Sector Insights: Coins as Cultural Goods: Promoting Conservation Over State Control in Low End Markets for Art and Cultural Goods (Palgrave MacMillian 2026)

 CPO is honored to publish his views on coins as cultural goods in an open access book funded by the European Union entitled,  Low-End Markets for Art and Cultural Goods (Palgrave Macmillan 2026).

From the abstract,
This chapter argues that historical coins, due to large mintages and significant survival rates, are best preserved and studied through private collecting and a robust numismatic trade rather than state control. Current regulatory schemes, including restrictive import and export controls in the United States and European Union, are overly burdensome and impractical, especially given the lack of provenance for many coins. The chapter critiques these regulations for undermining legitimate collecting and numismatic scholarship while offering limited benefits to cultural heritage preservation. Instead, it promotes a model based on the United Kingdom’s Portable Antiquities Scheme and Treasure Act, which encourages responsible reporting of finds and cooperation among finders, collectors, and institutions. As a result, we have a much better picture of early British economic history. The chapter concludes that policies emphasizing conservation and collaborative stewardship serve both cultural heritage and scholarly inquiry far more effectively than rigid governmental controls.

For the chapter, see https://link.springer.com/chapter/10.1007/978-3-032-27566-0_24

and https://rdcu.be/fxRiF

CPAC meets to discuss new Cultural Property Agreement with Romania and Renewals with Albania and Nigeria

 On July 14, 2026, the US Cultural Property Advisory Committee (CPAC) met in a virtual public session to accept comments regarding a proposed Cultural Property Agreement with Romania and renewals with Albania and Nigeria.

The State Department described these requests as follows:

Romania 

The Government of Romania seeks protection for archaeological materials from approximately 2 million years ago to A.D. 1800, and ethnological material from approximately the beginning of the 4th century A.D. to A.D. 1800.  Archaeological material is from the following periods:  Paleolithic, Neolithic, Chalcolithic, Bronze Age, Iron Age (including Dacian, Thracian, Archaic-Classical Greek, Hellenistic, and Roman Republic periods), Early Roman Empire, Late Roman Empire, Migration Periods/Early Middle Ages, Middle Ages/Byzantine/Ottoman periods, Renaissance/Early Modern periods, and the Modern period, and includes objects made from stone, metal, ceramic, bone, ivory, horn, wood, other organic materials, glass and faience, textiles, documents, and paintings.  Ethnological material is from the Late Roman Empire, Migration Periods/Early Middle Ages, Middle Ages/Byzantine/Ottoman periods, and Renaissance/Early Modern periods, and includes objects made from stone, metal, ceramic, bone, horn, ivory, wood, glass, textiles and garments, documents and archives, paintings, and mosaics. 

Albania 

Extending the Albania MOU would continue import restrictions on categories of archaeological material ranging in date from approximately 300,000 years ago to A.D. 1750, and ethnological material ranging in date from approximately A.D. 400 to 1913. 

Nigeria 

Extending the Nigeria MOU would continue import restrictions on categories of archaeological material ranging in date from approximately 1500 B.C. to A.D. 1770, and ethnological material ranging in date from approximately A.D. 200 to the early 20th century A.D. 

See  https://www.state.gov/cultural-property-advisory-committee-meeting-July-14-16-2026/  

The meeting was conducted entirely on Zoom.  None of the CPAC or ECA staff identified themselves to the speakers, so it was difficult to confirm who attended the meeting.

Nevertheless, based images from the Zoom platform, the following members (all appointed by President Biden) appeared to be present:  (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) and; (7) Cynthia Herbert (Represents/Expertise: International Sale of Cultural Property President, Appretium Appraisal Services LLC, Connecticut).

In contrast, the following members appeared to be absent: (8) Amy Cappellazzo, Represents/Expertise: International Sale of Cultural Property, Principal, Art Intelligence Global; (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)).

There were also Bureau of Educational and Cultural Affairs (ECA) Cultural Heritage Center staff present, presumably including Glen Davis, Director of the Cultural Heritage Center and Andrew Zonderman, who is serving as CPAC’s Executive Director.  

