The Virginia Museum of Fine Arts presents Treasures of Ancient Egypt: Sunken Cities. The exhibition showcases treasures recovered from two powerful ancient Egyptian cities that sank into the Mediterranean more than a thousand years ago. Destroyed by natural catastrophes in the 8th century AD, Thonis-Heracleion and Canopus were once mighty centers of trade, where Egyptian and Greek cultures merged in art, worship, and everyday life. In addition to objects recovered through underwater archaeology, the exhibit also includes some show stoppers from the Egyptian museum. It is well worth a visit! Social distancing is relatively easy because the pandemic has unfortunately kept many visitors away. The exhibit continues through January 18th. For more, visit the VMFA's website.
Thursday, November 19, 2020
At the VMFA, Treasures of Ancient Egypt: Sunken Cities
Thursday, October 29, 2020
Summary of Oct. 27, 2020 CPAC Meeting to Accept Public Comments on Proposed MOU with Nigeria and Proposed Renewals with Bolivia and Greece
On October 27, 2020, the US Cultural Property Advisory Committee (“CPAC”) met to consider a proposed MOU with Nigeria and proposed renewals with Bolivia and Greece. The following members were present: (1) Stefan Passantino (Chairman- Public); (2) Steven Bledsoe (Public); (3) Karol Wight (Museums); (4) J.D. Demming (Public); (5) Ricardo St. Hilaire (Archaeology); (6) Joan Connelly (Archaeology) and (7) Anthony Wisniewski (Collector-Sale of International Cultural Property). Allison Davis, CPAC’s State Department Executive Director, and Catherine Foster, a Cultural Heritage Center staffer, were also present.
In advance of this meeting, there was a major shake-up on CPAC. The following Obama appointees were removed or resigned: (1) Adele Chatfield-Taylor (Public); (2) James Reep (Public); and (3) Lothar Von Falkenhausen (Archaeology). At the last CPAC public session to discuss a renewal the MOU with Italy, von Falkenhausen told ancient coin collectors (who were represented at the meeting) that he believed that they should take up another hobby. It is unclear if this comment had anything to do with his departure. President Trump appointed Messrs. Bledsoe and Demming to replace Ms. Chatfield-Taylor and Mr. Reep. One archaeological slot remains unfilled.
Chairman Passantino welcomed the speakers. He indicated that the Committee had read all the comments, and that given the large number of speakers, each would only be allowed 3 minutes to focus on points most important to them. Chairman Passantino called on speakers who had put in papers on Nigeria first, then speakers who had written about Bolivia, and finally Greece. There was some overlap because some speakers put in papers on more than one topic. He deferred questions to the end to be assured everyone who registered to speak would be heard.
The following individuals provided public comments: (1) Tess Davis (Antiquities Coalition); (2) Brian Daniels (Archaeological Institute of America); (3) Kathleen Bickford (Northwestern University); (4) Leslye Amede Obiora (Institute for Research on African Women, Children and Culture); (5) Kate FitzGibbon (Committee for Cultural Policy); (6) Donna Yates (Maastricht University); (7) Maria Bruno (Dickinson College); (8) Kris Lane (Tulane University); (9) Daniel Sedwick (International Association of Professional Numismatists); (10) Peter Tompa (Global Heritage Alliance); (11) Christos Tsirogiannis (University of Aarhus, Denmark); (12) Kim Shelton (Berkley); (13) Nathan Elkins (Baylor University); (14) Ute Wartenberg-Kagan (Columbia University); (15) Morag Kersel (DePaul University); (16) Dmitry Narkesis (Columbia University); (17) Rocco Dibenedetto (Hahn Loeser- Association of Art Museum Directors); (18) Douglas Mudd (American Numismatic Association); and (19) Randolph Myers (Ancient Coin Collectors Guild).
