Summary of October 5, 2021, Cultural Property Advisory Committee Meeting to Address Emergency Import Restrictions Request on Behalf of the “Former Government of Afghanistan,” Proposed Renewals of MOUs with Cyprus and Peru.

                On October 5, 2021, the US Cultural Property Advisory Committee (“CPAC”) met to consider proposed emergency import restrictions on behalf of the “former government of Afghanistan” as well as proposed renewals of MOUs with Peru and Cyprus.  The following members were present: (1) Stefan Passantino (Chairman- Public); (2) Steven Bledsoe (Public); (3) Karol Wight (Museums); (4) J.D. Demming (Public); (5) Ricardo St. Hilaire (Archaeology); (6) Joan Connelly (Archaeology); Rachael Fulton Brown (Archaeology?); (7) Anthony Wisniewski (Collector-Sale of International Cultural Property); Mark Hendricks (Sale of International Cultural Property?); and David Tamasi (International Sale of Cultural Property?).  Allison Davis, CPAC’s State Department Executive Director, and Michele Prior, also of ECA, were also present.

                It appears that the State Department has seated last minute Trump Appointees in slots reserved to represent the interests of archaeology and the international trade of cultural property, but that has not yet been confirmed on the State Department website.   Rachael Fulton Brown is an associate professor of History at the University of Chicago.  David Tamasi is a Founding Partner and Managing Director of Chartwell Strategy Group, a Washington based government relations and strategic communications firm.  Mark C. Hendricks is a principal at Taradin Service Ltd., a private equity firm.  Messrs. Tamasi’s and Hendricks’ background in the international sale of cultural property is unclear.

Chairman Passantino welcomed the speakers.  He indicated that the Committee had read all the comments, and speakers could only be allotted 4 minutes time given the busy schedule.  He also indicated that due to the addition of Afghan emergency import restrictions to the schedule, the Committee’s consideration of the Cypriot renewal would be tabled until a January meeting.  Nonetheless, speakers were free to discuss Cyprus if they were prepared to do so.  Alternatively, they could defer their comments until January. 

The following speakers addressed the Committee: (1) Kate FitzGibbon (Committee for Cultural Policy/Global Heritage Alliance); (2) Josh Knerly (Association of Art Museum Directors); (3) Dr. Elizabeth Greene (Archaeological Institute of America); (4) Dr. Brian Bauer (University of Illinois); (5) Dr. Karen Olsen Bruhns (San Francisco State University); (6) Peter Tompa (International Association of Professional Numismatists/Professional Numismatists Guild; (7) Dr. Brian Daniels (Archaeological Institute of America); (8) Tess Davis (Antiquities Coalition); (9)  Allen Berman (Author, Professional Numismatist); and (10) Randolph Myers (Ancient Coin Collectors Guild).

Kate FitzGibbon (KFG) spoke first on behalf of the Committee for Cultural Policy (CCP) and Global Heritage Alliance (GHA).  Although she also put in a paper on Peru, she will focus her comment on Afghanistan.  KG lived in Afghanistan from the 1970s to early 1980s writing about the culture and dealing in ethnographic art.   She had to flee the country in 1982 after the Soviet invasion.  The real issue today is not looting but the fear that the Taliban will intentionally destroy cultural heritage either intentionally to score jihadist propaganda points or to exploit Afghanistan’s mineral wealth.  Section 1216 of the National Defense Authorization Act does not provide a basis for safe harbor for Afghan antiquities. ECA should forget about emergency import restrictions and instead work with the trade and museums in protecting Afghan cultural heritage and extracting Afghan archaeologists from the country. 

The CCP’s and GHA’s testimony on Afghanistan can be found here:  https://www.regulations.gov/comment/DOS-2021-0032-0068

