Monday, January 30, 2012

CPAC Meeting on Renewal of MOU with Cyprus

The United States Cultural Property Advisory Committee (CPAC) met on January 18, 2012, to discuss the Cypriot MOU. Once again, CPAC Chair Prof. Patty Gerstenblith (PG, DePaul, Public Representative) began by thanking all speakers or those who had provided comments to CPAC. PG was joined by the following CPAC members Katherine Reid (KR, Cleveland Museum (retired)-Museum); Nina Archabal (NA, Minn. Historical Society-Museum); Marta de la Torre (MT- Florida International University, Public); James Willis (JW, James Willis Tribal Art-Trade); Nancy Wilkie (NW-Carlton College, Archaeology); Barbara Bluhm Kaul (BK,Trustee, Art Institute of Chicago- Public); Jane Levine (JL, Sotheby’s Compliance Department (ex-prosecutor)- Trade); and Rosemary Joyce (RJ,U. Cal., Berkley-Anthropology). Two slots, one in archaeology and the other a trade representative, remain vacant. KR, NW and JW also served under the Bush Administration. The others are Obama Appointees though PG and MT also served the Clinton Administration. There was also staff present including CPAC Executive Director Maria Kouroupas, a Committee lawyer, and Committee archaeologists.

The following individuals spoke at the meeting in support of the MOU: Carmen Biucchi (Harvard); Brian Daniels (U. Pennsylvania Cultural Heritage Center); Nathan Elkins (Baylor); Jane Evans (Temple); Raymond Ewing (CAARI); Ellen Hersher (CAARI); Anne Marie Knobloch (Virginia Tech); Laetitia La Follette (U. Mass./ AIA); Andrew McCarthy (CAARI); Joanna Smith (Princeton); Chris Shaegel (U. Cyprus); Tom Kline (Andrews Kurth); Josh Knerly (AAMD).

The following individuals spoke against the MOU: Peter Tompa (IAPN/PNG); Wayne Sayles (ACCG); and Eloise Ullman (ICTA). In addition, 77% of the comments recorded on the website either opposed the MOU or their extension to coins.

Carmen Biucchi (Harvard) indicated that coins provide important documentation of early Cypriot history because there are few written sources. Even low value bronze coins are important because they frequently appear at archaeological sites. We need to all work together to preserve the past. Cypriot coins are relatively uncommon. In response to a question, Biucchi indicated that it is relatively easy to trace expensive coins due to their appearance at auction, but this is not the case for less expensive coins. She also indicated that metal detectors are the problem.

Brian Daniels (U. Penn. Cultural Center) argued for the extension of restrictions to post-Byzantine period ecclesiastical material. He also suggested that US law enforcement pursue better coordination with Cypriot law enforcement, and other countries with strong Greek cultural influence, including Greece itself and Bulgaria.

Nathan Elkins (Baylor) indicated that Cyprus’ cultural property is in jeopardy as proven by a recent large seizure of artifacts, which included bronze and silver coins. There is a large market in the US as demonstrated by the fact that 200 Cypriot coins are currently listed on the V-coins website. Most Cypriot coins circulated locally. If you add together a list prepared by Wayne Sayles of coins found outside of Cyprus and a list Elkins compiled of coins from Cypriot contexts, that shows that Cypriot coinage is much more prevalent in Cyprus than outside of Cyprus.

Jane Evans (Temple) also indicated that it was important to continue restrictions on coins because it is important that their context not be lost.

Raymond Ewing is a former ambassador to Cyprus. He now serves a CAARI’s President. CAARI receives funding from the US Department of State, Bureau of Educational and Cultural Affairs and the National Endowment for the Humanities. Import restrictions should be as closely conformed to Cypriot law, that covers artifacts up to 1850, as possible.

Ellen Hersher is a scholar and archaeologist associated with CAARI. Cyprus has been a specialty for over 40 years. Looting is a historical problem in Cyprus. Looting still goes on until today. Looting only declined during the periods of WWI and WWII and during the 1950’s when British forces were involved in anti-insurgency operations. Wealthy Cypriots have collected Cypriot antiquities since the 19th Century. There is no shame in looting in Cyprus. Increasing efforts are being made to educate the populace. There is a great need for a new museum (the current one dates back to Victorian times) to encourage youth to respect their past. Metal detectors continue to be a serious problem; more legislation is needed. The major collections are grandfathered in. It is Ms. Hersher’s opinion that they are no longer adding much material, but most Cypriots don’t think that looting is wrong. We shouldn’t point fingers at Cyprus, but try to fix the problem.