The Chair, Alexandra Jones, welcomed the speakers.  She thanked the speakers for attending, and then indicated that speakers should try to limit themselves to 4 minutes and 30 seconds  each given the number of presenters. 

Dr. Ömür Harmanşah spoke as the Vice President for Cultural Heritage, Archaeological Institute of America (AIA).  He first provided some background about the organization.  The AIA currently has 150,000 members, a figure that includes not only professional archaeologists, but others interested in archaeology, including subscribers to the AIA’s magazine.   The AIA supports all three Cultural Property Agreements (CPAs).  He notes Romania and Albania have hosted American archaeologists and have offered museum loans. Moreover, both countries face continuing problems with looting.  For example, an important helmet excavated in Romania was stolen from a museum in the Netherlands and the AIA’s letter references a report about looting in Albania. While there has been less collaboration with Nigeria, an American archaeologist was recently awarded with a grant to study glass production in Nigeria.

Here are links to the AIA’s written comments:

Albania: https://www.regulations.gov/comment/DOS-2026-0628-0066

Nigeria:  https://www.regulations.gov/comment/DOS-2026-0628-0068

Romania:  https://www.regulations.gov/comment/DOS-2026-0628-0067

Elias Geraoulis spoke as the Executive Director of the Global Heritage Alliance (GHA).  Gerasoulis focused his oral testimony on Nigeria.  He urged the Committee to reject or pause extension of a CPA.  He believes this CPA must be examined in light of pressing issues pertaining to U.S.-Nigeria relations.  He noted that the Trump Administration and Congress have expressed grave concerns about religious persecution and human rights abuses in the country, including mass killings of Christians. He believes Nigeria is a failed state with much of the North currently under the control of terrorist organizations such as Boko Haram.  He further noted that other armed groups have moved from the North southward with parts of the army being compromised as well.  He further argued that Nigeria is a failed state, and that should raise questions about the safety of any cultural objects which may be repatriated there. 

CPAC member Nii Otokunor  Quarcoopome questioned whether Christians are really being targeted and argued that CPAC in any case should not address any such concerns in the context of deliberating about at CPA.   

Elias Gerasoulis countered that he based his testimony on statements of members of Congress and the Administration.  His view is that any renewal must be considered in the context of current diplomatic relations with Nigeria.

Teresa Ngan is a student associated with the Oregon Archaeological Society.  She believes that CPAs are necessary to protect our understanding of Romanian and Albanian archaeology.  She shared her screen to show images of various artifacts, including inscriptions and jewelry.  She argued that CPAs are necessary to protect both archaeological context and our knowledge of ancient societies.

Peter Tompa spoke next as the Executive Director of the International association of Professional Numismatists (IAPN).  He noted that IAPN had submitted comments on all the proposed CPAs, but focused his words on the new CPA with Romania and the renewal with Albania.  He first noted that the “designated list” for Albania ignored numismatic research submitted by IAPN, was grossly overbroad, and that efforts to limit it to coins that “circulated primarily” in Albania did not comply with the “fair notice” requirements of the Cultural Property Implementation Act (CPIA).  With regard to Romania, he indicated that the vast majority of coins that circulated there also circulated regionally and internationally, making it impossible to “assume” that they were “first discovered” within Romania, and hence were subject to Romanian export control.  He then reminded the Committee that Transylvanian coins are neither archaeological nor ethnological objects under the CPIA and are considered “Hungarian” rather than “Romanian”  in numismatic literature.

 He next focused in on the failure of the State Department to recognize that the EU has comprehensive export rules which are binding on all member states that allow these countries to export coins and other artifacts with or without an export permit according to local law.  He further indicated that the failure to recognize EU rules would lead to ridiculous results.  In particular, if the State Department again imposes an embargo on the import of virtually all coins made before 1750, that could include Hungarian and Austro- Hungarian (Hapsburg) Empire coins simply because in addition to circulating in Austria, Hungary, and a number of other countries, they also circulated heavily in Transylvania, now a Romanian province since 1920.  Thus, we could have a situation where an American collector could legally purchase and export such a Hungarian or Austro-Hungarian coin from Austria or Hungary consistent with EU law, but Customs could still seize it under a CPA with Romania for no other reason that it was of a type found on the “designated list” for Romania.

