On May 25, 2023, the Ancient Coin Collectors Guild filed comments with the Cultural Property Advisory Committee, to object to proposed extension of the MOU with the Government of Bulgaria as it impacts the importation of ancient coins.
Our procedural objections complained that the Federal Register public notice of only 5-days before the filing deadline was untimely and effectively denied the public the ability to submit meaningful comments. Our substantive objections focused on the Cultural Property Implementation Act, where we argued that ancient coins did not qualify as artifacts of “cultural significance,” that ancient coinage cannot be assumed to have been “first discovered within” and “subject to the export control” of Bulgaria, that other available “less drastic remedies” existed, that Bulgaria had not taken adequate measures to protect its cultural patrimony, and that there was no indication that the current 2019 United State-Bulgaria MOU was effective. Doug Mudd, of the American Numismatic Association, testified on the ACCG’s behalf at the CPAC’s public zoom session on June 5, 2023, because Randy Myers was unavailable. The ACCG's comments can be found at https://www.regulations.gov/comment/DOS-2023-0016-0031.