Anne Marie Knobloch is a CAARI board member, who teaches at Virginia Tech. She is also an AIA member. Cyprus has important religious sanctuaries that need to be studied. Virginia Tech offers students the opportunity to excavate in Cyprus and would like to do more with Cypriot students.

Laetitia La Follette is the AIA’s VP for professional responsibility. She is associated with the University of Massachusetts. Looting remains a problem, including for coins. Because ancient coins are handmade, they are all different and may be traced. The AIA can help draft the designated list. The laws in the Greek Cypriot area need to be tightened. The laws in the North are actually stronger.

Andrew McCarthy is a CAARI trustee. Looting has increased since the 1960’s. There is a famous incident where a tomb was set aside as a dowry. The Department of Antiquities is doing its best to fight against looting. A site where McCarthy works has not suffered looting from 2007-2011. There was one incident where looters struck the site, presumably looking for coins. CAARI gives all documentation created from archaeological investigations to the Department of Antiquities. MOU’s can help educate Cypriots about the importance of their heritage.

Joanna Smith of Princeton is a past CAARI Trustee. Cyprus is an academic cross-roads. Cypriot children are being taught about their history and Cyprus sends exhibits abroad.

Chris Shaegel is from the University of Cyprus. He works closely with CAARI. Because there are few manuscripts that predate 1600, the preservation of Cypriot material culture is important. Coins should be protected and the restrictions should be extended further in time. Icons also need protection. There is no internal market in Cyprus.

Peter Tompa spoke for IAPN and PNG, two trade associations that represent the small business of the numismatic trade. Each Committee member must ask themselves whether they can do so in good conscious after considering these undisputed facts: (1) Coins were evidently placed on the designated list on the orders of former Undersecretary Nicholas Burns as a “thank you” to Cypriot advocacy groups which had given him an award; (2) Jay Kislak, CPAC’s former chair, has stated under oath that the State Department misled Congress and the Public about CPAC’s vote against import restrictions on coins: (3)In 2007, the AIA claimed that Cypriot coins “rarely circulated” to justify restrictions on “coins of Cypriot type.” However, a top Cypriot official has admitted that “It is true that Cypriot coins shared the same destiny as all other coins of the ancient world. As a standard media of exchange they circulated all over the ancient world due to their small size, which facilitated their easy transport…” Moreover, this view has substantial scholarly support; (4) The CPIA requires less drastic remedies to be tried first before import restrictions are imposed, but Cyprus has no coherent regulatory scheme for metal detectors and even allows British tourists to bring them to the Island; and (5) Restrictions imposed on unprovenanced “coins of Cypriot type” only discriminate against American collectors and the small businesses of the numismatic trade; such coins may be shipped from abroad to anywhere but the USA, including Cyprus.

Moreover, he stated that there is no good reason to renew the MOU for yet another 5 years. Cyprus has already had the benefit of restrictions since 1999 on ethnological artifacts and 2002 on archaeological artifacts. Yet, a Swiss scholar reports most looted material goes to wealthy Greek Cypriot collectors, and not as has been maintained to collectors abroad. In addition, all this appears to be done with the full knowledge and acquiescence of Greek Cypriot authorities. Thus, restrictions only discriminate against American collectors.

In response to a question from JW, Tompa indicated it was wrong to so burden the small businesses of the numismatic trade just so archaeologists might occasionally get some relevant information about dating sites from a coin. He also disputed the claim by JL that import restrictions are easy to comply with. He noted that US Customs will not allow entry of coins and other antiquities unless they are pictured in a catalogue that predates restrictions. Thus, even the difficult to obtain certifications are not enough for Customs.

Wayne Sayles indicated that the ACCG represents the interests of the approximately 50,000 serious ancient coin collectors in the United States. The ACCG is interested in fair and equitable application of US law. The CPIA was meant to protect significant artifacts, not everything under the sun. In response to a question from PG, Wayne Sayles indicated that it is unrealistic to ask the small businesses of the numismatic trade to provide provenance information for every coin they import.

