Monday, October 31, 2011

PhDiva Gets a Jump On Everyone Else

Kudos to PhDiva for describing what's missing from the so-called Benghazi Treasure. For more, see

Rather than all the usual speculative blather about shadowy Western collectors organizing the looting of the world's treasures, its nice to see someone associated with the archaeological community making such a timely and positive contribution to describing what is lost.

Kudos to PhDiva for doing so.

We would be all better off if others took her cue.

Treasures Stolen from Benghazi Vault-- But When and By Whom?

The Sun Newspapers and others have reported that a treasure trove of gold artifacts and coins was stolen from a Benghazi bank vault. See

Collectors and dealers in ancient art should obviously report any efforts to sell such materials to the authorities. Here are some other thoughts.

1. Although some will apparently use this news as a basis to claim there is a need for "emergency import restrictions" on Libyan cultural material, these objects would already be treated as stolen under US and other law.

2. While the theft of this material is said to have happened during revolution, if what happened in Iraq is any guide, it's also possible that the material was stolen earlier by officials associated with the former regime, and the loss is only coming to light now.

3. It would have been easier to identify this material if it had been properly recorded by either the Italian authorities who returned it to Libya back in 1961 or the Libyans themselves. Unfortunately, this does not appear to have been the case, so all we will be left with is some general descriptions of the material. Hopefully, Libyan authorities will put out as detailed as possible descriptions of the missing artifacts soon.

Friday, October 28, 2011

SAFE Shortcuts Public Comment Procedure

Saving Antiquities for Everyone (SAFE) has begun a petition campaign in support of the Bulgarian MOU. See

But the State Department Bureau of Educational and Cultural Affairs has already set up a procedure for public comment open to all interested in whether there should be an MOU with Bulgaria. Can't SAFE follow directions?

Petitions like SAFE has prepared are inherently unreliable:

  • There is no way to verify that the signatories are real people or if one person has signed the petition under different names;

  • It's doubtful that many of the signatories have any real knowledge of the issues involved beyond the minimal information they have received with the petition.

  • It is likely that some signatories have also made public comments, thereby overstating support for the proposition.

    • SAFE already has already asked its supporters to use the website to comment on the Bulgarian MOU? So, can this petition accomplish anything, but to mislead?

      Thursday, October 27, 2011

      State Department Clarifies Egyptian MOU

      The State Department Cultural Heritage Center has clarified the situation on the Egyptian MOU as follows:

      What's New

      Potential Memorandum of Understanding between U.S. Immigration and Customs Enforcement and Egypt’s Ministry of State for Antiquities

      The Department of State’s Cultural Heritage Center has become aware that confusion exists concerning a potential MOU between U.S. Immigration and Customs Enforcement and Egypt’s Ministry of State for Antiquities. Such an agreement would differ from the type of MOU made under Article 9 of the 1970 UNESCO Convention for import restrictions on certain categories of cultural materials. The Department understands that the MOU presently under discussion by U.S. Immigration and Customs Enforcement concerns information exchange and not import restrictions. If the Government of the Arab Republic of Egypt requests an agreement pursuant to Article 9 of the 1970 UNESCO Convention, the Department of State would announce receipt of such a request in the Federal Register. This procedure is the only means currently available to a country wishing U.S. import restrictions on its cultural property.

      Given this clarification, a recap of how this issue arose is in order.

      Last May, then Egyptian Antiquities Minister Zahi Hawass stated on his blog,

      [A Coalition of US archaeologists] reported that the US Government is willing to impose emergency restrictions on Egyptian antiquities....The coalition will be drafting a formal agreement between the US and Egyptian governments...."


      Last June, the Cultural Policy Research Institute made FOIA requests on the matter, that have not been answered satisfactorily.


      Last September, it was reported that the State Department [not US Customs] had given ICOM a sole source contract to prepare a "red list of Egyptian antiquities at risk." See

      Just this week, an Egytian newspaper that is viewed as the unofficial voice of the Egyptian military government reported,

      New strategy to prevent illegal trade in Egyptian antiquities

      Nevine El-Aref, Sunday 23 Oct 2011

      American-Egyptian memorandum of understanding to track down antiquities smugglers in the United States to be signed soon

      In an attempt to tighten security measures on antiquities trafficking, Egypt is to sign a memorandum of understanding with the United States enabling the Customs and National Security Department in the USA to track and catch antiquities smugglers in the country. They will also be able to take all legal procedures to return illegally smuggled antiquities to Egypt.

