He became interested in the coins from Kyrene because they depict Silphium, a now extinct medicinal plant.  He uses coins in his history classes.  His students benefit from the tactile experience of handling coins.  He only buys from established dealers, but worries about the chilling effect restrictions are having on the hobby.

Kate FitzGibbon- The short comment period has disenfranchised Jewish groups which are incensed that Libya is seeking U.S. Government approval for its efforts to claim the property of expelled Jews as its own.  The request should also be denied as to Tuareg material  as most Tuaregs live outside Libya and one cannot tell recent tribal arts from early tribal arts that are the target of this MOU.

Nathan Elkins- Looting is well documented in Libya.  Restrictions should also extend to coins as for other objects.  Coins are special targets for looters.  CPAC should be wary of the misrepresentations of the lobbyists for the coin trade.  Nancy Wilkie (Archaeology) asked Elkins if metal detectors were used in Libya.  Elkins does not know for sure, but assumes so.   Dorit Straus (Trade) asked Elkins about documenting coins.  Elkins does not understand why collectors don’t document coins as he did as a collector before stopping for ethical reasons.  

No Reason for More Ill-Considered Restrictions on Coins

     Here is what I said more or less at today's CPAC meeting:       

          I am speaking on behalf of the International Association of Professional Numismatists and the Professional Numismatists Guild, which represent the small businesses of the numismatic trade.  In many ways, this hearing is a much greater test for CPAC than for ancient coin collectors.  This is a very troubling request being rushed through the system, but for what purpose? Libya has no government to speak of, much less one that can ensure that any artifacts that may be repatriated will be protected from the militias really running the country.  As such, IAPN and PNG believe this request should either be tabled pending receipt of more information, or at most treated as an emergency request with restrictions only granted for site specific material from Libya’s 5 UNESCO World Heritage Sites as well as any material—including coins—that is identifiable as being stolen from public or private collections.

            There is no reason for more ill-considered import restrictions on coins that don’t mesh with the CPIA’s requirements that restrictions only be placed on objects of “archaeological interest” of “cultural significance” “first discovered within,” and “subject to export control by” the requesting state, here Libya. 

            There is a history here which most of you probably don’t know.  For 25 years after the CPIA was passed, there were no restrictions on coins.   This should be no surprise.  Coins are items of commerce.  So, it is difficult for modern nation states to justifiably claim them as their “cultural property.”  They are probably amongst the most common of historical artifacts and are not of “cultural significance.”  They are avidly collected and traded worldwide—including in places like Libya.  It simply makes no sense to preclude Americans from importing coins where there is no real “concerted international response.”   Indeed, when the CPIA was being discussed, Mark Feldman, a high ranking State Department lawyer, represented to Congress that it was “hard … to imagine a case where we would need to deal with coins except in the most unusual circumstances.”

            In 2007, this changed with Cypriot coins.   According to the declarations of two former CPAC Members that change was made against CPAC’s recommendations.  In 2011, a federal court was asked to look at the issue, but determined that the matter was non-justiciable which is just a fancy way of saying it’s not my problem.  So, if anything, that makes the issue “your problem” all the more. 

            Why shouldn’t coins be restricted?  The CPIA only limits restrictions to objects of cultural significance.  Just because an object is of archaeological interest does not give it cultural significance.  Coins which exist in multiples lack cultural significance.  The CPIA also limits restrictions to archaeological material first discovered within and subject to the export control of the specific country, here Libya.  The hoard evidence we discuss in our paper confirms that one simply cannot safely assume Libyan coins are found at Libyan archaeological sites.

