Not MAGA: CPA Train Continues Chugging Along With New Grossly Overbroad Import Restrictions for Nepal

Today's Federal Register announced another grossly overbroad embargo, this time of Nepalese cultural goods dating from 32,000 BC to 1950 AD: https://www.federalregister.gov/documents/2026/08/12/2026-16432/imposition-of-import-restrictions-on-categories-of-archaeological-and-ethnological-material-of-nepal

This is yet anther in a series of wide ranging Cultural Property Agreements (CPAs) initiated under the Biden Administration but implemented under Trump. Once again, there has been  no “disruption” of the State Department Bureau of Educational Affairs Cultural Heritage Center CPA train despite all the MAGA rhetoric.

As has been the case of late, the import restrictions on coins are also exceptionally broad, covering all items made or “commonly circulating” in Nepal down to 1770 AD (without recognizing that many such coins also circulated at least regionally). 

 4. Coins—Coins minted in or commonly circulating in Nepal over past millennia come in a variety of sizes and denominations. 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 of Buddhist and Hindu religious figures or ruling figures, religious symbols, crests, and animal, floral, architectural, geometric, and/or vegetal motifs, and/or may be inscribed in various languages and scripts.

a. Early Historic Period types include punch-marked coins and may include depictions of human figures and deities, as well as natural, animal, floral, and/or geometric motifs. Approximate Date: 1200 B.C.E.-200 C.E.

b. Historic Period types include Lichchavi coins with portraits, depictions of deities, inscriptions, and human figures. Approximate Date: 200-11th century C.E.

c. Medieval Period types include silver and gold circular and square mohars and copper dams, and may include emblems, inscriptions, and crests featuring religious and mythological icons as well as geometric, floral, and vegetal motifs. Often with decorative borders and with a central trident icon. Approximate Date: 11th century-1770 C.E.

Leaving aside that the “Medieval Period” now apparently goes to 1770 AD, the  real problem of course is that once a coin type is placed on the designated list, the burden is on the importer to prove that the coin left Nepal before the effective date of the governing regulations. This might make some sense if such coin types were only found in Nepal, but many coin types that circulated there also circulated elsewhere, particularly regionally. Even if the coin type circulated elsewhere in quantity, the assumption will be that it came from Nepal and is therefore subject to detention, seizure, and forfeiture. 

 What's also of note here is that this CPA probably owes more to "woke" archaeological advocacy groups than the Government of Nepal.  Once again, such groups may be a target of Trump's MAGA movement elsewhere but not when it comes to CPAs.  For more, see  Kate FitzGibbon’s excellent analysis on behalf of the Committee for Cultural Policy:  https://culturalpropertynews.org/state-department-seeks-import-restrictions-on-nepalese-art/