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/

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. 

State Department Cultural Property Advisory Committee Meeting on Cultural Property Agreement Renewals with Bolivia, Egypt and Greece

On March 3, 2026, the US Cultural Property Advisory Committee (CPAC) met in a virtual public session to accept comments regarding a proposed renewals of current Cultural Property Agreements with Bolivia, Egypt and Greece. 

The State Department described these renewals as follows:

Bolivia

Extending the Bolivia MOU would continue import restrictions on categories of archaeological material ranging in date from approximately 10,000 B.C. to 1532 A.D., and ethnological material of the Colonial and Republican periods ranging in date from 1533 A.D. to 1900 A.D.

Egypt

Extending the Egypt MOU would continue import restrictions on categories of archaeological material ranging in date from approximately 300,000 B.C. to 1750 A.D., and ethnological material ranging in date from 1517 A.D. to 1914 A.D.

Greece

Extending the Greece MOU would continue import restrictions on categories of archaeological material ranging in date from approximately 20,000 B.C. to approximately the 15th century A.D., and ecclesiastical ethnological material ranging in date from the 4th century A.D. to the 15th century A.D.

See  https://www.state.gov/cultural-property-advisory-committee-meeting-march-3-5-2026/

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

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.  Messrs. Davis and Zonderman are new to their positions.  

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

The Chair, Alexandra Jones, welcomed the speakers.  She thanked the speakers for attending, indicated that all comments had been read, and that speakers should try to limit themselves to under five minutes each given the number of presenters. 

Kate FitzGibbon spoke as the Executive Director of the Committee for Cultural Policy (CCP).  While the CCP submitted comments on all the renewals being considered, Ms. FitzGibbon focused her oral comments entirely on the Egyptian Renewal.  Here is what she stated:

Egypt’s government has not met the statutory conditions required to renew the U.S.–Egypt Memorandum of Understanding (MOU) under the CPIA - and extending U.S. import restrictions would function less as a targeted anti-looting measure than as an expansive, renewable embargo that benefits Egypt’s state narrative and tourism agenda while failing to address core preservation and governance failures.

The CPIA is also intended to benefit US museums and the public. It does not authorize generalized enforcement of another country’s cultural policy or restrictive regime; it requires factual determinations that cultural patrimony is in jeopardy from pillage, that the requesting nation is taking meaningful “self-help” measures, that import restrictions would substantially deter pillage, that less drastic remedies are unavailable, and that restrictions remain consistent with the international interest in cultural interchange for scientific, educational, and cultural purposes. Egypt’s extension request is not supported by transparent, verifiable evidence.

Egypt has heavily invested in prestige projects meant to glorify and politically brand “Pharaonic” Egypt. It has devoted a billion dollars to a flagship museum presented as a civilizational spectacle while day-to-day stewardship has lagged—particularly for archaeological sites, storerooms, inventory controls, and the heritage of Islamic, Christian, and Jewish communities. A government seeking an MOU must demonstrate basic capacities and behaviors including credible reporting about prosecutions justifying a U.S. embargo supposedly driven by demand in the United States, showing that import restrictions are a “substantial benefit” deterrent. Today, returned objects consist of small, common, low-value tourist items that entered the US decades before.

Current U.S. restrictions cover Egyptian archaeological material from roughly 300,000 B.C. to A.D. 1750 and ethnological material from A.D. 1517 to 1914, spanning many cultures, media, and object categories. This scope is far from the CPIA’s intent of targeted categories demonstrably at risk from pillage. A designated list covering stone, metal, ceramics, wood, glass, bone/ivory, leather, paper, textiles, writing, and human and animal remains—across millennia—is a generalized embargo. Categories such as coinage and “Ottoman” objects unquestionably cover objects not first found in Egypt.

Academic research shows that much Egyptian material in circulation left through licensed export, including state-operated sales up to 1983. Egypt did not retain export records, yet now claims that all were “stolen.”

Today, Egypt’s heritage policy links the Sisi government to Pharaonic grandeur, while foreign archaeological work can be conditioned on government review of publication and researchers who publish without approval may lose excavation privileges. Heritage protection is ethically and practically undermined if the requesting state also polices historical interpretation and scholarly discourse. That is completely contrary to the CPIA’s requirement that restrictions be consistent with cultural and scientific interchange.

