Here is what I said at yesterday's CPAC meeting to discuss proposed renewals with Belize and Libya. My comments related solely to Libya. I hope to upload a summary of what happened in the near future.
Thank you for letting me speak on behalf of the micro and small businesses of the numismatic trade. CPAC should focus on facts not false narratives based on a report from ASOR, which received $800,000 in State Department grants for its work in Libya.
ASOR’s report will be used to justify extending this MOU to quote “save” Libyan cultural heritage. However, after reading it, one can only conclude that Libya has failed to take necessary self-help measures. Libya does not enforce its own confiscatory Ghaddafi era laws. ASOR only documents five seizures of looted antiquities in Libya since 2017 when import restrictions were first promulgated. Thefts from museums after the 2011 Revolution are detailed, but poor documentation makes recovery far more difficult. Anything recovered could be returned as “stolen property” anyway, without an MOU.
Given the reality on the ground, can CPAC in good conscience recommend further import restrictions on coins? It is impossible to assume most coins on the designated list were found in Libya. The current designated list includes many Imperial coin types that circulated regionally or internationally. Other Greek silver and gold coins did not even “circulate primarily” in Libya, the State Department’s own standard. Recently, IAPN demonstrated that coins of Alexander the Great should be delisted for Cyprus because they did not meet this criteria. However, the State Department ignored this research and instead expanded the current Cypriot list even further! That raises the question, is the State Department’s own standard “just for show?”
Libya is a complete mess with a bloody gun battle between rival factions in Tripoli just last week. Hopefully, one day Libya will be at peace and $800,000 can be used to fund a Portable Antiquities Scheme rather than trying to justify suppressing coin collecting further. US collectors are not at fault for Libya’s problems and should not suffer further damage in search of an illusory solution. Thank you.