Sep 19, 2016 | ancient, coins, legal, policy
Here we go again… the government want to take your ancient coins away from you.
This is different from other conspiracy theories because since there is no mechanism for them. Here, foreign governments are working in collusion with the United States Department of State Cultural Property Advisory Committee (CPAC). The problem with CPAC is that it is not a real committee. They are largely a rubber-stamp part of the State Department’s Bureau of Educational and Cultural Affairs kowtowing to any foreign government who feels that items found in their country have been stolen from regardless of the evidence. This includes common ancient coins or coins that were removed from circulation long before the existence of the 1970 UNESCO Convention that created this situation.
If you want to read a more extensive discussion on the problems facing collectors of ancient coins, read my post “An ancient dilemma” from 2014.
The information comes from the Ancient Coin Collectors Guild (ACCG). Even if you are not a collector of ancient coins you should appreciate that the problems with governments wanting to stop your hobby. If they go after the ancients, what is to prevent these countries from trying to recall obsolete money? We need to support the ACCG and the community to prevent overreach by foreign governments and a committee who does not care what the coin collectors think.
Here’s the current issue as outlined by ACCG Executive Director Peter Tompa
Dear Fellow ACCG Member:
The State Department’s Bureau of Educational and Cultural Affairs and its Cultural Heritage Center have announced a comment period for a proposed extension of a Memorandum of Understanding (MOU) with Cyprus. See https://www.federalregister.gov/articles/2016/08/10/2016-19018/notice-of-meeting-of-the-cultural-property-advisory-committee
The U.S. Cultural Property Advisory Committee will review these comments and make recommendations based upon them with regard to any extension of the current agreement with Cyprus.
According to U.S. Customs’ interpretation of the governing statute, import restrictions authorized by this MOU currently 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.
You may ask, why bother to comment—when Jay Kislak, CPAC’s Chairman at the time, has stated that 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 Bulgaria?
Simply because, our silence 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 more recent 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? Go to https://www.federalregister.gov/articles/2016/08/10/2016-19018/notice-of-meeting-of-the-cultural-property-advisory-committee to submit short comment just click on the green box on the upper right hand side of the above notice that says “submit a formal comment” and follow their directions.
If you are having trouble, go to the Federal eRulemaking Portal (http://www.regulations.gov), and enter Docket No. DOS-2016-0054 for Cyprus, and follow the prompts to submit comments. What should I say? The State Department bureaucracy has dictated that any public comments should relate solely to the following statutory criteria:
- Whether the cultural patrimony of Cyprus is in jeopardy from looting of its archaeological materials;
- Whether Cyprus has taken measures consistent with the 1970 UNESCO Convention to protect its cultural patrimony;
- 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,
- 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. (These particular restrictions have hurt the ability of Cypriot Americans to collect ancient coins of their own culture.) 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. Finally, Cyprus is a member of the European Union, so why not allow legal exports of Cypriot coins from other EU countries?
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. Please submit comment just once, before the deadline on September 30, 2016.
Thank you for your help,
Peter,
Peter K. Tompa,
Executive Director
Ancient Coin Collectors Guild
Apr 25, 2016 | ancient, coins, commentary, policy
Over the last few years, I have asked readers to sign various petitions and write to the Department of State to stop restrictions on ancient coins.
Once again, the Ancient Coin Collectors Guild (ACCG) needs your help. This time, the Greek government has requested changes to the Memoranda of Understanding that can hurt ancient coin collectors.
Please read the following letter that was sent by ACCG President Peter Tompa. If you would like to help, please use the links in his letter. Thank you!
Dear Fellow ACCG Member:
The State Department’s Cultural Property Advisory Committee is soliciting public comments for the upcoming renewal of a Memorandum of Understanding with the Hellenic Republic. Current restrictions exempt certain ancient Greek Trade coins, including Athenian Tetradrachms, Corinthian Staters and Tetradrachms of Alexander the Great and his father, Philip, as well as later Roman Imperial and Byzantine coins. On the other hand, many other ancient Greek coins are restricted, including larger denomination coins of many Greek City states and smaller denomination silver and bronze coins of Alexander and his successors.