            Let me touch on some issues raised by Dr. Nathan Elkins in his papers.    First, Dr. Elkins claims that restrictions are proper for any coins that predominantly circulated in Libya.  However, this proposed test is inconsistent with the plain meaning of the CPIA that limits restrictions only to artifacts “first discovered within” and “subject to export control by” Libya.  This language makes clear that only coins actually found in Libya and hence subject to its export control can be restricted.   Second, even under Elkins’ standard, Libyan coins could not be restricted because all recorded hoards of Libyan coins are found outside Libya.  [Note, Dr. Elkins disputed this point.  My written comments and research can be found here.]  Finally, given the small number of such coins on the open market, there is no reason to believe they are “gushing out” of Libya as he claims.  If anything, the small number and modest values of such coins on the market suggest that any restrictions would not deter pillage.  Thank you on behalf of the small businesses of the numismatic trade and collectors for your consideration of our views.

ACCG Gets Amicus Support

Six collector and trade groups have supported the Ancient Coin Collectors' Guild's appeal seeking to ensure that the due process rights of collectors are protected.  The Guild has asked the Fourth Circuit Court of Appeals to overturn an order forfeiting fifteen (15) of its coins.  

The Guild has argued that the district court could not assume away important elements of the government’s case merely because its coins were of types subject to import restrictions.  Under the Convention for Cultural Property Implementation Act, the government may only seize and forfeit archaeological and ethnological objects “first discovered within” and “subject to export control by” specific countries.  And even then, the government must make some showing that the articles left that country after the effective date of those regulations.  Here, at most, all the government showed was that the coins were of types on the “designated lists” for Cyprus and China.

The briefs of the Guild and amici can be accessed here. 

Comment Fatigue Can't Mask Special Interest Nature of MOU Program

Given the short (7 day) comment period over the July 4th weekend, CPO is not too surprised that there were so few comments posted on the regulations.gov website concerning a proposed MOU with Libya:  https://www.regulations.gov/document?D=DOS_FRDOC_0001-4160

After eliminating duplicates and a few unclear comments, it appears that only 19% or 7 of the commentators supported the MOU with the remaining 34 opposed in whole or part.

Four of the proponents represented group interests.  Of these, one was a University and another was an archaeological group that also is a State Department contractor.  Six trade associations or collector advocacy groups were among those opposed to any MOU in whole or in part.  Most of the individual comments came from coin collectors or dealers.

No doubt some proponents will spin these the low numbers as a lack of public opposition to any MOU.  But what really should be asked is whether the whole enterprise is really nothing more than a special interest program for archaeological groups either tied to source countries where they excavate or the State Department which funds them.  Maybe there needs to be a rethink whether scarce State Department resources should be earmarked for other programs that further our national interest or promote American business abroad.

My Personal Comment on the Proposed Libyan MOU

Here is my personal comment on the proposed Libyan MOU:

Please accept these personal comments. I have also commented on behalf of a number of organizations.

1. CPAC should view this request with skepticism. Few details have emerged that support Libya's MOU request. Moreover, this request has been rushed, with a short comment period smack in the middle of a long holiday week. This action, which can only limit the number of comments CPAC receives, in itself suggests that this request should be viewed with caution-- even if the country itself wasn't a mess as it has been since its revolution of 2011.

2. The country has 3 governments, and two antiquities authorities jockeying for position. It's not even clear which of these entities supports this request. In any case, whatever "government" Libya has, powerful militias are in the background that can break these "governments" pretty much at will.

3. There are no guarantees that any artifacts Customs sends to Libya under any MOU will be protected, much less studied and displayed. None of Libya's museums are open and what staff remains have to make do under very trying circumstances.

4. Frankly, instead of yet another round of import restrictions, the State Department, along with other international organizations, should instead focus on helping Libyan community groups protect Libya's 5 UNESCO World Heritage sites from the deprivations of Islamic fundamentalists. Ultimately, Palmyra and Nimrud suffered severe damage because local communities didn't care enough to protect them from ISIS. Let's help those locals who care about these sites protect them.

