US Customs has just announced very broad “emergency” import restrictions on “Lebanese” cultural goods:
These new rules are based on a decision rendered at the end of the Biden Administration which is being implemented by the Trump Administration.
The coverage is as follows:
The designated list set forth
is representative only. Any dates and dimensions are approximate.
The restrictions on coins are also extremely broad, including coins that circulated both regionally and internationally.
12. Coins and Other
Currency —Coinage has a great variety and long history in Lebanon that
spans the Achaemenid Persian, Hellenistic, Roman, Byzantine, medieval, and
early Ottoman periods. This category consists of coins in metals such as gold,
silver, billon (an alloy), copper, bronze, brass, and lead that are minted in
or found in Lebanon, as well as other forms of currency, such as metal bullion
or ingots and cut and weighed silver pieces ( hacksilber).
a. Iron Age Persian
Period— The earliest coinage of Lebanon dates to the Achaemenid Persian
Empire and consists of silver shekels, fractional denominations thereof, and
bronze coins minted in Sidon, Tyre, and Byblos. Some typical designs include
the king standing or running with a bow, slaying a lion, or processing in a
chariot; galley ships; chariots; walled cities; hippocamps; owls with an
Egyptian crook and flail; dolphins; sphinxes; griffins; vultures; rams; shells;
lotus flowers; Egyptian scepters; warriors; and lions and bulls in combat. May
bear Phoenician inscriptions or monograms. Includes Persian imperial and
Archaic Greek coins that also circulated in Lebanon during this period.
Approximate date: 510 to 332 B.C.E.
b. Hellenistic and Roman
Periods —Includes coins in gold, silver, and bronze on Phoenician, Greek,
and Roman weight standards. In this period, coins were minted in Sidon, Tyre,
Byblos, Beirut ( Berytus/Laodicea), Tripoli ( Tripolis), Batroun
( Botrys), Arqa ( Caesarea ad Libanum), Bhannine ( Orthosia),
Anjar ( Chalcis ad Libanum), and Baalbek ( Heliopolis) in the
name of Macedonian, Ptolemaic, Seleucid, and Roman rulers, or in the name of
the cities themselves. The obverse shows designs such as the bust of the ruler,
the god Heracles-Melqart, the city-goddess Tyche wearing a “mural” crown (in
the form of a walled city), or other figures. The reverse shows designs such as
various Hellenic, Roman, or local deities and heroes; temples and symbols of
the divine; or symbols like an eagle, palm tree, galley, ship's prow or stern,
club of Heracles, cornucopia, or legionary insignia. Inscriptions and monograms
may be in Greek, Latin, or Phoenician. Includes Hellenistic and Roman period
coins of other regional mints, such as Antioch, that circulated in Lebanon.
Approximate date: 332 B.C.E. to 498 C.E.
c. Byzantine Period
—Coins in gold, silver, bronze, copper, and electrum from regional mints such
as Constantinople, Nikomedia, Alexandria, Carthage, Antioch, Cyzicus, and
Thessalonica that circulated in Lebanon. Byzantine coins typically bore Greek
inscriptions. Some typical designs include a bust or standing figure of the
emperor facing forward on the obverse and Christian symbols and/or the letters
M, K, or I on the reverse. Includes coins issued by the Vandal mints of North
Africa that circulated in Lebanon in the 6th century C.E. Approximate date: 498
to 635 C.E.
d. Islamic Caliphates
—Coins minted during the Umayyad, Abbasid, Fatimid, Ayyubid, Mamluk, and early
Ottoman period including at Baalbek, Byblos, Tripoli, and Tyre. Coins were
minted in gold, silver, bronze, copper, and lead. The earliest Islamic coins in
Lebanon are imitations of Byzantine coin types (“Arab-Byzantine coins”). In the
Umayyad period and later, coins typically bore Arabic inscriptions on both
sides, and occasionally symbols, animals, or flowers. Includes coins of Islamic
dynasties from other regional mints, such as Damascus, Cairo, and Istanbul,
that circulated in Lebanon. Approximate date: 635 to 1774 C.E.
e. Crusader Period
—Coins in gold, silver, billon (an alloy), bronze, and copper minted at Tyre,
Sidon, Beirut, and Tripoli in the Crusader Kingdom of Jerusalem and County of
Tripoli. Designs often featured a cross, other Christian symbol, or building in
a central medallion surrounded by a Latin inscription. Other Crusader coin
designs imitated contemporary Islamic coinage with Arabic or pseudo-Arabic
inscriptions. Approximate date: 1095 to 1291 C.E.
The International Association of Professional Numismatists (IAPN) provided ample evidence that such overbroad restrictions were contrary to the Cultural Property Implementation Act's (CPIA's) mandate, but that evidence appears to have been ignored. See https://www.regulations.gov/comment/DOS-2024-0028-0021
At the Cultural Property Advisory Committee meeting, IAPN and others also pointed out that repatriating artifacts to a “failing state” like Lebanon is no recipe for their “protection.” Furthermore, they also warned that repatriating objects to Lebanon could benefit the Hezbollah terror group which effectively ran the Lebanese Government. See https://culturalpropertyobserver.blogspot.com/2024/09/summary-of-cpac-meeting-to-discuss.html
Under the circumstances, one must ask: Is this really an environment to even contemplate repatriating cultural artifacts to?
Indeed, that prospect seemed so concerning that CPO even thought it necessary to conjure up the spirits of Senators Moynihan and Dole, the CPIA's sponsors, to express their own doubts: https://culturalpropertynews.org/careful-collector-30-sending-art-and-antiquities-to-failed-states-no-recipe-for-preservation/
To be sure, due to Israel's actions killing much of Hezbollah's top-level leadership, Hezbollah’s influence has since diminished, but that influence still exists and Lebanon remains a failing state that may yet again slide back into war at any time.
Leaving aside the policy question of the wisdom of repatriating objects to a failing state, the major problem for US collectors is three-fold.
First, the Lebanese designated list is again grossly overbroad, incorporating items that are also found regionally or for coins, internationally.
Second, Customs (with the blessing of Judge Wilkinson of the 4th Circuit US Court of Appeals) believes all Customs need show is that an item is of a type on these increasingly overlapping designated lists before it can be detained, seized, and repatriated. https://culturalpropertynews.org/an-epic-battle-u-s-v-3-knife-shaped-coins/
Third, Customs (again with the blessing of the 4th Circuit) can apply these regulations as embargos on all “designated” items imported into the US after the effective date of the regulations rather than having to show that they were illicitly exported from Lebanon after that effective date.
While CPO does not read the CPIA that way, according to Judge Wilkinson and the 4th Circuit US Court of Appeals, all this is a “foreign policy matter” not subject to the Administrative Procedure Act or any meaningful judicial review.
And adding insult to injury, all this ultimately raises the question whether collectors now have fewer due process rights at least as far as Judge Wilkinson is concerned than illegal aliens who are also alleged to be MS-13 gang members. https://culturalpropertyobserver.blogspot.com/2025/04/should-american-collectors-get-at-least.html
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