Cultural Property Advisory Committee Meeting, February 4-6, 2025; New MOU for Vietnam; Renewals for Chile, Italy and Morocco

 In what has become a holiday “tradition,” the State Department has provided advance notice of an upcoming Cultural Property Advisory Committee meeting on Feb. 4-6, 2025.

 The meeting will cover a proposed new cultural property MOU with Vietnam as well as renewals for Chile, Italy, and Morocco.  The advanced notice can be found here:

https://eca.state.gov/highlight/cultural-property-advisory-committee-meeting-february-4-6-2025

 Coin collectors and others should be particularly concerned if as has been the case in several recent renewals, that the renewal with Italy could be used as an opportunity to apply new restrictions to items of more recent vintage.  

Hopefully, the renewal of the MOU with Italy will not be used to expand the current designated list  to additional coin issues, particularly those of the late Republic and Roman Empire.  The current MOU with Italy does not include Roman Republican coins post 211 BC or or any Roman Imperial coins, but recently the State Department imposed restrictions on such coins on behalf of Afghanistan, Pakistan, and Ukraine, despite the lack of evidence many are found there.  

The numbers of such coins found in Italy are also relatively small compared to those found elsewhere.  Additionally, there is a huge legal internal market in Italy itself which undercuts any claim that import restrictions will lessen demand for "looted" material.  

The real issue of course is that US Customs takes the position that the mere placement of coin types on the designated list is sufficient for Customs to "assume' they were illicitly exported from a particular country absent specific evidence to the contrary.  Of course, such an assumption has no factual basis behind it, but to date courts have been unwilling to question State Department and Customs discretion in this area.   

Moreover, coin collectors and the general art trade should be concerned about another recent trend, imposing restrictions on everything and anything identifiable as being produced or used by a given culture down to 1774 for “archaeological objects” and even more recently for “ethnological objects” which have included paintings, most recently for Ukraine.  See https://www.federalregister.gov/documents/2024/09/10/2024-20385/emergency-import-restrictions-imposed-on-categories-of-archaeological-and-ethnological-material-of

Such restrictions place embargoes on anything and everything ever made or used in a given country despite the negative impacts such restrictions have on legitimate trade and cultural exchange.  

Here are the relevant dates:

January 27, 2025- All written comments and requests to speak due.

February 4, 2025 @ 1 PM- Public meeting.

CPO will provide updates about this CPAC hearing, once the regulations.gov starts accepting comments.  Hopefully, there will also be further clarity if  there will be a move to expand current restrictions under the MOU with Italy to more recent "Italian" material.  

ACCG Secures Heavily Redacted FOIA Release of Materials Related to "Invitation Only" Roundtable to Sign Controversial MOU with Saudi-Supported Faction in Yemen

The Ancient Coin Collectors Guild has secured heavily redacted materials in response to its FOIA request  relating to a controversial "invitation only" roundtable organized by the Antiquities Coalition, a mysteriously well-funded archaeological advocacy group with ties to Middle Eastern dictatorships. The ACCG has appealed the State Department's decision to redact the materials, but what was produced demonstrates that the Biden-Harris State Department has gone even further than prior administrations in favoring archaeological advocacy groups and cutting out other interested stake holders representing trade, collector, museum, and religious and ethnic minority interests.  All this advocacy on behalf of a foreign governments also begs the question why these archaeological advocacy groups apparently do not feel a need to register under either the Lobbying Disclosure Act or Foreign Agents Registration Act.

Summary of CPAC Meeting to Discuss Proposed Agreements or Emergency Import Restrictions for Lebanon and Mongolia and Renewal of Agreement with El Salvador

On September 24, 2024, the US Cultural Property Advisory Committee (CPAC) met in a virtual public session to accept public comments regarding proposed Memorandums of Understanding (MOUs) or emergency import restrictions with Lebanon and Mongolia and a renewal of a current agreement with El Salvador.  An update on the Bureau of Educational and Cultural Affairs’ (ECA’s) website made shortly before the hearing provided further information about the scope of the requests:

Lebanon

Protection is sought for archaeological material from the Paleolithic period (approximately 700,000 years ago) to 1774 CE, including, but not limited to, objects in stone (such as tools, statues, figurines, sarcophagi, stelae, architectural elements, seals, amulets, objects of daily use, jewelry, and ceremonial and cultic objects), ceramic (such as vessels, figurines, objects of daily use, and ceremonial and cultic objects), metal (such as vessels, statues, figurines, jewelry, tools, objects of daily use, weapons and armor, and coins), plaster (such as wall paintings and frescoes), glass (such as vessels, seals, jewelry, and objects of daily use), bone and ivory (such as carvings, seals and amulets, jewelry, and objects of daily use), wood (such as panel paintings, icons, and objects of daily use), textiles, manuscripts (on parchment, paper, and leather), and rare specimens of fossilized fauna and flora.

