State Department Cultural Property Advisory Committee Meeting on Cultural Property Agreement Renewals with Bolivia, Egypt and Greece

 On March 3, 2026, the US Cultural Property Advisory Committee (CPAC) met in a virtual public session to accept comments regarding a proposed renewals of current Cultural Property Agreements with Bolivia, Egypt and Greece. 

The State Department described these renewals as follows:

Bolivia

Extending the Bolivia MOU would continue import restrictions on categories of archaeological material ranging in date from approximately 10,000 B.C. to 1532 A.D., and ethnological material of the Colonial and Republican periods ranging in date from 1533 A.D. to 1900 A.D.

Egypt

Extending the Egypt MOU would continue import restrictions on categories of archaeological material ranging in date from approximately 300,000 B.C. to 1750 A.D., and ethnological material ranging in date from 1517 A.D. to 1914 A.D.

Greece

Extending the Greece MOU would continue import restrictions on categories of archaeological material ranging in date from approximately 20,000 B.C. to approximately the 15th century A.D., and ecclesiastical ethnological material ranging in date from the 4th century A.D. to the 15th century A.D.

See  https://www.state.gov/cultural-property-advisory-committee-meeting-march-3-5-2026/

The CPAC members did not introduce themselves before the public session, but CPAC currently includes the following individuals, all  appointed by President Biden: (1) Alexandra Jones (Chair, Represents/Expertise Archaeology, Anthropology, related fields, CEO Archaeology in the Community, Washington, DC); (2) Alex Barker (Represents/Expertise Archaeology, Anthropology, related fields) Director, Arkansas Archeological Survey, Arkansas); (3) Mirriam Stark, Represents/Expertise Archaeology, Anthropology, related fields, Professor of Anthropology, University of Hawaii); (4) Nii Otokunor Quarcoopome (Represents/Expertise Museums, Curator and Department head, Detroit Museum of Art); ( (5) Andrew Conners (Represents/Expertise Museums, Director, Albuquerque Museum, New Mexico); (6) Michael Findlay (Represents/Expertise: International Sale of Cultural Property, Director, Acquavella Galleries, New York); (7) Amy Cappellazzo, Represents/Expertise: International Sale of Cultural Property, Principal, Art Intelligence Global; (8) Cynthia Herbert (Represents/Expertise: International Sale of Cultural Property President, Appretium Appraisal Services LLC, Connecticut); (9) Thomas R. Lamont (Represents Public, President of Lamont Consulting Services, LLC, Illinois);  (10) Susan Schoenfeld Harrington  (Represents Public, Past Deputy Finance Chair, Democratic National Committee, Past Board member, China Art Foundation); and, (11) William Teitelman (Represents General Public, Legislative Counsel to the PA Trial Lawyers Association, Attorney (Retired)).

There were also Bureau of Educational and Cultural Affairs (ECA) Cultural Heritage Center staff present, presumably including Glen Davis, Director of the Cultural Heritage Center and Andrew Zonderman, who is serving as CPAC’s Executive Director.  Messrs. Davis and Zonderman are new to their positions.  

The meeting was conducted entirely on Zoom.  None of the CPAC or ECA staff identified themselves to the speakers, so it was difficult to ascertain who attended the meeting.

The Chair, Alexandra Jones, welcomed the speakers.  She thanked the speakers for attending, indicated that all comments had been read, and that speakers should try to limit themselves to under five minutes each given the number of presenters. 

Kate FitzGibbon spoke as the Executive Director of the Committee for Cultural Policy (CCP).  While the CCP submitted comments on all the renewals being considered, Ms. FitzGibbon focused her oral comments entirely on the Egyptian Renewal.  Here is what she stated:

Egypt’s government has not met the statutory conditions required to renew the U.S.–Egypt Memorandum of Understanding (MOU) under the CPIA - and extending U.S. import restrictions would function less as a targeted anti-looting measure than as an expansive, renewable embargo that benefits Egypt’s state narrative and tourism agenda while failing to address core preservation and governance failures.

The CPIA is also intended to benefit US museums and the public. It does not authorize generalized enforcement of another country’s cultural policy or restrictive regime; it requires factual determinations that cultural patrimony is in jeopardy from pillage, that the requesting nation is taking meaningful “self-help” measures, that import restrictions would substantially deter pillage, that less drastic remedies are unavailable, and that restrictions remain consistent with the international interest in cultural interchange for scientific, educational, and cultural purposes. Egypt’s extension request is not supported by transparent, verifiable evidence.

Egypt has heavily invested in prestige projects meant to glorify and politically brand “Pharaonic” Egypt. It has devoted a billion dollars to a flagship museum presented as a civilizational spectacle while day-to-day stewardship has lagged—particularly for archaeological sites, storerooms, inventory controls, and the heritage of Islamic, Christian, and Jewish communities. A government seeking an MOU must demonstrate basic capacities and behaviors including credible reporting about prosecutions justifying a U.S. embargo supposedly driven by demand in the United States, showing that import restrictions are a “substantial benefit” deterrent. Today, returned objects consist of small, common, low-value tourist items that entered the US decades before.