CPAC member Alex Barker questioned Tompa.  He took the position that the US should ignore these rules because any CPA is with Romania not the EU and Romania’s own rules do not normally allow for the export of even common coins.   Tompa responded by noting that the EU has its own rules which allow Romania to ask for the return of illicitly excavated materials and that IAPN’s concerns were particularly warranted given the way US Customs and Border Protection (CBP) enforces CPAs as embargos based on coin types alone without any probable cause that any particular coin that is seized was illicitly removed from a given country with a CPA after the effective date of any import regulations.

Here are links to IAPN’s written comments:

Albania:  https://www.regulations.gov/comment/DOS-2026-0628-0020

Nigeria: https://www.regulations.gov/comment/DOS-2026-0628-0022

Romania:  https://www.regulations.gov/comment/DOS-2026-0628-0021

Here are Tompa’s oral comments:  https://culturalpropertyobserver.blogspot.com/2026/07/yes-cpac-there-is-eu-and-its-member.html

In addition, here are his personal comments:

https://www.regulations.gov/comment/DOS-2026-0628-0034

Kate FitzGibbon next spoke on behalf of the Committee for Cultural Policy (CCP)  She first noted that the CCP had uploaded specific comments on all three CPAs, but she wanted to speak more generally about the concerns CCP and others have about the trajectory such agreements are taking.  She noted that before decision making was folded into the State Department, there were only limited numbers of such agreements and they never covered such wide ranges of materials.  The numbers of CPAs have grown exponentially from 13 in 2010 to 36 today, with more pending every year.  Moreover, the scope of the designated lists has grown as well, with it now being common for such lists to encompass 1 million years of cultural heritage, including items made for trade as well as ecclesiastical objects and folk art.  FitzGibbon argues that the claim the whole material culture of a given country is subject to pillage is dubious at best and that CPAs have been granted in all cases even though it is doubtful that all four required determinations have been actually met.

She further indicated that overbroad CPAs and designated lists have had a chilling effect on museums, collectors, and the legitimate trade whereas Mark Feldman, the State Department’s chief architect for the CPIA, has indicated that Congressional intent sought a balanced approach to only address serious concerns about the looting of archaeological and ethnological objects of cultural significance.   She noted that trade statistics demonstrate that there is not much imported from Romania.  She further indicated that Romania spends little on protecting its cultural heritage, and much of that is used to pay awards to metal detectorists for their finds.   She also indicated that there are serious minority issues that must be considered in Romania relating to Hungarians and the Roma and in Nigeria with regard to Benin bronzes.  With regard to the Benin bronzes, they have been returned to the hereditary Oba whose ancestors enslaved Africans without any acknowledgment of this history or the interests of American descendants of slaves in this issue.

Here are the CCP/GHA comments:

Albania:  https://www.regulations.gov/comment/DOS-2026-0628-0061

Nigeria: https://www.regulations.gov/comment/DOS-2026-0628-0060

Romania:  https://www.regulations.gov/comment/DOS-2026-0628-0062

Michael Galaty of the University of Michigan has worked in Albania for his entire career.  He has seen burial grounds decimated.  Metal detecting is a major problem. He has been offered coins by children. Some metal detectorists are hobbyists, but he believes a lot of what is found is smuggled into the European Union. 

Miriam Stark asks Galaty if coins can be excavated without damaging archaeological context.  He indicates that is impossible.

[CPO Note:  IAPN’s written comments indicated that only the very few coins found in “secure contexts” at archeological sites are useful for dating purposes.  It also indicated that Romanian law allows metal detecting and has instituted a system of awards for metal detectorists that turn in their finds.]

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

https://www.regulations.gov/comment/DOS-2026-0628-0047

Brittany Kyle is a Professor at the University of Northern Colorado.  She has studied human skeletons to investigate how Greek and native populations interacted in the ancient world. Her work has taken her to Albania to investigate how Greek colonists at Apollonia interacted with local Illyrians.  She has worked with American and Armenian students in this capacity.

Guards at a site in Apollonia tried to sell Kyle coins.  [CPO Note:  Doesn’t this instead suggest that foreign archaeological missions investing in site security and paying guards a fair living wage may be a solution?]   Prior work at Himara in Sicily shows the importance of coins from documented find spots.  There, coins were found in the mouths of skeletons as payment to the ferryman to cross the River Styx.  Had those coins been removed by looters, that evidence and the story they tell would have been lost forever.

