CPAC Should Be Skeptical About New Restrictions on Coins

 This is what I said more or less at yesterday's CPAC hearing.  Due to the time to speak being cut to 4 minutes, I did not get to address the MOU with PRC as much as I would have liked. 

        I’m speaking on behalf of IAPN, which represents the small businesses of numismatic trade.   CPAC should be especially skeptical of US import controls on Bulgarian and Chinese coins.  Both countries have large internal markets in the exact same sorts of coins that are embargoed under US import restrictions. 

          Let me first address the MOU with Bulgaria.   The Cultural Heritage Center’s website now suggests that it does not seek new restrictions on coins, but IAPN nonetheless urges CPAC to oppose any effort to expand the current designated list to include widely circulating Roman Republican and Roman Imperial coins.  CPAC previously rejected such import restrictions during its past deliberations in 2011 and 2018.   Currently, only “Roman Provincial coins” are restricted.  They are completely different than Roman Republican and Roman Imperial coins.  Roman Provincial coins, usually of bronze, were struck by local authorities and were meant to circulate locally.  In contrast, Roman Republican and Roman Imperial coins were struck under the authority of Roman Republican or Imperial officials and were designed to circulate throughout the Roman Empire.

          The Cultural Property Implementation Act limits any restrictions to coins “first discovered within, and … subject to the export control by” Bulgaria.  However, Roman Imperial coins found in Bulgaria represent a very small portion of those found internationally. Only 3.2% of hoards containing Roman Imperial coins struck at the late Roman branch mint at Serdica (modern day Sofia) are found within Bulgaria and 96.8% are found outside that country. Moreover, only 6.58% of hoards containing coins from the most prolific Roman Imperial Mint, that at Rome, are found in Bulgaria with the remainder of such coins found elsewhere.  Thus, hoard evidence proves that one simply cannot make the required assumption that such coins were necessarily found in Bulgaria before they can be placed on the designated list. 

          CPAC also should not confuse the Roman Provincial Mint that operated in Serdica during the early Imperial period with the Roman Imperial Mint that operated there in the late 3^rd and early 4^th century A.D.   Coins of the Roman Provincial Mint at Serdica are restricted already.  Those of the Roman Imperial mint of Serdica are not; nor should they be because again only a small fraction of the entire universe of such coins are found in Bulgaria today.  

          CPAC should also consider the failure of the State Department to hold Bulgaria to its prior promise to facilitate the legal export of coins of the sort that Bulgarians already collect.  Given this failure, CPAC should recommend that U.S. Customs harmonize U.S. import controls with E.U. export controls. The CPIA was passed before the E.U. created a system of export controls for cultural goods.  MOUs with E.U. countries like Cyprus, Italy, Greece and Bulgaria should be consistent with these E.U. export controls.  This can be done simply by making import restrictions under such MOUs subject to E.U. export controls which have supremacy within the E.U.  This would allow Americans to import coins exported lawfully from Bulgaria’s fellow E.U. members even if they are subject to import restrictions. 

          The current MOU with China should be allowed to lapse.  The PRC should not be rewarded for destroying the cultural heritage of its repressed minorities.   Nor should the US reimpose import restrictions on Chinese coins when its government turns a blind eye to the counterfeiting of US historical coins.   The PRC is also the world’s most sophisticated surveillance state, and simply does not need U.S. help to stop looting.  The PRC government also prides itself on fostering a brisk trade in cultural goods, including coins.  While IAPN commends China for allowing its own citizens to collect common ancient coins, this also means that US import restrictions have the perverse effect of providing Chinese dealers and auction houses with a competitive advantage over their American counterparts.  Indeed, while the US has been enforcing its embargo on Americans importing ancient Chinese coins and other art, Chinese auction houses and dealers have been opening up shop in the US for the express purpose of exporting Chinese art bought here back to China for resale.  Thank you for listening to our concerns.