Current U.S. restrictions cover Egyptian archaeological material from roughly 300,000 B.C. to A.D. 1750 and ethnological material from A.D. 1517 to 1914, spanning many cultures, media, and object categories. This scope is far from the CPIA’s intent of targeted categories demonstrably at risk from pillage. A designated list covering stone, metal, ceramics, wood, glass, bone/ivory, leather, paper, textiles, writing, and human and animal remains—across millennia—is a generalized embargo. Categories such as coinage and “Ottoman” objects unquestionably cover objects not first found in Egypt.

Academic research shows that much Egyptian material in circulation left through licensed export, including state-operated sales up to 1983. Egypt did not retain export records, yet now claims that all were “stolen.”

Today, Egypt’s heritage policy links the Sisi government to Pharaonic grandeur, while foreign archaeological work can be conditioned on government review of publication and researchers who publish without approval may lose excavation privileges. Heritage protection is ethically and practically undermined if the requesting state also polices historical interpretation and scholarly discourse. That is completely contrary to the CPIA’s requirement that restrictions be consistent with cultural and scientific interchange.

Import restrictions risk reinforcing state appropriation of Christian, Jewish, and other minority heritage while restricting diaspora communities’ access to their own documentary and ritual history. Look at the restoration of the Ben Ezra Synagogue reopening as as a tourist site rather than a living place of worship, and the seizure and removal of documents from a genizah discovered at the Bassatine Jewish cemetery. Such actions erode the moral premise that “return to Egypt” equals restoration to rightful custodians.

Saint Catherine’s Monastery and the Sinai landscape, a UNESCO inscribed World Heritage Site has been monetized and irrevocably damaged through state-led tourism development.  Egypt’s “Great Transfiguration Project” has destroyed the integrity of a sacred, ancient, living religious site and its cultural landscape. The project is a mass-tourism remaking that threatens traditional architecture, the monastic community, local Bedouin connections to place, and the site’s environmental and spiritual character. Egypt not only ignored UNESCO’s  concerns - but a May 2025 court ruling now threatens minority religious rights across the country.  

Finally, meaningful “self-help”, as Congress intended, depends on civil society, local communities, journalists, and scholars who can monitor sites, document harms, and expose corruption – who are now severely repressed by Egypt’s government.  Formal assurances about robust Egyptian stewardship are not enough. We urge that the MOU not be renewed and that, if any renewal were considered, it should be narrowed and conditioned on measurable benchmarks including inventories, access to minority archives, transparency in enforcement, and demonstrable compliance with World Heritage requirements at Saint Catherine’s.

Here is a link to  CCP’s Comments on Bolivian Renewal:

https://www.regulations.gov/comment/DOS-2026-0133-0051

Here is a link to CCP’s Comments on Egyptian Renewal:

https://www.regulations.gov/comment/DOS-2026-0133-0054

Here is a link to CCP’s Comments on Greek Renewal:

https://www.regulations.gov/comment/DOS-2026-0133-0053

Dr. Ömür Harmanşah spoke as the Vice President for Cultural Heritage, Archaeological Institute of America (AIA).  He first provided some background about the organization.  The AIA was chartered by Congress in 1906.  It currently has 150,000 members, a figure that includes not only professional archaeologists, but others interested in archaeology, including subscribers to the AIA’s magazine.   The AIA supports the renewal of all three Cultural Property Agreements (CPAs).  They are necessary because cultural property continues to be smuggled into the US.  One recent example was the seizure of Egyptian artifacts in Maryland.  He indicates that Bolivia, Egypt and Greece have all hosted important archaeological digs for American archaeologists.  Moreover, they have all taken important steps to protect their cultural patrimony as well as providing loans for museums. Greece recently upgraded the status of archaeological authorities within the country as a bureaucratic matter by designating them as a General Directorate. 

Here is a link to the AIA’s Comments on Bolivian Renewal:

https://www.regulations.gov/comment/DOS-2026-0133-0100

Here is a link to the AIA’s Comments on Egyptian Renewal:

https://www.regulations.gov/comment/DOS-2026-0133-0099

Here is a link to the AIA’s Comments on Greek Renewal:

https://www.regulations.gov/comment/DOS-2026-0133-0102

Peter Tompa spoke next as the Executive Director of the International association of Professional Numismatists (IAPN).  Here is the substance of what he stated:

IAPN takes no position on the proposed renewals of Cultural Property Agreements with Bolivia, Egypt, and Greece, but opposes any import restrictions on coins.  Furthermore, IAPN believes that the Trump Administration must reform the system to ensure more transparency and fairness for American collectors and the trade.

There currently are no restrictions on Bolivian coins and Bolivia’s former Director General of Cultural Property has written there is no basis to impose new restrictions on Spanish Colonial and early Republican era coins that also served as legal tender in the U.S. until 1857.

In social media, the State Department has claimed, “these agreements help protect U.S. museums and collectors, support lawful trade, and deter illegal trafficking of cultural property,” but import restrictions on Egyptian and Greek coins demonstrates that narrative is misleading at best.

The current import restrictions on coins are grossly overbroad.   The Egyptian restrictions cover all coins struck in Egypt to 1750 A.D.  The Greek restrictions cover numerous coin types through the 15^th century.  One cannot assume that these coins were “first discovered within” and were “subject to export control by” Egypt and Greece, fundamental requirements of the Cultural Property Implementation Act.