5. I do not believe that Libya and the proponents of import restrictions have made out a case for either "regular" or "emergency restrictions." Nonetheless, if CPAC feels it cannot resist bureaucratic pressure to "do something," Libya's request should be treated as an "emergency one" and restrictions limited to site specific material from Libya's endangered World Heritage Sites: (1) Kyrene; (2) Leptis Magna; (3) Sabratha; (4) Tadrat Acacus; and (5) Ghademes. (See Libya's five World Heritage sites put on List of World Heritage in Danger, (UNESCO) (July 14, 2017), available at [URL REMOVED]

6. Under no circumstances should there be restrictions placed on historical coins except those identifiable as stolen from Libyan public and private collections. Here, IAPN, PNG and ACCG have noted what hoard evidence that is available shows that "Libyan" coins are typically found outside of the confines of modern day "Libya," which would make any restrictions placed upon them contrary to governing law. Ancient Coin Collectors Guild v. U.S. Customs and Border Protection, 801 F. Supp. 2d 383, 407 n. 25 (D. Md. 2011) ("Congress only authorized the imposition of import restrictions on objects that were 'first discovered within, and [are] subject to the export control by the State Party.").

Thank you for your consideration of these comments.

Sincerely,

Peter Tompa

Ask CPAC to Limit or Table the Problematic Libyan MOU request Rather than Rush it Through

The State Department has announced an exceptionally short comment period for a proposed MOU with Libya ending on July 10th.  The exceptionally short time frame for public comment as well as the timing of this request to coincide with a raft of highly exaggerated reports claiming that the antiquities trade funds terrorism emanating from the Antiquities Coalition, a well-funded and politically connected advocacy group with ties to MENA authoritarian governments, suggests that the Libyan MOU is yet another done deal.  

Still, if one feels strongly about their continued ability to collect ancient artifacts and/or historical coins, CPO believes they should comment on the regulations.gov website here: 

https://www.regulations.gov/document?D=DOS_FRDOC_0001-4160


Why? Because silence will only be spun as acquiesce by US and Libyan cultural bureaucracies as well as the archaeological lobby with an ax to grind against collectors.

A.    The Law

The Cultural Property Implementation Act (“CPIA”) contains significant procedural and substantive constraints on the executive authority to impose import restrictions on cultural goods. 

“Regular” restrictions may only be applied to archaeological artifacts of “cultural significance” “first discovered within” and “subject to the export control” of a specific UNESCO State Party.  They must be part of a “concerted international response” of other market nations, and can only be applied after less onerous “self-help” measures are tried.  They must also be consistent with the general interest of the international community in the interchange of cultural property among nations for scientific, cultural, and educational purposes.

“Emergency restrictions” are narrower.  They focus on material of particular importance, but no “concerted international response” is necessary.  The material must be a “newly discovered type” or from a site of “high cultural significance” that is in danger of “crisis proportions.” Alternatively, the object must be of a civilization, the record of which is in jeopardy of “crisis proportions,” and restrictions will reduce the danger of pillage.

 The Cultural Property Advisory Committee (“CPAC”) is to provide the executive with useful advice about this process.

   

The CPIA contemplates that CPAC is to recommend whether import restrictions are appropriate as a general matter and also specifically whether they should be placed on particular types of cultural goods.  In the past, CPAC has recommended against import restrictions on coins.  Initially those recommendations were followed, but beginning with the renewal of Cypriot import restrictions in 2007, this has changed.  Now, there are restrictions on coins made in Cyprus, China, Italy, Greece, Bulgaria, Syria and Egypt.  

  

Import restrictions make it impossible for Americans to legally import collectors’ coins widely and legally available worldwide.   Foreign sellers are typically unwilling or unable to certify the coin in question (which can retail as little as $1) left a specific UNESCO State Party before restrictions were imposed as required by the CPIA and U.S. Customs and Border Protection rules.   Restrictions have drastically limited Americans’ abilities to purchase historical coins from abroad and have negatively impacted the cultural understanding and people to people contacts collecting fosters. 

B.     The Request

The Committee for Cultural Policy has written a good analysis of the request: https://committeeforculturalpolicy.org/libya-requests-us-to-send-artifacts-back-to-war-torn-libya/  

I quote that analysis in pertinent part here:

The Public Summary of Libya MOU Request that has been made available is actually written by the Department of State, and “authorized” by the Libyan government. The Department does not provide copies of actual requests, which makes it impossible to know if the request itself complies with Congressional criteria.