Their testimony on the proposed renewal of a MOU with Cyprus can be found here:

https://www.regulations.gov/comment/DOS-2021-0032-0077

Their testimony on the proposed renewal of a MOU with Peru can be found here:

https://www.regulations.gov/comment/DOS-2021-0032-0097

                Josh Knerly (JK) spoke next on behalf of the Association of Art Museum Directors (AAMD).  The request of the “former Government of Afghanistan” raises some serious legal issues.  The government that made the request no longer exists and there was insufficient information provided about the proposal within a short five (5) day comment period to make intelligent comment or for CPAC to have a full grasp of the issues.  The effect of import restrictions may be to freeze objects in place in Afghanistan where they may be destroyed by the Taliban. CPAC needs to consider the consequences of any import restrictions carefully. Section 1216 of the National Defense Authorization Act is not a safe harbor provision.  It only immunizes from seizure institutional loans already covered by an Afghan Government export certificate.  It would make far more sense to defer consideration of the matter until the situation on the ground is clearer.  JK next discussed the Peruvian renewal.  He criticizes the State Department’s replacement of tailored language for each MOU with generic language in Article II of the Agreement.  This generic language does not help AAMD members negotiate with State Parties on museum loans.   The terms and conditions of each MOU should encourage source countries to provide such loans with reasonable fees.  Peru’s loan fees are very high. 

                The AAMD’s written testimony regarding Peru and Cyprus can be found here:

https://www.regulations.gov/comment/DOS-2021-0032-0105

                Dr. Elizabeth Greene (EG) is the president elect of the Archaeological Institute of America (AIA).  She focuses her comments on the Fourth Determination that any import restrictions are consistent with the general interest of the international community in the international exchange of cultural property.   She indicates the AIA’s 200,000 members (this figure derives from the number of subscribers to the AIA’s “Archaeology” Magazine) have benefitted from the MOU.  Many have taken AIA sponsored trips to Peru to view Peruvian cultural heritage.  Peru has been generous with loans, including one recent loan of 200 items. Dr. Greene specializes in the study of transport amphora.  They may appear to be duplicates but have manufacturing marks that makes each unique.  MOUs can protect duplicate objects like amphora and coins as well as ensure the market only contains legitimate material.  They are not perfect, but they do help reduce looting. 

                Dr. Brian Bauer (BB) appreciates the fact that Spanish Colonial era documents have been added to MOUs.  He now asks CPAC to recommend changes to Article II of the MOU with Peru to ensure that archaeological samples can be exported for further study.  There are no labs within Peru which can do this work, but the Peruvian cultural bureaucracy, especially on a provincial level, have made it a bureaucratic nightmare to export such material.  Only material shepherded through the system with the help of Peruvian colleagues gets exported.   Many times requests for export get lost or simply stay in limbo so long that the researcher just gives up.  The MOU needs to be modified to encourage Peruvian authorities to fix this problem.

                Dr. Karen Olsen Bruhns (KOB) believes MOUs are essential to fight illicit networks.  She has been involved in the fight against looting since 1963.  She has seen the depredations of looters in Latin America firsthand.  She assists U.S. Customs in repatriating artifacts.  She names US dealers she claims sell looted goods.  She attacks US Museums as being filled with looted material.  She views collectors as no better than looters.

                Peter Tompa (PT) spoke on behalf of the International Association of Professional Numismatists (IAPN) and the Professional Numismatists Guild (PNG).  He defers his comments on Cyprus to focus attention on Peru and Afghanistan.  Spanish Colonial and Republican era coinage of Peru do not fit the statutory definitions for archaeological or ethnological material.  They cannot be considered archaeological material because they are not normally found underground and/or do not meet the 250-year-old threshold.  Such coins were also produced by Europeans using sophisticated industrial processes that churned out thousands of virtually identical coins.  As such, they cannot be ethnological material either. PT then turns to Afghanistan.  He indicates that is should weigh heavily on CPAC that import restrictions could have the perverse effect of requiring US Customs to “claw back” undocumented Bactrian coins imported from Europe and hand them over to the Taliban who could resell, or even worse, melt them.  The CPIA does not contain a “safe harbor” provision to keep that from happening, and Section 1216 of the National Defense Reauthorization Act will provide no help.  Items will be repatriated when diplomatic relations are reestablished, a decision that will be made based on considerations other than the Taliban’s treatment of cultural heritage.  Restrictions are especially problematic for coin collectors since they are applied not as prospective restrictions on illicitly excavated coins but as embargoes to coins already on legal markets within our major trading partners in the EU, UK, and Switzerland. 