Tess Davis (TD) indicates that the Antiquities Coalition works with partners in the art market, the U.S. Government and Foreign Governments. She believes import restrictions help protect the legitimate market. She denies that import restrictions act as embargoes because they allow listed material into the country that has been documented as being outside the country for which restrictions were provided before those restrictions went into place. She also believes that U.S. customs should not accept export certificates from other EU governments where objects have been listed for specific EU countries like Greece. She notes certain EU countries do require export permits within the EU despite the general free circulation of goods within the EU.
The Antiquities Coalition’s written comments can be found here:
Brian Daniels (BD) focuses on the Fourth Determination under the Cultural Property Implementation Act (“CPIA”), regarding the international exchange of cultural patrimony. He notes that Nigeria has sent several exhibits to the United States. Most recently, the Block Museum of Art at Northwestern University (Greater Chicago) hosted the 2019 exhibition, Caravans of Gold, Fragments in Time: Art, Culture, and Exchange across Medieval Saharan Africa, which displayed the scope of Saharan trade and the shared history of West Africa, the Middle East, North Africa, and Europe from the eighth to sixteenth centuries. This exhibition involved significant loans from Nigeria. It was slated to travel to the National Museum of African Art, Smithsonian Institution (Washington, D.C.) in 2020, but its opening has been postponed due to COVID-19. He indicates that both Bolivia and Greece have been similarly generous in sending exhibitions to the United States.
The Archaeological Institute of America’s written comments can be found here:
Kathleen Bickford (KB) discusses her role as curator for the Caravans of Gold exhibit for the Block Museum of Art at Northwestern University. She states Nigeria's request meets all criteria for determinations in favor of cultural property protections. Important cultural patrimony, ranging from fragments to complete objects, continue to emerge from archaeological sites within the country, while objects of more recent date remain within communities and at royal courts, as well as in homes, shrines, and storehouses. These objects are under severe threat from pillage and theft. Despite efforts to curtail the international market for archaeological and traditional objects from Nigeria, including tighter requirements on provenance among North American museums and accelerating debates about the restitution of African objects from the colonial period, there continues to be a high demand in the international art market for cultural heritage objects from Nigeria. She also indicates there are many fakes on the market. Finally, she notes that there is much violence in Nigeria and that cultural heritage is a unifying force.
KB’s written comments can be found here:
Leslye Amede Obiora (LAO) has been a Professor of Law in the United States since 1992. She previously served as the Minister of Mines and Steel Development for the Federal Republic of Nigeria. She states cultural heritage issues are human rights issues. LAO indicates there is a cabal of powerful people involved in looting in Nigeria. She believes a MOU will help bolster civil society, and she wonders why it has taken so long for the United States to offer one to Nigeria.
Kate FitzGibbon (KFG) indicates that the Committee for Cultural Policy and Global Heritage Alliance applaud efforts to help Nigeria address looting, but question whether sufficient evidence has been submitted to support entering into a MOU. There are many Nigerian materials on the market and in private and museum collections, but the vast majority of these materials left Nigeria decades ago. Most of this material was removed during the colonial era. Material produced after 1945 is considered touristic in nature. There is little in the record about Nigerian self-help measures. KG is concerned that this request is about closing the barn door after the horses have already left.
The CCP’s and GHA’s written comments on the Nigerian MOU may be found here: https://culturalpropertynews.org/nigeria-support-cultural-expansion-not-art-blockade/
The CCP’s written comments about the Greek MOU can be found here:
Donna Yates (DY) indicates that she has tracked illicit Colonial and Republican era Bolivian artifacts. She indicates that while there appears to be less thefts from churches now, it takes years for this material to surface on the market. DY also indicates there is absolutely no social, educational, or scientific benefit to allowing a market for illegally obtained Bolivian cultural objects to exist in the United States. The destruction of the original contexts of these objects in the looting process annihilates our ability to conduct any meaningful archaeological analysis on them. The violent removal of sacred art from churches tears the very fabric that has held small and indigenous communities together for centuries, reducing cultural diversity and survival.
