Wednesday, November 30, 2022

CPAC to Meet on Jan. 30th to Consider New MOUs with North Macedonia and Uzbekistan as well as a renewal of a current MOU with Cambodia.

The State Department has provided advance notice of a Cultural Property Advisory Committee (CPAC) meeting that will take place from Jan. 30-Feb. 2, 2023.  See 

 https://eca.state.gov/highlight/cultural-property-advisory-committee-meeting-January-30-February-02-2023

During that meeting, CPAC will (1) consider extending and amending the cultural property agreement with the Government of Cambodia, (2) review a new request from the Government of North Macedonia, and (3) review a new request from the Government of Uzbekistan for cultural property import restrictions.  The Committee invites public comment on these proposals through the regulations.gov website, but that site is not active as yet.  When it does become active, comments will be accepted through Jan. 23, 2022.  CPO will be updated to include the link where to comment once a Federal Register notice with this information is published. 

The potential MOU with North Macedonia could have the most impact on coin collectors.   There is a substantial overlap among coins thought to have been struck in the area that circulated regionally in Albania, Bulgaria, Greece, Kosovo, modern North Macedonia, Romania, Serbia, and Turkey. Other types known to be struck elsewhere, like Alexander III tetradrachms, Roman Republican and Imperial coins, Byzantine issues, and Venetian and Ottoman coins circulated even further afield in international commerce.  That makes it impossible to assume that coins of types that circulated in these countries (and beyond) are exclusively found in North Macedonia or even that they “circulated primarily” there. 

The potential MOU with Uzbekistan could further impact Kushan and Bactrian coins which are already covered under emergency import restrictions for Afghanistan.  The same issue of regional circulation is raised for such coins which also may be found in Pakistan and India.  There is a pending MOU with Pakistan, but none with India.

In contrast, the proposed renewal of the MOU with Cambodia should raise few issues.  There currently are no import restrictions on coins and the State Department would be hard pressed to find that Cambodian coins meet the threshold requirements for either archaeological or ethnological artifacts. They don’t appear to be typically found in the ground.  Nor are they the products of tribal cultures.  Coins came to Cambodia quite late, and most were made with modern minting machinery. 

Addendum (12/22/22):  It is now possible to post comments for a renewal and possible amendment of the current MOU with Cambodia, and new proposed MOUs with North Macedonia and Uzbekistan here:  https://www.regulations.gov/document/DOS-2022-0048-0001