Let us discuss Egypt first.  The elephant in the room is that Egypt’s authoritarian rulers nationalized all antiquities in private hands in 1983 without compensation.  Before that time, there was a booming antiquities trade in Egypt, with millions of objects leaving the country legally but without the paperwork now deemed necessary to “prove” legal export.  

For coins, the situation is exacerbated because the State Department evidently latched onto the argument that Egypt had a “closed monetary system,” to justify maximalist import restrictions on all coins made in Egypt before 1750 A.D.  However, that system was meant to keep foreign coins “out,” not Egyptian coins “in.”  Moreover, despite ample scholarly evidence demonstrating that such coins circulated regionally or even internationally, the State Department simply ignored that factual record and, in the latest renewal, added restrictions on Roman Imperial, Byzantine and Ottoman coins made in Egypt.

The restrictions for Greece go well beyond what the Greek government originally requested. Greece’s Ambassador told CPAC that its request only concerned antiquities that have been found exclusively on Greek territory.  Yet, the State Department has  imposed broad restrictions on ancient and medieval coins that circulated regionally as well as internationally.  As indicated in IAPN’s comments, that  has resulted in Customs detaining and seizing coins merely because they look “Greek.”    Furthermore, those restrictions even apply to coins legally exported from Greece’s fellow European Union members despite the fact that Greece is part of the E.U.’s common export control regime.   That raises the question: Does the State Department really consider coins legally exported from the E.U. to be “trafficked” cultural property?

So what to do?  Short term, coin types that did not exclusively circulate within the confines of modern Egypt and Greece should be delisted and any new CPA with Greece should treat any coins legally exported from sister EU countries as legal exports under that CPA. 

Going forward, the best long term solution would be for the Trump Administration to order the preparation of designated lists be subject to the Administrative Procedure Act, and for any detentions, seizures and forfeitures of cultural property to be subject to the Civil Asset Forfeiture Reform Act of 2000.  The former would require the government to justify the inclusion of specific coin types in the designated lists. The latter would help  ensure that import restrictions only apply in situations where there was some evidence that the coin in question was illicitly exported from a country with a cultural property agreement or emergency restrictions after the effective date of the governing regulations.

Several members asked questions.  The Chair noted that IAPN and several others had put in comments about the Bolivian Renewal even though Bolivia had not asked for import restrictions on coins.   Tompa indicated IAPN felt it necessary to do so based on the first time import restrictions were imposed on coins, for Cyprus.  That MOU was billed as solely a renewal as well; however, coins were then added to the designated list.  Tompa indicated IAPN would welcome absolute clarity as to whether new coin restriction were being considered to save everyone time.   The Chair indicated she would discuss this further with State Department staff. 

The chair then asked about the “cultural significance” of coins, noting that Wayne Sayles suggested that coins of Greece were culturally significant in his comments.  [This does not seem borne out from reviewing those comments.  They can be read here:  https://www.regulations.gov/comment/DOS-2026-0133-0035 ) The State Department  put Tompa on mute during his extended response while he was discussing the influence of archaeological groups on the process,  but the Chair allowed Tompa an additional 30 seconds to summarize his views.  He stated as a statutory matter one should not confuse archaeological interest with cultural significance.  He also indicated that given there are thousands of examples of coins already available in Greek museums they could not be considered “culturally significant.”  Finally, he indicated that given the Greek Ambassador’s own words, only coins that exclusively circulated within Greece might be of cultural significance to the modern nation state of Greece.

Tompa then confirmed Alex Barker’s understanding that IAPN took no position on the renewals themselves. 

Miriam Stark then asked Tompa if he had ever worked on an archaeological dig.  He indicated no but stated he knew archaeologists who did, including two members of a local Washington, DC coin club who don’t see anything wrong with collecting ancient coins.  Tompa also indicated that there were no restriction on coins from 1982 when the governing statute, the Cultural Property Implementation Act, became law and 2007, when the first import restrictions were imposed on coins for Cyprus.  He also indicated  the CPAC Committee at the time, which included archaeologists, opposed the inclusion of coins. 

Here is a link to IAPN’s Comments on the Bolivian Renewal:

https://www.regulations.gov/comment/DOS-2026-0133-0108

Here is a link to IAPN’s Comments on Egyptian Renewal:

https://www.regulations.gov/comment/DOS-2026-0133-0038

Here is a link to IAPN’s Comments on Greek Renewal:

https://www.regulations.gov/comment/DOS-2026-0133-0040

Teresa Ngan is a student associated with the Oregon Archaeological Society.  She espoused a Marxist view that protection and repatriation of cultural property is necessary to understand the class divisions in ancient societies. 

A link to her comments can be found here:

https://www.regulations.gov/comment/DOS-2026-0133-0069

Tess Davis spoke on behalf of the Antiquities Coalition in support of the renewals for Bolivia, Egypt and Greece.  She argued that the MOUs and related import restrictions close the market to illicit material and thereby protect the legitimate trade.  She noted that a number of other countries have joined the US in doing so.  She also indicated that Cultural Property Agreements provide opportunities to engage with foreign governments over minority cultural heritage issues.

A link to the Antiquities Coalition’s Comments can be found here:

https://www.regulations.gov/comment/DOS-2026-0133-0068

Dr. José M. Capriles Flores is an Bolivian archaeologist who supports the renewal of the MOU with Bolivia.   Looting remains a problem in Bolivia along with destruction due to construction projects.  The government is actively trying to protect the country’s cultural heritage and is also making strides in promoting cultural exchange with foreign institutions.