Please write CPAC expressing concerns about the current restrictions and any effort to expand the current designated list. Comments should focus on how import restrictions have damaged collecting, the preservation of coins, the study of the history they represent, the appreciation of other cultures, and the people to people contacts collecting brings.
While it’s easy to be cynical that public comments are ignored, silence will be taken as acquiescence about the State Department’s actions which have already diminished the supply of ancient coins available on the market.
Comments are due on or before 11:59 PM on May 9th. For a direct link to comment on the government website, go to https://www.regulations.gov/#!documentDetail;D=DOS-2016-0009-0001 and click on the blue “comment now” button in the upper right hand corner of the screen.
For additional background along with suggestions on what to say, see http://culturalpropertyobserver.blogspot.com/2016/03/please-comment-on-proposed-renewal-of.html
For details about what coins are currently restricted, please see https://www.gpo.gov/fdsys/pkg/FR-2011-12-01/html/2011-30905.htm
Sincerely,
Peter K. Tompa
Jul 11, 2014 | ancient, coins, commentary, policy
During a time where disinformation is a product of hyper-partisanship, it is difficult to write about issues without feeding into the conspiracy theories of the day. The problem with conspiracy theories is that there are so many moving parts and so many people who would have to cooperate that when you really think about their content beyond the headline, you understand how difficult it would be for conspiracies to exist on the scale many suggest.
Conspiracy theories are not a new phenomenon. What is new is how fast they can spread and how the extremes on both side of the aisle can see the same circumstances are come up with radically different conclusions.
Rather than talk about conspiracies, we should look at the issues as more of the result of unintended consequences.
1933 Saint Gaudens Double Eagle is an example of the Law of Unintended Consequences.
For collectors of ancient coins, it is difficult to ignore the law of unintended consequences of Cultural Property Implementation Act (CPIA; 19 U.S.C. §§ 2601 et seq.) and how it is implementation by the State Department’’s Cultural Property Advisory Committee (CPAC). CPIA is the law that was created when the United States signed and the Senate approved the Convention on the Means of Prohibiting and Preventing the Illicit Import, Export and Transfer of Ownership of Cultural Property 1970, often called the 1970 UNESCO Convention. The purpose of the treaty was to stop archaeological pillaging and trafficking in cultural property. In real terms, it would prevent the filling of the British Museum in London with the artifacts from ancient Egypt, Greece, the Middle East, North Africa, and any other place where the British tried to maintain their empire.
EID·MAR Silver Coin commemorating the death of Cæsar on March 15
Although this may sound reasonable, Article 1 paragraph (e) of the treaty defines a category of cultural property as “antiquities more than one hundred years old, such as inscriptions, coins and engraved seals.” This means that any coin minted before 1914 can be considered cultural property and not only be subject to restrictions but confiscated if it cannot be proven that it was found or purchased legally prior to the convention.
With the different rules and laws around the world that has different documentation requirements that were more lax prior to the convention, how does the collector of ancient coins prove the coin that was bought in good faith from a dealer or another collector is not a country’s cultural property? A coin that could have changed hands hundreds of times since it arrived in the United States and enjoyed by its collectors may have had its more modern provenance lost to time and be subject to confiscation by the State Department and returned to the country of origin.
Although the CPAC tries to make the Memoranda of Understanding between the foreign country and the United States simple, the law and convention has a number of problems that have not been addressed in the 40 years it has been in existence. One problem is the existence of ancient Roman coins all over Europe. While the coins were minted in Rome, they were carried throughout the empire by the military, business people, and travelers that were eventually left behind. Since the coins were struck in Rome does it mean that the coins are the property of Italy or the country where they were found? If they country where they were found follows the convention to its letter, since the coins were not manufactured there are they really cultural objects and subject to these export and trade restrictions?