      Mustafa Amin, secretary-general of the Supreme Council of Antiquities, told Ahram Online that according to the memorandum, training courses would be provided for Egyptian archaeologists responsible for archaeological units in ports and airports in order to discover any smuggling attempts across Egyptian borders.

      The United States will also offer Egypt a financial grant to implement a special security strategy at all its archaeological sites, museums and borders. State-of-the-art security equipment such as electronic gates, burglar alarms connected to TV circuits, and cameras will also be provided.

      Under the circumstances, while the State Department's clarification is welcome, it should be followed up with more transparency about the issue.

      Wednesday, October 26, 2011

      The Bulgarian MOU: What's Really At Stake

      Behind all the slogans, what will be the real impact of any US decision to impose import restrictions on behalf of Bulgaria?

      Will it end looting of archaeological sites by Bulgarians? No.

      Will it diminish demand for Bulgarian antiquities? Doubtful, as any restrictions will only apply to American collectors. Collectors in Bulgaria, the rest of the EU and emerging markets in Asia and the Middle East will be unaffected.

      Will it end corruption in Bulgaria? No, if anything, it might actually open up new avenues for corrupt officials such as the resale of repatriated antiquities.

      Will it encourage the Bulgarian cultural establishment to implement more rational and inclusive laws governing the sale and possession of cultural goods? No, if anything, it will butress the current status quo.

      Will it make it far more difficult to import coins "of Bulgarian type" into the United States? Yes. Despite some claims to the contrary made by know-it-all archaeologists with no practical experience whatsoever, it really is difficult to import coins on the designated list. Information for the required certifications as to the whereabouts of a restricted coins as of the date of the restrictions, is typically unavailable for all but the very few coins that are photographed for purposes of auctions, perhaps 1 coin in every 10,000, and valuable ones at that. Thus, while the impact of restrictions on expensive coins that are more likely to have appeared at auction is tempered to some extent, as a practical matter import restrictions bar legal entry of the vast majority of coins readily available in legitimate markets abroad.

      So, by all means, let your views be your guide in commenting on the Bulgarian MOU-- but hopefully only do so with knowledge of what is really at stake.

      Tuesday, October 25, 2011

      SAFE: Say Yes to the Corrupt Bulgarian Status Quo?

      Saving Antiquities for Everyone (SAFE) has started yet another "Say Yes" advocacy campaign in support of import restrictions, this time on behalf of Bulgaria.

      But, what will SAFE's campaign (and that of the AIA) for "no questions asked" import restrictions really do for Bulgaria and the protection of its cultural patrimony, but help support the corrupt status quo?

      Though SAFE's advocacy document has plenty of links detailing individual stories about looting of archaeological sites, SAFE's advocacy fails to mention a sobering report about the state of Bulgaria’s cultural policy prepared by the Center for the Study of Democracy. See The Antiquities Trade-Dealers, Traffickers, and Connoisseurs, in Organized Crime in Bulgaria: Markets and Trends 178-197 (Center for Study of Democracy 2007) (“CSD Report”) (available at: checked, 10/19/11).

      This report, prepared with funding from the U.S. Department of Justice, appears to largely reflect the views of government cultural officials and archaeologists. Nevertheless, the report contains some eye-opening facts that should give pause to anyone who might assume all is well with how Bulgaria manages its own cultural patrimony:

      • From 100,000 to 250,000 Bulgarians regularly conduct illicit excavations. (Id. at 179.)

      • “Most Bulgarian museums have poor recording practices of the artifacts in stock. The general lack of accountability, in particular of museum directors, further aggravates the situation…. The majority of museums do not observe the international standard for describing art, antiques and antiquities with photographs and descriptions of each object (the so called Object ID). In Bulgarian museums objects are often loosely described in general terms, which makes it impossible for them to be tracked, positively identified and restored. The dire state of museum documentation dooms to failure any efforts to trace stolen coins or other items transferred abroad.” (Id. at 183.)