Here is a link to Dr. Capriles Flores’ comments:

https://www.regulations.gov/comment/DOS-2026-0133-0091

Sarah Parkek is an archaeologist associated with the University of Alabama.  She testified during the initial MOU hearing for Egypt back in 2014, discussing her use of remote sensing technology to track looting in Egypt.  At the time, she indicated that there were 300,000 looting pits identified.  She then reported on her work since then, indicating after a spike in looting during the Arab Spring, there has been little new looting.  She attributes this in part to the US MOU with Egypt. 

One of the CPAC members asked Prof. Parkek about her views on the Egyptian Government’s actions related to St. Catherine’s Monastery.   All she will say is that the issue is a complex one and that the Egyptian Antiquities Ministry with which she collaborates in not involved. 

Alex Barker asks Dr. Parkek about what types of artifacts are being looted.  She indicates that objects from all periods are at risk.  She has personal experience related to early artifacts being looted at a site where she works.  She also indicated that some looting was scattershot, while other looting was more focused, and probably done by more sophisticated looters.  

Andrew Vaughn spoke for the American Society of Overseas Research (ASOR).  Dr. Vaughn indicated that he has made several trips to Egypt where he has participated in academic conferences.  He also has an affinity to the country because his parents met there.  He believes that it is particularly important to renew the CPA with Egypt to show America respects its culture, particularly in this time of military conflict.  He also believes that his Egyptian colleagues have an inclusive approach when it comes to minority heritage. 

Doug Mudd speaks for the American Numismatic Association (ANA) and the Ancient Coin Collectors Guild.  He serves as the curator for the ANA’s Money Museum.  Mudd grew up in a Foreign Service Family posted in the Middle East.  He also is concerned with looting, but believes there are more pragmatic approaches to address it, like that found in the United Kingdom’s Portable Antiquities Scheme.  He indicated that overlapping import restrictions have hurt the ANA’s educational mission because visiting lecturers are afraid to bring in coins with them from overseas for fear they will be seized by US Customs.  He also believes that coins need to be treated differently than other artifacts because they typically exist in many multiples. 

Nil Otokunor Quarcoopome  asks Mudd if there are already enough coins in the US to allow the ANA’s educational mission to continue.  Mudd indicates the problem is that import restrictions limit supply and the fact that collectors have difficulty acquiring specimens ultimately hurts museums.  The only way most museums can afford to acquire new coins is from donations from collectors.  

Here is a link to the Ancient Coin Collectors Guild and American Numismatic Association’s Comments:

https://www.regulations.gov/comment/DOS-2026-0133-0023

Kim Shelton excavates in Greece.  She is a professor with the University of California at Berkeley.  She is known for her directorship of the Nemea Center and she focuses her studies on the Mycenaean era. She has witnessed looting first hand.  She indicates coins are targets for looters which damages the ability to study them.  

Elias Gerasoulis is the Executive Director of the Global Heritage Alliance.  He focuses his comments on St. Catherine Monastery in Egypt.  He urges the State Department to use the renewal of the CPA with Egypt as a vehicle to help ensure that the Monastery remains a place of worship, not simply an over commercialized tourist destination.  

A link to the Global Heritage Alliance’s comments can be found here:  

https://www.regulations.gov/comment/DOS-2026-0133-0072

The Chair then thanked the speakers before closing the CPAC meeting which went 15 minutes over the allotted one hour due to the questions asked by CPAC members. 

 

 

Renewals for Bolivia, Egypt and Greece Point to the Need for Major Reform

This is what I said more or less at today's CPAC hearing.  I hope to have a summary done when I can, but it will probably be delayed due to travel commitments.

Thank you for this opportunity to speak on behalf of the International Association of Professional Numismatists.

IAPN takes no position on the proposed renewals of Cultural Property Agreements with Bolivia, Egypt, and Greece, but opposes any import restrictions on coins.  Furthermore, IAPN believes that the Trump Administration must reform the system to ensure more transparency and fairness for American collectors and the trade.

There currently are no restrictions on Bolivian coins and Bolivia’s former Director General of Cultural Property has written there is no basis to impose new restrictions on Spanish Colonial and early Republican era coins that also served as legal tender in the U.S. until 1857.

In social media, the State Department has claimed, “these agreements help protect U.S. museums and collectors, support lawful trade, and deter illegal trafficking of cultural property,” but import restrictions on Egyptian and Greek coins demonstrates that narrative is misleading at best.

The current import restrictions on coins are grossly overbroad.   The Egyptian restrictions cover all coins struck in Egypt to 1750 A.D.  The Greek restrictions cover numerous coin types through the 15^th century.  One cannot assume that these coins were “first discovered within” and were “subject to export control by” Egypt and Greece, fundamental requirements of the Cultural Property Implementation Act.

Let us discuss Egypt first.  The elephant in the room is that Egypt’s authoritarian rulers nationalized all antiquities in private hands in 1983 without compensation.  Before that time, there was a booming antiquities trade in Egypt, with millions of objects leaving the country legally but without the paperwork now deemed necessary to “prove” legal export.  