DY’s written comments can be found here:
Maria Bruno (MB) states that Bolivian patrimony remains in jeopardy from pillage through the illicit excavation of archaeological sites with the purpose of selling desired objects. Bolivian governmental and volunteer organizations work tirelessly to protect archaeological sites from destruction and to educate the public on the value of preserving their ancient past. Local communities also work together to protect their local patrimony from destruction as the revenue generated from tourism to the site provides jobs and contributes to the local pride.
MB’s written comments can be found here:
Kris Lane (KL) shares the archaeologists’ concerns about looting, but thinks coins should be treated differently than other objects, like historic records. While archives should not be removed from their place of origin, items like coins were not state property and were intended to circulate far from where they were made. This is certainly the case for coins struck in Bolivia. The Bolivian gold escudo and silver peso were international currencies. They were even legal tender in the United States before the Civil War.
Dan Sedwick (DS) indicates that IAPN supports Bolivian efforts to restore the Potosi mint. DS provides some history. Bolivian coins are very common. DS has always had some in inventory. Minting in Bolivia begins with hand-struck silver coins in 1573-4 under Spanish dominion and continues through early Republic times starting in 1825 to present day. Throughout these four-and-a-half centuries of minting, most of the coins were the property of rich men back in Spain, not the people of Bolivia, and these coins traveled far from the current boundaries of Bolivia, in fact to all the continents of the earth except Antarctica. DS also notes that IAPN’s submission shows that current Bolivian laws do not explicitly treat coins as cultural heritage. As for Greece, DS states this renewal should not be an excuse to expand current import restrictions to trade coins that circulated around the ancient world.
The International Association of Professional Numismatists’ and the Professional Numismatists Guild’s written comments can be found here:
Peter Tompa (PT) discusses both the Greek and Bolivian MOUs. First, as to the proposed renewal of the Greek MOU, he states that this renewal is no excuse to expand current import restrictions. Those restrictions purport to only apply to coin types that circulated locally in Greece in order to comply with the statutory requirements found in 19 U.S.C. § 2601. That provision requires that such coins were “first discovered within” and are therefore subject to Greek export controls. Under no circumstances should CPAC recommend expanding those restrictions to widely circulating trade coins which can be found most anywhere. Second, CPAC should recognize the obvious ramifications of Greece’s membership in the European Union (“E.U.”). Coins on the current designated list may be traded outside the E.U. with or without an export license according to the local law of Greece’s sister E.U. members. CPAC, the State Department and U.S. Customs and Border Protection (“CBP”) should honor these E.U. export controls, which, after all, are also binding on Greece as an E.U. member. Finally, he urges that archaeologists be asked to do their own part too. CPAC should ensure archaeological missions pay diggers a fair living wage and that they be required to file site security plans which take advantage of modern electronic surveillance technology.
PT’s full oral statement can be found here: http://culturalpropertyobserver.blogspot.com/2020/10/this-is-no-time-to-expand-restrictions.html
GHA’s written comments on the Greek MOU can be found here:
GHA’s and CCP’s written comments on the Bolivian MOU can be found here:
Christos Tsirogiannis (CT) has worked with law enforcement, including the DA in New York City and U.S. Homeland Security, to repatriate artifacts to Greece and other countries. He is also working on a way to detect looted antiquities using new technology. Recently, Greek police broke up a antiquities smuggling operation in Patras, Greece, that had coins and other artifacts.
CT’s written comments can be found here:
Kim Shelton (KS) excavates at Nemea. She has spent sleepless nights in fear of looters. Economic austerity has made the problem worse. Coin evidence is important to her work.
Nathan Elkins (NE) supports restrictions on all ancient coins that circulated in quantity in Greece, including trade coins like Athenian Tetradrachms, which currently are not restricted. Looting results in the loss of important contextual information. Coins can be important dating tools. They helped date the ruins of an ancient Synagogue he helped excavate in Israel.