Import restrictions risk reinforcing state appropriation of Christian, Jewish, and other minority heritage while restricting diaspora communities’ access to their own documentary and ritual history. Look at the restoration of the Ben Ezra Synagogue reopening as as a tourist site rather than a living place of worship, and the seizure and removal of documents from a genizah discovered at the Bassatine Jewish cemetery. Such actions erode the moral premise that “return to Egypt” equals restoration to rightful custodians.

Saint Catherine’s Monastery and the Sinai landscape, a UNESCO inscribed World Heritage Site has been monetized and irrevocably damaged through state-led tourism development.  Egypt’s “Great Transfiguration Project” has destroyed the integrity of a sacred, ancient, living religious site and its cultural landscape. The project is a mass-tourism remaking that threatens traditional architecture, the monastic community, local Bedouin connections to place, and the site’s environmental and spiritual character. Egypt not only ignored UNESCO’s  concerns - but a May 2025 court ruling now threatens minority religious rights across the country.  

Finally, meaningful “self-help”, as Congress intended, depends on civil society, local communities, journalists, and scholars who can monitor sites, document harms, and expose corruption – who are now severely repressed by Egypt’s government.  Formal assurances about robust Egyptian stewardship are not enough. We urge that the MOU not be renewed and that, if any renewal were considered, it should be narrowed and conditioned on measurable benchmarks including inventories, access to minority archives, transparency in enforcement, and demonstrable compliance with World Heritage requirements at Saint Catherine’s.

Here is a link to  CCP’s Comments on Bolivian Renewal:

https://www.regulations.gov/comment/DOS-2026-0133-0051

Here is a link to CCP’s Comments on Egyptian Renewal:

https://www.regulations.gov/comment/DOS-2026-0133-0054

Here is a link to CCP’s Comments on Greek Renewal:

https://www.regulations.gov/comment/DOS-2026-0133-0053

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 was chartered by Congress in 1906.  It 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 the renewal of all three Cultural Property Agreements (CPAs).  They are necessary because cultural property continues to be smuggled into the US.  One recent example was the seizure of Egyptian artifacts in Maryland.  He indicates that Bolivia, Egypt and Greece have all hosted important archaeological digs for American archaeologists.  Moreover, they have all taken important steps to protect their cultural patrimony as well as providing loans for museums. Greece recently upgraded the status of archaeological authorities within the country as a bureaucratic matter by designating them as a General Directorate. 

Here is a link to the AIA’s Comments on Bolivian Renewal:

https://www.regulations.gov/comment/DOS-2026-0133-0100

Here is a link to the AIA’s Comments on Egyptian Renewal:

https://www.regulations.gov/comment/DOS-2026-0133-0099

Here is a link to the AIA’s Comments on Greek Renewal:

https://www.regulations.gov/comment/DOS-2026-0133-0102

Teresa Ngan is a student associated with the Oregon Archaeological Society.  She espoused a Marxist view that protection and repatriation of cultural property is necessary to understand the class divisions in ancient societies. 

A link to her comments can be found here:

https://www.regulations.gov/comment/DOS-2026-0133-0069

Peter Tompa spoke next as the Executive Director of the International association of Professional Numismatists (IAPN).  Here is the substance of what he stated:

IAPN takes no position on the proposed renewals of Cultural Property Agreements with Bolivia, Egypt, and Greece, but opposes any import restrictions on coins.  Furthermore, IAPN believes that the Trump Administration must reform the system to ensure more transparency and fairness for American collectors and the trade.

There currently are no restrictions on Bolivian coins and Bolivia’s former Director General of Cultural Property has written there is no basis to impose new restrictions on Spanish Colonial and early Republican era coins that also served as legal tender in the U.S. until 1857.

In social media, the State Department has claimed, “these agreements help protect U.S. museums and collectors, support lawful trade, and deter illegal trafficking of cultural property,” but import restrictions on Egyptian and Greek coins demonstrates that narrative is misleading at best.