For coins, the situation is exacerbated because the State Department evidently latched onto the argument that Egypt had a “closed monetary system,” to justify maximalist import restrictions on all coins made in Egypt before 1750 A.D.  However, that system was meant to keep foreign coins “out,” not Egyptian coins “in.”  Moreover, despite ample scholarly evidence demonstrating that such coins circulated regionally or even internationally, the State Department simply ignored that factual record and, in the latest renewal, added restrictions on Roman Imperial, Byzantine and Ottoman coins made in Egypt.

The restrictions for Greece go well beyond what the Greek government originally requested. Greece’s Ambassador told CPAC that its request only concerned antiquities that have been found exclusively on Greek territory.  Yet, the State Department has  imposed broad restrictions on ancient and medieval coins that circulated regionally as well as internationally.  As indicated in IAPN’s comments, that  has resulted in Customs detaining and seizing coins merely because they look “Greek.”    Furthermore, those restrictions even apply to coins legally exported from Greece’s fellow European Union members despite the fact that Greece is part of the E.U.’s common export control regime.   That raises the question: Does the State Department really consider coins legally exported from the E.U. to be “trafficked” cultural property?

So what to do?  Short term, coin types that did not exclusively circulate within the confines of modern Egypt and Greece should be delisted and any new CPA with Greece should treat any coins legally exported from sister EU countries as legal exports under that CPA. 

Going forward, the best long term solution would be for the Trump Administration to order the preparation of designated lists be subject to the Administrative Procedure Act, and for any detentions, seizures and forfeitures of cultural property to be subject to the Civil Asset Forfeiture Reform Act of 2000.  The former would require the government to justify the inclusion of specific coin types in the designated lists. The latter would help  ensure that import restrictions only apply in situations where there was some evidence that the coin in question was illicitly exported from a country with a cultural property agreement or emergency restrictions after the effective date of the governing regulations.

Thank you for your consideration of the views of the micro businesses of the numismatic trade.

Time Again to Tell the Cultural Property Advisory Committee What You Think About Import Restrictions on Coins for Authoritarian Egypt, Greece and Bolivia.

 The State Department has announced a Cultural Property Advisory Committee (CPAC) Meeting to consider renewals of current cultural property memorandums of understanding (MOUs) with Bolivia, the authoritarian government of Egypt, and Greece. 

CPAC will hold a session open to the public on March 3, 2026 at 2:00 PM. 

The State Department’s announcement can be found here:  https://www.state.gov/cultural-property-advisory-committee-meeting-march-3-5-2026/

The State Department is also soliciting written comments here: https://www.regulations.gov/document/DOS-2026-0133-0001

Comments are due on or before February 20, 2026.

The renewal for Egypt should be controversial because it prioritizes “soft power” on behalf of Egypt’s authoritarian government over the interests of American collectors, museums, and the trade in cultural goods. 

There was a longstanding legal antiquities and ancient coin market in Egypt until the Mubarak dictatorship.  When the legal market was closed, the government also nationalized all collections although collectors’ families are still allowed to “possess” them until such time the Egyptian government gets around to building more storage space. So, in  fact, what the State Department is proposing with this MOU is to reauthorize US Customs and Border Protection (CBP) to act as the enforcer for Egypt’s draconian, confiscatory laws, laws that would be considered an unconstitutional “taking” if the US Government confiscated American collections without providing fair compensation.  The other issue with the most recent renewal is that new import restrictions on Roman Imperial coins from the mint in Alexandria as well as new restrictions on Byzantine coins were added.  This was done despite the evidence provided to CPAC that one cannot assume that such coins must be found in Egypt given their wide circulation patterns See https://www.regulations.gov/comment/DOS-2021-0003-0016

The issues related to the MOU with Greece are in some ways more egregious given Greece’s voluntary association with the European Union.  While Greece is a Democracy,  it has very stringent laws dating back to the 1930s requiring collections to be registered—although it is still possible to import ancient coins from abroad.  However, the real annoyance is that CBP pretends that Greece is not part of the EU.  EU rules govern all exports from the Union.  They explicitly allow EU members to export cultural goods, with or without a permit, depending on value as determined by the member state.  Most EU members allow exports of collector’s coins, usually without a permit.  However, Customs will seize any coin on the designated list for Greece, or the other EU countries with MOUs (Bulgaria, Cyprus,  and Italy) even where the coins were legally exported from a sister EU country.   Representatives of the trade and collectors have raised this concern over and again, most recently with the renewal of the MOU with Italy, but it has fallen on deaf ears.

The current MOU with Bolivia only covers pre-Colombian and later ethnographic artifacts, but there have been previous requests to impose import restrictions on Spanish colonial and early Republican coinage from Latin America, despite the fact such coins were also legal tender in the US until 1857.

For coin collectors, the big issue is the grossly overbroad designated lists that cover coins that circulated regionally or internationally.  

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.

Despite the ever increasing number of overlapping import restrictions on coins, it is  still important to comment, for no other reason that without public comment State Department bureaucrats could claim to political appointees that restrictions on coins are “not controversial.”  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 “soft power” 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 that widely circulated or those 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.

CPO’s 2025 Year in Review- Repatriation on Demand Continues as Law of the Land

 The past year was another challenging one for collectors, the trade and museums.  Despite the Trump Administration’s “America First” rhetoric, repatriation on demand as a “soft power” measure pitched as a means to address “past wrongs” remains the default position of the US State Department, law enforcement, and increasingly US Museums. 