Protection is additionally sought for ethnological material dating from the 17th century until today, including all cultural works, artifacts, and artworks (such as textiles, traditional garments, headdresses, accessories and jewelry, liturgical objects, manuscripts, books, archives, weapons and armor, and objects of daily use) crafted, made, or produced by Lebanese artists, craftsmen, writers, symbolic personalities, or made on the Lebanese territory and considered unique and representative of the diversity of the Lebanese identity and its recognition worldwide (such as works of Gibran Khalil Gibran and famous Lebanese painters).

Mongolia

Mongolia seeks protection of its cultural artifacts including archaeological material, including stone tools and statues; terracotta architectural materials and containers; religious and ceremonial objects; ornaments decorated with gold, silver, bronze, and precious stones; metal objects including coins, equipment, tools, and weapons;  manuscripts and objects used to create or bind manuscripts; wooden objects; carpets; clothing and shoes; and objects made from animal hide, animal skin, and wool.  The protection would also include hand-made ethnological materials including religious figures of deities and other religious objects; shoes and clothes; decorative items; handwritten manuscripts and other literary objects; fine art items; sewn, knit, and embroidered items; items used in traditional ceremonies or festivals; traditional ger housing materials; agricultural equipment; and musical instruments.

 El Salvador

Extending the El Salvador MOU would continue import restrictions on categories of archaeological material ranging in date from approximately 8000 B.C. to A.D. 1550 and certain ethnological material, including categories of ecclesiastical material from the Colonial period to the first half of the twentieth century (A.D. 1525 to 1950).

Cultural Property Advisory Committee Meeting, September 24-26 2024, Bureau of Educational and Cultural Affairs Media Center (amended August 27, 2024) available at  https://eca.state.gov/cultural-property-advisory-committee-meeting-Sept-24-26-2-24 (last visited September 24, 2024). 

The CPAC members did not introduce themselves before the public session, but CPAC currently includes the following individuals: (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)).

The meeting was conducted entirely on Zoom.  None of the members identified themselves to the speakers so it was difficult to ascertain who asked the few questions that were posed.

The Chair, Alexandra Jones, welcomed the speakers.  She thanked the speakers for attending, indicated that all comments had been read, and that speakers would be given five minutes each to present their oral comments. 

Dr. Ömür Harmanşah spoke as the Vice President for Cultural Heritage, Archaeological Institute of America (“AIA”).  Given time constraints, he focused his comments on Lebanon and Mongolia.  He stated that the AIA was founded in 1906 and that today it has some 200,000 members which includes professionals and members of the interested public.  Dr. Harmanşah indicated that Lebanon’s cultural heritage has been endangered since the 1975-1991 Civil War when looting was at its peak.  In Mongolia, a 2019 report indicated that most tombs had been looted.  Lebanon and Mongolia both have legislation meant to address looting that satisfies the “self-help” requirement.  In 2003, the Lebanese government partnered with the World Bank and bilateral agencies to implement what is known as the Cultural Heritage and Urban Reconstruction Project (CHUD) “to help conserve and restore the country’s cultural heritage in five of its historic cities: Baalbek, Byblos, Saida, Tripoli, and Tyre."

The AIA’s written comments about Lebanon can be found here:  https://www.regulations.gov/comment/DOS-2024-0028-0054

The AIA’s written comments about Mongolia can be found here: https://www.regulations.gov/comment/DOS-2024-0028-0055

The AIA’s written comments about El Salvador can be found here: 

https://www.regulations.gov/comment/DOS-2024-0028-0056

Kate FitzGibbon spoke as the executive director of the Committee for Cultural Policy.  She indicated that since she served on CPAC reasonable restrictions on trade have been replaced by blanket restrictions and perpetual MOUs.  The Lebanese government is beholden to Hezbollah, an Iranian proxy, putting objects potentially at risk.  Most looting in Lebanon occurred during the civil war of the 1990s under the direction of various militias.  There are only five paid Lebanese archaeologists who are expected to protect the entire country, which is impossible.  There is no “self-help” whatsoever.  In El Salvador, a blockade on art has done nothing to protect cultural heritage from destruction due to development.   Mongolian material is not going to the US, but China.  Much of what may appear on a designated list for Mongolia would be either Chinese made Buddhist religious artifacts, some of which were taken to Mongolia by Tibetans fleeing Chinese oppression.  It would be a shame if a MOU were used to take such material away from Tibetan exiles.