                PT’s oral testimony can be found here:  https://culturalpropertyobserver.blogspot.com/2021/10/the-cpia-cannot-support-import.html

                IAPN’s and PNG’s written testimony on Afghanistan can be found here:

https://www.regulations.gov/comment/DOS-2021-0032-0088

                IAPN’s and PNG’s written testimony on Cyprus can be found here:

https://www.regulations.gov/comment/DOS-2021-0032-0038

                IAPN’s and PNG’s written testimony on Peru can be found here:

https://www.regulations.gov/comment/DOS-2021-0032-0021

Dr. Brian Daniels (BD) spoke for the Archaeological Institute of America (AIA).  The request for a MOU by the former government of Afghanistan allows the Committee to consider emergency import restrictions.   There is looting of crisis proportions in Afghanistan.  Research has shown that 170 sites have suffered looting from 2000-2017.   In 2019, there was an uptick in looting of inscriptions.  Customs has seized archaeological material which appears to be from Tillya Tepe.  In the past decades, US archaeologists have worked on capacity building with their Afghan colleagues. BD acknowledges Section 1216 of the National Defense Reauthorization Act would only have helped evacuating Afghan material when the former government was in power.  Now emergency import restrictions are necessary not only to keep looted material off the market but to support Afghan colleagues.  Customs has inherent authority to hold onto such items until it is safe to return them to Afghanistan. 

The AIA’s submission on Afghanistan can be found here:

https://www.regulations.gov/comment/DOS-2021-0032-0069

                Tess Davis (TD) spoke on behalf of the Antiquities Coalition (AC).  The Antiquities Coalition supports emergency import restrictions on Afghan cultural goods.  It is important to take decisive action now given the warning from the Afghan National Museum that looters and smugglers are taking advantage of political instability following the Taliban take over.   Emergency restrictions are not MOUs, but they can protect cultural heritage and collections.  They do not vest title of artifacts in the government.  No concerted international response is necessary.  The US did not adopt emergency restrictions on Cambodian artifacts in the 1970s and we are now seeing the consequences with investigations into Latchford’s sales of Cambodian conflict antiquities to US collectors and museums. 

                AC’s submission on Afghanistan can be found here:

https://www.regulations.gov/comment/DOS-2021-0032-0082

                AC’s submission about Cyprus can be found here:

https://www.regulations.gov/comment/DOS-2021-0032-0080

AC’s submission on Peru can be found here:

https://www.regulations.gov/comment/DOS-2021-0032-0081

                Allen Berman (AB) is an author, publisher and the American Numismatic Association’s instructor on medieval coinage.  He believes that the law of unintended consequences may apply to import restrictions on coins.  Provenanced coins already cost more, but there are very few comparatively on the market because there was no reason historically to keep the provenance of most coins.  On Peru, 95% of coins produced there was made for export.  On Afghanistan, the last time the Taliban were in control, they not only dynamited the Bamiyan Buddhas; they also smashed artifacts in the National Museum.  AB is horrified by the prospect that the US Government may hand over Bactrian coins to the Taliban.  All these coins feature pagan images the Taliban find offensive.  As to Cyprus, thousands of Crusader era coins are documented as having been found outside of Cyprus so you cannot assume such coins were found there.  It would be better for Cyprus and other countries to try systems akin to the United Kingdom’s Portable Antiquity Scheme and Treasure Act.  This system encourages people to report their finds and allows the government the right of first refusal to buy them.

AB’s written testimony on Afghanistan can be found here:

https://www.regulations.gov/comment/DOS-2021-0032-0037

                His written testimony on Cyprus can be found here:

https://www.regulations.gov/comment/DOS-2021-0032-0035

                Randolph Myers appeared on behalf of the Ancient Coin Collectors Guild (ACCG).  Given the time, he indicated he would defer his comments on Cyprus until January.

                The ACCG’s written testimony on Afghanistan can be found here:

https://www.regulations.gov/comment/DOS-2021-0032-0040

The ACCG’s written testimony on Cyprus can be found here:

https://www.regulations.gov/comment/DOS-2021-0032-0025

Question and Answer Period:

Ricardo St. Hilaire asked JK about Article II in the Peru agreement.  JK indicated that standardized Article IIs do not work.  Peru charges high fees for loans which need to be addressed on an individualized basis in Article II of any renewal.

 Karol Wight asks JK if AAMD museums have faced the same bureaucratic obstacles to loans as BB has experienced with exports of archaeological samples.  JK responds that loans with Peru take an inordinate amount of time to negotiate and that loan fees are high.