Eloise Ullman indicated that most ICTA members have under 5 employees. She also noted that President Obama recently recognized that it is important not to overburden small businesses with paperwork when his administration signed onto an effort to end a burdensome requirement that coin dealers prepare 1099 forms for every purchase over $600.

Tom Kline disclosed that he previously represented Cyprus. He stated that Cyprus is a leader in protecting its own cultural property, but takes a reasonable approach in doing so. The Turkish Republic is an illegal regime so he disputes that DOS look to their laws on antiquities as models. We need higher ethical standards from collectors. The import restrictions on coins should be no big deal because the restrictions only date from 2007. Collectors only have themselves to blame if they do not keep adequate documentation.

Josh Knerly spoke on behalf of the AAMD which supports the MOU with Cyprus with some limited provisos. First, the AAMD would like to know more about a proposal to extend restrictions to new types of ecclesiastical objects. It appears members of the archaeological community know details of the request, but these have not been shared by the public at large. KR asked why no Museum Director was present. Knerly indicated he would determine if some curators with specialized knowledge would be able to testify in the future.

Sunday, January 29, 2012

ICOM "Red List" to Pave the Way for New Restrictions on Egyptian Cultural Goods?

In the US, Congress has established the following process for imposing import restrictions: (1) a State Party to the 1970 UNESCO Convention requests US assistance; (2) the request is vetted by the US Cultural Property Advisory Committee (CPAC) as to whether it meets the statutory requirements generally and for what artifacts specifically; (3) the President's Designee in the State Department considers CPAC's recommendations in making her own findings whether the statutory criteria are met: (4) if the statutory criteria are met, US Customs restricts entry of certain artifacts that meet the statutory criteria.

Unfortunately, a new extra-legal model has emerged that appears to have been perfected under the Obama Administration either through inattention by political appointees or by design: (1) Archaeologists intone that looting (real or imagined) justifies a clamp down on another collecting area; (2) their allies in the State Department Cultural Heritage Center issue a sole source contract to a NGO associated with the extreme archaeological view to prepare a list of artifacts that supposedly can be assumed to be "stolen" unless proven otherwise; (3) Archaeologists lobby the modern foreign government that sits on the land where these artifacts can be found to ask the US to impose import restrictions; (4) CPAC (which is now populated almost exclusively by those sympathetic to the extreme archaeological view) and the President's Designee in the State Department go through the motions of considering a request, but ignore all the statutory criteria in order to "get there"; and (5) artifacts are restricted based on the "Red List" prepared by the NGO associated with the extreme archaeological view.

It is quite possible that the process has already begun for imposing new restrictions on Egyptian cultural artifacts.

1. During unrest during the Egyptian revolution, there apparently was some looting, though the extent does not seem to be very extensive.

2. Archaeologists have argued this justifies a clamp down on collectors of Egyptian artifacts.

3. The State Department issued a sole source contract (See to ICOM for the creation of a "Red List." See also, (noting that the Cultural Heritage Center funds Red Lists as a "special project.")

4. ICOM has now completed its work. See Note, according to ICOM: " Any cultural object that could have originated in Egypt should be subjected to detailed scrutiny and precautionary measures."

5. Although the State Department has indicated that former Egyptian Cultural Heritage Pharaoh Zahi Hawass' claim that a MOU was in the offing actually related to an agreement with US Customs, that does not foreclose the possibility that the process for imposing new import restrictions on Egyptian cultural goods has already commenced with the production of this "Red List." See

Only time will tell.

Tuesday, January 24, 2012

Renewal of Import Restrictions on Cypriot Coins Being Considered

The ACCG has issued this press release about the recent CPAC hearing about the potential renewal of the Cypriot MOU:

I hope to post a summary of the meeting on this blog as soon as my schedule permits me to review my notes.

Friday, January 20, 2012

Italian Justice on Trial: Bob Hecht Vindicated?

Well, that is one way this sorry tale can be spun:

After all the headlines, Bob Hecht, the alleged middleman at the center of an international conspiracy to launder looted art, has been freed because the statute of limitations has run under Italian law.

Paolo Ferri, Hecht's prosecutor, points the fingers at the "system." but presumably Ferri was responsible for moving the case forward, and with a little less show boating, perhaps that might have actually happened within the allotted time.

