Friday, March 18, 2022

Import Restrictions on "Albanian" Coins Announced

U.S. Customs and Border Protection has announced new import restrictions on "Albanian coins" as part of another overbroad laundry list of import restrictions on anything and everything that may be found in Albania from 300,000 B.C. to 1913.

Effective date:  March 17, 2022

Source: 87 FR 15079-15084 (March 17, 2022), available at               import-restrictions-on-categories-of-archaeological-and-ethnological-material-of

The Designated list of coins subject to import restrictions is as follows. 

8. Coins—This category includes coins of Illyrian, Greek, Macedonian, Roman provincial, Byzantine, Medieval, and Ottoman types that circulated primarily in Albania, ranging in date from approximately the 6th century B.C. to A.D. 1750. Coins were made in copper, bronze, silver, and gold. Examples are generally round, have writing, and show imagery of animals, buildings, symbols, or royal or imperial figures.

Comment:  The designated list of coins is particularly broad and includes coins that circulated regionally as well as internationally.  It goes far beyond coins that "primarily circulated" within Albania. Despite the assumption contained in the regulation, no Greek, Byzantine, and Ottoman types “circulated primarily” within Albania or were even made there.  As for Illyrian coins, hoard evidence indicates that popular cow/calf coins from the Roman Republican period “circulated primarily” in Romania, not Albania.  The only bright spot is that neither Roman Republican nor Roman Imperial coins seem to be restricted. 

A case can be made that the “circulated primarily” standard is statutorily deficient because it is contrary to the CPIA requirement that restricted items must be first discovered within and subject to export control of a particular country.  There also is a fair notice issue because how is a typical collector or dealer to know whether or not a particular issue “circulated primarily” in Albania or not?

It is frustrating that the State Department invites public comment, and then promptly ignores it. Both ACCG and IAPN prepared detailed papers about coin circulation in Albania, but either no one at the State Department bothered to read them or no one cared what facts were presented.

Another abuse of power designed to ensure the broadest possible import restrictions apply.