NE’s written comments can be found here:
Ute Wartenberg-Kagan (UWK) supports restrictions on all ancient coins that circulated in quantity in Greece. Coins are among the most frequently looted items. Once taken out of their archaeological context, some of the historical and economic meaning is often lost. Sadly, numismatists are used to working with coins that have no archaeological context, and the fact that there is a finite number of coins in the ground makes their protection all the more important. Unfortunately, the trend is going very much in the wrong direction, and here modern technology enables looting on a scale that has not been seen before. Ever more sophisticated and cheaper metal detectors allow more people to dig up coins. Online sales via eBay, vcoins, Amazon, or in Facebook groups, allow the sale of staggering numbers of coins. On any given day, over 100,000 ancient coins and coin lots are for sale on eBay. MOUs should be considered friends of collectors because they help keep looted material off the market.
UWK’s written comments can be found here:
Morag Kersel (MK) says she was interviewing a collector who had a Cyclodelic figurine which the collector said was worth $1 million. He indicated now that ancient art is an investment. MK indicates that the high prices for ancient art helps stimulate looting.
Dmitry Narkesis (DN) has witnessed looting at archaeological digs. Looting is real problem that impacts archaeology. It takes a lot of time and effort to try to fight it.
Rocco Dibenedetto (RD) states that the AAMD does not oppose the Greek MOU, but Greece should be held to account for its obligations under Art. II of the current agreement. One of those undertakings is to facilitate loans of materials to U.S. museums. Despite Greece’s promises to do so, that has not happened. The designated list should also be scrutinized to ensure that it only covers archaeological objects over 250 years old.
The AAMD’s written comments can be found here:
Douglas Mudd (DM) states that current import restrictions have hurt the ANA’s educational mission because foreign scholars have been unwilling to bring their collections to the United States for fear of them being seized by U.S. customs. Despite import restrictions being renewed over and again, looting remains a problem which suggests they are not working. DM states that a new paradigm needs to be considered given their failure, one based on Britain’s Portable Antiquities Scheme, which encourages people to report finds with the prospect of a cash award for any coins kept by the government. While expense is an issue, perhaps aid from wealthy countries can help get these programs going.
The ANA’s written comments can be found here:
Randolph Myers (RM) states there can be no dispute ancient coins circulated in great numbers far from where they were found. This is detailed in a report appended to the ACCG’s written comments. This is significant because as recognized by a U.S. District Court import restrictions are only appropriate on archaeological objects both first discovered within and subject to the export control of a specific country.
The ACCG’s written comments can be found here:
Question and Answer Period
Karol Wight asks LAO about the situation in Nigeria. LAO states Nigeria is under siege, but that is no reason not to enter into a MOU on its behalf. She again suggests a MOU is a human rights issue.
Anthony Wisniewski asks TD and DY if they receive foreign government money. (The State Department recently issued a directive calling for the disclosure of such information. See https://www.politico.com/news/2020/10/13/trump-think-tanks-foreign-funding-429209) TD states that the Antiquities Coalition does not receive such funding. DY indicates she receives such funding from the European Union. (She currently holds a €1.5 million European Research Council grant to study the illicit trafficking of cultural objects.)
Anthony Wisniewski asks UWK if it is unremarkable that Roman or Byzantine coins from the Thessalonica mint can be found in large numbers in today’s Turkey and Albania. She agrees with this statement.
Joan Connelly asks KS about what coins have been found at Nemea. KS indicates that coins from many different Greek cities have been found there probably because it was the center for sacred games. They also find many different coins at a Christian sanctuary on the site.
Karol Wight asks KB if she has had any other interaction with Nigerian scholars outside her work on exhibits. KB says all her work has been on exhibits.
J.D. Demming asks DM to elaborate on his ideas to disincentivize looting. DM states that the U.K.’s Portable Antiquities Scheme incentivizes people to report their finds. Perhaps there can be a global antiquities scheme with funding from richer countries.
