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  • February 05, 2024 11:23 AM | Keith Twitchell (Administrator)

    Report on the Cultural Property Advisory Committee

    Open Session Regarding MOUs with India and Algeria

    January 30, 2024

    The purpose of the hearing was to take verbal public comments, adding to written comments previously received, regarding the possible five-year renewal of an existing Cultural Property MOU with Algeria, and entering into a new Cultural Property MOU with India.  Following is a summary of comments from most of the speakers, and in some cases, follow-up questions from CPAC members and the responses.  A few additional observations are included.

    Dr. Mark Lycett, Director of the South Asian National Resource Center, University of Pennsylvania, focused on the fourth criterion of the Cultural Property Implementation Act (CPIA) as it relates to the India MOU.  As required, the MOU appears consistent with the interests of the international community, and would not impede the exchange of cultural property for research or exhibition purposes.  He felt that the MOU would actually support these purposes, while protecting India’s cultural patrimony.

    Dr. Lycett was asked about the looting of cultural and historical sites in India.  He concurred that this was happening, especially with temple complex sites, including some that are still in active use.  He stated that he thought the MOU would help reduce this.  It should be noted that in making this statement, he did not address that the current and ongoing destruction of these sites is frequently done with the tacit support, if not outright encouragement, of India’s present government.

    Kate Fitz Gibbon, representing the Committee for Cultural Property and the Global Heritage Alliance, opened by stating that at present, India does not meet the legal criteria established by the CPIA.  She views this MOU as more about politics than cultural protection, and noted that India needs a significant revamp of its domestic policies relating to cultural preservation before entering into international agreements.  India’s own parliament has issued a report highly critical of the current government’s efforts in this area.  Entering into the MOU would be a political act by the United States in support of India’s prime minister.  The MOU does not reflect Congress’ intentions as stated in the original statue, nor the intent of the CPIA.  India uses its current cultural property laws for wrongful political purposes, and the MOU would only add to that.

    She also observed that India as a nation is a fairly new construct, while the collecting of Indian art has gone on for ages.  Indian art in the United States has produced important research work, while the country itself is not protecting either its cultural sites or the inventory of items in its possession.  Museums are not preserving their holdings, and many objects are simply rotting away in warehouses.  Mosques are being bulldozed, and Muslim residents are being killed.  In sum, India does not meet the criteria for a cultural property agreement as stated in the CPIA, and the proposed MOU should be denied.

    Nicholas Fritz, a professional numismatist with Stacks Bowers, focused on the third section of the CPIA, which states that if less drastic remedies can be used to protect cultural heritage, they are what should be enacted.  Instead, the proposed MOU is too broad, and includes too many items.  It will serve only as a trade barrier.  He noted that coins from the Indian subcontinent circulated far beyond the borders of modern India, and cannot be claimed as cultural heritage.  The vast majority of coins from this area were never buried in the ground, and cannot be specifically identified as having been found within India’s present borders.  Most types are widely known, and thus not germane to historical research nor imbued with cultural import.  He also pointed out that these coins are freely tradable within India.  The MOU needs to be narrower in focus, without the current blanket restrictions, which he suggested if enacted would likely lead to the establishment of a black market to continue the current trade.

    Mr. Fritz was asked several follow-up questions, including how he could determine whether or not coins had ever been in the ground; how he would distinguish between coins that might actually have research value and those that would not; and even if he was defining the boundaries of modern India for the purposes of the MOU.  The questions were hostile in nature, and the last question was absurd, as such MOUs are based on internationally recognized borders, and Mr. Fritz struggled to answer several of the questions.  He did suggest that in terms of the importance of specific coins, that would have to be done on a case by case basis.

    Peter Tompa, the Executive Director of the International Association of Professional Numismatists, opened by asking, in regard to both MOUs, should countries be allowed to take the rights of displaced peoples.  Regarding Algeria, most of the coins found in Algeria today circulated over wide areas in ancient times, and the MOU should be scaled back to address only locally-produced coins.

    He echoed the previous speaker in noting that the Indian subcontinent is a vast area, and coins from that region circulated widely beyond India’s current borders.  While the CPIA statue requires that items listed must be found within the specific country, this cannot be assumed with the majority of coins that exist in India today.  Some of the coins listed do not meet the statutory requirement of being at least 250 years old if found in the ground.  Further, most of the coins listed do not qualify as ethnological objects because they were produced in multiples by what at the time were sophisticated industrial practices, and are not the handicrafts of tribal cultures.  He also cited the extensive market within India for trading coins, and added that collectors help protect these coins, many of which would otherwise be melted for their metal by jewelers, as is often occurring already.

