Not MAGA: Trump Administration Implements Biden Embargo on "Indian" Cultural Goods

The Federal Register has announced long anticipated import restrictions on Indian cultural goods.  This is yet another wide-reaching Biden Administration  MOU implemented by the Trump Administration.

Following a trend that picked up steam under the Obama Administration and accelerated under Trump I and Biden, the announced restrictions are extremely broad, covering archaeological material dating as recently as 1770 and ethnological material dating as recently as the end of the Raj in 1947.

 Here is a link to the restrictions: 

https://www.federalregister.gov/documents/2025/07/28/2025-14114/imposition-of-import-restrictions-on-archaeological-and-ethnological-material-of-india

For coin collectors, the restrictions generally include all coins found in India, including Persian, Greek, Roman, and later issues with types struck in India specifically named as part of the designated list: 

 (5) Coins—Ancient coins include gold, silver, copper, lead, and copper alloy coins in a variety of sizes and denominations. Includes gold and silver ingots and commemorative coins. Coins may be circular, oval, square, or polygonal in shape, may be punch-marked, hammered, cast, molded, and/or gilded. Coins may include designs on one or both sides, including edges. Designs may include portraits, crests, deities, and animal, floral, architectural, geometric, and/or vegetal motifs, and/or may be inscribed in various languages and scripts. Includes depictions of symbols and figures from Buddhist, Jain, Hindu, Christian, Sikh, and Zoroastrian religious traditions, among others. Includes Roman, Persian, Greek or Hellenistic, Gandharan, Central Asian, and other coins found in India. Includes coins that were reused or converted into decorative objects or objects of personal adornment. Approximate Date: 600 B.C.E.-1770 C.E.

a. Early Historic Period includes punch-marked coins, discs, tokens, among others in gold and silver. May include depictions of animals, geometric, floral, and/or vegetal motifs.

b. Historic Period includes, but is not limited to, Mauryan punch marked coins ( karshapana) with various symbols such as suns, crescents, six-arm designs, hills, peacocks, human figures, animals, and others, and inscriptions in Brahmi script; Roman silver and bronze coins; Hellenistic and Gandharan drachms, tetradrachms, and gold staters featuring iconography of Hellenistic deities and human portraiture and inscriptions in Greek and Kharoshti; Kushan dinars, tetradrachms, and copper alloy denominations with iconography from Persian, Zoroastrian, Buddhist, and Hindu traditions; Western Satraps coins with bull-and-hill or elephant-and-hill images; Indo-Scythian coins; Satavahana coins with Prakrit inscriptions and animal, floral, geometric, star, Buddhist shrines or stupas, human, wheel, and/or maritime motifs; Ashokan stambha coins featuring a central pillar; Gupta dinaras and drachms and others with images of animals, human figures, mythological birds, archery, javelins, battle-axes, wheels and scepters, deities, and portraiture along with floral, geometric, and/or vegetal motifs, including inscriptions in Brahmi script.

c. Medieval Period includes, but is not limited to: Gurjara-Pratihara, Pallava, and other dynastic coins or tokens with portraiture and geometric, animal, and religious motifs; Chola coins with crests of animals and weapons, mythological icons, and inscriptions in the Nagari script; Vijayanagara pagoda coins featuring Hindu deities and related symbols; Delhi Sultanate tankas and jitals with animal, religious, floral, geometric, and/or vegetal motifs and calligraphic inscriptions in various languages and scripts such as Arabic.

d. Mughal Empire or Early Modern Period includes, but is not limited to, rupiya, dam, and mohur coins primarily featuring calligraphy and literary or religious verses, but also figures and portraits of rulers, zodiac signs, birds, animals, and other icons.

 What are not included are the machine struck coins of the British Raj.

For further background on  the arguments for and against these restrictions, see this blog post about the Jan. 30, 2024, CPAC hearing related to this MOU: https://culturalpropertyobserver.blogspot.com/2024/02/public-meeting-of-us-cultural-property.html

Some of the issues raised by collectors and the trade (but completely ignored) are the fact that there is a huge internal market for items like coins within India itself, but with no working system for legal exports as contemplated under both the UNESCO Convention and the Cultural Property Implementation Act. 

There is also the important issue of the impact of these restrictions on the ability of Indian-Americans to own their own cultural heritage, including heirlooms brought from India. 

Given the breadth of these restrictions and their enforcement as embargoes, there needs to be Congressional intervention to rein in the State Department and US Customs.  For a modest proposal which would accomplish just that, see here:  https://culturalpropertynews.org/time-to-make-collecting-great-again/

 For coin collectors, it’s also important to support HR 595, legislation which would facilitate the lawful exchange of collector's coins already subject to cultural property MOUs.  For more, see here:  https://accguild.org/HR-7865