The State Department has announced a Cultural Property Advisory Committee (CPAC) Meeting to consider renewals of current “emergency” import restrictions on behalf of Taliban Afghanistan, and the renewals of current cultural property memorandums of understanding (MOUs) with Erdogan’s Türkiye and Colombia. CPAC will also consider a new MOU with Cameroon.
The State Department’s announcement can be found here: https://www.state.gov/cultural-property-advisory-committee-meeting-september-15-17-2025/
The State Department is soliciting comments here: https://www.regulations.gov/document/DOS-2025-0203-0001
Comments are due on or before September 8, 2025.
The renewals for Afghanistan and Türkiye should be controversial
because they prioritize soft power efforts directed at a terrorist state
(Afghanistan) and an authoritarian one (Turkey) over the interests of American
collectors, museums, and the trade in cultural goods. For coin collectors, the big issue is the grossly
overbroad designated lists for both countries that cover coins that circulated
regionally or internationally. There are currently no import restrictions for
coins for Colombia, and it does not appear that Cameroon is requesting any
restrictions, likely because coins were not used there until recently.
The other big issue relates to enforcement. Unfortunately, in the only case that addressed
the issue, courts in the US Fourth Circuit gave Customs a “green light”
to detain, seize and repatriate coins for no other reason that they were of
types on a “designated list” for import restrictions. This puts collectors importing such coins at
risk because it is often difficult, if not impossible, to produce the
documentation necessary for legal import under current “safe harbor” procedures.
For further details about these MOUs and emergency
restrictions and how to comment see this solicitation from the Ancient Coin
Collectors Guild https://accguild.org/news/13533301 as well as this
critique from the Cultural Property Observer blog: https://culturalpropertyobserver.blogspot.com/2025/08/soft-power-love-for-taliban-trump-state.html Again, comments are due on or before September 8, 2025, with the CPAC hearing to take
place on September 15, 2025, via a Zoom video conference.
What should you say? It’s better to write in your own words
about how import restrictions hurt your ability to access coins and learn more about other
cultures or even get in touch with your own cultural heritage. However, here is a model for you to consider:
Please do not renew current import restrictions that prioritize the interests of a terrorist state (Afghanistan) and an authoritarian one (Türkiye) over the rights of American coin collectors. If you nonetheless renew these agreements, please ensure that the designated lists are rewritten so that it is absolutely clear that they do not impact coins legitimately imported from legal markets abroad, particularly those in Europe. Coin collecting is a hobby that promotes cultural understanding and relationships with collectors abroad. It is troubling that the State Department Bureau of Cultural Affairs is behind efforts that do considerable damage to a hobby that actually promotes the cultural understanding the Bureau supposedly aims to foster.