    Committee member Miriam Stark asked Mr. Tompa if he had ever worked on an archeological project, to which he replied that he had not but knew many people that had.  She then asked how coins older than 250 years old get to the market.  He replied that most coins found at archeological sites are not attractive to collectors, in part because they are often corroded from being in the ground.  He added that what is needed, in India and elsewhere, is a system similar to what the British use, which catalogues all findings.  Most coins are not found in archeological sites, and there are far more of them than can be studied or placed in museums.  In terms of research, only the few coins found in secure contexts have some value as dating tools, and they are not even particularly useful for that purpose because they often circulated for many years prior to landing at the site where they are found.

    A question/statement from the Committee member made the false equivalency of coins being found at a site and the destruction of the site, and further stated that any place a coin was found was by definition an archeological site.  Included in this was a question about the use of metal detectors.  Mr. Tompa recommended that countries restrict the use of metal detectors, and link their use to treasure trove programs as is done in the U.K.  He was questioned as to whether CPAC and the U.S. government could advise India to ban metal detectors.  He responded affirmatively, noting that such recommendations have been made in the past, to Cyprus for example.  The State Department lawyers are well aware that the statute requires consideration of less drastic measures for protecting cultural property, and addressing metal detector issues would be an example of that.

    Randolph Myers, an ancient coin collector and board member of the Ancient Coin Collectors Guild, raised three issues.  The first is that the State Department has documented that both of these countries have abused religious minorities among their citizens; he asked whether we should recognize the rights of these governments to hold the cultural heritage of these same minorities.  The second issue he raised related to the advance notice requirements for public comment and the hearing itself, which he said were 60 days and had not been met.  The Committee chair countered that the advance notice requirement was only 15 days.  Citing his past experience as a government attorney, he disagreed.  His third point returned to the issue of the CPIA requirement that CPAC consider less drastic measures to achieve the statute’s objectives, as had been noted by previous speakers.

    Elias Gerasoulis, representing the Global Heritage Alliance, opened by stating that neither country meets the CPIA requirements for establishing an MOU.  He endorsed the comments regarding India by Ms. Fitz Gibbon.  Regarding Algeria, he noted that there was no documented history of looting of sites within that country, and that only one illegally exported item has ever been identified within the United States.  Algeria’s protection of its historic monuments has been widely criticized by many, including UNESCO.  The CPIA requires proving that proposed import restrictions would not interfere with international exchange and study, while Algeria has never sent an exhibition of cultural items abroad.  Meanwhile, the rights of religious communities within the country are being trampled, and their own property is being confiscated.

    Omur Harmansah, representing the Archeological Institute of America, observed that despite the efforts of both governments, pillaging and looting of historic sites and illegal trafficking of cultural objects remain problems (he did not note the role of the governments themselves in exacerbating these problems).  He stated that both governments have expressed concern about this and documented such occurrences.  Both countries have extensive research ongoing with American researchers working with their governments.  AIA itself has conducted archeological tours of sites in India.  The restrictions are intended to decrease trafficking by denying illegal exporters access to items.  The AIA supports both MOUs.

    In general, Mr. Harmansah’s testimony was somewhat vague and not necessarily on point (the fact that AIA conducts tours in India seems hardly relevant), and completely ignored issues such as the persecutions conducted by both governments and their complicity in cultural destruction.

    Peter Herdrich, Executive Project Director for the digitization of Algerian heritage¸ stated that he had direct experience with that country’s efforts to preserve its heritage, and he supports the MOU extension.  Algeria has been successful in meeting the second criterion of the CPIA, protecting its cultural patrimony.  The government has worked with international experts to strengthen its legislation on this subject.  He acknowledged the existence of illegal markets for historic and cultural items within Algeria.  He stated that multiple ministries within the government, including Defense and Interior, were working on cultural protection issues.  He is working with various authorities to digitize the content of Algerian museum collections; the next step will be expanding the work to include manuscripts, including working in the southern part of the country.  This is vital due to increasing threats to the manuscripts from climate change.  He concluded by saying that Algeria is succeeding in its preservation efforts, and therefore the MOU should be renewed.