      • “To make their anti-looting and anti-trafficking efforts seem more effective enforcement agencies announce lavish values of the illicitly acquired cultural objects they capture.” (Id.)

      • “During interviews, carried out for purposes of this paper, it was made clear that the prescribed system of registration [of coins in private collections] by commissions made up of local museum employees was not found trustworthy, as it did not provide safeguards against the theft of valuable coins which could be replaced with cheaper lower grade versions by museum workers.” (Id. at 193.)

      • “Some collectors have voiced their suspicions that past burglaries of private coin collections have been committed with the involvement of corrupt police officers or other enforcement officials.” (Id. at 193 n. 312.)

      • “Inertia and neglect are not the only factors to throttle effective enforcement. Widespread corruption among local middle-ranking law-enforcement officers who earn personal gains on the black cultural property market also has an adverse effect. Experts have outlined three major forms of corrupt relationships between police officers and antique dealers/looters: 1) policemen are bribed to cover looters and deter police investigation; 2) officers of higher rank become directly involved in illicit antiquities trading, and 3) officers that must prevent and fight cultural property violations become collectors. In addition, the grading of cultural objects held by looters, dealers or collectors is itself often done by would-be experts whose only training is a two-week course delivered by the Privatization Agency on a regular basis that can hardly have equipped them with the knowledge they need to possess about cultural goods. Despite their determination to get looters or persons in illicit hold of antiquities convicted, law-enforcement and investigative bodies are often hampered by either incompetent or intentionally falsified expert assessments presented at the trial phase.” (Id. at 194.)

      • “In 2003, the head of Cultural Property Department at the National Police Col. Georgi Getov was discharged. According to media reports he had operated one of the main antiquity smuggling channels in Bulgaria in partnership with a number of prosecutors, NSCOC officers, local archaeological museum directors and other officials who had served as a supply link between looters and the implicated department head. Maritsa Dnes daily, 7 May 2003.” (Id. at 194 n. 316.)

      The report goes on to make detailed suggestions on how to address the problem of looting in Bulgaria, including the regulation of metal detectors and the passage of a cultural heritage law that takes into account the concerns of collectors as well as archaeologists.

      The report is relevant because Bulgaria is expected to take self-help measures before import restrictions are imposed. In addition, less severe remedies must be considered before the State Department again limits the ability of Americans to import artifacts. (26 USC Section 2602 (a) (1) (B) and (C)(ii).)

      Under the circumstances, the US could best help Bulgaria by tabling any talk of import restrictions to allow Bulgaria time to act on the CSD report's recommendations. Though any looting of Bulgarian archaeological sites is regrettable, it is best addressed in Bulgaria itself through the regulation of metal detectors and serious consideration of CSD's other suggestions before import restrictions are imposed.

      Sunday, October 23, 2011

      CPAC and Egypt: Why Bother?

      Ahramonline, the Egyptian Military Dictatorship's mouthpiece, has reported that US and Egyptian authorities are poised to sign yet another MOU which will purportedly clamp down on the trade in Egyptian artifacts. See

      Of course, such MOU's are only supposed to be decided after a formal request from a State Party to the State Department. CPAC is then supposed to make recommendations to the President's designee at the Department of State, Bureau of Educational and Cultural Affairs, who in turn is only supposed to agree to import restrictions if specific statutory criteria are met.

      Here, all this appears to be a formality. Some months ago former Egyptian antiquities chief Zahi Hawass reported that American archaeologists had secured the State Department's agreement to enter into import restrictions. Then, the State Department gave ICOM a sole source contract to develop a "red list" of Egyptian antiquities at risk, which can also serve as a ready made "designated list" for import restrictions.

      If the reports emanating out of Egypt are true, it's just more evidence that the whole CPAC process is but a bad joke.

      Saturday, October 22, 2011

      No Credit to the Archaeological Community

      While the comments to CPAC about the Bulgarian MOU from the archaeological community have been few, Archaeo-Blogger Paul Barford has gone into high gear in his criticism of collectors' views on the State Department's and the AIA's efforts to suppress ancient coin collecting in this country.