The Committee for Cultural Policy’s and the Global Heritage Alliance’s written comments on all the requests can be found here:

https://www.regulations.gov/comment/DOS-2024-0028-0048

Elias Gerasoulis spoke as executive director of the Global Heritage Alliance.  He indicated that the MOU with Lebanon cannot be divorced from the political situation in the country.  El Salvador cannot meet the “self-help” requirement because it has prioritized construction projects over protecting cultural heritage.  It is important that the State Department hold countries seeking MOUs to certain standards.

Peter Tompa spoke as executive director for the International Association of Professional Numismatists (IAPN).  He made the following three points.  First, CPAC should reject any cultural property agreement or emergency import restrictions for Lebanon.  US  Customs should not be made the “culture cop” for a government dominated by Hezbollah, a terrorist group and proxy for Iran’s dictatorial regime.  Repatriating objects to a war zone where they could be destroyed also makes no sense.  Second, the State Department has misleadingly claimed that MOUs only stop trafficked property from entering the US and promote legal cultural exchange.  In fact, MOUs are instead used to claw back coins and other designated archaeological and ethnological material from legitimate markets abroad, particularly in Europe.  Third, there is no factual basis for the assumption that coins minted or found in El Salvador, Lebanon or Mongolia necessarily come from those countries.  IAPN presented scholarly evidence that coins minted or found in these countries are also found elsewhere regionally or internationally in much greater numbers.  The Shekel of Tyre is a specific example.  This coin was used to pay the Temple Tax and is found in great numbers in Israel. 

Peter Tompa’s oral statement can be found here:  https://culturalpropertyobserver.blogspot.com/2024/09/cpac-meeting-on-new-agreements-or.html

Peter Tompa’s personal comments can be found here:

https://www.regulations.gov/comment/DOS-2024-0028-0040

IAPN’s comments on Lebanon can be found here:

 https://www.regulations.gov/comment/DOS-2024-0028-0021

IAPN’s comments on Mongolia can be found here:

https://www.regulations.gov/comment/DOS-2024-0028-0023

IAPN’s comments on the extension of the current agreement with El Salvador can be found here:

https://www.regulations.gov/comment/DOS-2024-0028-0019

Randy Myers spoke as a board member on behalf of the Ancient Coin Collectors Guild.  He also spoke on behalf of the American Numismatic Association.  He touched on four points.  First, the State Department continues to provide inadequate notice to the public for upcoming MOUs.  This makes it difficult to solicit informed public comment.  In this case, notice was first provided 32 days before the CPAC hearing, and it only became clear 21 days in advanced that both Lebanon and Mongolia sought import restrictions on coins.  Even here, no details were provided about what coin types were included in the request, and any factual basis for doing so.  Second,  Myers reiterated Tompa’s point about “Lebanese” coins circulating well beyond Lebanon, such that it is impossible to assume any particular coin was found there.  Myers mentioned that the largest hoard of “Shekels of Tyre” (over 4,000 coins) was found in Israel, not Lebanon.  Finally, Myers indicated that there could be no credible “self-help” measures since Lebanon is a failed state.  He further noted that in addition to Hezbollah’s malign influence, the Cultural Ministry itself is run by Amal, another militia which is also a proxy of Syria and Iran. 

The Ancient Coin Collectors Guild’s and the American Numismatic Association’s comments regarding Lebanon can be found here:

 https://www.regulations.gov/comment/DOS-2024-0028-0022

After Myers spoke, an unidentified Committee members asked Tompa, FitzGibbon or Myers why they thought the US Government would be repatriating antiquities to terrorists.  Tompa explained that Hezbollah, a terrorist organization, was the most powerful force in the country, effectively controlling its government.  He further indicated that the US Government and Manhattan DA’s office had already given over antiquities to the Lebanese government. 

Andrew G. Vaughn spoke as executive director of the American Society of Overseas Research (ASOR).  Vaughn visited Lebanon back in 2017 and 2019.  He was impressed by the efforts of Lebanese authorities to overcome obstacles caused by war, and now more than any other time the US should support Lebanon by entering into a MOU.  He maintained that during times of conflict, concerns about looting increase, which would be addressed by such a MOU.  Recently, 60 Lebanese archaeologists visited the US for training.  Lebanon needs our support to continue to use cultural heritage to bring its diverse population back together.  Vaughn quotes President Biden that the US must “lead not by example of power, but power of our example.”  He also maintains that Mongolia is also doing a wonderful job protecting its own cultural heritage. 