J.D. Demming asks if instead of keeping Afghan artifacts in Afghanistan it would be better if they escaped the country given Taliban control.  KOB states that providing a market for antiquities encourages looting.  The real problem is antiquities dealers in the US which now have a “bad odor.”  Sotheby’s now avoids selling antiquities in the US to avoid this perception.  KFG indicates that KOB has an outdated view of the antiquities market based on practices of decades ago.  The art market today takes pains to ensure that what it sells is legal.  Complicating the situation here is that it was quite legal to sell and export antiquities from Afghanistan for decades.  Therefore, one cannot assume items on the market are the products of recent, illicit digs.   Repatriating items to Taliban Afghanistan will not help protect them.  The real issue is the danger of Taliban intentional destruction or destruction of artifacts through mining.  BD indicates that import restrictions will protect items currently in the ground within Afghanistan because there will be less incentive to loot them.  US Customs and the State Department have ample authority to provide safe harbor to any antiquities that are seized.  PT appreciates what BD says about import restrictions protecting unexcavated artifacts within Afghanistan, but the problem is that Customs applies them far too broadly and will repatriate artifacts that have been out of Afghanistan for decades merely because they do not have solid provenances. 

Anthony Wisniewski gets the last word.  He has spent over 500 hours on his CPAC duties.  He has seen lots of conflict between the parties, but thinks all sides believe in cultural property preservation.  He will be working to bring people together to find common ground which promotes both transparency and protects private collections. 

Report on January 21, 2020, CPAC hearing to discuss proposed MOU's with Turkey and Tunisia

               On January 21, 2020, the U.S. Cultural Property Advisory Committee (“CPAC”) met to consider proposed MOU’s with Turkey and Tunisia.   CPAC is currently constituted as follows.  (1) Stefan Passantino (Public); (2) Adele Chatfield-Taylor (Public); (3) James Reap (Public); (4) Karol Wight (Museums); (5) Nancy C. Wilkie (Archaeology); (6) Ricardo A. St. Hilaire (Archaeology); (7) Lothar Von Falkenhausen (Archaeology); and  (8) Anthony Wisniewski (Collector-Sale of International Cultural Property).

                Due to the large number of speakers, the Chair indicated each speaker would only be allowed two (2) minutes rather than the usual five (5) minutes.  Those speakers in favor of MOU’s with Turkey and/or Tunisia were as follows: (1) Dr. Lynn Dodd; (2) Dr. Jane Evans; (3) Sam Hardy; (4); Dr. Christina Luke; (5) Dr. Brian Rose; (6) Tess Davis; (7) Dr. Nathan Elkins; (8) Dr. Elizabeth Greene; and (9) Katie Paul.  Those opposed to one or both MOU’s or their application to certain types of artifacts were as follows:  (1) Stephen Knerly; (2) Elias Gerasoulis; (3) Carol Basri; (4) Kate FitzGibbon; (5) Douglas Mudd; (6) Peter Tompa; and (7) Randolph Myers.

                Chairman Passatino welcomed the speakers.  He indicated that the Committee had read all the comments, particularly those of the speakers.  Given the large number of speakers, Mr. Passatino indicated that speakers would be limited to 2 minutes.  After all the speakers were finished, he would open up the floor to questions.

                Dr. Lynn Dodd is an archaeologist.  She supports Turkey’s MOU.  She indicates Turkey has met all the criteria to be granted a MOU.

                Dr. Jane Evans indicates coins are at risk from metal detectors.  She indicates excavation coins typically are local issues that do not circulate far from where they are made so they should be restricted.

                Sam Hardy starts his presentation honoring an archaeologist who took his own life rather than taking the blame for embezzlement.  He indicates trafficking is a real problem in Turkey.  He finds it odd that Turkey would not be granted a MOU because of problems within the country because granting a MOU will encourage positive forces in Turkey to clean up the country’s act.

                Dr. Christina Luke works in Turkey.  She echoes her support of others for a MOU with Turkey.

                Dr. Brian Rose of the University of Pennsylvania has seen looted sites.  Looting is a lucrative business that needs to be addressed. Turkey allows US Archaeologists to work in the country, which promotes educational exchange.

                Tess Davis and her organization, the Antiquities Coalition, supports the MOU with Turkey.  She focuses her comments on the third determination. She indicates there is a concerted international response of market nations now that the EU has promulgated import controls on cultural artifacts.

 

                Stephen Knerly spoke for the Association of Art Museum Directors.  He indicates that a MOU in this case would not be appropriate because the Turkish government is involved in state sanctioned looting and destruction of Turkey’s cultural patrimony.