While those of us in the United States have been captivated by the Saddle Ridge Hoard of gold coins, people in the United Kingdom have been buying metal detectors in record number to scour the countryside looking for ancient coins left behind by their ancestors. Recently, someone found four coins dating back to the Iron Age that sparked an archeological search. The find included Roman coins that were not made in England or the land that would become England. Are these British artifacts?
As an aside, British law allows the finders to keep the coins. But since the full archeological search was managed by a British university in conjunction with the military, subsequent finds are the property of the crown since both are paid using public tax money. However, based on the wording of the 1970 UNESCO Convention, does Italy have a claim if they want to pursue those coins?
Recently, the CPAC held an open meeting to hear the new Egyptian government’s request to ban the import of artifacts dating through the time of the Ottoman Empire. Based on reporting by Richard Gierdroyc in Numismatic News, the questioning of the committee and the answers by those representing the archeological community not only would not grant an exemption for coins but would consider the confiscation of coins that could not be proven to have been legally purchased prior to the 1970 UNESCO Convention and have since fairly traded.
There is a very vocal crowd in the archeological community that would want to see everything dug up from the earth put into museums or otherwise locked away from the public. (Links to these people omitted on purpose) Using the pejorative “coinys” to describe collectors of ancient coins, these people have advocated for the confiscation of these coin so that they can be entombed behind display glass inside the state run museums of the world. They consider coinys profiteers who would rather trade in history than preserve history.
Collecting, in all of its forms, is a preservation of history. Whether you collect coins, stamps, political campaign buttons, old car emblems, license plates, old kitchen objects, books, toys, postcards, letters, and other ephemera, these items would be lost to time if people did not save them. Owning history helps connect us to our past and even helps us understand how the world has evolved.
History must be preserved and every country has the right to protect the property within its borders. If Egypt wants to protect its property and any future property that archeologists discover, then that should be their right. However, if Egypt wants to restrict United States collectors of coins or other artifacts that have been in circulation for many years, it is suggested that they end their hypocrisy by preying on the “we must do right by the world” policies of the United States and demand that the British Museum to return its holdings.
May 13, 2014 | ancient, coins, policy
Before I begin today’s missive, please read the story I wrote about my friends who were arrested at the airport of a foreign country after digging up the $20 worth of ancients coins they found on a beach while playing in the sand. Go ahead… (click here) I’ll wait!
It is difficult to ignore the law of unintended consequences of Cultural Property Implementation Act (CPIA; 19 U.S.C. §§ 2601 et seq.) and how it is implementation by the State Department’s Cultural Property Advisory Committee (CPAC). Unfortunately, they are at it again.
CPAC will hold meetings on June 2-4, 2014 to review a new cultural property request from the Government of the Arab Republic of Egypt seeking import restrictions on archaeological and ethnological material. As with all of the other Memos of Understand (MOU), it will include ancient coins, even those that are common for ancient collectors and will also contain fuzzy language to make it look like Egypt could try to seek the return of undocumented items no matter when they were purchased.
The Ancient Coin Collectors Guild (ACCG) needs your help to make sure that the MOU between the United States and the Arab Republic of Egypt does not turn ancient coin collecting into a hobby where collectors have to look over their shoulders to watch out for foreign agents looking to confiscate their collections. This is not conspiracy theory talk. It has actually happened. Read the account by Patrick Heller in this article printed in Numismatic News (see the paragraph beginning with “Number four….”).
I ask that you support the ACCG and its efforts to prevent the government overreach into coin collecting by asking the State Department to “Exempt Ancient Coins” in whatever words or with whatever reasons you wish to offer. All you have to do is go to http://www.regulations.gov/#!docketDetail;D=DOS-2014-0008 and click on the blue “Comment Now” button on the right side of the page.
Comments are due by WEDNESDAY, May 14, 2014 before midnight.
Your effort is important and will be very much appreciated by the ACCG and the entire collecting community.
Sep 26, 2013 | ancient, coins, commentary, foreign, legal
Fred and Wilma (not their real names) are friends who decided to celebrate their empty nest by taking a trip to the Mediterranean after dropping their youngest child off at college. Fred is what I respectfully call a hacker. He is a wizard programming computers and someone who I go to in order to understand some of the more esoteric aspects of computer exploits he researches. In his spare time, Fred plays with his computers and tinkers with electronics. Fred is also known as an overgrown boy scout. He is contentious about his work, children, and the activities he is involved with. Fred is probably the most honest person I know.