No Central Government Control

It is important to note that this request comes from the current Government of Libya, which holds only a portion of Libyan territory at this time. Libya is divided and ruled by two competing governments and its territory is controlled by six major militia factions, and many smaller parties and entities. There is no single effective Government of Libya that controls Libyan territory.

As part of every US agreement on cultural property, the US agrees to send any art that enters the US back to the source country. This policy applies even to art that has poor prospects of surviving in conflict-ridden nations, and art from oppressed ethnic or religious minorities that have been forced out of the source country. The CPIA does not provide for return of embargoes art to anyone but a source country government.

The Request is Over Broad

The request for the imposition of U.S. import restrictions covers the entire history of the geographic region that is Libyan territory from the Paleolithic through the Ottoman Era (12,000 B.C.-1750 A.D.). and on its ethnological material dating from 1551 to 1911 A.D. That is – virtually everything – up to 1911.

The material covered would be “archaeological material in stone, metal, ceramic and clay, glass, faience, and semi-precious stone, mosaic, painting, plaster, textile, basketry, rope, bone, ivory, shell and other organics. Protection is sought for ethnological material in stone, metal, ceramic and clay, wood, bone and ivory, glass, textile, basketry and rope, leather and parchment, and writing.” That is, everything one can think of.

No Cultural Administration

The cultural administrative staff of Libya appear in the request to have been scattered and in considerable disorder. The request fails to demonstrate that there is currently a government hierarchy capable of administering cultural heritage in much of the country, even if it wished to do so. The request provides numerous examples of failure by the Libyan government to address cultural heritage issues. It notes that

• “[A]rtifacts, which had been excavated from temples, were also stolen from the storerooms.”
• “Museums have also been vandalized and looted by invading militias.”
• “There are also reported thefts from museums and storerooms of documented and undocumented objects.”
• “[A]ll of the country’s twenty-four museums are closed.”
• Lacking government support, Department of Antiquities staff “continue to take personal responsibility for the objects housed in their institutions.”

No US Market for Illicit Artifacts

The Libyan request’s description of the U.S. market for ancient artifacts in Libyan style does not claim that any came recently from Libya or that any were not legally acquired.

The Tuareg materials and Islamic objects of the 18th and 19th century for which “protection,” i.e. embargo is sought were legally available for trade in Libya for many decades and are widely and legally available in European, Asian, and US markets. The request does not even claim that ethnographic materials were restricted in export from Libya in the past.

No Access for US Citizens, No Study, No Sharing of Excavated Materials

The request fails to meet criteria set by Congress that require that US citizens have access to Libyan culture through museum exhibitions or other venues. There is not a single traveling exhibition mentioned in the request.

Although the request acknowledges that foreign institutions and missions have done extensive archaeological work in Libya, these archaeological agreements do not allow sharing or even permanent export from Libya of any objects for study.

Based on the written request as presented by the Department of State, Libya’s recent governments have done little or nothing in the last decade to protect Libyan sites. Nor has any Libyan government made any effort to ensure that US citizens were able to access Libyan art and artifacts through traveling exhibitions, museum loans, or even through providing digital online access to art in Libya itself.

US Organizations with Middle East Ties are Promoting the Libyan Request

This request appears timed to coincide with a raft of recent presentations about the trade in looted Middle Eastern art by the Antiquities Coalition and its various partners – much of it based on discredited data. The presentations have focused on the evils of the international trade in looted art from these regions, and by wholly unsubstantiated statements that looted artifacts from the crisis areas in the Middle East have entered the US market or are being sold here. In these presentations, the value of the legal market in provenanced antiquities, especially the auction market, are used to justify claims about a supposed illicit market. In the view of the Antiquities Coalition, agreements under the CPIA with authoritarian Middle Eastern governments are seen as positive because they will end the art trade.