Vaughn did not submit his own written comments, but here are comments submitted on Lebanon on ASOR’s behalf:  https://www.regulations.gov/comment/DOS-2024-0028-0043

Dr. Jeffrey H. Altschul spoke on behalf of  Coalition for Archaeological Synthesis regarding Mongolia.  He indicated that looting is a serious problem that Mongolian authorities are trying to address.  Mongolians also can benefit from interacting with their American colleagues. 

Dr, Altschul’s written comments can be found here:

https://www.regulations.gov/comment/DOS-2024-0028-0028

Dr. Julia Clark of Nomad Science spoke about looting in Mongolia.  She indicated that looters had focused on materials buried in permafrost because they tend to be well preserved. They keep items like cloth with gold thread and discard less salable items as well as human remains.  A MOU is necessary to disincentivized this type of looting and empower Mongolian archaeologists.  Dr. Clark is asked if looting occurs elsewhere. She indicates it has. 

Dr. Clark’s written comments can be found here: 

https://www.regulations.gov/comment/DOS-2024-0028-0036

Carlos Flores Manzano is a PhD student at Yale from El Salvador.  He speaks for a renewal of the current MOU.  He indicates that while urban development is a problem, El Salvador is trying to address these issues as best as it can. Recently, the Cultural Ministry and Foreign Ministry have cooperated in seeking repatriations from abroad. 

Mr. Flores Manzano’s written statement can be found here:  https://www.regulations.gov/comment/DOS-2024-0028-0041

The docket contains all written statements, the vast majority of which opposed import restrictions on coins.  See https://www.regulations.gov/document/DOS-2024-0028-0001/comment

Notable statements include that of the American Israel Numismatic Association, which can be found here:

https://www.regulations.gov/comment/DOS-2024-0028-0025;

CINOA which can be found here:

https://www.regulations.gov/comment/DOS-2024-0028-0012;

and the Oriental Numismatic Society which can be found here:

https://www.regulations.gov/comment/DOS-2024-0028-0020.

The speakers finished 15 minutes early.  As there were no additional questions beyond the two posed by CPAC members, the Chair thanked the speakers and ended the session abruptly.

CPAC Meeting on New Agreements or Emergency Restrictions for Lebanon and Mongolia and Renewal for El Salvador

 Here is what I said more or less during today's CPAC hearing: 

Thank you for this opportunity to comment on behalf of IAPN and the micro businesses of the numismatic trade and the collectors they service.

1.   CPAC should reject any cultural property MOU or emergency import restrictions with Lebanon. US Customs should not be made the “culture cop” for a government dominated by Hezbollah, a terrorist group and proxy for Iran’s dictatorial regime.  Additionally, no decision should be made to repatriate artifacts to Lebanon when Israel and Hezbollah are gearing up for a full scale war.  Repatriated antiquities are in danger of being destroyed or sold to fund Hezbollah’s jihad against America and Israel.

2.   While the State department has claimed and I quote “Agreements create import restrictions that stop trafficked cultural property from entering the United States while encouraging the legal exchange of cultural property for scientific, cultural, and educational purposes”  that is untrue. They are actually applied far more broadly as embargoes that “claw back” common items like coins that are available for sale and export from legal markets abroad, particularly in Europe.  Once a coin type is “listed,” US Customs can assert its authority to detain, seize, and forfeit similar coins under the assumption they “belong” to the particular country for which import restrictions have been granted. 

3.   There is no factual basis for such an assumption for coins minted or found in El Salvador, Lebanon or Mongolia.  Until recently, these countries were parts of much larger Empires.  One simply cannot assume that such coins are only found there, a key requirement of the CPIA. IAPN has provided scholarly evidence demonstrating that coins struck in Lebanon circulated regionally and even internationally.  Notably, “Shekels of Tyre” that were accepted to pay the Temple tax are often found in Israel. Scholars believe some may have been made to order for King Herod or that they may even have been struck in Israel. CPAC must avoid blessing overbroad designated lists that do not comply with CPIA requirements.  Fact based decision-making must prevail.  Thank you for listening.   