Dr. Kyle’s written testimony may be found here:  https://www.regulations.gov/comment/DOS-2026-0628-0036

Deadria Farmer-Paellmann spoke on behalf of the Restitution Study Group.  The Restitution Study Group has worked for the past 25 years on issues of reparatory justice relating to the transatlantic slavery trade.  The Restitution Study Group supports protecting Nigerian cultural heritage but asks CPAC to strengthen cultural property policy by recognizing all communities whose histories are materially embedded within Nigerian cultural heritage.  Specifically, the Benin bronzes represent a unique circumstance. They represent both art and crimes against humanity perpetrated by the Kingdom of Benin working with European slave traders.  During this period, 50 bronze manilla currency bracelets were used to purchase a woman and 57 to purchase a man.  Scientific analysis has now demonstrated that many Benin Bronzes were cast from brass consistent with the composition of these manillas.  It is important that the descendants of the slaves purchased with these manillas be made part of the conversation.  She asked  the any CPA with Nigeria take into account the Restitution Study Group’s recommendations meant to preserve this history, which has been rejected by the Smithsonian Institution and other museums in the rush to repatriate Benin bronzes to Nigeria.   

The Restitution Study Group’s written testimony can be found here: 

https://www.regulations.gov/comment/DOS-2026-0628-0050

The Hon. Ogechukwu Nkere is a human rights activist and is serving as the Prime Minister of the Biafran Government in Exile (BRGIE). Mr. Nkere recounted the suffering of the Biafran people during the Civil War between 1966 and 1970 which took the lives of 3 million Biafrans, mostly due to forced starvation.  More recently the Biafran people, who are Christians, have been subject to a Nigerian government campaign of torture, extrajudicial killings, and disappearances.  Mr. Nkere cited statements from President Trump condemning these actions and noted that any CPA with Nigeria should be put on hold until Nigeria aligns with US policy regarding Biafra. 

Dr. Scott MacEachern spoke for the Society for American Archeology.  He supports an extension of the current CPA with Nigeria.  He has worked in Nigeria since the 1990s. His primary fieldwork site has unfortunately been overrun by Boko Haram terrorists. Boko Haram primarily attacks Muslim communities that are considered heretics.  There isn’t necessarily a correlation between terrorism and looting.  So far, Boko Haram does not appear to be interested in exploiting antiquities.  Instead, others focus on objects from the Nok and Benin cultures as items to loot. Bilateral agreements are the primary instrument for fighting illegal networks.

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

https://www.regulations.gov/comment/DOS-2026-0628-0056

Stephen Knerly represents the Association of Art Museum Directors (AAMD).  AAMD offered qualified support for the extension of the CPA with Nigeria.  He indicated any renewal should promote opportunities for American museum goers to interact with the many diverse and important cultures of Nigeria.  As a result, museums must look to loans from source countries like Nigeria if they are to fulfill their mission of bringing the world's cultures to the public.  While there appears to be some interest from Nigerian officials in providing such loans, the process lacks predictability and standard practices. Improvements to the status quo can be promoted as a condition for any renewal.   Issues include who has authority to make loans, what documents can be used for such transactions, and what immunity arrangements may be worked out to foster such loans.  Formerly, such issues were addressed on a case by case basis in each agreement, but recently the ability to do so has been lost with the creation of standardized CPAs.

The AAMD’s written comments can be found here:

https://www.regulations.gov/comment/DOS-2026-0628-0040

Adam Rabinowitz is an associate professor at the University of Texas.   He spoke on his own behalf as a field archaeologist who has been working in Romania for the last 10 years.

He wanted to second the AIA’s testimony about the interest in Romanian material on the illicit market for antiquities.  He gave as an example a helmet and three gold bracelets stolen from a Dutch museum which were subsequently recovered.  (CPO note:  Such material would be considered “stolen” under US and International law even without a CPA.)  He is also familiar with illicit excavations noting that metal detectors are used to recover coin hoards.  (CPO note:  Metal detecting is legal in Romania with Romanian authorities paying finders awards.)

