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.
Thursday, October 17, 2024
Monday, September 30, 2024
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.
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.
Tuesday, September 24, 2024
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.
Tuesday, September 10, 2024
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.
Saturday, July 27, 2024
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).
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.
Saturday, July 20, 2024
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.
Thursday, June 6, 2024
U.S. Cultural Property Advisory Committee Meeting About Proposed Cultural Property MOU Renewals with Ecuador and Jordan and a New MOU with Ukraine
On June 4, 2024, the US Cultural Property Advisory Committee (“CPAC”) met in a virtual public session to hear public comments regarding proposed renewals of Memorandums of Understanding (“MOUs”) with Ecuador and Jordan and a new proposed MOU with Ukraine. 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. See Cultural Property Advisory Committee Meeting, June 4-6, 2024, Bureau of Educational and Cultural Affairs Media Center (April 30, 2024), available at https://eca.state.gov/highlight/cultural-property-advisory-committee-meeting-june-4-6-2024
(last visited June 5, 2024). That
document indicated that neither Ecuador nor Jordan sought restrictions on
additional categories of materials. Ukraine,
however, sought restrictions on a wide variety of archaeological and
ethnological objects as follows:
Protection is sought for archaeological material from the
Paleolithic Period (approximately 1.4 million years ago) to 1774 CE, including
metal (sculpture, jewelry, weapons, coins, vessels, and horse fittings and
trappings); ceramic (sculpture, vessels, and seals); stone (sculpture,
monuments, vessels, tools, and jewelry); bone, ivory, wood, horn, and other
organic material; glass and faience; paintings and mosaics. Ethnological
materials for which protection is sought span from the Roman Period (3rd century
CE) to 1917 CE and include religious, ritual, and ecclesiastical objects; rare
books, manuscripts, and other written documents; architectural elements;
objects related to funerary rites and burials, both ritual and secular;
paintings; military material; and traditional folk clothing and textiles.
Dr. Chris Jasparro, Associate Professor in the National
Security Affairs Department and Director of the Africa Regional Studies Group
at the Naval War College, spoke first. He
indicated that a MOU with Ukraine would be an important tool to fight organized
crime and Russian aggression. Jasparro
maintained that Russian forces destroyed archaeological sites, but also looted
small items which would then enter international markets. He also indicated that a MOU could act as a
token of American support for Ukraine. He
further maintained that “stolen antiquities” were used to test smuggling routes
for other, more dangerous items. The factual
basis for this contention is unclear.
Dr. Patricial Juninska of Artyfact, an archaeological
management company, spoke next. She indicated
that 341 Kurgans or burial mounds have been damaged during the war. She believed that a MOU will demonstrate our
support for Ukraine and its efforts at preservation during a difficult time.
Dr. Sam Hardy of the Norwegian Institute for Cultural
Heritage Research (NIKU) spoke next.
He indicated that Ukraine has struggled for years against looters. Russian looting and destruction of cultural
heritage is being investigated as a war crime.
Looting incentivizes corruption. Hardy
has found social media indicating that Russian mercenaries have been trading in
antiquities. One of these individuals was pictured with Russian President Putin
and former Russian Defense Minister Shoigu.
His written testimony may be found here: https://www.regulations.gov/comment/DOS-2024-0015-0049
(last visited June 5, 2024).
https://www.regulations.gov/comment/DOS-2024-0015-0010
(last visited June 5, 2024).
https://www.regulations.gov/comment/DOS-2024-0015-0011
(last visited June 5, 2024).
https://culturalpropertyobserver.blogspot.com/2024/06/cpac-meeting-to-discuss-renewals-of.html
(last visited June 6, 2024).
https://www.regulations.gov/comment/DOS-2024-0015-0039
(last visited June 6, 2024).
https://www.regulations.gov/comment/DOS-2024-0015-0003 (Last visited June 6, 2024).
https://www.regulations.gov/comment/DOS-2024-0015-0004
(last visited June 6, 2024)
https://www.regulations.gov/comment/DOS-2024-0015-0012
(last visited June 6, 2024).
https://www.regulations.gov/comment/DOS-2024-0015-0045
(last visited June 6, 2024).
https://www.regulations.gov/comment/DOS-2024-0015-0036
(last visited June 6, 2024).
https://www.regulations.gov/comment/DOS-2024-0015-0050
(last visited June 6, 2024).
https://www.regulations.gov/comment/DOS-2024-0015-0052
(last visited June 6, 2024).
https://www.regulations.gov/comment/DOS-2024-0015-0041
(last visited June 6, 2024).
https://www.regulations.gov/comment/DOS-2024-0015-0044
(last visited June 6, 2024).
Sarah Rowe is an Associate Professor Department of
Anthropology at the University of Texas Rio Grande Valley. Professor Rowe commended Ecuador for its
efforts at community engagement including the training of local and foreign
archaeologists. She also praised the
creation of the first code of archaeological ethics for Latin America in
Ecuador as well as programs with local communities aimed at discouraging
looting.
https://www.archaeological.org/aia-submits-letters-to-u-s-cultural-property-advisory-committee/
(last visited June 6, 2024).