Cultural Property Advisory Committee Meeting, September 24-26, 2024 to Discuss New MOUs with Lebanon and Mongolia and a Renewal With El Salvador

The State Department’s website has given advanced notice of a Cultural Property Advisory Committee Meeting to discuss new cultural property Memorandums of Understanding (MOUs) with Lebanon and Mongolia and a renewal with El Salvador.

The proposed MOU with Lebanon should be highly controversial. The UNESCO Convention assumes that nation states are the “best stewards” of cultural heritage and MOUs authorize US Customs to repatriate cultural goods seized under them to their care.  But Lebanon is a failing state.  The power there is not in the weak and corrupt government, but Hezbollah (“the Party of God”), a heavily armed Shiite militia group that acts as the Iranian regime’s proxy force against Israel and the United States.  The United States Government has designated  Hezbollah as a terrorist organization, and right now, it has been raining down rockets on Northern Israel,  forcing residents to flee.   Israel, of course, has retaliated, shelling and bombing  parts of Lebanon intensively in an effort to root out Hezbollah terrorists and their allies.

How then can a MOU with Lebanon even be considered?  Repatriating objects to failed states that have become war zones is not a recipe for their “protection” under any circumstance.  Moreover, the State Department's Cultural Heritage Center and its  "partner organization," the Antiquities Coalition, have claimed that "looted antiquities" are a significant terrorist funding source.  RAND Corporation and others dispute such claims, but given that “narrative” shouldn’t the State Department also be concerned that Hezbollah will resell whatever may be returned for funds?

The public session will take place September 24, 2024, at 2:00 p.m. (EDT).

 Public comments will be due no later than September 16, 2024. 

Proposed new MOUs with Lebanon and Mongolia that will likely again cover collectors coins that circulated regionally or internationally making it difficult to import them from legitimate markets in Europe again underscores the need for HR 7865.  More here: https://accguild.org/HR-7865

Addendum (8/19/24):  Regulations.gov is now accepting comments for these MOUs.  Here is a direct link to comment:  https://www.regulations.gov/document/DOS-2024-0028-0001

Alternatively, go to Regulations.gov and then search for DOS-2024-0028.  

What should you say?  Of course, it is much better to speak in your own words, but here is a template for coin collectors:

CPAC should reject any MOU with Lebanon.  Any such MOU would not help "protect" cultural heritage.  Rather, repatriating artifacts would be disastrous for their continued preservation.  Lebanon is a failed state dominated by Hezbollah, a terrorist group and Iranian proxy at war with Israel and the United States.  There is no money to properly preserve artifacts and there is a real danger they will be either destroyed in a conflict or sold to fund Hezbollah's terrorist activities.  

Additionally, there is no reason to apply import restrictions to coins for Lebanon, Mongolia or El Salvador.  For most of their history, these countries were but small parts of much larger Empires, meaning all or most all coins that circulated there also circulated in much greater quantities elsewhere.  One simply cannot assume that coins of a particular type were found there, a prerequisite for them being restricted under the governing statute.    

State Department and Customs Impose Broad Import Restrictions on behalf of Tunisian Government

The State Department and US Customs have imposed import restrictions on behalf of Tunisia’s increasingly authoritarian government that cover an exceptionally  broad range of archaeological (dating from approximately 200,000 BC to 1750 AD) and ethnological (from approximately 1574 AD to 1881 AD) materials. Items listed include religious artifacts, coins and even rope!  

The restrictions on ethnographic materials at least implicitly apply to the cultural heritage of Tunisia’s displaced Jewish minority population. These restrictions recognize the rights of the Tunisian State to the ownership and control of such artifacts despite a history of religious discrimination aimed at the country's remaining Jews, and virulent antisemitism  exemplified by the recent attack on one of the country’s few remaining synagogues.

The restrictions on coins apply to a wide variety of ancient, medieval and early modern coins to 1750 AD, including Carthaginian types which also circulated elsewhere in North Africa, Spain and Italy:  

10. Coins—This category includes coins of Numidian, Carthaginian (sometimes called Punic), Roman provincial, Vandal, Byzantine, Islamic, Norman, and Ottoman types that circulated primarily in Tunisia, ranging in date from the fifth century B.C. to A.D. 1750. Numidian, Roman provincial, and Vandal coins were made primarily in bronze, though some Numidian and Vandal types occur also in silver. Carthaginian types occur in electrum, a natural pale yellow alloy of gold and silver. Local Byzantine and later coin types were made in copper, bronze, silver, and gold. Coins may be square or round, have writing, and show imagery of animals, buildings, symbols, or royal figures.

These latest overbroad  import restrictions on coins again points to the need for collectors to ask their member of Congress to cosponsor HR 7865, legislation to facilitate the lawful trade in ancient, medieval, and early modern coins.