Rabinowitz is working with a numismatist at the Museum of National History and archaeology in Constanța on the coins that we excavated at an archaeological site. He also has a project about trade currency that appears frequently on the international coin market. He believes Romanian authorities are doing their best to preserve heritage and enforce existing laws.

Professor Rabinowitz’s written comments can be found here:

https://www.regulations.gov/comment/DOS-2026-0628-0054

Vivien Bence speaks on behalf of the Hungarian Human Rights Foundation (HHRF).  She asked that the Romanian request be rejected if any restrictions are to apply to Transylvanian or Hungarian items as that would in effect recognize Romanian government ownership and control over the cultural heritage of the Hungarian diaspora. 

The HHRF has monitored the rights of ethnic Hungarian minorities in Eastern Europe since 1976, with particular focus on Romania as the home to a 1.1 million strong Hungarian community.  This community has suffered since Transylvania was forcibly incorporated into Romania from Hungary in 1920.  Although it has been almost 40 years since the fall of Communism, the Romanian government has delayed returning property confiscated from Hungarian interests during this period.  The HHRF is especially concerned about the Batthyaneum Library and Astronomical Observatory and its priceless collection of rare manuscripts. The Romanian state has ignored domestic laws and European Union decisions ordering the return the building and the Library’s contents to its legitimate owner, the Alba Iulia Catholic Archdiocese.  The HHRF called on CPAC  to recommend that the State Department condition any CPA  with Romania on an assurance that Romania will return objects belonging to the Batthyaneum Library and other significant cultural institutions that were unlawfully expropriated from the autochthonous Hungarian national minority to representatives of that community within Romania.

The HHRF’s written comments can be found here:

https://www.regulations.gov/comment/DOS-2026-0628-0045

John O’Shea speaks on behalf of the Society for American Archaeology.   He has worked in the Tri national boundary area of Romania Serbia and Hungary since 1976  so he has some perspective  how regimes have changed and how the rules have changed. In 1989, it was unthinkable there would be a collaborative project involving both Hungary and Romania.  Because both Hungary and Romania are part of the Schengen zone of the EU, it is relatively easy for traffickers to move material.  (CPO note:  EU rules provide for law enforcement cooperation between borders and the area is well policed against traffickers in cultural property.) 

Metal detecting is a huge issue particularly because of artifacts produced during the Roman and Medieval eras. Because again of the Schengen zone connection Romania is not only the subject of looting but it's also becoming a node in the international movement of illicit cultural property. 

One of the big problems with the funding is that young professionals that are graduating from school don't see a future in cultural heritage protection in Romania and they immigrate to in Germany. EU funding is critical as is the EU regulations and the CPA with the US.  O’Shea indicated that he did not want the US to become a loophole in this system.

Another concern is that “trafficking” is a charge that is used against archaeologists in Romania to derail careers.  There needs to be a better way to facilitate the legal export of archaeological materials for study purposes.

After this testimony, the Chair thanked everyone for their public testimony and close the public session. 

Yes, CPAC there is a EU and Its Member States Allow Exports of Historical Coins

 Here is what I said today, more or less, during the public session of the Cultural Property Advisory Committee to discuss a proposed Cultural Property Agreement with Romania, and renewals with Albania and Nigeria.

        Thank you for this opportunity to speak on behalf of the small and micro businesses of the International Association of Professional Numismatists, including IAPN member firms in both the US and European Union.

          IAPN has submitted detailed comments on the proposed CPA with Romania and the renewal with Albania along with a short comment on Nigeria. First, let me highlight a few issues related to Albania and Romania.  The Albanian comments point out that the current grossly overbroad designated list ignores the extensive numismatic research IAPN provided about the broad circulation of Illyrian coins and that the “circulated primarily” standard referenced in current restrictions fails to provide importers with the fair notice required under 19 USC Section 2604 as to what coins are actually covered.  The Romanian comments similarly discuss that coins that are found in Romania also circulated regionally and internationally.  It also notes that the Transylvanian coins struck there are neither archaeological nor ethnological objects, and are more properly considered “Hungarian” than “Romanian.”  