    One Committee member inquired as to how much of the digitization effort was focused on Berber heritage and collections.  Mr. Herdrich replied that the work was directed by the government and what the actual holdings in the museums consisted of, which do include some Berber items.  In follow-up, he was asked if he had noticed any patterns of emphasis by the government on specific communities, i.e., Roman or Ottoman versus Berber.  He replied that it was hard to comment on collections across all facilities.  Thus far, the emphasis has been on the northern half of the country, but as he previously stated, it is now expanding to the south.  He was then asked about Jewish artifacts, and whether there was any evidence of the Jewish community and history being acknowledged and respected.  He responded that he had seen material from this community but was not aware of any specific collection of it.  He did not think that any groups were being overlooked.

    This line of questioning suggests that at least some CPAC members share the concerns that were expressed regarding the nations in question’s treatment of minority communities and their heritage.  Also, Mr. Herdrich made no apparent link between the work he reported on and the impacts of the current MOU with Algeria.  Since the work is the digitizing of existing institutional collections, it has no obvious connection to protection of historical/cultural sites and items.

    In conclusion, testimony in opposition to the MOUs raised important questions about the suitability of the two governments to be custodians of their own cultural and historical heritage, particularly in light of their treatment of minority groups within their countries.  Questions were also raised about the actual impact of the MOUs as proposed on achieving this objective, with several speakers noting the statutory requirement to consider less drastic measures.  The MOUs were described as overly broad, both in terms of items listed – especially coins – and the geography of modern national borders as compared to historical regions.  The existence of internal markets for coins and artifacts was noted, as well as the role of collectors in both the study and preservation of the coins involved.

    Proponents of the MOUs articulated the need to increase protections for historical and cultural sites in the two countries, especially India.  They cited work by both governments to preserve their cultural patrimony, but drew only a few direct links between either existing efforts or potential future opportunities and the MOUs themselves.  In general, their testimony was somewhat vague.  They did not address documented failures by both governments to protect minority communities, nor the deficiencies of their current cultural preservation efforts.


  • January 10, 2024 6:08 PM | Peter Tompa (Administrator)

    The ACCG and ANA have uploaded joint comments on the proposed MOU with India and a proposed MOU renewal with Algeria.  Import restrictions associated with the current MOU with Algeria already impact a wide variety of coins that circulated regionally and internationally.  ACCG and IAPN urge CPAC to recommend that the designated list for Algeria be reformed to comply with the underlying statute and raises concerns about any new restrictions on Indian coins.  Details here:  https://www.regulations.gov/comment/DOS-2023-0040-0012

  • December 15, 2023 4:09 PM | Keith Twitchell (Administrator)

    By Peter K. Tompa, December 5, 2023

    Mike Markowitz is a defense analyst and wargame designer for the U.S. military by trade, but his avocation is collecting ancient Byzantine gold coins. Mike focuses on more than his own collection; he also devotes substantial amounts of his free time to learning more about all types of ancient and medieval coins so he can pursue outreach efforts aimed at teaching others about them. As “Second Counsel” for the Ancient Numismatic Society of Washington, D.C. and Vice President of the Fairfax Coin Club in Virginia, Mike has planned and given educational programs about ancient and medieval coins geared to fellow collectors. Mike has also written extensively about particular coin issues and the ancient cultures that made them for “CoinWeek.com,” an online publication. However, Mike’s most rewarding efforts relate to using ancient Roman coins as teaching tools for kids.

    Latin students at the Hill School in Middleburg, Va., are just one group that has benefited from Mike’s expertise. In their case, Mike’s lecture is just part of a much more comprehensive program. The Hill School’s Latin teacher, Dean of Students Christie Lovelette, integrates genuine ancient Roman coins into her lesson plan to further engage her students.

    Read full article

  • September 01, 2023 12:43 PM | Peter Tompa (Administrator)

    The ACCG has uploaded comments pointing out that inadequate notice was provided for a proposed MOU with Nepal and a Renewal of the Current MOU with Honduras.  ACCG's comments can be found here.