In any event, without a conviction in such a high profile case, perhaps Hecht can feel vindicated, at least to some extent.

The Italian show trial did convince US Museums to repatriate significant pieces to Italy. I wonder though, whether any have any nagging doubts about that now, at least with respect to some pieces. Also, the trial likely helped convince the AAMD and others to adopt a 1970 provenance rule. The foolishness of that decision is only now being felt, but nagging doubts about that one will grow too as fewer and fewer items become available for accession under these rules.

Chasing Saddam's Butt

UK police have arrested a British veteran and have charged him with trying to sell a piece of a Saddam statute given to him by US Marines following the fall of Baghdad. See

The retired British special forces soldier had hoped to donate the proceeds to wounded veterans, but when the Iraqi Embassy got wind of the sale, they evidently demanded that British polices seize the item as their "cultural property."

The veteran has it right:

Describing the furore surrounding the buttock as farcical, Ely questioned how a piece of metal from a statue put up by a dictator could be classified as national cultural property.

The ex-soldier asked: "How can it be classed as cultural property when it was put up by the biggest tyrant since Attila the Hun?"

Ely believes that Iraqi officials decided to demand the return of the war relic after seeing media coverage of its value.

"American Marines gave it to me and at that time Baghdad was under American control," he added. "There wasn't even an Iraqi government and I have since turned it into a piece of war relic art.

"This is like having a chunk of the Berlin Wall – it's part of history but it's not cultural property."

Wednesday, January 18, 2012

There is No Reason for CPAC to Change its Recommendations on Coins

Here is my prepared oral statement regarding the proposed renewal of the MOU with Cyprus:

I’m speaking on behalf of IAPN and PNG, which represent the small businesses of the numismatic trade. In many ways, this hearing is a much greater test for CPAC than for coin collectors. Prior committees have twice recommended against import restrictions on coins for good reason. Yet, there will certainly be pressure to change course and to fall into line with the State Department’s controversial 2007 decision to impose import restrictions on “coins of Cypriot type.”

Each Committee member must ask themselves whether they can do so in good conscience after considering these undisputed facts, particularly because the restrictions at issue can lead to civil or criminal liability for American collectors and the American small businesses of the numismatic trade, including seizure of their coins:

1. Coins were evidently placed on the designated list on the orders of former Undersecretary Nicholas Burns – now of Harvard University’s Kennedy School-- as a “thank you” to Cypriot advocacy groups which had given him an award;

2. Jay Kislak, CPAC’s former chair, has stated under oath that the State Department misled Congress and the Public about CPAC’s vote against import restrictions on coins;

3. In 2007, the AIA claimed that Cypriot coins “rarely circulated” to justify restrictions on “coins of Cypriot type.” However, a top Cypriot official has admitted that “It is true that Cypriot coins shared the same destiny as all other coins of the ancient world. As a standard media of exchange they circulated all over the ancient world due to their small size, which facilitated their easy transport…” Moreover, this view has substantial scholarly support, as set forth in our papers;

4. The CPIA requires less drastic remedies to be tried first before import restrictions are imposed, but Cyprus has no coherent regulatory scheme for metal detectors and even allows British tourists to bring them to the Island;

5. Restrictions imposed on unprovenanced “coins of Cypriot type” only discriminate against American collectors and the small businesses of the numismatic trade; such coins may be shipped from abroad to anywhere but the USA, including Cyprus.

Moreover, there is no good reason to renew the MOU for yet another 5 years. Cyprus has already had the benefit of restrictions since 1999 on ethnological artifacts and 2002 on archaeological artifacts. Yet, a Swiss scholar reports most looted material goes to wealthy Greek Cypriot collectors, and not as has been maintained to collectors abroad. In addition, all this appears to be done with the full knowledge and acquiescence of Greek Cypriot authorities. Under the circumstances, why should the US burden its own citizens and small businesses with such restrictions? To do so will only reward Cypriot authorities for their own hypocrisy and thus make a mockery of the supposed purpose of such MOU’s to protect archaeological context.

In sum, please give heed to the 77% of the public comments posted on the website opposed to import restrictions on coins. Thank you.