Ricardo St. Hilaire asks LAO about whether she saw any parallels between looting and illegal mining. LAO says Nigeria recognized that it takes a thief to catch a thief so it invested resources to help illicit miners become clean. She refers to DM’s statements about PAS and says there may be parallels.
Tuesday, October 27, 2020
This is no Time to Expand Restrictions; It is time to Facilitate Lawful Trade and Encourage Archaeologists to do Their Part
This is what I said more or less at today's CPAC hearing. I hope to summarize the public session to discuss a proposed MOU with Nigeria and proposed renewals with Greece and Bolivia shortly.
Thank you for this opportunity to speak to you on behalf of the Global Heritage Alliance. I also drafted comments on behalf of IAPN and PNG, so feel free to refer any detailed questions about those papers to me.
First, as to the proposed renewal of the Greek MOU, we would echo IAPN’s and PNG’s concerns that this renewal is no excuse to expand current import restrictions. Those restrictions purport to only apply to coin types that circulated locally in Greece in order to comply with the statutory requirements found in 19 U.S.C. § 2601. That provision requires that such coins were “first discovered within” and are therefore subject to Greek export controls. Under no circumstances should CPAC recommend expanding those restrictions to widely circulating trade coins which can be found most anywhere. Those coins can be found in many countries, including ones with no MOU with the U.S.
CPAC already considered the issue in 2010, and rejected the proponent’s request to expand current restrictions further when the MOU was renewed in 2016. There is simply no reason to revisit this decision, particularly when much of the coin trade is already being badly hurt by Covid related shut downs of coin shows. Indeed to do so would not only be contrary to the statutory requirements, but the words of Greece’s Ambassador who back in 2010 stated that Greece’s request only concerned “antiquities that have been found exclusively on Greek territory.”
Thursday, October 22, 2020
Trump Administration Finally Tilts CPAC Away from Archaeology Over All Perspective
Very late in his first (and if polls are to be believed perhaps his only) term, President Trump has finally tilted CPAC away from an archaeology over all perspective. Before he left office, President Obama loaded up CPAC with archaeological supporters in slots supposedly representing the interests of the the public, museums, and even the trade. Now, slots for the public and trade have been filled with Trump supporters who appear to come from business friendly backgrounds. Coincidentally or not, three (3) Obama appointees who recently either resigned or were removed left CPAC around the same time a coalition of ten (10) advocacy and trade groups wrote the State Department to express serious concerns about the extremist views found on CPAC. That letter provided as an example the statement of one of those individuals, now departed from CPAC, who told coin collectors testifying before CPAC that as far as he was concerned, they should take up another hobby. These became his "famous last words."
Wednesday, September 2, 2020
Slim Public Support for Renewal of MOU with Italy; Significant Opposition to Restrictions on Coins
A review of the comments posted on regulations.gov website with regards to a proposed renewal of the Italian MOU confirms slim public support for a renewal with Italy and significant public concerns expressed about current import restrictions on coins as well as any effort to extend those restrictions to late Roman Republican and Roman imperial coins.
Although 500 comments are listed on the regulations.gov website, only 456 are visible. Of these, only 13 letters were in support of the MOU with Italy (primarily from scholars), and 439 were either against the MOU or against import restrictions on coins. The few other comments related to the proposed MOU renewal with Colombia.
Monday, August 31, 2020
Calling all Collectors Again- Please Comment on Proposed Renewal of MOU with Greece
The State Department has announced a proposed renewal of a Memorandum of Understanding Concerning the Imposition of Import Restrictions on Categories of Archaeological and Byzantine Ecclesiastical Ethnological Material through the 15th Century A.D. of the Hellenic Republic. That MOU first authorized import restrictions on Greek cultural artifacts in 2011. It has been renewed once in 2016 without further changes. The initial MOU authorized import restrictions on certain ancient Greek coins. We hope to preclude any further expansion of those restrictions and advocate for acceptance of legal exports from fellow EU countries to be treated like a legal export from Greece.