          Now let me focus on another important point that has been raised multiple times before only to be ignored.  This issue relates to one of the necessary findings CPAC must make about “less drastic” measures under 19 USC Section 2602(a) (1) (C) (ii) before any import restrictions on coins or other artifacts may be imposed.   In particular, CPAC, the State Department, and US Customs and Border Protection (CPB) must recognize that any legal export from one European Union (EU) country is also binding on other EU members.

          Claims that any CPA is with “Romania” not with the “EU” fall flat when one recognizes Romania’s own export controls are part of an integrated system that recognizes the rights of each EU member state to export cultural goods with or without a permit according to local law.^[1] 

          The applicable provision, Council Regulation (EC) No 116/2009, and in particular, Article 2.2 authorizes all EU countries to export ancient and early modern coins that may appear on “designated lists” for Romania and soon Albania with an export certificate or without one as objects of limited archaeological or scientific interest. Indeed, this rule is also consistent with the EU’s recent import controls, which treat all coins not traced directly to archaeological sites as “low risk” items that only require “importer’s statements” when they are over 200 years old and valued at more than 18,000 Euros. 

          Our request can be simply accommodated by ensuring Article I of any CPAs with Romania and Albania make any import restrictions inapplicable to cultural objects legally exported from another EU country, with or without a formal export permit as required under local law. 

          The ridiculous results likely from not adopting this commonsense proposal should be obvious.  If import restrictions under a Romanian CPA are applied to the Hungarian or Austro-Hungarian coins that circulated in quantity in what is now Romanian Transylvania, CBP could detain, seize and forfeit such coins legally exported from either Austria or Hungary even though neither country has a CPA with the US and such coins are available for legal export in both countries.  As an aside, this would be particularly painful for Austrian and Hungarian Americans who purchase such coins to keep in touch with their own cultural heritage.

          So, yes, CPAC, State Department, and CPB, there is a European Union that has created a comprehensive system of import and export controls for cultural goods, and there is no rational basis to contend that it doesn’t exist.  Thank you for listening to our concerns and please let me know if you have any questions.

---

[1] See Council Regulation (EC) No 116/2009, available at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32009R0116 (last visited February 12, 2026). 

 

Time Again to Tell the Cultural Property Advisory Committee What You Think About Import Restrictions on Coins and Other Artifacts, including Minority Cultural Heritage, for Romania, Albania and Nigeria

 The State Department has announced a Cultural Property Advisory Committee (CPAC) Meeting to consider a new Cultural Property Agreement (CPA) with Romania and renewals of current CPAs with Albania and Nigeria. 

CPAC will hold a session open to the public on July 14, 2026, at 2:00 PM. 

The State Department’s announcement can be found here:  https://www.state.gov/cultural-property-advisory-committee-meeting-July-14-16-2026/   The formal Federal Register notice can be found here:  https://www.federalregister.gov/documents/2026/06/04/2026-11197/notice-of-meeting-of-the-cultural-property-advisory-committee-proposals-to-extend-bilateral-cultural

 The State Department is also soliciting written comments on the Regulations.gov website: https://www.regulations.gov/document/DOS-2026-0628-0001. If the link does not work, go to www.regulations.gov and search for docket number: DOS-2026-0628. Written comments and requests to testify are due on or before July 5, 2026, the day after our country’s 250^th anniversary celebrations. 

Issues for Coin Collectors

The big issues for coin collectors are grossly overbroad designated lists.  Past import restrictions on "Albanian coins" demonstrate the scope of the problem. Recent import restrictions have taken a maximalist approach that "designates" virtually all coin types that may have circulated within a given country down to the mid-18th Century, including many coin types that circulated regionally or internationally in bulk.  Once "designated," under current procedures US Customs and Border Protection (CPB) can "assume" such coins were illicitly exported from that country, even where they were legitimately bought, sold and legally exported from our major trading partners in the European Union (EU).   

The issue is even more egregious for EU countries like Romania and prospective EU members like Albania.  EU law binding on EU countries recognizes the rights of EU countries to export cultural goods. Yet, CPB will detain, seize and repatriate coins and other artifacts to EU countries with CPAs with the US, including Bulgaria, Cyprus, Greece and Italy, even where they are legally exported from other EU countries like Germany with or without an export permit as permitted under local law.  It is as if the State Department and CBP do not believe the EU exists! 