Tuesday, January 17, 2012

Acropolis for Rent

In a move that will no doubt leave archaeological purists aghast, the bankrupt Greek state is considering putting up its major historical sites for rent:

Hopefully, the next step will be the deaccession of excess museum inventory and the creation of a licit antiquities and numismatic market in the country.

What better way to generate much needed cash and to end a corrupt system that allows only the connected to collect what they want.

Addendum: Perhaps the Acropolis is not for rent after all:

Tuesday, January 10, 2012

No Shipment to the USA

The practical impact of import restrictions should be made crystal clear with these words, "No Shipment to the USA."

This German dealer will no longer ship this Syracusian Tetradrachm to the USA, presumably because of import restrictions on "coins of Italian type." See

There is no indication this coin is a "fresh find." Indeed, given its toning, this coin has likely been in a collection for years. Yet, since the dealer has not identified this coin as being pictured in an auction catalogue or price list dating from before the restrictions, the dealer cannot ship it to the USA lest it be seized by US Customs and returned to its presumptive supposed find spot, the modern day Republic of Italy. (Though US Customs is supposed to accept certifications that such coins were out of the country before the date of restrictions, even where this information is available, Customs has been known to reject them absent auction catalogue citations.)

Yet, the same coin can be shipped to collectors ANYWHERE else in the world, including within Italy. How then do the restrictions comply with the CPIA's "concerted international response requirement" that was meant to the ensure the comity and effectiveness of import restrictions and also thus preclude any such discrimination against American collectors?

Metal Detectorists Preserve Artifacts Archaeologists Often Destroy or Ignore!

Karl also makes this intersting observation in his "Highway to Hell" article cited below:

But what are Austrian metal detectorists really digging up? Do they typically dig sizeable trenches, and do they dig down into stratified contexts? As far as can be ascertained from the results of my survey, they normally do neither. Rather, the overwhelming majority restrict their activities mostly to digging just the topsoil (Figure 10) and to digging pits of less than one-quarter of a square metre (Figure 11).

Yet, the topsoil is that part of an archaeological stratigraphy that is usually removed by a mechanical digger on the vast majority of Austrian excavations. This is true for pretty much all rescue excavations, and even for many, if not most, research digs. Manual removal of the topsoil is the rare exception to the rule, and even where this happens, the topsoil is rarely thoroughly searched for finds (least of all using a metal detector), if at all.

Thus, most of the activity of metal detectorists seems to be limited to those parts of archaeological stratigraphies neither observed nor documented in systematic archaeological excavations. It thus seems rather peculiar that we accuse these amateur archaeologists of intentionally destroying the archaeological contexts of their finds. After all, professional archaeologists rarely even bother attempting to recover the finds that derive from topsoil contexts; rather, they run them over with a large digger or remove them rapidly and with little regard for implementing intensive recovery strategies.

See more here:

Monday, January 9, 2012

On the Highway to Hell

Raimund Karl of Bangor University in the UK has written a thought provoking piece entitled, On the Highway to Hell: Thoughts on the Unintended Consequences for Portable Antiquities of Section 11 (1) Austrian Denkmalschutzgesetz. See

He concludes that a change in Austrian law has led metal detectorists to stop reporting finds they would otherwise report:

By effectively outlawing the use of metal detectors by members of the public to search for archaeological finds through § 11(1) DMSG, the many responsible amateur archaeologists who would be both willing to assist and interested in assisting with the protection of the archaeological heritage have been criminalized. This has completely removed many people’s motivation to report finds, intended to be strengthened by § 8 DMSG awarding a half share in the ownership of legally found and reported finds to the finder. As a result, most have practically stopped reporting any of their finds: this would, after all, be an at least implicit admission of having broken the law, resulting in the loss of any ownership rights to the finds according to § 400 ABGB, and possibly even inviting prosecution.

After reading his article, one might conclude that Professor Karl seems to be blessed with common sense that has detoured him away from the "highway to hell" that has been taken by some of his more ideological colleagues in the archaeological community.

Thursday, January 5, 2012


While some archaeo-bloggers are claiming that the 20% or so of the comments in favor of the extension of the MOU with Cyprus are somehow more profound than the 77% opposed (as if this makes up for the deficit), what they don't say, but which should be readily apparent from reviewing the comments is that virtually all those supporting the MOU are either archaeologists that depend on excavation permits from the Cypriot government to maintain their livelihoods, or are individuals or institutions otherwise dependent on the good graces of the Cypriot authorities to conduct their work.