Further information about the October 27, 2020 Cultural Property Advisory Committee (CPAC) meeting and how to comment before the October 13, 2020 deadline can be found here: https://www.federalregister.gov/documents/2020/08/20/2020-18262/cultural-property-advisory-committee-notice-of-meeting You should also be able to comment directly from this link (click on green “submit a formal comment” button in upper right hand corner).
A. Background for Coin Collectors
There are large numbers of coin collectors and numismatic firms in the US. Very few collectors do so to “invest.” Most collect out of love of history, as an expression of their own cultural identity, or out of interest in other cultures. All firms that specialize in ancient coins in the US are small businesses. Private collectors and dealers support much academic research into coins. For example, an American collector collaborated with academics to produce an extensive study of Seleucid coins. A further clamp down on collecting will inevitably lead to less scholarship.
While what became the Cultural Property Implementation Act (CPIA) was being negotiated, one of the State Department’s top lawyers assured Congress that “it would be hard to imagine a case” where coins would be restricted. In 2007, however, the State Department imposed import restrictions on Cypriot coins, against CPAC’s recommendations, and then misled the public and Congress about it in official government reports. What also should be troubling is that the decision maker, Assistant Secretary Dina Powell, did so AFTER she had accepted a job with Goldman Sachs where she was recruited by and worked for the spouse of the founder of the Antiquities Coalition, an archaeological advocacy group that has lobbied extensively for import restrictions. Since that time, additional import restrictions have been imposed on coins from Algeria, Bulgaria, China, Egypt, Greece, Iraq, Italy, Jordan, Libya, Syria and Yemen.
The current restrictions encompass coins the State Department evidently believes can only be found in Greece. U.S. Customs and the State Department describe these coin types as follows:
Coins—Many of the mints of the
listed coins can be found in B.V. 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 Greece are
listed in A. Burnett et al., Roman
Provincial Coinage I: From the Death of
Caesar to the Death of Vitellius (44 BC–
AD 69) (London, 1992) and id., Roman
Provincial Coinage II: From Vespasian
to Domitian (AD 69–96) (London, 1999).
a. Greek Bronze Coins—Struck by
city-states, leagues, and kingdoms that
operated in territory of the modern
Greek state (including the ancient
territories of the Peloponnese, Central
Greece, Thessaly, Epirus, Crete and
those parts of the territories of ancient
Macedonia, Thrace and the Aegean
islands that lay within the boundaries of
the modern Greek state). Approximate
date: 5th century B.C. to late 1st century
b. Greek Silver Coins—This category
includes the small denomination coins
of the city-states of Aegina, Athens, and
Corinth, and the Kingdom of Macedonia
under Philip II and Alexander the Great.
Such coins weigh less than
approximately 10 grams and are known
as obols, diobols, triobols,
hemidrachms, and drachms. Also
included are all denominations of coins
struck by the other city-states, leagues,
and kingdoms that operated in the
territory of the modern Greek state
(including the ancient territories of the
Peloponnese, Central Greece, Thessaly,
Epirus, Crete, and those parts of the
territories of ancient Macedonia, Thrace
and the Aegean islands that lie within
the boundaries of the modern Greek
state). Approximate date: 6th century
B.C. to late 1st century B.C.
c. Roman Coins Struck in Greece—In
silver and bronze, struck at Roman and
Roman provincial mints that operated in
the territory of the modern Greek state
(including the ancient territories of the
Peloponnese, Central Greece, Thessaly,
Epirus, Crete, and those parts of the
territories of ancient Macedonia, Thrace
and the Aegean islands that lie within
the boundaries of the modern Greek
state). Approximate date: late 2nd
century B.C. to 3rd century A.D.