                Elias Gerasoulis speaking for the American Hellenic Institute opposes any MOU with Turkey.  There is no rule of law in Turkey under Erdogan.  A number of Byzantine era cathedrals have been turned from museums into mosques.  Over 400 churches have been destroyed in Cyprus. Erdogan has shown disdain for religious minorities and the material remains of their culture.

                Dr. Nathan Elkins notes that prior MOUs have focused on coins that have circulated locally, but is time to expand upcoming MOU’s to include Roman Republican, Roman Imperial and Byzantine coins.  There are enough MOUs already where coins have been included that now is the time to treat all coins like other objects that are found on different designated lists.

                Dr. Elizabeth Greene supports the MOU.  MOUs ensure that objects of minority groups are preserved. From her work on shipwrecks, Greene knows that even common artifacts like transport amphorae are important to understanding the past.

                Katie Paul speaks for the Athar Project.  She shows images of artifacts from Tunisia and Turkey on sale on Facebook.  She indicates some buyers are located in the US.  She also indicates that she is Pontic Greek.  She wants Greek artifacts protected as evidence of the Greek Diaspora.

                Carole Basri contrasts her prior work for the State Department to more recent State Department efforts to recognize the rights of authoritarian MENA governments to the artifacts of displaced minority populations.  At some risk to her personal safety, Ms. Basri collected records of Jews in Iraq on December 11, 2003 for the State Department.  Some of these records were later deposited in the US Holocaust Museum.  Carole Basri believes there needs to be a carve-out in any MOU for religious artifacts of displaced Jews and other minority populations. 

                Kate FitzGibbon speaks for the Committee for Cultural Policy and the Global Heritage Alliance.  It is essential that CPAC adhere to the CPIA’s requirements.  Turkey has engaged in legalized theft of minority religious artifacts.  A book written by a US diplomat discusses the artifacts available in the Grand Bazar for sale to foreigners. 

                Doug Mudd speaks for the American Numismatic Association.  Import restrictions on coins have had a negative impact on the ANA’s educational mission.  An instructor at the Summer Seminar was afraid to bring his coins from abroad because he was concerned they would be seized.  People can learn from ancient coins which are amongst the most common ancient artifacts.

                Peter Tompa speaks for the International Association of Professional Numismatists.  Any MOU would recognize the Erdogan Government’s rights to “claw back” cultural goods of “ethnically cleansed” Greek, Armenian and Assyrian populations.  Since 2007, a series of grossly over broad import restrictions placed on common ancient coins of the sort widely collected worldwide (including within most of the countries for which import restrictions have been granted) have done quite a bit of damage to ancient coin collecting. Their cumulative impact has been problematic because outside of some valuable Greek coins, most coins simply lack the document trail necessary for legal import under the “safe harbor” provisions of 19 U.S.C. § 2606.  Another embargo, this time potentially impacting a wide variety of Greek, Carthaginian, Roman Provincial, Roman and Byzantine coins struck or sometimes found in Turkey and Tunisia, will bring even more damage. As set forth in IAPN's submissions, there are many statutory reasons why this should not happen. Moreover, CPAC also needs to consider whether import restrictions on coins are really necessary, particularly because it appears that both Turkey and Tunisia allow for the internal sale of ancient coins.

                Randolph Myers is a coin collector.  Coins struck in large multiples lack cultural significance. CPAC should also consider whether less drastic measures, like the institution of a Treasure Act or Portable Antiquity Scheme, should be tried first.  Finally, there is no evidence presented that either Turkey or Tunisia are undertaking adequate self-help measures.

Questions:

              Karol Wight asks if the AAMD polled its members about loans from Turkey.  Stephen Knerly indicates that because the State Department has started using a standard Article II in their MOU’s there is no reason to seek this information from members.  He does note, however, that Turkey demands high loan fees.  It would be beneficial to all concerned if Art II of MOU’s (which relate to requirements placed on the foreign country) are written individually.

            Anthony Wisniewski asks Kate FitzGibbon if restrictions should be placed on coins.  She indicates it is important to look to the wording of the CPIA to ascertain whether restrictions are appropriate.  She then defers to Peter Tompa.  Peter Tompa indicates restrictions should not be placed on coins, but if they are so placed they must take care that they only apply to coins both first discovered within a country and subject to its export control.  He notes that restrictions would be wholly inappropriate on Roman coins which circulated from England to Sri Lanka and which are found in many more countries than where there are MOUs on coins.  Dr. Nathan Elkins is allowed to comment.  He believes restrictions should come in as long as over 50% of coins are found in a given place, but this should be further expanded to everywhere coins are found.