That is not to say that the views of these individuals are not sincere. However, the fact that Cypriot authorities can easily monitor comments on the website may very well color what these individuals say, and thus make it even less likely that they will say anything at all that might depart from the Cypriot Government "party line."

For instance, do any of them so much as acknowledge what everyone knows-- that wealthy Greek Cypriot collectors are the major consumers of recently excavated antiquities on the Island and that they collect with the full knowledge and approval of Greek Cypriot authorities? Of course not.

In addition, the exceptionally low level of public support and its linkage almost exclusively to such "hangers-on" again suggests that the State Department's import restrictions regime is little more than a special interest program for archaeologists and other academic institutions that do business in Cyprus.

Wednesday, January 4, 2012

77% of Posted Comments Against Renewal of Cypriot MOU

John Hooker has performed the following analysis of the 338 comments posted on the website in response to the State Department's invitation to comment on the proposed renewal of the MOU with Cyprus:

The following results are rounded to 1% and are accurate to within 0.5%

Against the renewal of the MoU: 77%

For the renewal: 20%

This breaks down over the coin issue thus:

Those against the renewal that mentioned coins: 71%

Those against the renewal that did not mention coins: 6%

Those for the renewal that mentioned coins: 8%

Those for the renewal that did not mention coins: 12%

Inappropriate responses (6 people thought they were responding to a Peru MoU, one to the Bulgarian MoU): 3%

Putting a Happy Face on ECA's Work-- But No Mention of Its Import Restrictions Regime

The Bureau of Educational and Cultural Affairs has posted this year in review on the State Department's Blog:

Oddly, there is no mention at all about the Bureau's deeply unpopular effort to clamp down on American coin collectors. Instead, there is only a short reference to an agreement to help "protect" Greece's cultural heritage. Wonder why?

Tuesday, January 3, 2012

Chasing Aphrodite at the National Press Club

Jason Felch and Ralph Frammolino, investigative journalists and authors of "Chasing Aphrodite: The Hunt for Looted Antiquities at the World’s Richest Museum" will join Gary Vikan, director of the Walters Art Museum and Arthur Houghton, a former curator at the Getty Museum, to discuss looted antiquities and transparency in American museums at 6 p.m. Jan. 24 in the National Press Club ballroom.

The event will be moderated by James Grimaldi, investigative reporter for the Washington Post.

In "Chasing Aphrodite," their gripping art world detective story, Felch and Frammolino reveal the inner workings of the J. Paul Getty Museum and its quest to build a worldclass collection of Roman and Greek art. Hubris, greed and ethics are key themes in the book, which culminates with Italy’s criminal indictment of the Getty’s antiquities curator and the return of $1 billion of ancient objects from U.S. museums and private collections.

"Chasing Aphrodite" gives an unparalleled glimpse into the reality that lies behind many of America’s collections of ancient art. It is the culmination of five years of reporting that began with a Los Angeles Times series for which Felch and Frammolino were finalists for the Pulitzer Prize in 2006.

The National Press Club is located at 529 14th Street, NW - 13th Floor, Washington, DC 20045.

China's Disappearing Past: A Victim of Modernization or Greedy Foreign Collectors?

Here are two different reports with two very different conclusions about the reasons behind China's fast disappearing cultural history. See and

The first report repeats the usual "party line" of the archaeological community that the problem is due to gangs of looters working to supply collectors, particularly wealthy foreign ones. The State Department's broad import restrictions on Chinese cultural artifacts have been justified based on such reports, this despite the uncontested fact that by far the biggest collectors of ancient Chinese material are the Chinese themselves.

The second report attributes the destruction of China's cultural history to the vast construction projects going on in that quickly modernizing country. Why don't we hear more of this? Is it because such reports don't fit the narrative necessary to justify unpopular import restrictions that only impact American collectors and museums?

Monday, January 2, 2012

Turnabout is Fair Play

Archaeo-Blogger Paul Barford has sought to make sport of the heartfelt comments of ancient coin collectors opposed to the extension of the MOU with Cyprus. Accordingly, his own comments to CPAC deserve at least some scrutiny.