  • June 16, 2023 1:10 PM | Peter Tompa (Administrator)

    On June 14, 2023, the ACGG joined by three other organizations, submitted a Petition For Rulemaking to the Department of the Treasury and U.S. Customs and Border Protection, seeking to amend their regulations on import restrictions of designated cultural property when there is a cultural property agreement with a State Party.  The other organizations that joined the ACCG  are the Global Heritage Alliance, Inc., the American Numismatic Association,and the International Association of Professional Numismatists.   Our Petition asserts that the existing regulations need to be amended because they are inconsistent with both the Convention on the Ownership of Cultural Property and the Cultural Property Implementation Act.  We assert the existing regulations should be amended to reflect that the Convention and the Act are neither self-executing nor retroactive, that designated cultural property must be “first discovered within, and subject to the export control by the State Party,” and that the government bears the initial burden of proof that a seized object is a designated cultural property subject to import restriction and was located in the country after the implementation of the cultural property agreement.  


  • June 11, 2023 8:12 AM | Peter Tompa (Administrator)

    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 accessed here: https://www.regulations.gov/comment/DOS-2023-0016-0031


  • March 06, 2023 1:22 PM | Peter Tompa (Administrator)

    In response to allegations in a criminal complaint filed in New York City alleging that certain valuable coins were sold with false provenances, the ACCG has updated its ethics rules to make clear that it condemns the use of unsubstantiated provenances to sell historical coins.  The ACCG’s ethics rules already urge that “sellers will not knowingly purchase coins stolen from private or public collections or reasonably suspected to be the direct products of illicit excavations in contravention of national patrimony laws. Coin collectors and sellers will also comply with all applicable customs laws.”  For more, see https://accguild.org/CodeOfEthics

  • February 24, 2023 5:28 PM | Peter Tompa (Administrator)

    ACCG Board Member Andy Pierucci has written an opinion piece explaining how collecting Roman Imperial coins is now in danger.  It was published on-line by the Deseret News, Utah's oldest newspaper.  You can read it here:  

    https://www.deseret.com/opinion/2023/2/18/23604528/ancient-coin-collecting-us-import-restrictions

  • February 03, 2023 9:23 AM | Peter Tompa (Administrator)

    By Keith Twitchell

    February 3, 2023

                After watching the most recent meeting of the Cultural Property Advisory Committee, it’s easy to draw the conclusion that coins – and coin collectors – are collateral damage in the battle over importation of culture and historical artifacts in general.

                The Committee met in open session on January 30, 2023 to consider Memorandums of Understanding relating to proposed import restrictions on cultural goods with three countries:  Cambodia, North Macedonia and Uzbekistan.  The latter two would be new agreements, while the Cambodia proposal would extend and expand a current MOU.  The meeting’s purpose was to receive public input on these documents.

                As proposed, all three are extraordinary in their scope, in time frame and types of items covered.  Since this is not the forum for going into great detail, here is a very brief overview of the proposed agreements.

    • -          Cambodia:  depending on the type of artefact, the MOU would reach as far back as circa 2500 BC, and for some items, through 1891.  Requested for inclusion in the new agreement are items made of stone, ceramic, glass, bone, wood, and metal, including coins.  Architectural elements, manuscripts, and religious and funerary objects would be covered.
    • -          North Macedonia:  the proposed period for the agreement is 300,000 BC to the 1950s.   Coverage is requested for archaeological items made from ceramics, stone, bone, ivory, glass, faience, and metal, including coins.  Some specific items are listed, including musical instruments, pipes, mosaics, textiles, and artworks.
    • -          Uzbekistan:  maximum time frame is 50,000 BC to 1917.  Materials include those in the two other proposals, along with plaster, stucco, unfired clay, birch bark, vellum, and shell, among others.  Also included in this MOU would be human remains.

                While there are important, legitimate issues relating to looting of archeological sites and illegal exporting of artefacts from each of these countries, the proposed MOUs are so vast in scope that they may well cause as many problems as they solve.  That did not deter a number of individuals from testifying in their favor during the meeting.  Speaking in opposition were Randy Myers on behalf of the Ancient Coin Collectors Guild and Peter Tompa, officially representing the International Association of Professional Numismatists. The American Numismatic Association joined the ACCG’s written comments but was not present at the open session. 

                The majority of oral comments addressed only the MOU with Cambodia.  Along with people speaking from an institutional vantage point, several individuals, primarily displaced Cambodian citizens, addressed the Committee.  They spoke movingly of the damage to great, ancient structures, and to the subsequent damage to history and religion within Cambodia, that is caused by looting.

                The institutional representatives addressing the Cambodia MOU tended to speak very generally, while in the process pointing out other as-yet untaken measures that would help solve the problems, and even acknowledging that the current MOU has been limited in its effectiveness.  For example, Stephen Acabado, of the Society for American Archeology, pointed out that the lack of surveys and inventory listings of sites and items in Cambodia contributes substantially to the problem.

