Elkins suggests, without providing any supporting evidence, that the restrictions comply with the governing statute, the Convention on Cultural Property Implementation Act (CPIA), because such coins "primarily circulated in and are found in ancient Bulgaria." But the plain meaning of the statue only allows for restrictions of artifacts "first discovered within" and "subject to the export" control of Bulgaria, a far stricter standard. 19 U.S.C. Section 2601 (2). Moreover, there is a real question whether restrictions on "Greek coins from nearby regions that are found in Bulgaria" provides importers with fair notice of what is restricted, a requirement not only of 19 U.S.C. Section 2604 but of constitutional due process.7. Coins – In copper, bronze, silver and gold. Many of the listed coins with inscriptions in Greek can be found in B. Head, Historia Numorum: A Manual of Greek Numismatics (London, 1911) and C.M. Kraay, Archaic and Classical Greek Coins (London, 1976). Many of the Roman provincial mints in modern Bulgaria are covered in I. Varbanov, Greek Imperial Coins I: Dacia, Moesia Superior, Moesia Inferior (Bourgas, 2005), id., Greek Imperial Coins II: Thrace (from Abderato Pautalia) (Bourgas, 2005), id., Greek Imperial Coins III: Thrace (from Perinthus to Trajanopolis), Chersonesos Thraciae, Insula Thraciae, Macedonia (Bourgas 2007). A non-exclusive list of pre-Roman and Roman mints include Mesembria (modern Nesembar), Dionysopolis (Balchik), Marcianopolis (Devnya), Nicopolis ad Istrum (near Veliko Tarnovo), Odessus (Varna), Anchialus (Pomorie), Apollonia Pontica (Sozopol), Cabyle (Kabile), Deultum (Debelt), Nicopolis ad Nestum (Garmen), Pautalia (Kyustendil), Philippopolis (Plovdiv), Serdica (Sofia), and Augusta Traiana (Stara Zagora). Later coins may be found in A. Radushev and G. Zhekov, Catalogue of Bulgarian MedievalCoins IX-XV c. (Sofia 1999) and J.Youroukova and V. Penchev, Bulgarian Medieval Coins and Seals (Sofia 1990).a. Pre-monetary media of exchange including “arrow money,” bells, and bracelets. Approximate date: 13th century B.C. through 6th century B.C.b. Thracian and Hellenistic coins struck in gold, silver, and bronze by city-states and kingdoms that operated in the territory of the modern Bulgarian state. This designation includes official coinages of Greek-using city-states and kingdoms, Sycthian and Celtic coinage, and local imitations of official issues. Also included are Greek coins from nearby regions that are found in Bulgaria. Approximate date: 6th century BC through the 1st century B.C.c. Roman provincial coins – Locally produced coins usually struck in bronze or copper at mints in the territory of the modern state of Bulgaria. May also be silver, silver plate, or gold. Approximate date: 1st century BC through the 4th century A.D.d. Coinage of the First and Second Bulgarian Empires and Byzantine Empire – Struck in gold, silver, and bronze by Bulgarian and Byzantine emperors at mints within the modern state of Bulgaria. Approximate date: 4th century A.D. through A.D. 1396.e. Ottoman coins – Struck at mints within the modern state of Bulgaria. Approximate date: A.D. 1396 through A.D. 1750.
Finally, it's worth noting that the same coins that are now restricted for American collectors are freely and legally available for sale within Bulgaria itself, and that public comments received by CPAC were overwhelmingly against restrictions:of the 499 relevant comments posted on the regulations.gov website (a few meant for the MOU with Belize were listed on the docket for Bulgaria), 353 (mostly coin collectors) were opposed to the MOU while only 146 favored it (or 71%-29%). So, we again have a situation where State and Customs have not only ignored the law but the majority of public comments. More evidence, if any were needed, that the entire CPAC process has become a farce of the sort we hear is common in infamously corrupt places like Bulgaria, but supposedly not here in our own Democracy.