Fred is not a coin collector and has no interest in collecting coins even though he does own the 2004 Thomas Edison commemorative coin and the 2005 Albert Einstein 2 Shekel proof coin from Israel because these are two people he admires. On many occasions, Fred has said that he did not understand what I saw in collecting coins. Even after showing him my original Lincoln cent folder with coins I have found in change dating back to when I started collecting, he did not understand the lure of the chase.
While sitting on a beach along the Mediterranean, Wilma started to dig in the sand around a sleeping Fred to have fun at his expense. After she dug nearly two feet down, Wilma unearthed metal object that she originally thought was trash. After waking Fred and watching him roll into her newly dug hole, Fred brushed himself off and looked at what she found. A trip to the water to rinse off the items to find three ancient coins and a shell. The way it was described to me was that the coins were sitting in the shell as if it were a change holder. They dug some more and found three more coins. To some degree, he began to understand the thrill of the chase.
With the help of the hotel concierge, Fred and Wilma found a coin dealer who spoke English to ask about the coins. After talking with the dealer they found that the coins were common and would only be worth the equivalent of a few dollars. Undeterred, the coins were placed in a small bag and throw in the bottom of their carry on luggage as souvenirs and continued with their vacation.
A few days later, Fred and Wilma packed their bags and went to the airport to return home. At their host country’s departure screening, Fred was asked if there was anything to declare. Fred, being an overgrown boy scout, declared everything—even things he did not have to declare. As the officers were inspecting the items on the table, one picked up the bag with the coins and asked about coins. Fred showed the officer the written estimate from the dealer thinking that would resolve any issue.
According to Fred, the officer took coins and the estimate to another officer he described as having more decorations on his uniform. This higher ranking officer looked at the coins and paper while discussing the situation in their native language. After a moment, Fred became concerned and Wilma became nervous.
Another officer walked over with the higher ranking officer and acted as a translator as it was explained to Fred that the coins were “cultural antiquities” and would be confiscated. Fred was not happy but he accepted the situation until the translator said that Fred and Wilma would be detained while the officials investigated. They were allowed to gather their luggage and were escorted to a nearby room.
After waiting for an hour, another official came into the room and spoke to Fred and Wilma in English. Fred explained how he obtained the coins and why he was taking them home. After the official started questioning them as if they were criminals Fred asked to speak with the United States Embassy.
Fred and Wilma were escorted by local police to two separate facilities to be incarcerated pending an investigation. The facilities were in separate parts of town since these were not co-ed accommodations. They waited two days before seeing anyone other than the guards.
Two days later, both were escorted to a local judge and said they were being charged with trying to smuggle antiquities out of the country. An attorney was appointed to represent them. The attorney did not speak English and only wanted them to plead guilty for a three-year sentence. Thankfully, there was an American in the courtroom who told the attorney that he would contact the U.S. Embassy and not to plead on the case.
The next day, someone from the Embassy was able to have Fred and Wilma released to their custody, recovered their luggage, and let them stay in the embassy while trying to resolve the situation.
Obviously, the embassy accommodations were better than what they had at the local jail. Fred described the embassy staff as very nice including the natives who worked non-diplomatic jobs. Unfortunately, they could not leave the embassy since they were technically under house arrest. Although it was a gilded cage it was still a cage.
It took nine days to resolve the issue which Fred was told was lightning speed for that country. The coins were left in the country they were visiting, which Fred offered to do at the airport when confronted by the officials. They were driven to the airport by a U.S. military driver and escorted to the screening area by a member of the diplomatic staff who ensured their passports were returned and that they were allowed to board the plane.
The plane landed in a more friendly country where Fred and Wilma were met by local and U.S. officials for a debrief. Although the debrief was friendly, it did come after a stressful period in another country and lasted a few hours. Eight hours after landing in London, Fred and Wilma was en route back to the United States.