The current import restrictions on coins are grossly overbroad.   The Egyptian restrictions cover all coins struck in Egypt to 1750 A.D.  The Greek restrictions cover numerous coin types through the 15^th century.  One cannot assume that these coins were “first discovered within” and were “subject to export control by” Egypt and Greece, fundamental requirements of the Cultural Property Implementation Act.

The elephant in the room is that Egypt’s authoritarian rulers nationalized all antiquities in private hands in 1983 without compensation.  Before that time, there was a booming antiquities trade in Egypt, with millions of objects leaving the country legally but without the paperwork now deemed necessary to “prove” legal export.  

For coins, the situation is exacerbated because the State Department evidently latched onto the argument that Egypt had a “closed monetary system,” to justify maximalist import restrictions on all coins made in Egypt before 1750 A.D.  However, that system was meant to keep foreign coins “out,” not Egyptian coins “in.”  Moreover, despite ample scholarly evidence demonstrating that such coins circulated regionally or even internationally, the State Department simply ignored that factual record and, in the latest renewal, added restrictions on Roman Imperial, Byzantine and Ottoman coins made in Egypt.

The restrictions for Greece go well beyond what the Greek government originally requested. Greece’s Ambassador told CPAC that its request only concerned antiquities that have been found exclusively on Greek territory.  Yet, the State Department has  imposed broad restrictions on ancient and medieval coins that circulated regionally as well as internationally.  As indicated in IAPN’s comments, that  has resulted in Customs detaining and seizing coins merely because they look “Greek.”    Furthermore, those restrictions even apply to coins legally exported from Greece’s fellow European Union members despite the fact that Greece is part of the E.U.’s common export control regime.   That raises the question: Does the State Department really consider coins legally exported from the E.U. to be “trafficked” cultural property?

So what to do?  Short term, coin types that did not exclusively circulate within the confines of modern Egypt and Greece should be delisted and any new CPA with Greece should treat any coins legally exported from sister EU countries as legal exports under that CPA. 

Going forward, the best long term solution would be for the Trump Administration to order the preparation of designated lists be subject to the Administrative Procedure Act, and for any detentions, seizures and forfeitures of cultural property to be subject to the Civil Asset Forfeiture Reform Act of 2000.  The former would require the government to justify the inclusion of specific coin types in the designated lists. The latter would help  ensure that import restrictions only apply in situations where there was some evidence that the coin in question was illicitly exported from a country with a cultural property agreement or emergency restrictions after the effective date of the governing regulations.

Several members asked questions.  The Chair noted that IAPN and several others had put in comments about the Bolivian Renewal even though Bolivia had not asked for import restrictions on coins.   Tompa indicated IAPN felt it necessary to do so based on the first time import restrictions were imposed on coins, for Cyprus.  That MOU was billed as solely a renewal as well; however, coins were then added to the designated list.  Tompa indicated IAPN would welcome absolute clarity as to whether new coin restriction were being considered to save everyone time.   The Chair indicated she would discuss this further with State Department staff. 

The chair then asked about the “cultural significance” of coins, noting that Wayne Sayles (the Ancient Coin Collectors Guild’s founder) suggested that coins of Greece were culturally significant in his comments.  [This does not seem borne out from reviewing those comments.  They can be read here:  https://www.regulations.gov/comment/DOS-2026-0133-0035 ) The State Department  put Tompa on mute during his extended response while he was discussing the influence of archaeological groups on the process,  but the Chair allowed Tompa an additional 30 seconds to summarize his views.  He stated as a statutory matter one should not confuse archaeological interest with cultural significance.  He also indicated that given there are thousands of examples of coins already available in Greek museums they could not be considered “culturally significant.”  Finally, he indicated that given the Greek Ambassador’s own words, only coins that exclusively circulated within Greece might be of cultural significance to the modern nation state of Greece.

Tompa then confirmed Alex Barker’s understanding that IAPN took no position on the renewals themselves. 

Miriam Stark then asked Tompa if he had ever worked on an archaeological dig.  He indicated no but stated he knew archaeologists who did, including two members of a local Washington, DC coin club who don’t see anything wrong with collecting ancient coins.  Tompa also indicated that there were no restriction on coins from 1982 when the governing statute, the Cultural Property Implementation Act, became law and 2007, when the first import restrictions were imposed on coins for Cyprus.  He also indicated  the CPAC Committee at the time, which included archaeologists, opposed the inclusion of coins.  Finally, he noted that European Union import controls distinguish between “coins in trade” and coins found at archaeological sites.  Imports of coins in trade are only regulated if they have a value over 18,000 Euros. 

