Upcoming CPAC Meeting of Biden Holdovers Should Be Postponed

On December 4, 2024, the State Department Cultural Heritage Center provided advance notice of a Cultural Property Advisory (CPAC) meeting to address a new cultural property memorandum of understanding (MOU) with the Socialist Republic of Vietnam and renewals of current agreements with Chile, Italy and Morocco.

Coin collectors and the trade are concerned that this CPAC hearing is being rushed through to avoid Trump Administration scrutiny of  a likely effort to place new import restrictions on widely collected Roman Imperial coins on behalf of Italy.  Others have expressed concern that  any agreement with Communist Vietnam would impact the ability of refugees to import their own cultural heritage. Based on a review of posted comments, none of these MOUs or renewals would seem to have much public support.

There is no good reason why the CPAC meeting needs to be conducted now.  The current MOUs with Italy and Morocco do not expire until 2026 and the current agreement with Chile does not expire until September 2025.  There is no “emergency” impacting Vietnamese cultural goods requiring prompt action.

All CPAC members are holdover Biden political appointees, some of whom are openly hostile to collecting.  State Department Cultural Heritage Center staff are associated in one way or the other with archaeological advocacy groups that offer unqualified support for MOUs being used to “claw back” virtually all cultural goods so they can be repatriated to their countries of origin.  These archaeological advocacy groups have also received substantial State Department funding to help create and justify these cultural property MOUs.  

As of today, the current February 4, 2025 CPAC hearing is set to go forward even though the last time an important Cultural Property MOU with China was being considered, the State Department postponed that hearing so that any Trump I holdovers could be replaced by Biden appointees (who would be more likely to bless this controversial agreement). 

Moreover, the hearing is taking place despite the existence of President Trump’s “regulatory freeze.”

Under the circumstances, if this meeting is not postponed, it could be viewed as a bureaucratic effort to undermine Trump executive authority in order to push through new import restrictions despite the vast number of comments received on the issue. 

Low Public Support for Renewal of MOU with Italy, New MOU with Vietnam and Other Renewals for Chile and Morocco

The comment period for next week's CPAC meeting to address a renewal of the MOU with Italy, a new MOU with Vietnam, and other renewals with Chile and Morocco has now closed.  

A total of 214 comments were uploaded.  

Here a breakdown of comments by subject matter:

Coins: 176/214

Chile: 48/214

Italy: 131/214

Morocco: 52/214

Vietnam: 47/214

 Most of the comments (about 80%) came from coin collectors or dealers concerned about new or renewed import restrictions, particularly possible new restrictions on Roman Imperial coins on behalf of Italy.

There were very few comments calling for import restrictions on coins.   All came from either archaeological advocacy groups or archaeologists associated with these groups.  

The American Society of Overseas Research (ASOR), the Archaeological Institute of America, and ATHAR were the only archaeological groups that appear to have engaged on the issues.   The Committee for Cultural Policy, Global Heritage Alliance, and CINOA posted comments questioning the MOUs or proposed import restrictions.  A number of numismatic groups commented, particularly on Roman Imperial coins:  American Numismatic Association; Ancient Coin Collectors Guild; International Association of Professional Numismatists; and the Oriental Numismatic Society.

The renewal of the Italian MOU received the most support from archaeologists, but even here the numbers were limited.  This demonstrates once again that the MOU program which is pitched as a “soft power” effort, really has very small constituency.  It also should be noted that one of these commenters, ASOR, is a major State Department contractor which has received considerable funding to write reports to help justify cultural property MOUs.  

Are Trump DOGE budget cutters watching?