Under current Customs procedures, the above types can only be imported into the United States with: (a) an export certificate issued by Greece (which is virtually impossible to procure); (b) “satisfactory evidence” demonstrating that the coins were exported from or were outside of Greece at least 10 years prior to importation into the U.S.; or (c) “satisfactory evidence” demonstrating that the coins were exported from or were outside of Greece before restrictions were announced on December 2, 2011. What constitutes “satisfactory evidence” is ultimately left to the discretion of Customs, but usually takes the form of a declaration by the importer and a statement by the consigner.
The current restrictions do not extend to Greek trade coins—like Athenian Tetradrachms and Corinthian Staters that are extremely popular with collectors. However, we cannot afford to take this for granted; we simply cannot assume that the archaeological lobby—which actively opposes private collecting—won’t press for “more” this time around. Accordingly, if one feels strongly about their continued ability to collect such coins, they should comment on the regulations.gov website. Why? Because silence will only be spun as acquiesce. So, serious collectors should oppose restrictions on coins or their expansion to widely circulating trade coins as unnecessary and detrimental to the appreciation of Greek culture and the people to people contacts collecting brings.
The cumulative impact of import restrictions has been very problematical for collectors since outside of some valuable Greek coins, most coins simply lack the document trail necessary for legal import under the “safe harbor” provisions of 19 U.S.C. § 2606. The CPIA only authorizes the government to impose import restrictions on coins and other artifacts first discovered within and subject to the export control of Italy. (19 U.S.C. § 2601). Furthermore, seizure is only appropriate for items on the designated list exported from the State Party after the effective date of regulations. (19 U.S.C. § 2606). Unfortunately, the State Department and Customs view this authority far more broadly. In particular, designated lists have been prepared based on where coins are made and sometimes found, not where they are actually found and hence are subject to export control. Furthermore, restrictions are not applied prospectively solely to illegal exports made after the effective date of regulations, but rather are enforced against any import into the U.S. made after the effective date of regulations, i.e., an embargo, not targeted, prospective import restrictions. While it is true enforcement has been spotty, CPO knows of situations where coins have been detained, seized and repatriated where the importer cannot produce information to prove his or her coins were outside of a country for which import restrictions were granted before the date of restrictions.
B. What You Can Do
Admittedly, CPAC seems to be little more than a rubber stamp. Still, to remain silent is to give the cultural bureaucrats and archaeologists with an ax to grind against collectors exactly what they want-- the claim that any restrictions will not be controversial.
For comments, either comment through the Federal Register notice above or use http://www.regulations.gov, enter the docket [DOS–2020–0036] and follow the prompts to submit your comments. Alternatively, click this link and click on the Blue “Comment Now” Button which should pull up a screen that allows you to comment https://www.regulations.gov/docket?D=DOS-2020-0036 (Please note comments may be posted only UNTIL Oct. 13, 2020 at 11:59 PM.). Alternatively, if this link does not work, as set forth further above, you should also be able to post via the Federal Register website: https://www.federalregister.gov/documents/2020/08/20/2020-18262/cultural-property-advisory-committee-notice-of-meeting
Please also note comments submitted in electronic form are not private. They will be posted on http://www.regulations.gov. Because the comments cannot be edited to remove any identifying or contact information, the Department of State cautions against including any information in an electronic submission that one does not want publicly disclosed (including trade secrets and commercial or financial information that is privileged or confidential pursuant to 19 U.S.C. 2605(i)(1)).
C. What Should You Say?
Friday, July 24, 2020
CPAC Meets to Discuss Renewals of Colombian and Italian MOU’s
Campaigns to increase awareness that pre-Columbian Native American artwork is not simply a potential economic resource have had an impact, as have enforcement efforts, but more remains to be done. Sadly, the US continues to be a major market for looted Colombian cultural materials.
In concluding, Mr. Russo also indicates that any effort to extend restrictions to Roman Republican and Imperial coins is simply ridiculous as it uncontested that the vast majority of these coins are found outside the boundaries of Italy. In closing, he reiterates that current restrictions should be frozen until Italy makes it easier to procure export licenses.