C.     What You Can Do

Admittedly, all the evidence points to the matter being already decided—no matter what the CPIA says, what the facts really are, and what American citizens or others interested in collecting Libyan artifacts may think.  Still, to remain silent is to give cultural bureaucrats and archaeologists with an ax to grind against collectors exactly what they want-- the claim that any MOU is not controversial. 

So, to submit comments concerning the proposed MOU, go to the Federal rulemaking Portal and enter Docket No. DOS-2017-0028 and by all means speak your mind.  For a direct link, try here:  https://www.regulations.gov/document?D=DOS_FRDOC_0001-4160  and click on the “comment here” button to make your case.

 

What should you say?  Provide a brief, polite explanation about why the request should be denied or limited.  Indicate to CPAC how restrictions will negatively impact your business and/or the cultural understanding and people to people contacts collecting provides.   Coin collectors should add that it’s typically impossible to assume a particular coin was “first discovered within” and “subject to the export control” of  Libya and that Libyan historical coins while not as common as others, are widely and freely available for sale elsewhere, particularly in Europe.  And, of course, feel free to mention any concerns you might have about government transparency, whether this is a real “emergency” of “crisis proportions,” and how the State Department has generally handled this request.   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.  

Problematic MOU Request

The State Department has notified the public of its receipt of a request for a MOU with Libya.  It remains to be seen how a country with two competing governments, that is over-run by militias and which remains in danger from ISIS can meet its obligations under UNESCO and the CPIA to protect and preserve is own cultural property let alone that which may be repatriated from the US under the terms of any agreement.  Libya needs our help, but that help should be focused on protecting its world class archaeological sites from the depredations of ISIS and other radical Islamic groups. Turning US Customs loose to seize and forfeit "undocumented" "Libyan" artifacts will only harm legitimate trade and the appreciation for Libya's ancient cultures.  It certainly won't help protect Libyan archaeological sites and museums from their greatest threat, which is hammer and explosive wielding religious fanatics.

Desperately Seeking Continued Funding?

On June 8, 2017, CPO attended a panel discussion entitled, "Preserving Northern Iraq's Cultural Heritage."   The major theme of the event was to document the good work the Smithsonian is doing stabilizing what is left of Nimrud after ISIS dynamited and bulldozed much of the site.

However, the continued hype about the supposed value of ISIS looted material ($80 million!) as well as surprising claims that cultural heritage preservation fights terrorism and fosters minority rights seem calculated to sway Trump Administration and Congressional budget officials as much as anything else.  Indeed, it probably was no coincidence that representatives of the House Foreign Relations Committee were in the audience.

If anything, the American Schools of Oriental Research (ASOR) should be subject to serious scrutiny from appropriators given the $900,000 taxpayer costs of ASOR's cooperative agreement with the State Department, ASOR's efforts to lobby on issues related to that same contract, and the continuing efforts of ASOR members to hype the value of looting by ISIS long after other, more disinterested sources have questioned such hype.

Museum and Auction House Work Together To Reunite Collector With His Coins

This is a great story about the efforts of Virginia State authorities, the Virginia Museum of Fine Arts and CNG, Inc. to find the owner of a box of ancient coins that had been lost.  A happy ending about how government officials and private industry worked together to reunite a collector with his collection.

Import Restrictions Without End

The drafters of the CPIA contemplated that import restrictions would give breathing space for source countries to get their own house in order, but they were never supposed to go on forever.  Yet, the State Department and US Customs have extended import restrictions on Peruvian goods for the fourth time.  So, Americans have been limited in their ability to import Peruvian goods from third countries for yet another 5 years.

The extension expands restrictions to colonial era manuscripts although it is dubious that they meet the definition of ethnological objects under the CPIA.  Presumably, the restrictions were put into place to keep Peruvian citizens from selling off old manuscripts to foreigners.  Materials within Peruvian institutions are already restricted from entry in the US under the CPIA's stolen property provisions.

K-9 Looted Antiquities Detector Dog Funding Solicitation Relying on Misleading Data?