US imposes grossly overbroad emergency import restrictions on behalf of Ukraine and new import restrictions for Yemen without a public hearing

At the behest of the State Department, US Customs has imposed grossly overbroad emergency import restrictions on behalf of Ukraine.  It has also issued revised import restrictions on behalf of  "the Republic of Yemen" without a public hearing or full statutory Cultural Property Advisory Committee review. Both sets of import restrictions again demonstrate that the Biden-Harris State Department places a  premium on expediency over legality and the interests of American collectors and the small and micro businesses of the trade in cultural goods.  

The Ukrainian emergency import restrictions cover archaeological material from the Paleolithic period (c. 1.4 million years ago) through 1774 AD and ethnological material from 200 AD to 1917.  The restrictions on widely collected coins  and medallions are exceptionally broad:

1. Coins —In gold, silver, bronze, copper, and lead. Some coin types minted in or commonly found in archaeological contexts in Ukraine in various periods are listed below.

a. Ancient Greek cities in Ukraine, including Olbia, Panticapaeum, Chersonesus, and Tyras, minted coins of various weights and metals. Cast currency in dolphin, sturgeon, and arrowhead forms was also produced in this period. See Zograph, A. Ancient Coinage, Part II, Ancient Coins of the Northern Black Sea Littoral. (Oxford, 1977). Approximate date: 600-47 B.C.E.

b. In the Roman period, Panticapaeum continued to mint coins, and other Roman imperial coins were also used. See MacDonald, D. An Introduction to the History and Coinage of the Kingdom of the Bosporus, Classical Numismatic Studies 5. (Lancaster, 2005). Approximate date: 47 B.C.E.-500 C.E.

c. Coins minted in the Kyivan Rus period include gold and silver zlatnyks with a portrait of the ruler and the trident (tryzub) symbol. Hexagonal cast ingots (hryvnia) were also produced. Bohemian deniers and dirhams of Islamic states were also used in the Medieval period. Pierced coins and exfoliated (flaked) coins, including half-coins and forgeries, were common. Approximate date: 880-1240 C.E.

d. Coins in use during the Late Medieval and Early Modern periods include, but are not limited to, Mongolian dirhams, Lithuanian denars, Polish ducats, Crimean Khanate akces, Austro-Hungarian talers, Ottoman coins, and Russian rubles. Approximate date: 1240-1774 C.E.

2. Medallions —Usually featuring relief images, known since the Early Iron Age, with gold, silver, and bronze phaleras used during the Roman period. Approximate date: 1000 B.C.E.-1774 C.E.

Such import restrictions authorize the detention, seizure and repatriation of  coin types made in what is today Ukraine or occupied Crimea that circulated in quantity elsewhere as well as issues made elsewhere that primarily circulated well outside of present day Ukraine.  Early modern issues of the surrounding nation states of Austria, Hungary, Lithuania, Poland, and Russia are included.   As with ancient Roman Imperial coins, such coin types that are widely and legally sold  in legitimate markets in Europe are now in danger of confiscation on entry into the US unless the importer can "prove" they were out of Ukraine as of the September 10, 2024 effective date of the regulations.  

These concerns were raised in written and oral comments  made on behalf of the American Numismatic Association, the Ancient Coin Collectors Guild, and the International Association of Professional Numismatists, but they were ignored.  Additionally, by issuing "emergency import restrictions"  rather than entering into a cultural property MOU, the State Department avoided having to consider "less drastic measures" raised in these comments.  Such "less drastic measures" like the creation of a Portable Antiquities Scheme and a web based system for issuing export permits would have been particularly appropriate here since Ukraine allows a large internal market for the cultural goods that are now embargoed as well as the purchase and sale of metal detectors.  

In one positive move that cynics will link to the election year, the new Yemeni restrictions on ethnological material explicitly exclude Jewish ceremonial and ritual objects and manuscripts.  JIMENA, B'nai B'rith and Global Heritage Alliance have argued that such materials should exempted from cultural property MOUs with repressive Middle Eastern and North African (MENA) governments which have forced their Jewish populations into exile.  

Addendum (9/16/24):  What the administrative state "gives" with one hand, it "takes" with the other.  A further review of the Ukrainian restrictions linked above demonstrates that they explicitly include Jewish and Christian ceremonial and ritual objects.  Of course, Ukraine is no  Yemen, but such restrictions could still lead to trouble for Christians or Jews of Ukrainian decent bringing such material into the US for religious purposes.  

Cultural Property Advisory Committee Meeting, September 24-26, 2024 to Discuss New MOUs with Lebanon and Mongolia and a Renewal With El Salvador

The State Department’s website has given advanced notice of a Cultural Property Advisory Committee Meeting to discuss new cultural property Memorandums of Understanding (MOUs) with Lebanon and Mongolia and a renewal with El Salvador.

