Bogdanos Becomes Prop for Chinese Propaganda

 Attention-seeking "world culture cop" Matthew Bogdanos has allowed himself and Alvin Bragg's Manhattan DA's office to become a prop for Chinese propaganda of the Communist Party's Xinhua News Agency by repatriating Tibetan cultural heritage to the very same government which has been engaged in "cancelling" Tibetan culture.   Unfortunately, this and the recently renewed State Department MOU with the PRC recognizes the rights of China's authoritarian Communist Government to the cultural heritage of its repressed minority populations.  The basis for the seizure is unclear, but even if it were a valid one, why shouldn't such materials instead be given to the representatives of the Tibetan people in exile?  

US Customs and State Department issue more grossly overbroad restrictions on behalf of another unfriendly authoritarian government, this time Pakistan

 The US State Department and its Cultural Heritage Center have again  deputized U.S. Customs and Homeland Security to enforce the export controls of another unfriendly, authoritarian government, this time Pakistan. It remains unclear how they will apply these exceptionally broad import restrictions, which cover a host of materials also found in Central Asia, Afghanistan, India, Sri Lanka, and, indeed, as far away as Northern Europe.  

The designated list for coins is in particular very broad.  It lists types that circulated regionally as well as internationally, including Roman Imperial coins, which the designated list itself admits are only "sometimes" found in Pakistan.  The entire designated list for coins is as follows:

(5) Coins—Ancient coins include gold, silver, copper, and copper alloy coins in a variety of denominations. Includes gold and silver ingots, which may be plain and/or inscribed. Some of the most well-known types are described below:

(a) Early coins in Pakistan include silver sigloi of the Achaemenid Empire. Gold staters and silver tetradrachms and drachms of Alexander the Great and Philip III Arrhidaeus are also found. Regionally minted Achaemenid-period coins include silver bent bars ( shatamana) with punched symbols such as wheels or suns. Local Hellenistic (Greek)-period and Mauryan imperial punch-marked silver coins ( karshapana) are covered with various symbols such as suns, crescents, six-arm designs, hills, peacocks, and others. Circular or square, die-struck cast copper alloy coins with relief symbols and/or animals on one or both sides also date to this period. Approximate Date: 6th-2nd Centuries B.C.

(b) Greco-Bactrian, Indo-Greek, Indo-Scythian, and Indo-Parthian coins include gold staters, silver tetradrachms, drachms, and obols, and copper alloy denominations. Copper alloy coins are often square. The bust of the king, the king on horseback, Greek and Hindu deities, the Buddha, elephants, bulls, and other animals are common designs. The name of the king is often written in Greek, Kharosthi or Brahmi script. Approximate Date: 2nd Century B.C.-1st Century A.D.

(c) Roman Imperial coins struck in silver and bronze are sometimes found in archaeological contexts in Pakistan. Approximate Date: 1st Century B.C.-4th Century A.D.

(d) Kushan coins include gold dinars, silver tetradrachms, and copper alloy denominations. Imagery includes the king as a portrait bust (“Augustus type”), standing figure with a fire altar, or equestrian figure; emblems ( tamgha); and figures from Greek, Zoroastrian, Buddhist, and Hindu religious traditions. Inscriptions are written in Greek, Bactrian, and/or Brahmi scripts. Approximate Date: A.D. 30-350.

(e) Sasanian coins include gold dinars, silver drachms, obols ( dang), and copper alloy denominations. Imagery includes the bust of the king wearing a large crown and Zoroastrian fire altars and deities. Inscriptions are usually written in Pahlavi, but gold dinars minted in Sindh with Brahmi inscriptions are included. Approximate Date: A.D. 240-651.

(f) Kushano-Sasanian or Kushanshah coins include gold dinars, silver tetradrachms, and copper alloy denominations. Some Kushano-Sasanian coins followed the Kushan style of imagery, while others resemble Sasanian coins. Inscriptions are written in Greek, Bactrian, Brahmi, or Pahlavi scripts. Approximate Date: A.D. 225-365.

(g) Gupta coins include gold dinars and silver and copper alloy denominations. Imagery includes the king in various postures and activities, the queen, Hindu deities, altars, and animals. Inscriptions are usually written in pseudo-Greek or Brahmi script. Approximate Date: A.D. 345-455.

(h) Coins of the Hephthalite, Kidarite, Alchon and Nezak Hun, Rai, Brahmin Chacha, and Turk Shahi Dynasties include silver and copper alloy denominations. Designs resemble Sasanian coins with a portrait bust of the ruler wearing a distinctive crown on the obverse and a fire altar or other Zoroastrian imagery on the reverse. Coins sometimes bear emblems ( tamgha s) and/or inscriptions in Bactrian, Pahlavi, Brahmi, or Nagari script. Designs are sometimes highly schematized. Approximate Date: 5th-9th Centuries A.D.

(i) Hindu Shahi silver coins often bear inscriptions in Nagari or Sharada script and depict a horseman and a bull, or an elephant and a lion. Approximate Date: A.D. 822-1026.