Here is a link to IAPN’s Comments on the Bolivian Renewal:

https://www.regulations.gov/comment/DOS-2026-0133-0108

Here is a link to IAPN’s Comments on Egyptian Renewal:

https://www.regulations.gov/comment/DOS-2026-0133-0038

Here is a link to IAPN’s Comments on Greek Renewal:

https://www.regulations.gov/comment/DOS-2026-0133-0040

Here is a link to Tompa’s oral comments on behalf of IAPN:

https://culturalpropertyobserver.blogspot.com/2026/03/renewals-for-bolivia-egypt-and-greece.html

Here is a link to Tompa’s personal comments:

https://www.regulations.gov/comment/DOS-2026-0133-0008

Tess Davis spoke on behalf of the Antiquities Coalition in support of the renewals for Bolivia, Egypt and Greece.  She argued that the MOUs and related import restrictions close the market to illicit material and thereby protect the legitimate trade.  She noted that a number of other countries have joined the US in doing so.  She also indicated that Cultural Property Agreements provide opportunities to engage with foreign governments over minority cultural heritage issues.

A link to the Antiquities Coalition’s Comments can be found here:

https://www.regulations.gov/comment/DOS-2026-0133-0068

Dr. José M. Capriles Flores is an Bolivian archaeologist who supports the renewal of the MOU with Bolivia.   Looting remains a problem in Bolivia along with destruction due to construction projects.  The government is actively trying to protect the country’s cultural heritage and is also making strides in promoting cultural exchange with foreign institutions.

Here is a link to Dr. Capriles Flores’ comments:

https://www.regulations.gov/comment/DOS-2026-0133-0091

Sarah Parkek is an archaeologist associated with the University of Alabama.  She testified during the initial MOU hearing for Egypt back in 2014, discussing her use of remote sensing technology to track looting in Egypt.  At the time, she indicated that there were 300,000 looting pits identified.  She then reported on her work since then, indicating after a spike in looting during the Arab Spring, there has been little new looting.  She attributes this in part to the US MOU with Egypt. 

One of the CPAC members asked Prof. Parkek about her views on the Egyptian Government’s actions related to St. Catherine’s Monastery.   All she will say is that the issue is a complex one and that the Egyptian Antiquities Ministry with which she collaborates in not involved. 

Alex Barker asks Dr. Parkek about what types of artifacts are being looted.  She indicates that objects from all periods are at risk.  She has personal experience related to early artifacts being looted at a site where she works.  She also indicated that some looting was scattershot, while other looting was more focused, and probably done by more sophisticated looters.  

Andrew Vaughn spoke for the American Society of Overseas Research (ASOR).  Dr. Vaughn indicated that he has made several trips to Egypt where he has participated in academic conferences.  He also has an affinity to the country because his parents met there.  He believes that it is particularly important to renew the CPA with Egypt to show America respects its culture, particularly in this time of military conflict.  He also believes that his Egyptian colleagues have an inclusive approach when it comes to minority heritage. 

Doug Mudd speaks for the American Numismatic Association (ANA) and the Ancient Coin Collectors Guild.  He serves as the curator for the ANA’s Money Museum.  Mudd grew up in a Foreign Service Family posted in the Middle East.  He also is concerned with looting, but believes there are more pragmatic approaches to address it, like that found in the United Kingdom’s Portable Antiquities Scheme.  He indicated that overlapping import restrictions have hurt the ANA’s educational mission because visiting lecturers are afraid to bring in coins with them from overseas for fear they will be seized by US Customs.  He also believes that coins need to be treated differently than other artifacts because they typically exist in many multiples, unlike other ancient artifacts, making them ideal for use as educational tools, and an excellent way to increase ancient history through collecting objects that are not individually rare or unique. 