The proposed MOU with Lebanon should be highly controversial. The UNESCO Convention assumes that nation states are the “best stewards” of cultural heritage and MOUs authorize US Customs to repatriate cultural goods seized under them to their care.  But Lebanon is a failing state.  The power there is not in the weak and corrupt government, but Hezbollah (“the Party of God”), a heavily armed Shiite militia group that acts as the Iranian regime’s proxy force against Israel and the United States.  The United States Government has designated  Hezbollah as a terrorist organization, and right now, it has been raining down rockets on Northern Israel,  forcing residents to flee.   Israel, of course, has retaliated, shelling and bombing  parts of Lebanon intensively in an effort to root out Hezbollah terrorists and their allies.

How then can a MOU with Lebanon even be considered?  Repatriating objects to failed states that have become war zones is not a recipe for their “protection” under any circumstance.  Moreover, the State Department's Cultural Heritage Center and its  "partner organization," the Antiquities Coalition, have claimed that "looted antiquities" are a significant terrorist funding source.  RAND Corporation and others dispute such claims, but given that “narrative” shouldn’t the State Department also be concerned that Hezbollah will resell whatever may be returned for funds?

The public session will take place September 24, 2024, at 2:00 p.m. (EDT).

 Public comments will be due no later than September 16, 2024. 

Proposed new MOUs with Lebanon and Mongolia that will likely again cover collectors coins that circulated regionally or internationally making it difficult to import them from legitimate markets in Europe again underscores the need for HR 7865.  More here: https://accguild.org/HR-7865

Addendum (8/19/24):  Regulations.gov is now accepting comments for these MOUs.  Here is a direct link to comment:  https://www.regulations.gov/document/DOS-2024-0028-0001

Alternatively, go to Regulations.gov and then search for DOS-2024-0028.  

What should you say?  Of course, it is much better to speak in your own words, but here is a template for coin collectors:

CPAC should reject any MOU with Lebanon.  Any such MOU would not help "protect" cultural heritage.  Rather, repatriating artifacts would be disastrous for their continued preservation.  Lebanon is a failed state dominated by Hezbollah, a terrorist group and Iranian proxy at war with Israel and the United States.  There is no money to properly preserve artifacts and there is a real danger they will be either destroyed in a conflict or sold to fund Hezbollah's terrorist activities.  

Additionally, there is no reason to apply import restrictions to coins for Lebanon, Mongolia or El Salvador.  For most of their history, these countries were but small parts of much larger Empires, meaning all or most all coins that circulated there also circulated in much greater quantities elsewhere.  One simply cannot assume that coins of a particular type were found there, a prerequisite for them being restricted under the governing statute.    

State Department and Customs Impose Broad Import Restrictions on behalf of Tunisian Government

The State Department and US Customs have imposed import restrictions on behalf of Tunisia’s increasingly authoritarian government that cover an exceptionally  broad range of archaeological (dating from approximately 200,000 BC to 1750 AD) and ethnological (from approximately 1574 AD to 1881 AD) materials. Items listed include religious artifacts, coins and even rope!  

The restrictions on ethnographic materials at least implicitly apply to the cultural heritage of Tunisia’s displaced Jewish minority population. These restrictions recognize the rights of the Tunisian State to the ownership and control of such artifacts despite a history of religious discrimination aimed at the country's remaining Jews, and virulent antisemitism  exemplified by the recent attack on one of the country’s few remaining synagogues.

The restrictions on coins apply to a wide variety of ancient, medieval and early modern coins to 1750 AD, including Carthaginian types which also circulated elsewhere in North Africa, Spain and Italy:  

10. Coins—This category includes coins of Numidian, Carthaginian (sometimes called Punic), Roman provincial, Vandal, Byzantine, Islamic, Norman, and Ottoman types that circulated primarily in Tunisia, ranging in date from the fifth century B.C. to A.D. 1750. Numidian, Roman provincial, and Vandal coins were made primarily in bronze, though some Numidian and Vandal types occur also in silver. Carthaginian types occur in electrum, a natural pale yellow alloy of gold and silver. Local Byzantine and later coin types were made in copper, bronze, silver, and gold. Coins may be square or round, have writing, and show imagery of animals, buildings, symbols, or royal figures.

These latest overbroad  import restrictions on coins again points to the need for collectors to ask their member of Congress to cosponsor HR 7865, legislation to facilitate the lawful trade in ancient, medieval, and early modern coins.