The other big issue relates to enforcement.  Unfortunately, in the only case that addressed the issue, courts in the US Fourth Circuit gave Customs a “green light” to detain, seize and repatriate coins for no other reason that they were of types on a “designated list” for import restrictions.  This puts collectors importing such coins at risk because it is often difficult, if not impossible, to produce the documentation necessary for legal import under current “safe harbor” procedures.

Issues for Dispossessed Minority Communities

Another major issue is CPAs being used to gain US government recognition of foreign government rights to the cultural heritage of displaced minority populations, most recently for Turkey.  Here, it is likely Romania will use this CPA to gain US approval for its control over the cultural heritage of its displaced Hungarian population from Transylvania.   Moreover, a renewal of the CPA with Nigeria raises similar issues for Biafrans and other minority groups within that country. 

Despite the ever-increasing number of overlapping import restrictions on coins, it is still important to comment, for no other reason that without public comment State Department bureaucrats could claim to political appointees that restrictions on coins are “not controversial.”  What should you say? It is better to write in your own words about how import restrictions hurt your ability to access coins and learn more about other cultures or even to get in touch with your own cultural heritage.  However, here is a model for coin collectors to consider:

Please do not place new or renew import restrictions on collector’s coins that prioritize “soft power” over the due process and private property rights of American coin collectors.  If you nonetheless enter into a new CPA with Romania and renew the prior agreement with Albania, please ensure that any designated lists are rewritten so that it is absolutely clear that they do not impact coins that widely circulated or those legitimately imported from legal markets abroad, particularly those in Europe.  Also, please do not put new restrictions on coins from Nigeria.  Nigeria only used coins in recent times so that such coins cannot be considered either archaeological or ethnological objects under the governing legislation.  Coin collecting is a hobby that promotes cultural understanding and relationships with collectors abroad.  It is troubling that the State Department Bureau of Cultural Affairs is behind efforts that do considerable damage to a hobby that actually promotes the cultural understanding the Bureau aims to foster.

 

Not MAGA: State Department Cultural Heritage Center Plans More Giveaways to Foreign Governments, this Time Romania, Albania and Nigeria

Today's  Federal Register has announced that the Cultural Property Advisory Committee, made up entirely of  Biden appointees, will consider a new Cultural Property Agreement (CPA) for Romania and renewals of current agreements with Albania and Nigeria.  

Once again, the Bureau of Educational and Cultural Affairs and its Cultural Heritage Center will be prioritizing "soft power" giveaways to foreign governments over protecting the private property and due process rights of American collectors and displaced minority populations. This time, the beneficiaries may be different, but many of the issues remain the same. 

Coin collectors will again face the prospect of having to deal with grossly overbroad import restrictions on widely collected coin types.  Past import restrictions on "Albanian coins" demonstrate the problem. Recent import restrictions have taken a maximalist approach that "designates" virtually all coin types that may have circulated within a given country down to the mid 18th Century, including many coin types that circulated regionally or internationally in bulk.  Once "designated," under current procedures US Customs and Border Protection (CPB) can "assume" such coins were illicitly exported from that country, even where they were legitimately bought, sold and legally exported from our major trading partners in the European Union  (EU).   The issue is even more egregious for EU countries like Romania.  EU law binding on EU countries recognizes the rights of EU countries to export cultural goods. Yet, CPB will detain, seize and repatriate coins and other artifacts to EU countries with CPAs with the US, including Bulgaria, Cyprus, Greece and Italy, even where they are legally exported from other EU countries like Germany with or without an export permit as permitted under local law.  It's as if the State Department and CBP do not believe the EU exists! 

Another major issue is CPAs being used to gain US government recognition of foreign government rights to the cultural heritage of displaced minority populations, most recently for Turkey.  Here, it is likely Romania will use this CPA to gain US approval for its control over the cultural heritage of its displaced Hungarian population from Transylvania.   Moreover, a renewal of the CPA with Nigeria raises similar issues for Biafrans and other minority groups within that country. 