The country where this incident occurred is allegedly friendly with the United States but that did not stop the officials at the airport from treating them with suspicion over the possession of a few common ancient coins. Based on Fred’s description of the coins, I asked a dealer who said that $20 would be an average retail price for the coins. When asked if Fred wanted to buy similar coins, Fred could not decline fast enough!
I have written several posts about the impact of the Convention on Cultural Property Implementation Act (CPIA; 19 U.S.C. §§ 2601 et seq.) and the potential for foreign countries to use Memoranda of Understanding that the State Department’s Cultural Property Advisory Committee (CPAC) agrees to without considering citizen comments. The CPAC has said that the collateral issues raised by the comments are baseless. Fred can tell them otherwise.
Fred said that the embassy would not answer questions about what happened. Neither did the government officials during their layover in Europe. He was told that they should be thankful that this “only” lasted two weeks because it could have taken two months or even two years to resolve.
Next time the Ancient Coin Collectors Guild (ACCG) asks for assistance in addressing a call for comments from the CPAC regarding a foreign country’s MOU request, please remember the plight of Fred and Wilma. Although their ordeal lasted “only” two weeks, the next person may not be as lucky and find themselves in the jail of a country whose laws are far less humane than the United States.
Image of the ancient coins courtesy of
NGC. These are
not the coins the story is about.
Apr 23, 2013 | ancient, coins, ethics, foreign, history, news, policy
While the State Department’s Cultural Advisory Committee (CPAC) continues to kowtow the the whims of foreign government looking to use the Convention on Cultural Property Implementation Act (CPIA; 19 U.S.C. §§ 2601 et seq.) as some sort of virtual tool to attack the United States, little seems to be said by the foreign archeological supporters when a Paris court ruled for a French auction house allowing them to sell Native American artifacts.
The case involves the sale of 70 artifacts from Arizona’s Hopi Tribe by the Paris auction house Néret-Minet. Hopi tribe members and historians believe that the items were illegally obtained. Representatives from Néret-Minet claim that the items were purchased legally from a collector in the United States.
A visitor looks at antique tribal masks revered as sacred ritual artifacts by a Native American tribe in Arizona which are displayed at an auction house in Paris April 11, 2013. (REUTERS/John Schults)
Following the ruling, Néret-Minet went ahead with the auction. According to The New York Times, the auction generated $1.2 million in sales (with buyer’s premiums). Five of the 70 items did not sell and not sold for less than their estimated value.
According to The New York Times:
Before starting, the auctioneer, Gilles Néret-Minet, told the crowd that the sale had been found by a judge to be perfectly legal, and that the objects were no longer sacred but had become “important works of art.” He added, “In France you cannot just up and seize the property of a person that is lawfully his.”
So let me get this straight, religious objects that are allegedly protected by the same treaties as ancient coins and United States law can be sold as “art objects” while foreign governments confront a dealer on a bourse floor while the State Department does little to protect collectors and those who have legitimate claims?
If France can do this with items of religious and cultural significance to the Hopi tribe, then will happen to the coin collecting hobby? I know some people can take their hobby seriously, but it is not religion. Most countries already have examples of the coins in question, so why are additional examples “culturally significant.” Remember, it was reported that when a dealer was approached in Baltimore by representatives of a foreign government, they were only interested in the more expensive coins and not the common coins from the same country with a lesser value.
The State Department is not doing enough to protect the American people, whether it is to protect what is really culturally significant items like the artifacts from the Hopi tribe or the abuse of international law as demonstrated by the actions of the State Department’s CPAC and the confrontation in Baltimore. This is something that must be addressed by the president!
Please take action!
I renew my request that all of my readers to go to http://wh.gov/MD2O and sign the petition. Share it on social media. I made it easy—just see the widget at the top of the right column. Petitions require 100,000 signatures in order to be answered by the White House. So far there are five signatures (THANK YOU!). Let’s see if we can motivate the coin collecting community to add more before you will not be able to own any foreign coin older than 100 years old!