US Import Restrictions under the Cultural Property Implementation Act

The Cultural Property Implementation Act (CPIA) authorizes the executive branch to enter into cultural property agreements or CPAs with foreign governments conditioned on specific findings.  In all but emergency situations, these must be specific findings that the cultural heritage of a specific country is in danger, that the country has engaged in “self-help” measures, that any action is being taken in concert with other market nations, that there are no less drastic remedies available, and that the any action is consistent with the interchange of cultural property for scientific and educational purposes.  19 U.S.C. § 2602 (a) (1).  In “emergency” situations, these requirements are relaxed, but the material to be restricted must either be a “newly discovered type” of “importance,” site specific, or there is a "crisis" threatening the record of a particular culture that can be addressed temporarily by import restrictions. Id.  § 2603.  Once a CPA is signed, U.S. Customs and Border Protection (CPB) prepares “designated lists” of objects subject to repatriation that are published in the Federal Register.   Id.  § 2604.

Over time, however, the required findings designed to place significant substantive and procedural constraints on executive authority have devolved into a “check the box” exercise, and mission creep has repurposed and vastly expanded the program.  What thus started as a forward looking, focused effort to protect archaeological sites and artifacts of cultural significance abroad has now morphed into a comprehensive program to “claw back” and repatriate most archaeological and ethnological objects made or found in a given country from prehistory to the early 20^th century.   While the number of seizures under the CPIA are impossible to determine because CBP has consistently stonewalled FOIA requests, they probably number in the thousands of objects with far more to come as AI is increasingly used to sift through shipments.

Most significantly for the sheer number of American citizens impacted, restrictions now typically extend to common items like historical coins.  Generally speaking, such coins circulated regionally and internationally as items of commerce in the past and are widely collected today.   Yet, under current enforcement guidelines, CBP  can “assume” that any coins of a type that appears on multiple, overlapping designated lists are subject to detention, seizure and forfeiture.

In contrast, a fair reading of the CPIA instead suggests that there must at least probable cause that “designated material” was “first discovered within and is subject to export control by, the State Party”  and that it was exported after the effective date of any governing regulations before it can be seized, forfeited and repatriated.  Id.  §§ 2601, 2606.  However, the Fourth Circuit Court of Appeals rejected an effort at judicial review, holding instead that the issue was a “foreign policy” matter beyond full judicial review.

As a result, import restrictions under the CPIA are not applied solely to illegal exports made after the effective date of regulations under § 2606, but rather are now enforced far more broadly against any import into the US made after the effective date of regulations, i.e., as an embargo, not targeted, prospective import restrictions.  Such enforcement damages legitimate trade, particularly with Europe, because many common artifacts like coins simply lack the documentation necessary to take advantage of a limited “safe harbor” provision for artifacts proven to be outside the country with a CPA before the effective date of any implementing regulations.

Despite significant “disruption” elsewhere, the “soft power” status quo remains alive and well at the Trump State Department when it comes to CPAs and import restrictions on cultural goods. Just in 2025, the Trump II administration implemented Biden era requests for import restrictions on virtually all archaeological and ethnological objects  for India, war-torn Lebanon, and Uzbekistan with renewals being considered for  Taliban Afghanistan, Chile, Columbia, Costa Rica, Italy, Morocco, and Turkey, and new CPAs being considered for Cameroon and Communist Vietnam.

Of particular concern for coin collectors is the expansion of import restrictions to widely collected Roman Imperial coins.  Despite the tiny percentages of such coins found in Afghanistan, Pakistan and Ukraine, the Biden Administration added Roman Imperial coins to “designated lists” for such countries. Moreover, in 2025, the State Department held CPAC hearings to consider renewals of current CPAs with Italy and Turkey, which could be an excuse to expand current import restrictions to include such coins.  

In mid-December, the State Department again renewed its current CPA with Italy, but without any of the past fanfare.  That renewal means that another 5 years of import restrictions must be announced on or before the current ones expire on January 19, 2026.  That makes it likely that the Trump II Administration will at least extend current Obama era import restrictions on ancient Greek, Punic and early Roman Republican era coins as part of the renewal.  What remains uncertain is whether the Trump Administration will continue the Biden Administration’s efforts to place new restrictions on widely collected Roman Imperial coins.  During a State Department Cultural Property Advisory Committee hearing in May, CPO and other representatives of collectors and the trade opposed any such move, citing scholarly evidence proving that such coins circulated in quantity from Britain to Sri Lanka, with  less than 6% of the total number of validated Roman Imperial coin hoards comprising almost 7 million coins being found in Italy,  Under the circumstances, it should be impossible for CBP to assume that any  particular Roman Imperial coin was found in and illicitly exported from Italy as of the effective date of any regulations, but it remains to be seen if undisputed scholarly evidence matters  more than “soft power.”

More evidence that the status quo has not changed can be seen in the lack of turnover in the Cultural Property Advisory Committee (CPAC) and continued State Department funding of archaeological advocacy groups, notably the American Society of Overseas Research (ASOR).    CPAC is an advisory committee that makes recommendations to the Executive Branch about entering into and renewing CPAs.  Its current membership, which is to represent the separate interests of the public, the trade, archaeology and anthropology, and museums, remains completely comprised of Biden appointees. Not surprisingly, based on their interactions with representatives of collectors and the trade at CPAC meetings, most, if not all these Biden political appointees seem to share the Biden State Department’s views that prioritized CPAs and “soft power” over protecting American  collectors and fostering legitimate trade.