           Anthony Wisniewski asks Dr. Rose about the provenance of coins found in the University of Pennsylvania Museum.   Dr. Rose said that the Museum secured these coins years ago under a system of partage.

          Chairman Passatino asks Elias Gerasoulis if his group could live with any MOU with conditions to address concerns of the Greek community.  Mr. Gerasoulis indicates that his group is unalterably opposed to a MOU because the Erdogan government cannot be trusted. He believes a MOU would make the situation worse, not better.   Moreover, this MOU raises questions not only about Greek property, but other minority property as well.  For example, how can we trust Turkey to respect Jewish minority property, when Erdogan hosted the leader of Hamas, an anti-Israel U.S. designated terrorist group, at the Presidential palace in Turkey last month?  This issue is not simply one of archeology. The political context needs to be looked at and understood. 

Short Comment Period for Proposed MOU's with Morocco and Yemen

The State Department's Cultural Heritage Center is only allowing a mere two weeks for written comment on proposed MOU's with Morocco and Yemen.  For the applicable Federal Register Notice along with a direct link for comments see here .

In what must be an unprecedented move, the State Department only provided public notice about the CPAC hearing the same day it published Yemen's Article 9 request.  While summaries of the requests are promised, none have yet been provided, making intelligent comment even more difficult.

Yemen's request should be controversial.  Yemen is involved in a three way civil war.  Its government and its Saudi allies stand accused of intentionally targeting cultural sites, including bombing the Dhamar Museum into dust. This raises questions whether the Yemeni government has "unclean hands" and whether artifacts should be repatriated to a war zone.  There are also other moral issues related to whether the United States Government should recognize Yemeni government rights to artifacts of displaced Jewish and Christian populations.  Under the circumstances, one has to wonder whether the short comment period is designed to keep potentially embarrassing comments about the merits of the Yemeni request to a minimum.

Addendum (10-7-19):  Additional information, including a Public Summary of the Yemeni request, can be found here.

Congressional Appropriators Hold State Department, CPAC and Source Countries Accountable

The House of Representatives has used the appropriations process to highlight the need for the State Department and the Cultural Property Advisory Committee to hold countries with MOUs with the United States accountable for spending adequate sums to protect their own cultural patrimony as a precondition for receiving continued US assistance.  For more, see here.  It's long past time for such a message to be sent.  If source countries are poor stewards for what they already have, why repatriate more objects under the misapprehension they will be properly studied, preserved and displayed?

Egyptian Dictatorship Plays the Victim Once Again

As the Sisi dicatorship and  its apologists would have it, Egypt is a victim trying to reclaim its cultural heritage from rich, foreign collectors.  Yet, others suggest the real problems are endemic corruption, a Pharonic approach to cultural heritage management and extreme poverty.

Cyprus: What's Wrong with This Picture?

Cypriot Government requests extension of MOU with US that authorizes the detention, seizure and repatriation of undocumented artifacts of Cypriot origin to Cyprus because they "may be stolen."  For more, see here.

Mayor of Paphos, Cyprus, accuses antiquities service of stealing artifacts; antiquities service says not stolen, just undocumented.  For more, see here.

Credulous Live Science Blames Western Collectors for the Death of Child Looters

In what must be a new low, advocates with ties to Egypt's military dictatorship have used credulous media to divert attention  from Egypt's poor cultural heritage record with inflammatory claims that Western collectors are responsible for the death of children from impoverished families that engage in looting.  And once again, the main "proof" for such claims are dubious figures billed as representing exports from Egypt but which in fact likely reflect exports of artifacts with a "country of origin" of Egypt that likely have been out of the country for years.  Coin collectors-- who have raised serious concerns about Egypt's problematical MOU request-- get special mention, again based on a dubious assumption that an increase in trade in gold coins must mean there has been more looting of Egyptian archaeological sites.  Of course, it's just as likely that the small overall increase in trade in antique gold coins with a country of origin of Egypt (at least compared to the immense number of gold coins that must be on the international market) relates to modern issues from the 19th century and earlier as opposed to ancient coins that originated in buried hoards.

Italy Squanders 150 Million Euros in Grant Money

More evidence, if any were needed, that MOU's won't cure  what really ails places like Italy.

