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.”