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:  [Add DOS-2026-0133 regulations.gov link when available.]

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 evidenced provided to CPAC that one cannot assume that such coins must be found in Egypt given their wide circulation patters.  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 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.