      His know-it-all blather is obnoxious enough when it is directed at other bloggers with whom he disagrees (even including at times some on "his side" of the issues!), but he has now achieved yet another new low in his ridicule of indivduals who have been forced by the State Department's "green initiative" to post their comments about the Bulgarian MOU on line.

      Leaving aside his insults, Barford seems to suggest that coin collectors are failing to specifically comment on these provisions of the CPIA:

      If the President determines, after request is made to the United States under article 9 of the Convention by any State Party--
      (A) that the cultural patrimony of the State Party is in jeopardy from the pillage of archaeological or ethnological materials of the State Party;
      (B) that the State Party has taken measures consistent with the Convention to protect its cultural patrimony;
      (C) that--
      (i) the application of the import restrictions set forth in section 2606 of this title with respect to archaeological or ethnological material of the State Party, if applied in concert with similar restrictions implemented, or to be implemented within a reasonable period of time, by those nations (whether or not State Parties) individually having a significant import trade in such material, would be of substantial benefit in deterring a serious situation of pillage, and
      (ii) remedies less drastic than the application of the restrictions set forth in such section are not available; and
      (D) that the application of the import restrictions set forth in section 2606 of this title in the particular circumstances is consistent with the general interest of the international community in the interchange of cultural property among nations for scientific, cultural, and educational purposes; the President may, subject to the provisions of this chapter, take the actions described in paragraph (2).....

      But how would most collectors be in any position at all to comment intelligently on most of this legalese? On the other hand, many collectors have quite rightly focused on the potential impact of import restrictions on their hobby.

      Don't such concerns go to the ability of Americans to trade and collect ancient coins that are freely available worldwide (including within Bulgaria itself)? And as such, don't complaints about discriminatory import restrictions go directly to the CPIA's concerted response requirement as well as the use of ancient coins as educational tools?

      So, what exactly is Barford, the obnoxious know-it-all, talking about?

      In any event, it certainly does no credit to other members of the archaeological community that one of their number is in effect seeking to suppress the First Amendment rights of American collectors as well as the views of collectors outside the US with his obnoxious ridicule of those forced to comment publicly on the website.

      Tuesday, October 18, 2011

      Greece's Bloated Cultural Bureaucracy

      The New York Times has a good story about Greece's bloated bureaucracy which has defied efforts to cut it. See

      Of course, the recently announced Greek MOU is a boon to the Greek cultural bureaucracy, which will no doubt cite it as a reason not to reform it.

      Yet, unless you are a State Department bureaucrat or an archaeologist, one should find it hard to escape the fact that while an oversized Greek cultural delegation was making the rounds in Washington to lobby for the MOU, rank and file museum guards were rioting on the Acropolis after not being paid. See

      Is the main purpose of MOU's to protect cultural sites or is their primary purpose protect the jobs of cultural bureaucrats abroad and thereby support the bankrupt status quo?

      Monday, October 17, 2011

      Bulgaria: Call to Comment

      Please consider sending this to any coin collector you know:

      The US State Department is seeking public comment on a new request for import restrictions made on behalf of Bulgaria. To submit comments electronically to the State Department’s Cultural Property Advisory Committee (CPAC), go here:!submitComment;D=DOS-2011-0115-0001

      For further details of the request, see

      What is at issue? Despite President Obama’s efforts to foster government transparency, the State Department has not indicated whether coins are part of the request. Nonetheless, based on recent history, it is probable that import restrictions on coins will be proposed. As a practical matter, this means the State Department and US Customs may be considering restrictions on tribal coinages from Thrace, coins of Greek city states like Apollonia Pontica and Messembria, Roman provincial coins struck at Bulgarian mints, and even some Roman Imperial coins. It’s also possible that any restrictions will include later coins as well. Though details are few, the public summary the State Department has provided indicates that Bulgaria seeks import restrictions on objects from 7500 B.C. to the 19th c. AD. If restrictions are imposed on coins, many common types will likely become so difficult to import legally that they will become unavailable to most collectors.