Barford has stated to CPAC:

As somebody deeply concerned about the illicit international trade in antiquities and other cultural property and the role of US dealers and collectors in this, I support the renewal of the MOU with Cyprus to help curb the movement of illicit antiquities across US borders by increased scrutiny of imports as per Art. 3 of the 1970 UNESCO Convention and the CCPIA. It gives out a strong message of US commitment to equable [sic] relations with the international community in such matters.

Comment: I don't doubt Mr. Barford's sincerity, but it should also be noted that Barford is apparently a contractor for UNESCO. This is at least as relevant to the validity of his views as his claims that US Dealers and collectors are motivated by financial interests in their opposition to these MOU's. It's interesting that Barford suggests that MOU's "give[] out a strong message of US Commitment to equable [equitable?] relations when these MOU's impose restrictions on Americans not borne by others including collectors in Cyprus.

The rich cultural heritage of Cyprus continues to be seriously threatened by looters who, in defiance of antiquity preservation laws, are systematically and clandestinely stripping sites of collectable items many of which are destined for sale on foreign markets. Cyprus applies the measures envisaged in the Convention to attempt to combat this looting but the financial temptations of the international no-questions asked market for smuggled goods (and the US market plays a potentially big role) encourage criminals to try and subvert these efforts.

Comment: A Swiss academic who has studied the issue has concluded that most looted artifacts no longer go abroad and instead go into collections of wealthy Cypriot collectors with the full knowledge and acquiescence of Cypriot authorities. Under the circumstances, Greek Cypriot Government propaganda repeated here masks a different truth.

I would ask the CPAC to urge the appropriate US authorities to pay especial attention to the US trade (both across the country’s borders as well as internally) in what the trade persists in calling “minor antiquities”, and in particular in dug-up coins. Coins like any other archaeological artefacts illegally taken out of the archaeological record and unlawfully exported cannot be exempt from scrutiny. Yet this is what the people who profit from trading this type of material would apparently like to see. It cannot fail to escape the notice of the CPAC that US coin dealers and their lobbyists are currently engaged in active opposition to the imposition of import controls on items without documentation of lawful export (19 U.S.C. 2606) which can only draw attention to the current form of the market for such items in the US. The comments in this docket include those of a few hundred collectors (among the 50 000 collectors of ancient coins the lobby group the Ancient Coin Collectors’ Guild claims). They, fired up by the alarmist rhetoric of the dealers’ lobbyists, oppose restricting imports onto the US market to only those with documentation of what the CCPIA considers to be lawful export. Their collective voice in favour of the reintroduction of an unrestricted flow onto the US market of freshly imported archaeological artefacts such as ancient coins without documentation of lawful export shows why it is so important that US vigilance is maintained.

Comment: Barford misstates the impact of import restrictions and thus mischaraterizes the nature of the opposition. Barford suggests that restrictions only impact freshly imported archaeological artifacts from Cyprus. In fact, import restrictions impact all imports of coins of Cypriot type from legitimate markets abroad. Such restrictions are grossly overbroad. Coins legitimately for sale in the UK or Germany cannot be imported under these restrictions without detailed documentation that does not exist for most ancient coins. Even worse, US Customs has evidently taken the position that coins of Cypriot type on the designated list may only be imported if they are pictured in an auction catalogue predating the 2007 restrictions. This bars entry of virtually all Cypriot coins. In addition, the "current form of the market in the US" Barford complains about is no different than the "current form of the market" in the EU, of which Cyprus is a part. As such, restrictions only discriminate against American citizens.

The US needs to maintain their [sic] tough stance with anyone attempting to abuse the system and continue to seize illicitly-exported material of this type at the US borders (in accordance with the measures envisaged by the 1970 Convention), and in doing so help make international controls on the movement of illicit artefacts more effective.

Closer scrutiny of archaeological and ethnographic material of Cypriot origin crossing US borders is a non-drastic means of providing this help and respecting the obligations of the USA and other states parties under the 1970 UNESCO Convention.

Comment: US Customs already has plenty of tools at its disposal to interdict artifacts looted from Cyprus (including claims of smuggling and theft) without resort to grossly overbroad restrictions that only discriminate against American citizens. If such restrictions are such a good idea, how come only the US applies them? And if Mr. Barford is so concerned about Cypriot cultural heritage, shouldn't he spend at least as much time railing against corrupt Cypriot practices as he does against American collectors?