Red Arch Cultural Heritage Law and Policy Research is soliciting public funding for detector dogs to roam airports in search of looted antiquities.  Leaving aside questions about practicality and the potentially self-serving nature of such an effort, CPO notes that Red Arch is soliciting funds based on dubious claims about the value of antiquity exports from the Middle East.  However, as CPO has explained over and over again, this data relates to "country of origin," which typically means place of manufacture NOT PLACE OF EXPORT.  So, it is not at all clear that the values cited actually support the supposition that is claimed.   So, instead of antiquities detector dogs, perhaps, then a BS detector is what is really needed more than anything else.  

A German View of How American Cultural Policy is Made

Coins Weekly questions whether Goldman Sachs money, power and influence have corrupted US cultural policy.  At a minimum, it is a legitimate question where the Antiquities Coalition's non profit archaeological advocacy and the for profit business interests of its founder begin and end.

ICE Sends Roman Coins From Middle East To Italy Because Roman Means Italian?

While Customs rightly repatriated manuscripts back to Italy in a ceremony today in Boston, as CPO pointed out back in 2015, Roman coins from Middle Eastern mints are an entirely different matter.  Hopefully, someone in the Trump Administration will catch onto this example of ICE overreach. This is yet another situation where the importer appears to have had a viable defense to forfeiture, but the cost of legal services greatly exceeds the value of the subject coins.

Pointing Fingers the Wrong Way?

A well known scholar who would like to remain anonymous asks if  fingers are being pointed the wrong way after the Cleveland Museum voluntarily repatriated a Roman portrait bust to Italy.

I suppose you have heard the story of this marble head in Cleveland, that either has been, or is in the process of being, returned to Italy because it turns out that it was stolen from the museum in Sessa Aurunca in 1944. The usual suspects are making rude remarks and pointing fingers about it, but, in fact, I think it might be a very good and exemplary story for you to tell on your blog.

The big thing is that it, and another piece, appeared at auction in Paris in 2004 - illustrated - but no one said peep about them. Apparently two Italian scholars wrote about the head around the time Cleveland acquired it, illustrating, FINALLY, record photos of a number of heads from Sessa that were discovered in excavations there in 1926. I want to stress the fact that despite there being record photos, taken in 1926, of some sculpture stolen in 1944, those photos were never publicly shown prior to 2011 or so!!! In any case, we can be sure that Cleveland actually did everything that was normally and humanly possible to do when they acquired the piece in 2012. The story they had: that the head was from a collection in France, brought there from Algeria in 1960 (when A was part of France), and previously in a collection in Algeria (they said since the 19th century), was by no means implausible. In any case, the possibility that the head had been looted in Sessa by French troops from Algeria in 1944 would go far to explain the head's supposed Algerian origins.

That the head should go back to Sessa is clear: it is modern war loot. But when does the story end? The way the usual suspects use the story to attack the "bad" American museum and the "bad" dealer, but say poo about the fact that a clear photograph, that was in existence by 1926 of an object that was stolen in 1944, remained unpublished until 2011/2013 or so is an even greater scandal!  

District Court Rules in Government's Favor in Long Running Forfeiture Action

The ACCG will likely appeal Judge Blake's ruling largely favoring the government in the long running forfeiture case.  It's important to defend the principle that the government must make out every element of its prima facie case before it can take private property.  More here.

President Putin Awards Russia's Highest Honor to Two American Archaeological Advocacy Groups

CPO republishes this post from "Patriotic Russia Today" and hopes the reader will draw their own conclusions.

President Putin Awards Russia's Highest Honor to Two American Archaeological Advocacy Groups

President Putin has designated two American Archaeological advocacy groups, "Saving Antiquities from Everyone" and the "Context Coalition,"  Heros of the Russian Federation for their efforts to spotlight Islamic State looting and destruction of Syrian cultural sites.

