Here is what I said at today's CPAC meeting:
Thank you for this
opportunity to speak on behalf of IAPN and the micro businesses of the
numismatic trade. I would like to make
these 4 points in my 4 minutes allotted.
1.
For most of their histories, Ecuador, Jordan,
and Ukraine were parts of larger political entities. IAPN uploaded historical maps of Ukraine into
the record to drive home that point. Political
geography helps explain why coins that circulated within what is today each
country also circulated regionally or even internationally. One simply cannot assume that coins found in
each of these countries are only found there, a key requirement of the CPIA. CPAC must avoid blessing overbroad designated
lists that do not comply with CPIA requirements. Fact based decision-making must prevail.
2.
CPAC must consider the realities on the ground. There
are open markets for coins within both Jordan and Ukraine. In Jordan, this market exists both at the
Petra archaeological site and in Amman, the nation’s capital. In Ukraine, there is a sophisticated auction
website selling coins. Given these
realities, assisting Jordan and Ukraine to create a workable web-based system
of providing export certificates for common items like coins as contemplated
both by the CPIA and UNESCO Convention is essential.
3.
Another reality on the ground is the use of
metal detectors. In Ukraine, such metal
detectors are openly available for sale.
The best way to deal with metal detectors is to help Jordan and Ukraine
create a working Portable Antiquities Scheme that will encourage finders to
report their finds.
4.
Congressional
appropriators have highlighted the importance of the CPIA’s reporting
requirements, particularly the Congressional mandate that “less drastic
measures” have been considered before import restrictions are imposed. The
creation of workable system of export certificates and a portable antiquities
scheme as well enforcing restrictions solely prospectively and not as embargoes
are just such “less drastic measures” as Congress contemplated. IAPN
urges CPAC and the State Department to heed these requirements. Congress as well as collectors are looking
over your shoulders.
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