State Department funding of ASOR and related archaeological groups is largely directed at conservation programs within countries with CPAs, but part of that funding has also been used to draft reports to help justify more controversial CPAs, like the one with one of the armed factions running Libya.  There is a built-in conflict of interest here because these groups represent archaeologists who can only excavate in these countries with the permission of their governments.  As a result, these groups are reluctant to criticize local corruption and mismanagement or laws that declare state ownership and/or control of most anything “old.”  Nor does the State Department have any incentive to rein in such practices.  The selective “evidence” these groups provide at CPAC hearings helps the State Department bureaucracy “check the box” on the CPIA’s statutory requirements and hence justify further “soft power” CPAs.  

In the past under Biden,  this “collaboration” went so far as to bypass CPAC review and public comment for the renewal of a CPA with a Saudi supported faction in Yemen.  Instead, the new CPA was signed at an “invitation only” event sponsored by the Antiquities Coalition, another advocacy group that has received substantial past State Department funding.  

With the Trump II Administration going into its second year, there remains only a fleeting hope that there will be a major “rethink” of the State Departments prioritizing “soft power” over the private property and due process rights of American collectors. no matter how damaging current import restrictions are to American collectors and lawful cultural exchange, primarily with Europe. 

Threats of Criminal Liability to Force Repatriations

Even more concerning than ever more expansive CPAs are the hard ball tactics of Alvin Bragg’s Manhattan District Attorney’s office (the same office that prosecuted President Trump for falsifying business records).   Matthew Bogdanos, an assistant DA in that office, has gained notoriety by utilizing threats of criminal prosecutions under New York law to “encourage” museums and collectors into “voluntarily” repatriating objects to countries as diverse as Communist China, Italy, Greece, the Islamic Republic of Iran, Libya, and Turkey.   As far as Bragg and Bogdanos are concerned, any object claimed by a foreign country under its own laws will also be treated as “stolen” under New York law even if it left that country decades ago.  The object need not be located in New York today as long as the artifact itself or any transaction related to that artifact, passed through New York at some point in the past.  Furthermore, limitations periods do not apply because each new day of possession a “stolen” object starts the statute of limitations running over again.

Forced repatriations of bronze statues traced to a Roman Imperial era sanctuary in Boubon, Turkey, illustrate some of these issues.  The statues in question apparently were illegally excavated by townspeople and smuggled from Turkey in the 1960s before the 1970 UNESCO Convention provided a legal basis for repatriation.  These statues were openly sold and displayed for decades until archaeological activists gained Bogdanos’ ear after which he demanded that the Cleveland Museum of Art repatriate one of them prominently displayed in its collection.  The Museum initially contested the claim but reconsidered once scholarly evidence suggested that the statue was indeed from Turkey. 

Since then, Bogdanos, with the help of archaeological activists, has been tracking down other statues from the same group.  Most recently, Bogdanos made a claim for another statue from a collector in California.  That collector initially fought the claim by bringing his own case in federal court only to dismiss it and capitulate after being indicted by the Manhattan DA’s office.  Obviously, any rational collector would give up whatever the merit of their own legal arguments given the threat of jail time. 

Once again, the narrative planted in the press only told part of the story.  While the collector apparently capitulated after evidence was disclosed that he knew it was smuggled from Turkey, important questions about the Manhattan DA’s jurisdiction over the object that had been in California for decades remained.  Another important issue here is that while Turkey’s authoritarian government likes to paint itself as a historic “victim,” reality is quite different.  Ottoman Turkey was an Imperial Power that enriched its own palaces with cultural goods taken from its oppressed, foreign subjects.  Moreover, Recep Tayyip Erdoğan’s Turkey of today has similar Imperialist pretentions.  The Turkish government has encouraged looting and destruction of cultural heritage abroad in places like Cyprus and Syria.  It has converted historic churches like Hagia Sophia into mosques.  It has also encouraged treasure hunting in former Christian and Jewish areas.  This should raise a basic question.  Should Turkey really benefit from repatriations of objects removed decades ago and openly displayed since when it has such “unclean hands” today?

Voluntary Repatriations from Museums

The past year was also another banner year for voluntary repatriation from museums.  While such voluntary repatriations may make sense in given circumstances (particularly when they relate to indigenous communities or individual victims), the problem is that returns made on “ethical considerations” to nation states or other governmental powers are all too often based on a selective review of the facts.

Museums are public institutions and Museum Trustees have a duty to retain and preserve the objects in their collections for the public.  After all, most objects in museum collections were donated by private citizens with the expectation that they would be displayed for the American public, not repatriated abroad.

Some years ago, activists with the the Archaeological Institute of America helped convince the Association of Art Museum Directors to adopt new acquisition guidelines.  These state that member museums should not acquire an object unless provenance research substantiates that the work was outside its country of probable modern discovery before 1970 or was legally exported from its probable country of modern discovery after 1970.  At the time, this 1970 date was pitched as a safe harbor for current and future acquisitions.  However, as we have seen,  all that has gone down the Orwellian memory hole as far as the Manhattan DA is concerned.  Moreover, despite the Trump Administration’s “war on woke” at museums, the 1970 Rule has increasingly been replaced with a much more subjective one calling for “ethical returns."  Such ethical considerations are increasingly being applied, particularly where it is alleged that the object in question is the product of “colonial exploitation.” 