A French supporter of the Indian cause, who refused to give his name, left, holds a flag of the American Indian Movement and an American exchange student, member of the Arizona’s Hopi tribe, Bo Lomahquahu, right, stand outside of the Druout’s auction house to protest the auction of Native American Hopi tribe masks in Paris, Friday, April 12, 2013. A contested auction of dozens of Native American tribal masks went ahead Friday afternoon following a Paris court ruling, in spite of appeals for a delay by the Hopi tribe, its supporters including actor Robert Redford, and the U.S. government. (AP Photo/Michel Euler)
Jan 2, 2012 | ancient, legal, policy
Start your new year off right and help the ancient coin collectors in the United States!
On December 17, I posted “First They Came For The Ancient Coins…” about the State Department accepting public comment on the extension of the Memoranda of Understanding with Cyprus by the State Department’s Cultural Property Advisory Committee (CPAC). The deadline for submitting comments is on January 3, 2012—TOMORROW!
Recently, the American Numismatic Association joined the cause. “We are deeply concerned that ever-expanding import restrictions have gravely damaged the ability of American citizens to learn about ancient cultures through handling common ancient coinage of the sort that is avidly collected worldwide,” ANA President Tom Hallenbeck said. “Such regulations, to the extent they exist at all, should be narrowly tailored to restrict goods that could only be the product of looting from archaeological sites. Coins cannot meet this test. By their nature, ancient coins have circulated far from their place of origin, have been extensively collected throughout the world in modern centuries, and like common mass-produced items, ancient coins do not normally have any verifiable provenance.”
To submit comments three pages in length or less electronically, go here: http://www.regulations.gov/#!submitComment;D=DOS-2011-0135-0002.
For more information and ideas of what to say, please reread my earlier post.
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.
Make it your resolution to help maintain the hobby for all of us!
Dec 17, 2011 | ancient, legal, policy
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:
- 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.
- 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)
- 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:
- Whether the cultural patrimony of Cyprus is in jeopardy from looting of its archaeological materials;
- Whether Cyprus has taken measures consistent with the 1970 UNESCO Convention to protect its cultural patrimony;
- 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,
- 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.
Oct 21, 2011 | ancient, legal, policy
I received this in email and thought it was important enough to reprint here.
This message is being transmitted on behalf of the Ancient Coin Collectors Guild (ACCG) concerning an urgent matter that affects all collectors of ancient coins.
What is being asked of you is to take 5 minutes to write a comment to the State Department’s Cultural Property Advisory Committee via a website. Please submit your comment once by the deadline of November 2, 2011, 5pm EST.
Please consider sending this to any coin collector you know:
The US State Department is seeking public comment on a new request for import restrictions made on behalf of Bulgaria. To submit comments electronically to the State Department’s Cultural Property Advisory Committee (CPAC), go here: http://www.regulations.gov/#!submitComment;D=DOS-2011-0115-0001. For further details of the request, see http://exchanges.state.gov/heritage/whatsnew.html.
What is at issue? Despite President Obama’s efforts to foster government transparency, the State Department has not indicated whether coins are part of the request. Nonetheless, based on recent history, it is probable that import restrictions on coins will be proposed. As a practical matter, this means the State Department and US Customs may be considering restrictions on tribal coinages from Thrace, coins of Greek city states like Apollonia Pontica and Messembria, Roman provincial coins struck at Bulgarian mints, and even some Roman Imperial coins. It’s also possible that any restrictions will include later coins as well. Though details are few, the public summary the State Department has provided indicates that Bulgaria seeks import restrictions on objects from 7500 B.C. to the 19th c. AD. If restrictions are imposed on coins, many common types will likely become so difficult to import legally that they will become unavailable to most collectors.
Why bother? Large numbers of coin collectors have made their concerns known to CPAC. Recently, 70% of the comments CPAC received on an MOU with Greece were from concerned coin collectors. Even though recent extensions of import restrictions to certain Greek and Roman Republican coins from Italy and on coins from Cyprus despite the vast amount of public comment make it easy to become cynical, public comment can at least help moderate demands for import restrictions. For example, the archaeologists actively sought import restrictions on Roman coins as well during the discussions about the Italian MOU, but they remain exempted, and thus easy to obtain on the open market, likely due to the 2000 or so faxes CPAC received from concerned collectors.