Nil Otokunor Quarcoopome  asks Mudd if there are already enough coins in the US to allow the ANA’s educational mission to continue.  Mudd indicates the problem is not that coins already exist in institutional collections in sufficient numbers, whether in Europe or the United States— it is that there is not sufficient exposure or interest in the history that coins represent.  Coin collecting develops a passion for history that encourages people to learn and study and in some cases, develop extraordinary private collections.  Import restrictions limit supply and the fact that collectors have difficulty acquiring specimens ultimately hurts museums.  The only way most museums can afford to acquire the rarest and most important collections of coins is through donations from advanced collectors.  Many significant coin collections like those at the Smithsonian Institution, the American Numismatic Society and the American Numismatic Association, have only developed through generous donations from collectors.  

Here is a link to the Ancient Coin Collectors Guild and American Numismatic Association’s Comments:

https://www.regulations.gov/comment/DOS-2026-0133-0023

Kim Shelton excavates in Greece.  She is a professor with the University of California at Berkeley.  She is known for her directorship of the Nemea Center and she focuses her studies on the Mycenaean era. She has witnessed looting first hand.  She indicates coins are targets for looters which damages the ability to study them.  

Elias Gerasoulis is the Executive Director of the Global Heritage Alliance.  He focuses his comments on St. Catherine Monastery in Egypt.  He urges the State Department to use the renewal of the CPA with Egypt as a vehicle to help ensure that the Monastery remains a place of worship, not simply an over commercialized tourist destination.  

A link to the Global Heritage Alliance’s comments can be found here:  

https://www.regulations.gov/comment/DOS-2026-0133-0072

The Chair then thanked the speakers before closing the CPAC meeting which went 15 minutes over the allotted one hour due to the questions asked by CPAC members. 

Renewals for Bolivia, Egypt and Greece Point to the Need for Major Reform

This is what I said more or less at today's CPAC hearing.  I hope to have a summary done when I can, but it will probably be delayed due to travel commitments.

Thank you for this opportunity to speak on behalf of the International Association of Professional Numismatists.

IAPN takes no position on the proposed renewals of Cultural Property Agreements with Bolivia, Egypt, and Greece, but opposes any import restrictions on coins.  Furthermore, IAPN believes that the Trump Administration must reform the system to ensure more transparency and fairness for American collectors and the trade.

There currently are no restrictions on Bolivian coins and Bolivia’s former Director General of Cultural Property has written there is no basis to impose new restrictions on Spanish Colonial and early Republican era coins that also served as legal tender in the U.S. until 1857.

In social media, the State Department has claimed, “these agreements help protect U.S. museums and collectors, support lawful trade, and deter illegal trafficking of cultural property,” but import restrictions on Egyptian and Greek coins demonstrates that narrative is misleading at best.

The current import restrictions on coins are grossly overbroad.   The Egyptian restrictions cover all coins struck in Egypt to 1750 A.D.  The Greek restrictions cover numerous coin types through the 15^th century.  One cannot assume that these coins were “first discovered within” and were “subject to export control by” Egypt and Greece, fundamental requirements of the Cultural Property Implementation Act.

Let us discuss Egypt first.  The elephant in the room is that Egypt’s authoritarian rulers nationalized all antiquities in private hands in 1983 without compensation.  Before that time, there was a booming antiquities trade in Egypt, with millions of objects leaving the country legally but without the paperwork now deemed necessary to “prove” legal export.  

For coins, the situation is exacerbated because the State Department evidently latched onto the argument that Egypt had a “closed monetary system,” to justify maximalist import restrictions on all coins made in Egypt before 1750 A.D.  However, that system was meant to keep foreign coins “out,” not Egyptian coins “in.”  Moreover, despite ample scholarly evidence demonstrating that such coins circulated regionally or even internationally, the State Department simply ignored that factual record and, in the latest renewal, added restrictions on Roman Imperial, Byzantine and Ottoman coins made in Egypt.

The restrictions for Greece go well beyond what the Greek government originally requested. Greece’s Ambassador told CPAC that its request only concerned antiquities that have been found exclusively on Greek territory.  Yet, the State Department has  imposed broad restrictions on ancient and medieval coins that circulated regionally as well as internationally.  As indicated in IAPN’s comments, that  has resulted in Customs detaining and seizing coins merely because they look “Greek.”    Furthermore, those restrictions even apply to coins legally exported from Greece’s fellow European Union members despite the fact that Greece is part of the E.U.’s common export control regime.   That raises the question: Does the State Department really consider coins legally exported from the E.U. to be “trafficked” cultural property?

