ANCIENT COIN COLLECTORS GUILD


Executive BRANCH

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  • October 02, 2022 4:58 PM | Randolph Myers (Administrator)

    On September 30, 2022, the ACCG won its Freedom of Information Act administrative appeal, were we sought documents from Customs and Border Protection, on the creation and enforcement of the Designated Lists of import restricted ancient coins of ten nations.  Back on February 5, 2022 Customs and Border Protection had responded to our FOIA requests that they had "no documents."  We then filed a FOIA administrative appeal that contended that their response was factually inaccurate and that they failed to conduct a thorough and reasonable search.   In upholding our FOIA administrative appeal on September 30, 2022, the Department of Homeland Security’s FOIA Appeals, Policy & Litigation Branch informed us that responsive documents did exist.  As for our request for documents on the creation of Designated Lists, they provided us with 66 pages of partially redacted records, while explaining that their agency only engaged in a “ministerial” function of publication in the Federal Register, and that it was “the State Department, through the Cultural Property Committee, [that] creates the Designated Lists.”   As for our request for documents on the enforcement of Designated Lists, they provided us with 13 pages of partially redacted spreadsheets from their Seized Assets and Case Tracking System (SEACATS), that identified fifty incidents between 2009 to 2021 where they seized coins, most of which were “antique.”   

  • July 07, 2022 8:58 AM | Randolph Myers (Administrator)

    On July 7, 2022 the ACCG filed comments with the Cultural Property Advisory Committee objecting to the proposed MOU with Libya as it impacts the importation of ancient coins We raise one procedural objection, and five substantive objections, why import restrictions should not include ancient coins, except to the extent that it is an artifact that has been identified as looted from one of Libya’s World Heritage sites. 

    The comments can be found here: 

    https://www.regulations.gov/comment/DOS-2022-0015-0002

  • April 14, 2022 8:29 AM | Randolph Myers (Administrator)

    On April 14, 2022 the Ancient Coin Collectors Guild filed comments with the Cultural Property Advisory Committee objecting to the proposed MOU with the Islamic Republic of Pakistan as it impacts the importation of ancient coins.  We raise two procedural objections, and five substantive objections, why import restrictions should not include ancient coins. 


  • April 13, 2022 6:00 AM | Randolph Myers (Administrator)

    On April 11, 2022, the ACCG submitted a Freedom of Information Act request to the Department of State, regarding the Designated List of restricted ancient coins from Albania, that was published by the U.S. Customs and Border Protection on March 17, 2022.  We requested seven categories of documents, including the basis of their “determinations” to legally justify such restrictions, how the restrictions can legally apply to coins that circulated outside Albania, and how they considered the public comments earlier submitted to the Cultural Properties Advisory Committee.


  • February 21, 2022 10:20 AM | Randolph Myers (Administrator)

    Our FOIA administrative appeal contends that Customs and Border Protection does have such responsive documents, and we cite not only the agency's legal obligations under FOIA's text and caselaw to conduct thorough and reasonable searches but offered examples where such CBP documents exist.


  • January 13, 2022 10:33 AM | Randolph Myers (Administrator)

    On January 13, 2022, the ACCG submitted a Freedom of Information Act request to the Department of State, regarding the Designated List of restricted ancient coins from Egypt, that was published by the U.S. Customs and Border Protection on December 3, 2021. We requested eight categories of documents, including the basis of their “determinations” to legally justify such restrictions, how the restrictions can legally apply to coins that circulated outside Egypt, and how they considered the public comments earlier submitted to the Cultural Properties Advisory Committee.


  • January 11, 2022 8:52 AM | Randolph Myers (Administrator)

    On January 3, 2022, the ACCG submitted a Freedom of Information Act request to the Department of State, regarding the Designated List of restricted ancient coins from Greece, that was published by the U.S. Customs and Border Protection on November 22, 2021. We requested seven categories of documents, including the basis of their “determinations” to legally justify such restrictions, how the restrictions can legally apply to coins that circulated outside Greece, and how they considered the public comments earlier submitted to the Cultural Properties Advisory Committee.


  • November 27, 2021 10:56 AM | Randolph Myers (Administrator)

    Our FOIA administrative appeal contends that our FOIA request, which was divided into three parts and contained almost two pages of supplementary information, did reasonably describe the records sought.  The two "art trade" members were recently posted as additions to the Cultural Property Advisory Committee, after the ACCG filed repeated complaints with Department of State and then to its Inspector General.  While the two "art trade" members purport to have expertise, however, there is nothing in the public record that they are "experts in the international sale of archaeological, ethnological, and other cultural property" as required by the Cultural Property Implementation Act.  Since the Act requires such members to be experts, and that appointments be made to ensure "fair representation" of the interests of various private sectors, the ACCG filed the FOIA request on November 26, 2021, seeking documents on how the two members qualified as experts and as "art trade" representatives.



  • October 25, 2021 1:11 PM | Peter Tompa (Administrator)

    The ACCG has asked FinCEN, a Treasury Department entity, not to impose costly and time consuming "anti-money laundering" regulations on the micro businesses of the coin trade.  For more, see https://www.regulations.gov/comment/FINCEN-2021-0006-0019

  • October 25, 2021 12:33 PM | Peter Tompa (Administrator)

    The ACCG has filed formal comments opposing any effort to impose emergency import restrictions on behalf of the "former Government of Afghanistan."   For more, see https://www.regulations.gov/comment/DOS-2021-0032-0040

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