The groups' extensive media efforts-- funded with the generous support of the Geldman Sox investment bank-- have not only exposed the problem of greedy Western collectors and museums and their desire to own Syrian cultural patrimony.  In addition, their work has sown confusion and suspicion within terrorist ranks.  Patriotic Russia Today has learned from sources within our glorious military intelligence service, the GRU, that the groups' social media efforts have also directly led to the execution of some key Caliphate financiers who could not explain why they never turned over a reported  $7 billion in funds made from stolen antiquities to their brother terrorists.  A mission well done!

In a break with tradition, the award ceremony will take place not at the Kremlin, but at the posh headquarters of Geldman Sox in New York.  There, it is also expected to be announced that Geldman Sox will provide financing to the legitimate Assad government for restoring Aleppo, another victim of the destruction wrought by Islamic terrorists.  Yes, there will be much to celebrate.

Cultural Heritage Center Faces Budget Cuts

The State Department's Cultural Heritage Center (CHC) along with the Bureau of Educational and Cultural Affairs (ECA) faces severe cuts in the Trump Administration's Budget proposal.  That proposal,

"Reduces funding for the Department of State's Educational and Cultural Exchange (ECE) Programs. ECE resources would focus on sustaining the flagship Fulbright Program, which forges lasting connections between Americans and emerging leaders around the globe.”

While the CHC's programs have been characterized as "soft power" diplomatic efforts, its MOUs have devolved into special interest programs that only benefit small numbers of archaeologists and foreign cultural bureaucracies that offer them excavation permits. Meanwhile, associated embargoes on cultural goods have thoroughly alienated large numbers of legitimate dealers and collectors both here and abroad. So, any supposed "soft power" benefits may in reality be deficits as far as the most of the general public is actually concerned.

It may be too much to hope for, but going forward the Trump State Department CHC should consider retooling to promote people to people cultural exchange that sees collecting as an asset and not an enemy.  Such an inclusive vision would increase CHC's popularity dramatically and help stave off any budget cuts going forward.  

Short Comment Period for Proposed MOUs with Belize, Guatemala and Mali

Regulations.gov is now accepting public comments for the Cultural Property Advisory Committee's review of proposed renewals of MOUs with Belize, Guatemala and Mali.  Simply click on the above link, read the background information and then click on the blue "Comment Now" button to make your views known.

Antiquities Coalition Chief of Staff: "Dealers Don't Have Civil Rights!"

FROM TWITTER:

Katie A. Paul‏

@AnthroPaulicy

Katie A. Paul Retweeted Peter Tompa

What a shameful accusation to compare the plight of antiquities dealers to those fighting for civil rights. Dealers don't have civil rights!

Katie A. Paul added,

Peter Tompa @Aurelius161180

@AnthroPaulicy No, stance this is a drop in the bucket and does not justify efforts to undercut collectors' and dealers civil rights.

No wonder why the Antiquities Coalition apparently thinks the burden of proof should be shifted away from the government and onto collectors and dealers to prove their collections are "licit" under obscure foreign laws, many of which are the products of dictatorships like that of Egypt.

Destruction of Mosul Artifacts Further Undercuts Archaeological Lobby's Narrative

Confirmation that ISIS appears to have destroyed the contents of the Mosul Museum should be a cause for sadness rather than an excuse for yet another sound bite condemning the purchase of "blood antiquities."  If anything, the destruction of portable antiquities like cuneiform tablets contradicts the archaeological lobby's narrative that ISIS loots rather than destroys for ideological reasons.

Real Turn Around or Business as Usual?

It would be nice to think that Deborah Lehr and her well-funded Antiquities Coalition have had a real change of heart about how the antiquities market encourages cultural exchange and the preservation of artifacts, but given the group's consistent efforts to portray collectors as witting or unwitting accomplices of terrorists and cultural racketeers one has to really wonder if any change is just for the moment and for business purposes related to her international consulting firm.  Only time will tell.

ANA Warns Import Restrictions Damage Mission

The American Numismatic Association explains how import restrictions on coins that focus on place of minting in ancient times rather than modern find spots have damagesd its educational mission.  CPO once again expresses hope that the Trump Administration will perform a cost benefit analysis of such restrictions and their impact on various stake holders.