So what to do?  Short term, coin types that did not exclusively circulate within the confines of modern Egypt and Greece should be delisted and any new CPA with Greece should treat any coins legally exported from sister EU countries as legal exports under that CPA. 

Going forward, the best long term solution would be for the Trump Administration to order the preparation of designated lists be subject to the Administrative Procedure Act, and for any detentions, seizures and forfeitures of cultural property to be subject to the Civil Asset Forfeiture Reform Act of 2000.  The former would require the government to justify the inclusion of specific coin types in the designated lists. The latter would help  ensure that import restrictions only apply in situations where there was some evidence that the coin in question was illicitly exported from a country with a cultural property agreement or emergency restrictions after the effective date of the governing regulations.

Thank you for your consideration of the views of the micro businesses of the numismatic trade.

Time Again to Tell the Cultural Property Advisory Committee What You Think About Import Restrictions on Coins for Authoritarian Egypt, Greece and Bolivia.

 The State Department has announced a Cultural Property Advisory Committee (CPAC) Meeting to consider renewals of current cultural property memorandums of understanding (MOUs) with Bolivia, the authoritarian government of Egypt, and Greece. 

CPAC will hold a session open to the public on March 3, 2026 at 2:00 PM. 

The State Department’s announcement can be found here:  https://www.state.gov/cultural-property-advisory-committee-meeting-march-3-5-2026/

The State Department is also soliciting written comments here: https://www.regulations.gov/document/DOS-2026-0133-0001

Comments are due on or before February 20, 2026.

The renewal for Egypt should be controversial because it prioritizes “soft power” on behalf of Egypt’s authoritarian government over the interests of American collectors, museums, and the trade in cultural goods. 

There was a longstanding legal antiquities and ancient coin market in Egypt until the Mubarak dictatorship.  When the legal market was closed, the government also nationalized all collections although collectors’ families are still allowed to “possess” them until such time the Egyptian government gets around to building more storage space. So, in  fact, what the State Department is proposing with this MOU is to reauthorize US Customs and Border Protection (CBP) to act as the enforcer for Egypt’s draconian, confiscatory laws, laws that would be considered an unconstitutional “taking” if the US Government confiscated American collections without providing fair compensation.  The other issue with the most recent renewal is that new import restrictions on Roman Imperial coins from the mint in Alexandria as well as new restrictions on Byzantine coins were added.  This was done despite the evidence provided to CPAC that one cannot assume that such coins must be found in Egypt given their wide circulation patterns See https://www.regulations.gov/comment/DOS-2021-0003-0016

The issues related to the MOU with Greece are in some ways more egregious given Greece’s voluntary association with the European Union.  While Greece is a Democracy,  it has very stringent laws dating back to the 1930s requiring collections to be registered—although it is still possible to import ancient coins from abroad.  However, the real annoyance is that CBP pretends that Greece is not part of the EU.  EU rules govern all exports from the Union.  They explicitly allow EU members to export cultural goods, with or without a permit, depending on value as determined by the member state.  Most EU members allow exports of collector’s coins, usually without a permit.  However, Customs will seize any coin on the designated list for Greece, or the other EU countries with MOUs (Bulgaria, Cyprus,  and Italy) even where the coins were legally exported from a sister EU country.   Representatives of the trade and collectors have raised this concern over and again, most recently with the renewal of the MOU with Italy, but it has fallen on deaf ears.

The current MOU with Bolivia only covers pre-Colombian and later ethnographic artifacts, but there have been previous requests to impose import restrictions on Spanish colonial and early Republican coinage from Latin America, despite the fact such coins were also legal tender in the US until 1857.

For coin collectors, the big issue is the grossly overbroad designated lists that cover coins that circulated regionally or internationally.  

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.

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’s 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 get in touch with your own cultural heritage.  However, here is a model for you to consider:

Please do not renew current import restrictions that prioritize “soft power” over the rights of American coin collectors.  If you nonetheless renew these agreements, please ensure that the 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.  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 supposedly aims to foster.