State Department Expresses Qualms Over Liberation of Palmyra from ISIS

Russian propagandists are having a field day with our State Department's apparent indifference to the Assad regime's liberation of Palmyra and its scarred  UNESCO World Heritage Site from ISIS.

CPO is a bit puzzled by the State Department stance given all the emphasis that has been placed on "saving" Syrian cultural patrimony.   And, isn't the point of the State Department Bureau of Educational and Cultural Affairs sponsored HR 1493 to repatriate undocumented Syrian cultural artifacts to the same Assad regime anyway?

CPO has serious qualms about repatriating any undocumented artifacts to the Assad regime because of its own part in destroying and looting Syrian cultural patrimony, but, even so, we should all be happy if ISIS is driven away from Palmyra given all the destruction it has caused to the ancient city and death it has visited on the city's modern inhabitants.

Update (3/28/16):  The State Department has issued a clarification.  The State Department now indicates despite its opposition to Assad, it welcomes Palmyra's liberation from ISIS.

As Cultural Bureaucrats, Culture Cops and Archaeologists Party-- Questions Linger about MOU with Italy

On March 23, 2016, the Italian Embassy will be hosting a party to celebrate (a bit late) the 15th anniversary of Italy's MOU with the United States.

Speakers will include the Italian Ambassador, Evan Ryan, the Assistant Secretary of the State Department's Bureau of Educational and Cultural Affairs, as well as representatives of the Archaeological Institute of America, the Carabiniri Command for Safeguarding Cultural Patrimony, Homeland Security Investigations and the Italian Ministry of Culture, i.e., the bureaucracies, police forces and archaeological groups that have benefited most from the agreement.

There will surely be no mention of the fact that 94% of the public comments received by CPAC were either opposed to the renewal of the MOU or continued import restrictions on historical coins of the sort widely collected within Italy itself.  Nor any discussion of the limited benefits of the MOU to American citizens, who, after all, have had to pay substantial admissions fees to visit museum exhibits hyped as "cultural exchange" under its terms.

Nor presumably will there be any discussion about the poor state of Italy's monuments or the gross under funding, corruption and bureaucratic malfeasance that has caused it.

After all, why spoil a good time?

More Cultural Racketeering In Egypt

Egyptian authorities are belatedly investigating the disappearence of 157 objects from Saqquara.  The Antiquities Coalition has yet to comment on such cultural racketeering  and the distinct possibility that high level insiders are involved.  Hopefully, this will not be yet another case where investigations of high level officials go nowhere. As CPO has previously observed, grandstanding is easy, but taking real care of one's cultural heritage is hard.

Jordanian Authorities Disclose Coin Thefts 15 Years After the Fact

Jordan's Prime Minister has disclosed that fakes were switched for genuine ancient coins at museums around the country back in 2001-2002.  This revelation follows another embarrassing discovery that more fakes were switched for real coins at the Citadel Museum in Amman.  Any relationship between the thefts is unclear as is the failure to take additional security precautions at other museums after the 2001-2002 thefts were discovered and referred to judicial authorities.

Grandstanding is easy, but taking real care of one's cultural heritage is hard.  Hopefully, although it's very late in the day, Jordanian authorities will investigate what must be an inside job, publish pictures of  what was stolen so that the legitimate trade can possibly help recover the coins, and, of course, put security measures into place to help keep the same thing from happening again.

Climate of Fear

The Egyptian military dictatorship has charged museum employees involved in a botched restoration of the world famous Tut gold burial mask.  The criminal charges come after months of denials about severity of damage to the artifact.

It's likely the group tried to cover up their mistake because of fear of Egypt's military rulers.  In a less harsh system, the initial problem with the mask's beard would likely have been reported rather than covered up with a amateurish restoration job.  And no doubt those responsible would have been fired, but not be subjected to criminal punishment.

Is the death penalty out of the question in Sissi's Egypt?  Others who have done far less to insult the State have already received such a sentence.

Scapegoating

While Egyptian officials blame  locals for the abysmal state of  important archaeological sites  in the country, cultural heritage lobbyists with ties to the Egyptian government are once again scapegoating collectors for the rise of ISIS.  Perhaps the real problem, however, is that Arab dictators have appropriated early civilizations for their own nationalistic purposes, making antiquities a target for disaffected individuals and groups.