      Why bother? Large numbers of coin collectors have made their concerns known to CPAC. Recently, 70% of the comments CPAC received on a MOU with Greece were from concerned coin collectors. Even though new import restrictions on coins of Italian and Cypriot "type" make it easy to become cynical, public comment can at least help moderate these demands. For example, archaeologists actively sought import restrictions on Roman Imperial coins during the discussions about the Italian MOU, but they remain exempted, and thus easy to obtain on the open market, likely due to the 2000 or so faxes CPAC received from concerned collectors.

      What should I say? Tell the State Department and CPAC what you think about the bureaucracy’s efforts to deny you the ability to collect common ancient artifacts that are available worldwide. You might also consider noting that coins from Bulgarian mints are common and often very inexpensive. Tens of thousands or hundreds of thousands exist in collections around the world, and because of the low price the vast majority of these coins will never have been through an auction and will have no verifiable provenance.

      If you are having trouble commenting from the direct link above, go to
      and search on docket number DOS-2011-0115. Further information about, including instructions for accessing agency documents, submitting comments, and viewing the dockets, is available on the site under “How To Use This Site.” Kindly note that your comments will be public so avoid conveying any personal information, and, of course, be polite in commenting on the issue.

      Please submit comments just once, before the cutoff of 5:00 PM EST Nov. 2, 2011.

      Comments on the Bulgarian Request: Why Bother?

      The State Department has announced another short comment period for proposed import restrictions that may include coins from Bulgaria. See

      Given recent import restrictions imposed on coins from Italy and Cyprus though, why bother to comment?

      Coin collectors and members of the small businesses of the numismatic trade have certainly dominated public comment when import restrictions on coins have been at issue.

      Most recently, 1347 individuals commented on the Greek MOU on the website. Of these, approximately 70% (942) opposed the MOU or its extension to coins with 30% in favor (404). Virtually all those opposed were coin collectors.

      The next most recent request was the renewal of the Italian MOU. A FOIA request reveals that while some 2000 collectors opposed the extension of import restrictions to coins only some 13 or so comments were in favor of it. (About 100 public comments favored an extension of the MOU but did not mention coins).

      Prior to that there was Cyprus. If memory serves, there were some 1200 or so public comments against import restrictions on coins generated in a short 10 day comment period.

      Yet, based on recent trends, I can certainly see how some might question whether public comment really matters when the State Department Cultural Heritage Center seems to be run as little more than an adjunct of the AIA and the rest of the State Department bureaucracy seems to value the wishes of foreign cultural bureaucracies over the interests of American citizens who collect and deal in ancient coins.

      Indeed, despite the lopsided number of public comments opposed to import restrictions on coins, the fact that such coins had been exempted before and the recommendations of CPAC, the State Department bureaucracy nonetheless recently imposed new import restrictions on Greek, certain Republican and city coins of "Italian types." Yet, despite the calls from the AIA, no import restrictions were imposed on most Roman coins.

      While an MOU has agreed to with Greece, we still do not know whether coins will be included in any restrictions.

      And as for Cyprus, import restrictions were indeed imposed despite the number of public comments and CPAC's recommendations, but only after behind the scenes lobbying evidently convinced the State Department's third ranking official, Nicholas Burns, to take up the archaeological cause.

      So do comments matter? I think they do, despite the fact that the deck appears to be obviously stacked against anyone not associated with the archaeological community.

      At a minimum, public comments do show the State Department bureaucracy that real people do care about this issue, and hence perhaps do some good in moderating outcomes.

      The Farce Continues: CPAC Hearings on Requests from Bulgaria and Belize

      The State Department has announced that CPAC will receive public comments on new requests for import restrictions from Bulgaria and Belize.
      For more, see

      Despite Obama Administration promises of greater government transparency, the public summaries of the requests provide little more than a history lesson about the cultures in both countries and some general information about looting in each country. Nothing at all is said about what particular objects are subject to possible restriction or any particular justifications for such actions.

      And once again, the public comment period is exceptionally short, ending on November 2nd.

      Accordingly, one must again unfortunately conclude that the State Department and its Cultural Heritage Center really are not looking for informed public comment from the broadest number of stakeholders possible.