Ethics are fine but “provenance research” must tell the whole story, not simply half-truths designed to justify repatriation.  Recent repatriations from the Smithsonian and other Institutions such as the Museum of Fine Arts, Boston, of Benin “bronzes” come to mind.  The return of these objects to the Oba, a traditional ruler in Nigeria, has been justified as righting the colonialist wrongs perpetrated during a punitive British colonial military expedition that took the bronzes as war prizes.  What is all too often left unsaid, however, is that the Oba’s own wealth derived from the slave trade and that the bronzes themselves are made up of melted “manilla” currency used to buy and sell slaves.   Shouldn’t that be relevant to repatriation decisions, particularly when it deprives Americans who descended from slaves taken by the Oba of tangible evidence of their own undeniable victimization?

Legislative Initiatives

It is not all gloom and doom, at least for coin collectors.  Last term, Congresswoman Beth Van Duyne (R-Texas) introduced a technical correction to the CPIA, H.R. 7865, towards the end of the 118^th Congress in April 2024.  This same bill was reintroduced in the 119^th Congress on January 21, 2025, as H.R. 595. The bill currently has fourteen cosponsors, including ten Republicans and four Democrats, making it bipartisan. 

The legislation’s “safe harbor” language allows for the import of coin types on “designated lists” with evidence the numismatic material was acquired lawfully, is of a known type, and is not the direct product of illicit excavations within a UNESCO State Party after the effective date of any import restrictions on coins. The hope is that the bill will be attached to a larger trade bill that is typically passed each Congress.  However, there is some concern that given the month-long government shutdown, there will be no such legislation this year, and it will be necessary to try to get H.R. 595 reintroduced again next term. 

While H.R. 595 would help protect the legitimate trade in collector’s coins, far more ambitious legislation also is necessary to rein in the State Department and Manhattan DA’s office and protect the due process and private property rights of collectors. 

For Further Reading

For coverage of 2025 CPAs, CPAC hearings and import restrictions Under the CPIA, see the Cultural Property Observer Blog, Blog Archive 2025, available at   https://culturalpropertyobserver.blogspot.com/2025/ (last visited January 2, 2026).

For a discussion of the ACCG’s past effort to seek judicial review of the decision to impose import restrictions on coins, see An Epic Battle: U.S. v. 3 Knife-Shaped Coins, Cultural Property News (October 15, 2018), available at https://culturalpropertynews.org/an-epic-battle-u-s-v-3-knife-shaped-coins/ (last visited January 2, 2026).

For a discussion of State Department funding of archaeological advocacy groups, see Peter K. Tompa, Careful Collector No. 22-Your Tax Dollars at Work, Cultural Property News (December 28, 2023), available at https://culturalpropertynews.org/careful-collector-no-22-your-tax-dollars-at-work/ (last visited January 2, 2026).

For a FOIA release related to the “invitation only event” to sign a CPA with a Yemeni faction, see The ACCG has secured important evidence about the extent of cooperation between the State Department and archaeological advocacy groups, most notably, the mysteriously well-funded Antiquities Coalition, Ancient Coin Collectors Guild Website, News, available at https://www.accguild.org/news/13420183 (last visited January 2, 2026).

For more on the Manhattan DA’s repatriation of a statue to Turkey, see Tom Mashberg and Grahm Bowley, Collector Surrenders ‘Nude Emperor’ Statue Identified as Looted, The New York Times (December 8, 2025), available at https://www.nytimes.com/2025/12/08/arts/design/nude-emperor-statue-met-marble-head-turkey.html#:~:text=But%20the%20Manhattan%20district%20attorney's,it%20too%20had%20been%20looted. (last visited January 2, 2026).

For more about the 1970 Rule, see 2013 Guidelines on the Acquisition of Archaeological Material and Ancient Art, Association of Art Museum Directors Website, Standards and Practices (January 29, 2013), available at https://aamd.org/standards-and-practices (last visited January 2, 2026).

For more about the Smithsonian’s ethical returns policy, see Shared Stewardship and Ethical Returns Policy, see Smithsonian National Museum of Asian Art, available at https://asia.si.edu/explore-art-culture/collections/collections-policies/shared-stewardship-and-ethical-returns-policy/ (last visited January 2, 2026).

For more about the legal complexities of the return of the Benin bronzes based on “ethical considerations,” see Channa M. Norman, Benin Bronzes Highlight Complexity of Repatriation Decisions, Shook, Hardy and Bacon Website, available at https://www.shb.com/intelligence/publications/2025/q4/norman-benin-bronzes (last visited January 2, 2026).

For more about H.R. 595, see HR 7865, a Bill to Facilitate the Lawful Trade in Collectors' Coins, Reintroduced as HR 595, Ancient Coin Collectors Guild Website, News, available at https://www.accguild.org/news/13463512 (last visited January 2, 2026).

For more about the legislative reform needed, see Peter K. Tompa, Opinion: It’s Time to Make Collecting Great Again!  Cultural Property News (April 3, 2025), available at https://culturalpropertynews.org/time-to-make-collecting-great-again/ (last visited January 2, 2026).