Adding insult to injury injury, the State Department requires public comments about these CPAs be made on or before July 5, 2026, the day after our country's 250th Anniversary of Independence.  As of this morning, the Regulations.gov docket is not yet accepting comments.  Nor does the State Department Cultural Heritage Center's website provide any promised additional information about the requests.  

Addendum (June 5, 2025):  The Cultural Heritage Center's website is now "live."  See https://www.state.gov/cultural-property-advisory-committee-meeting-July-14-16-2026/

Addendum (June 14, 2026):  The Regulations.gov website is now accepting comments here: https://www.regulations.gov/document/DOS-2026-0628-0001. 

Trump State Department Prioritizes "Soft Power" Outreach to Turkey's Authoritarian Government Over Protecting the Rights of American Collectors and Minority Groups

The Trump State Department has renewed a controversial Cultural Property Agreement with Turkey's authoritarian government over the objections of American coin collectors and representatives of displaced minorities.  The implementing regulations continue to embargo a wide variety of cultural goods made as recently as 1924, including an extensive list of ancient Greek, Roman Provincial, Byzantine and Ottoman coin types and religious objects associated with Turkey's displaced Greek, Armenian and Jewish minority communities.  This latest indication of "business as usual" once again demonstrates the need for Congress to pass HR 595, a bill to facilitate the lawful trade in historical coins, as well as to consider far more fundamental  reform legislation.  Such legislation would place guardrails on the regulatory process and enforcement efforts to help protect the private property rights of collectors and minority communities.  

Business as Usual at the Cultural Heritage Center

Despite the Trump Administration’s often painful “disruption” of the State Department and its workforce in support of its “America First” agenda, two bits of news suggest that it’s still “business as usual” at the State Department Bureau of Educational and Cultural Affairs and its Cultural Heritage Center. Moreover, instead of merely completing Biden Administration initiatives, the Trump State Department has instead doubled down on furthering the anti-collector status quo as a "soft power" measure. 

First, the Greek City Times has reported that the State Department has repatriated coins and other artifacts to Greece as a "sweetener" to promote a renewal of the current Cultural Property Agreement (CPA)  with the country.  Once again, though the narrative is that these repatriated items were “stolen,” they instead appear to have been seized from American collectors solely due to “missing legal documentation,” i.e., the lack of proof that they were out of Greece for at least ten years.  Even worse, once again it also appears that at least one of the items— a gold stater from Lampsacus in present day Turkey- isn’t even on the “designated list” for Greece, a mere detail for the State Department and the archaeological advocacy groups celebrating yet another round of repatriations.  And if it’s not as if the State Department wasn’t aware of these problems.  In fact, they were discussed in detail at a March 3, 2026, Cultural Property Advisory Committee meeting to consider the renewal of the CPA with Greece. 

Second, today’s Federal Register announced an extension  of highly controversial “emergency import restrictions” on behalf of Taliban Afghanistan.  Presumably, the extension will be again be billed as necessary to help “save” Afghan cultural heritage from “terrorists” even though the governing statute mandates repatriation back to the same Taliban warlords responsible for blowing up the Bamiyan Buddhas and allowing Chinese mining interests to bulldoze the important Buddhist site of Mes Aynak in search of copper ore. 

How is this possible?  Blame the State Department’s addiction to using CPAs as “soft power” measures in the hopes that even “failed states” “will like us more” as well as the continued influence of politically connected archaeological advocacy groups that also receive significant State Department funding.  Moreover, as the latest repatriation to Greece and the extension of Afghan emergency restrictions demonstrate, these efforts depend on pushing the false narrative that CPAs are only focused on keeping "stolen" materials off the market so they can be returned to their "rightful" owners.  Of course, left unsaid is that import restrictions treat all "undocumented" artifacts as "stolen" although many such artifacts legitimately bought and sold in open and legal markets abroad have been traded over and over again without such documentation or that the "rightful" owners as far as the State Department is concerned include authoritarian regimes that declare anything "old" state property. 

So, what’s the solution?  At this point, sanity can only be restored with reform legislation to place guardrails on the system to ensure that the private property and due process rights of American collectors and the trade receive at least as much consideration as foreign governments and their partner archaeological advocacy groups.  Of course, some of this can also be accomplished administratively, but only if the Trump State Department is willing to put American collectors first.