      And doesn't such a tact merely confirm the suspicions of many that the State Department bureaucracy views CPAC as little more than a rubber stamp for imposing the broadest import restrictions possible?

      While I'm sure Bulgaria's former Communist rulers would have approved of such a farce, what does it say about our own State Department's commitment to the democracy it preaches so loudly to others?

      Wednesday, October 5, 2011

      Staged Find

      It has been revealed that a well publicised story about Prime Minister and likely future President Putin finding an old amphora while scuba diving was staged. See

      No big surprise.

      Tuesday, October 4, 2011

      Chasing Aphrodite at the Walters

      A Story of Antiquities Purchases, Confidential Sources & Ethical Dilemmas

      Authors Jason Felch and Ralph Frammolino will field questions from local WYPR radio host Tom Hall and the audience, relating to their controversial new book Chasing Aphrodite: The Hunt for Looted Antiquities at the World’s Richest Museum. This is the first-ever presentation of this topic in an art museum, and participants will also include Baltimorean Arthur Houghton, a one-time curator at the J. Paul Getty Museum and major source for the book, and Walters Director Gary Vikan, who will help frame the broader question of how new cultural property guidelines might affect encyclopedic museum collections.

      Mining their confidential sources at the Getty, Felch and Frammolino reconstruct a compelling narrative that takes the reader—and will take the audience—through an exotic and sometimes ethically challenging world of antiquities acquisitions. The authors will provide their own account of how Getty museum officials grappled with the question of acquiring Greek and Roman antiquities for over 30 years and the eventual indictment of the museum’s antiquities curator in 2005. A reception will follow.
      The Walters Art Museum, Graham Auditorium
      Saturday, October 29, 2 p.m.

      Monday, October 3, 2011

      Now is it Time to Free the Coins?

      The dysfunctional Italian justice system has finally freed Amanda Knox after concluding she was probably not guilty of murder after all.

      But what of the dysfunctional Italian cultural bureaucracy?

      As its poor stewardship of major cultural sites like Pompeii shows, it has failed miserably at its core mission of preserving Italy's unparallelled cultural patrimony.

      Perhaps, then its not all that surprising that the Italian cultural bureaucracy has instead spent so much time and effort diverting attention away from its own failings by pointing the finger at collectors and auction houses and claiming that they are responsible for looting.

      But will funding shortfalls force a change in approach? Not likely, at least while the Italian cultural bureaucracy receives noisy support from archaeologists and their friends in the State Department Cultural Heritage Center bureaucracy.

      But does that make it right?

      Here, for example, is the reaction of one collector to Archaeo-blogger David Gill's continuing campaign against Christie's auction house on behalf of Italian authorities:

      The hypocrisy of David Gill's recent posts (see
      really is too much. First he plays gotcha with Christie's based on stills from the "Schinoussa Archive" and then he accuses Christie's of failing to cooperate with other international institutions. Objects like those terracottas would never make it to auction if Gill and his colleagues would cooperate and share the Schinoussa images with auction houses and the public. No auction house would put obviously problematic material on the market and no buyer would buy it. Gill, by refusing to cooperate with auction houses and dealers, is doing more to further the sales of illegally obtained objects than the average Italian looter.

      Why can't the Italian authorities make this archive publicly available rather than cooperating in Gill's game of gotcha?

      And, on another note, how crazy is it that courtesy of the Italian cultural bureaucracy, the AIA and the State Department most ancient Italian coins of Greek and early Roman Republican types are off limits to American collectors-- while Italians themselves as well as other collectors world-wide can import the same coins no questions asked. If it is really necessary to impose import restrictions on coins, how about at least requiring some proof that they are the products recent illicit excavation?

      Yes, its time to publish the Schinoussa archive and to free the coins.

      Saturday, October 1, 2011

      Frome Hoard Goes on Display

      The Frome Hoard has been put on display in the new Somerset Museum. See

      The Hoard was purchased after a successful fund raising campaign. Other, less significant hoards are typically returned to the finder who can keep them or sell them ultimately to collectors who then will have a coin with a known provenance to add to their collection. Is it really necessary for the State to retain everything?