I am sharing the following from Wayne G. Sayles, Executive Director of the Ancient Coin Collectors Guild (ACCG). Please read my comment following Wayne’s letter.

The following is an extremely important message from Peter K. Tompa, ACCG Board Member and Chairman of the Legislative Affairs Committee:

Fresh on the heels of its deliberation over import restrictions on coins from Bulgaria, the US State Department has now announced a hearing on extension of the MOU (Memoranda of Understanding) with Cyprus that is now up for its 5-year renewal. The Cultural Property Advisory Committee is seeking public comment on the renewal request To submit comments electronically to the State Department’s Cultural Property Advisory Committee (CPAC), see below:

Those present restrictions bar entry into the United States of the following coin types unless they are accompanied with documentation establishing that they were out of Cyprus as of the date of the restrictions, July 16, 2007:

  1. Issues of the ancient kingdoms of Amathus, Kition, Kourion, Idalion, Lapethos, Marion, Paphos, Soli, and Salamis dating from the end of the 6th century B.C. to 332 B.C.
  2. Issues of the Hellenistic period, such as those of Paphos, Salamis, and Kition from 332 B.C. to c. 30 B.C. (including coins of Alexander the Great, Ptolemy, and his Dynasty)
  3. Provincial and local issues of the Roman period from c. 30 B.C. to 235 A.D.

Why bother to comment when the State Department rejected CPAC’s recommendations against import restrictions on Cypriot coins back in 2007 and then misled both Congress and the public about its actions? And isn’t it also true that although the vast majority of public comments recorded have been squarely against import restrictions, the State Department and U.S. Customs have imposed import restrictions on coins anyway, most recently on ancient coins from Greece?

Simply, silence just allows the State Department bureaucrats and their allies in the archaeological establishment to claim that collectors have acquiesced to broad restrictions on their ability to import common ancient coins that are widely available worldwide. And, of course, acquiescence is all that may be needed to justify going back and imposing import restrictions on the Roman Imperial coins that are still exempt from these regulations.

Under the circumstances, please take 5 minutes and tell CPAC, the State Department bureaucrats and the archaeologists what you think.

How do I comment? To submit comments three pages in length or less electronically, go here: http://www.regulations.gov/#!submitComment;D=DOS-2011-0135-0002.

If you are having trouble, go to the Federal eRulemaking Portal (http://www.regulations.gov), enter the Docket No. DOS-2011-0135 for Cyprus, and follow the prompts to submit a comment. To send comments via US Mail or FEDEX see the directions contained in the Federal Register Notice above. For further information, also see http://exchanges.state.gov/heritage/whatsnew.html.

What should I say? The State Department bureaucracy has dictated that any public comments should relate solely to the following statutory criteria:

  1. Whether the cultural patrimony of Cyprus is in jeopardy from looting of its archaeological materials;
  2. Whether Cyprus has taken measures consistent with the 1970 UNESCO Convention to protect its cultural patrimony;
  3. Whether application of U.S. import restrictions, if applied in concert with similar restrictions by other art importing countries, would be of substantial benefit in deterring a serious situation of pillage and that less drastic remedies are not available; and,
  4. Whether the application of import restrictions is consistent with the general interest of the international community in the interchange of cultural property among nations for scientific, cultural, and educational purposes.

(See 19 U.S.C. § 2602(a).) Yet, collectors can really only speak to what they know. So, tell them what you think within this broad framework. For instance, over time, import restrictions will certainly impact the American public’s ability to study and preserve historical coins and maintain people to people contacts with collectors abroad. Yet, foreign collectors-including collectors in Cyprus-will be able to import coins as before. And, one can also remind CPAC that less drastic remedies, like regulating metal detectors or instituting reporting programs akin to the Treasure Act and Portable Antiquities Scheme, must be tried first.

Be forceful, but polite. We can and should disagree with what the State Department bureaucrats and their allies in the archaeological establishment are doing to our hobby, but we should endeavor to do so in an upstanding manner.

For more information about these issues, see: http://culturalpropertyobserver.blogspot.com/

Please submit comments just once, before the deadline on Jan. 3, 2012.

With best wishes and thanks for your support,

Wayne G. Sayles
Executive Director

From Scott: I am not a collector of ancient coins, but as a member of the numismatic community, it bothers me that the State Department has been capitulating to nearly every foreign government regarding artifacts that have been in worldwide circulation for hundreds or thousands of years with no issue. Suddenly, when countries appear to have an issue with the United States, they appear to be using peripheral means to try to take action against the U.S. and its citizens. Allowing the State Department to entertain these types of actions should be abhorrent to any collector because if it begins with the ancient coins, then where does it stop?

To borrow the concept from Pastor Martin Niemöller’s “First they came…”:

First they came for the ancient coins,
and I didn’t speak out because I wasn’t a ancient coin collector.

Then they came for all foreign coins,
and I didn’t speak out because I wasn’t a foreign coin collector.

Then they came for the obsolete currency,
and I didn’t speak out because I wasn’t a obsolete currency collector.

Then they came for the pattern coins,
and I didn’t speak out because I wasn’t a pattern coin collector.

Then they came for my silver and gold United State coins,
and there was no one left to speak out for me.

Speak now before they come for your coins!

The letter was sent via email by Wayne Sales on December 15, 2011. It was reformatted to fit in this space and some information links were added.

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