What should I say? Tell the State Department and CPAC what you think about the bureaucracy’s efforts to deny you the ability to collect common ancient artifacts that are available worldwide. You might also might consider noting that coins from Bulgarian mints are common and often very inexpensive. Tens of thousands or hundreds of thousands exist in collections around the world, and because of the low price the vast majority of these coins will never have been through an auction and will have no verifiable provenance.
If you are having trouble commenting from the direct link above, go to http://www.regulations.gov and search on docket number DOS-2011-0115. Further information about regulation.gov, including instructions for accessing agency documents, submitting comments, and viewing the dockets, is available on the site under “How To Use This Site.” Kindly note that your comments will be public so avoid conveying any personal information, and, of course, be polite in commenting on the issue.
Please submit comments just once, before the cutoff of 5:00 PM EST Nov. 2, 2011.
NOTE: Click this link to see the Notice of Receipt of Cultural Property Request From the Government of the Republic of Bulgaria.
From a note sent by vauctions.com.
Mar 15, 2011 | ancient, coins, commemorative
One of the most recognizable coin from ancient Rome is the Eid Mar denarius commemorative coin issued by Marcus Junius Brutus after he participated in the assassination of Julius Cæsar on the Ides of March (15th of March), 44 B.C.E. The fame of this coin was already cemented by the time Roman historian Cassius Dio wrote sometime in the second century, “Brutus stamped upon the coins which were being minted in his own likeness and a cap and two daggers, indicating by this and by the inscription that he and Cassius had liberated the fatherland.”
On the Ides of March, a group of senators conspired to assassinate Julius Cæsar to liberate the Roman Republic and save it from Cæsar’s tyranny. Brutus, who Cæsar thought was a friend and ally, was a leader of the conspirators. After Cæsar arrived at the senate, the conspirators stabbed Cæsar 23 times using daggers they hid under their robes. Cæsar died after seeing that Brutus was part of the conspiracy. William Shakespeare dramatizes this scene in Act 3, Scene 1 of the play Julius Cæsar:
Cæsar: Doth not Brutus bootless kneel?
Casca: Speak, hands, for me! [The conspirators stab Cæsar]
Cæsar: [Turning to Brutus] Et tu, Brute? Then fall, Cæsar!
[Cæsar dies]
Cinna: Liberty! Freedom! Tyranny is dead!
Run hence, proclaim, cry it about the streets.
Cassius: Some to the common pulpits, and cry out
‘Liberty, freedom, and enfranchisement!’
Brutus: People and senators, be not affrighted;
Fly not; stand stiff: ambition’s debt is paid.
There are 60 known examples of the EID MAR denarius in silver and only one known gold example. The gold coin is on loan to the British Museum. The obverse of the coin features the bust of Brutus with the inscription “BRVT IMP L PLAET CEST” which means “Brutus, Imperator (honored military commander), Lucius Plætorius Cestianus.” Lucius Plætorius Cestianus was the manager of the mint workers. It was common for the coiner’s name to appear on Roman coinage as a guarantee to the quality of the metal. The reverse features two daggers on either side of a liberty cap, a symbol of freedom. Inscribed below the cap is “EID MAR,” for the Latin Eidibus Martiis or the “Ides of March” to commemorate the day he saved the republic.
Anyone in the area of the British Museum on the Ides of March, they are presenting a gallery talk by Ian Leins of the British Museum about the Ides of March. The free 45-minute gallery talk will begin at 13.15 (1:15 P.M. London Time) in Room 68. This would be a fantastic… visit one of the world’s greatest museums and take a break with an interesting talk!
Image of the Eid Mar silver coin courtesy of dig4coins.com.
Image of the Eid Mar gold coin courtesy of the British Museum via guardian.co.uk.
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