Reality

The reality of how archaeological sites are treated in places like Iraq again should raise questions concerning whether nation states are the best stewards "cultural property."  Iraq, of course, remains mired in war, but Uruk is such an important site one have hoped it would receive better care.

Poor Security in Scotland's Museums

Poor security in Scotland's Museums has evidently encouraged thieves or corrupt insiders to steal some valuable coins.  It's unclear of the coins had been previously photographed.  If so, it will make them much easier to recover.

Consider the Source

This blog is up front.  It reflects the views of collectors.  But that's not the case for major sources for claims about looting in Syria.  Each source has interests and agendas not always apparent from news coverage or archaeological blogs that rely on such information (often without clear attribution).    That's not to say what these sources say is necessarily 100% false.  Rather,  just that its always a good idea to consider the source in assessing the information.

The Assad Regime-- The Assad Regime is a major source of information for others, particularly archaeological blogs.  The problem is pure propaganda.   As Syrian government officials would have it, ISIS is always to blame for all damage to Syrian cultural patrimony.  In contrast, brave Syrian cultural officials are always doing their best to protect Syrian cultural patrimony from destruction and looting.  The latter may or may not be based on fact, but the former is pure nonsense.  ISIS is an awful plague on the people of Syria and its cultural patrimony, but Assad's military has done its fair share of bombing cultural sites into dust.  Moreover, the Syrian military has certainly been involved in looting and otherwise damaging the major sites of Palmyra and Apamea before they fell to rebels.  And, of course, let's not forget Assad is wholly responsible for crushing a largely peaceful movement and thereby starting a full fledged civil war.

UNESCO-  UNESCO is run by a former Bulgarian Communist (now Socialist) and its pronouncements reflect a state ownership approach that ignores the rights of individuals, ethnic and religious groups.  Not surprisingly, UNESCO supports repatriation of artifacts to Assad in the midst of a civil war despite the Assad regime's poor stewardship and even purposeful destruction of cultural artfiacts.

American Schools for Oriental Research (ASOR) and the State Department's Syrian Heritage Initiative--   Potential conflict of interest is the problem here.   The State Department awarded a $600,000 contract to ASOR, an organization that takes a dim view of private collecting.  Furthermore, the contract seeks to help raise public awareness about looting in war torn Iraq and Syria at the very same time both the State Department and ASOR are lobbying Congress to impose what amounts to permanent import restrictions on all Syrian cultural goods and create a new bureaucracy within the State Department.  Enough said.

Palmyra Exhibit Poses Important Questions

The Smithsonian's Sackler Gallery is putting a magnificent portrait bust removed from a tomb in Palmyra on display to help raise awareness about danger to the site posed by ISIS.  While the Smithsonian (a major proponent of HR 1493 and its creation of a new bureaucracy in the State Department), may hope the exhibit will jump start the bill which appears to have lost some momentum in the Senate, CPO wonders if it will all backfire.  After all, won't it all just help underscore the fact that cultural diffusion helps preserve artifacts while concentration through repatriation only puts them further at risk, at least where a  civil war is going on?

"Italian" Coin Seizure: More to Come?

US Customs is bragging to the press about its seizure of Roman coins the importer "misrepresented" came from the Middle East when "everyone" knows "Roman" means "Italian."  But from the pictures, the coins appear to be from the 4th C. at which time Rome had mints in the "Middle East." Moreover, it's  quite likely the importer was being truthful about what he knew about their find spot.  So, this could very well be yet another case of Customs overreach that is not contested in court because the low value of items that are seized and the high cost of legal services.

US Customs promises to "repatriate" the coins (estimated value $1,000) to the Italian Government at a future date.  What the Italians will do with them remains to be seen, but CPO suspects they would be better off in collector's trays than dumped unwanted on Italy's grossly underfunded and corrupt cultural bureaucracy.

CPO is even more concerned that such questionable seizures will multiply if HR 1493, a bill meant to ramp up customs enforcement, becomes law.  There is already enough abuses visited on small businesses and collectors by overzealous Customs officers.  We need to encourage fairness and strict adherence to law,  not "getting a seizure" to "get more press."

More artifacts repatriated to a war zone

The Assad regime is reporting that neighboring countries have repatriated some 65,000 artifacts to the Syrian government.  It's unclear if the items were looted by ISIS, Assad, the Free Syrian Army or confiscated from hapless refugees.  What is clear is that by repatriating them to war-torn Syria they are again being put in danger.