(j) The Umayyad and Abbasid Caliphates and the Ghaznavid and Ghurid Empires issued gold dinars, silver dirhams, and copper alloy fulus (singular fals) bearing Arabic inscriptions on both faces. Inscriptions are often enclosed in circles, squares, rings of dots, or an inscription band. Silver and copper alloy denominations of local governors, the Habbari Dynasty of Sindh, and the Emirate of Multan are similar, but some coins of Multan carry inscriptions in Nagari or Sharada. Some Ghaznavid coins carry bilingual inscriptions in Arabic and Sharada scripts, and some bear images of a bull and horseman. Some Ghurid coins bear inscriptions in Devanagari and/or stylized images of a flower, bull, horseman, and/or goddess. Approximate Date: A.D. 712-1206.

(k) The Delhi Sultanate issued gold tankas, silver tankas and jitals, and copper alloy denominations bearing Arabic inscriptions, either enclosed in a circle, scalloped circle, octofoil, flower, square, or inscription band, or covering the full face of the coins. Some bear inscriptions in Devanagari and/or stylized images of a bull, horseman, lion, or goddess. Some coins are square. Approximate Date: A.D. 1206-1526.

(l) The Mughal Empire issued coins such as gold mohurs; silver shahrukhis, rupees, and tankas; copper and copper alloy dams, and other denominations. Coins bear Arabic inscriptions enclosed in a circle, ring of dots, square, or inscription band, or covering the entire face. Some coins are square. Some coins bear an image of the seated emperor, a portrait bust of the emperor, a sun, and/or Zodiac symbols. Approximate Date: A.D. 1526-1749.

It is also frustrating that the very same coins now subject to a State Department embargo are sold quite openly in Pakistan.  Moreover, despite the claim that Assistant Secretary, ECA Lee Satterfield considered "less drastic remedies" before imposing restrictions on coins, the coin trade's suggestions related to focusing restrictions solely on coins traced back to Pakistani contexts, the provision of export certificates, and the creation of a Pakistani Portable Antiquities Scheme were evidently ignored.  

State Department Offers Advance Notice of CPAC Hearing to Address New MOU with Ukraine and Renewals of Current MOUs with Ecuador and Jordan-- UPDATED 4/26/24, 5/6/24

The State Department Cultural Heritage Center has provided advance notice of a proposed MOU with Ukraine and renewals of current MOUs with Ecuador and Jordan. According to this preliminary notice, written comments and requests to speak at the June 4, 2024, CPAC hearing must be received on or before May 28, 2024.

Sympathy for the Ukrainian people and their struggle against Russian imperialism makes it difficult to oppose any MOU, but the State Department must still honor the CPIA’s statutory requirements in processing the request.

The CPIA closely defines archaeological and ethnological objects that may be subject to restrictions.  A threshold consideration for objects to be considered “archaeological or ethnological material” of Ukraine is that they were “first discovered within” Ukrainian territory and “subject to” Ukrainian export control.

This raises a serious question as to coins and other artifacts from the sites of ancient Greek Black Sea colonies that are now in occupied Crimea.   While Ukraine still maintains that Crimea remains part of that country, the reality is that Russia, which has occupied the peninsula since 2014, is unlikely to give up its conquest. 

Of course, there are other issues, particularly related to coins, including whether common types are of “cultural significance” and whether it is proper to assume that they were found on current Ukrainian territory when they were types that circulated regionally or even internationally.  

Overbroad designated lists enforced as embargos are a major concern for collectors.  Although the State Department and their "partner" archaeological advocacy groups claim that import restrictions are directed at current looting of archaeological sites, their impact is much broader.  In fact, they have allowed foreign governments to "claw back" coins and other cultural goods legally sold and available for export on open markets in Europe.   State and Customs then conduct elaborate "repatriation ceremonies" where they claim they are returning "stolen property."  The reality most often is simply that  some unfortunate collector was unable to provide provenance information that just does not exist for most low value items like coins.  Of course, all this goes against the fundamental Anglo-American view that the burden of proof always is on the government to prove guilt, but it is expediency in the name of "soft power" that prevails here.  

The issue of an overbroad designated list certainly already applies to the current import restrictions with Jordan.  Those import restrictions include coins that circulated regionally.  

The Jordanian MOU and its related import restrictions should also raise different questions because the very same types of coins (and pottery) that are now restricted to American citizens are openly available for sale there. 

At least, the current designated list with Ecuador does not include coins.  That makes sense because Spanish Colonial and Republican era coinage that circulated in Ecuador fails to fit the definition of either “archaeological” or “ethnological” objects.   

Nevertheless, the designated list for Ecuador remains overly broad, including colonial era art that stretches the definition of “ethnological objects.”

The legislative history makes clear that the CPIA’s drafters  believed that "ethnological objects" must be the products of what was at the time referred to as “primitive cultures.”  

Update: April 26, 2024-   The regulations.gov link to comment on the proposed MOU with Ukraine and renewals with Ecuador and Jordan is now live and can be found HERE.  

Update: May 6, 2025-  The State Department Cultural Heritage Center has confirmed fears that Ukraine is asking for very broad based import restrictions in a blog post dated April 30, 2024.  The request includes archaeological objects (including coins) created as recently as 1774 and ethnographic artifacts created as recently as 1917. More here.