                Tess Davis, the Executive Director of the Antiquities Coalition, freely acknowledged that looting and illegal exporting has continued despite the current MOU.  Davis also stretched so far as to suggest that the MOU should be extended in order to protect potential buyers of these items in the United States.

                The only person to speak in favor of the Uzbekistan proposal was Soeren Stark, a professor at New York University.  Yet he also acknowledged that looting of Uzbek archeological sites has “happened with the knowledge and silent consent of local authorities,” and that “Uzbekistan has the legal framework to protect this local heritage.”  In the process, he pointed out the need for local community education efforts to address these issues.

                To summarize, several speakers identified actions that could be taken within these countries to address these problems.  No one argued that the MOUs themselves would solve the problems, and there was even acknowledgment that the existing MOU with Cambodia has not deterred illegal looting and exporting.

                Left completely unaddressed was the fact that these would be bilateral agreements, meaning that only importation of artefacts into the United States would be restricted.  Illegal trade could continue in pretty much the entire rest of the world, meaning that even if the restrictions could be reasonably enforced (a major, separate issue), there would still be a vast market for these items.  Meanwhile, legitimate collectors, dealers and institutions in the U.S. would be unfairly faced with onerous, confusing and inconsistent processes.

                In countering these arguments, Myers cited the regional nature of coins and of the history of countries whose borders today do not match anything from any previous period of history.  For example, North Macedonia is a new nation altogether, and there are legitimate questions as to whether coins were ever minted within its borders.

                Tompa pointed out that the Convention on Cultural Property Implementation Act (CPIA), under whose aegis the MOUs are being proposed, requires correlation between where an item was made and where it was found.  Very few coins are ever found where they were minted, since the definition of coinage is to be circulated via commerce.  This is especially true of ancient coins; Tompa noted that Roman coinage served as world currency, and Roman coins have been found from England to Sri Lanka.

                While Committee members had few questions for other speakers, CPAC member Anthony Wisniewski directed a number at Tompa, affording him the opportunity to elaborate on several key points, and to further distinguish coins from the other items covered in the proposed MOUs.  Specifically, he noted that coins are not “ethnographic objects”, whose protection is the purpose of CPIA.  Tompa has written and spoken extensively on these issues, and those interested in the subject should read his considerably more detailed observations.

                After observing the Committee meeting, it seems clear that if collecting ancient and world coins is to be protected from unnecessary restriction and overreach, coins simply must be distinguished from art, artefacts and antiquities.  Coins are a category unto themselves.  Their purpose was commerce; as such, they were intended to circulate over wide areas.  They are not parts of physical structures, nor are they associated with religious and/or cultural heritage.

                The ongoing trend is towards more, and broader, MOUs of this nature.  That tide seems unlikely to turn soon, and if coins are not to be swept up in it, they absolutely must be separated out of the discussion to the highest possible degree.

                Keith Twitchell is a writer, nonprofit consultant and coin collector living in New Orleans.  He enjoys music, tennis, travel, people, and the ancient world, and writing about all of them.  He has been an ACCG member since 2017.  

    ACCG Article 020023 re CPAC meeting.pdf


  • January 10, 2023 9:39 AM | Randolph Myers (Administrator)

    On January 10, 2023, the Ancient Coin Collectors Guild joined by the American Numismatic Association, filed comments with the Cultural Property Advisory Committee, to object to proposed MOUs with the Governments of North Macedonia and Uzbekistan, as it applied to the  import restriction of ancient coins.  While the public notice was published in the Federal Register on December 21, 2022, the CPAC’s website failed to state that they were considering import restrictions on coins until January 2, 2023. 

    Our comments raised a number of procedural and substantive objections.  Our procedural objections complained that the public notice was untimely, vague and inadequate, which 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 the two counties, that other available “less drastic remedies” existed, that neither country submitted a statement of facts for the CPAC’s “determination,” and that coins minted after 1773 cannot be restricted since the Act requires objects be “at least two hundred and fifty years old.”  

    Our full comments can be found here:

    ACCG and ANA comments objecting to North Macedonia coin restrictions RMyers 1.10.2023.pdf

    ACCG and ANA comments objecting to Uzbekistan coin restrictions RMyers 1.10.2023.pdf

    Written comments on the proposed MOUs with North Macedonia and Uzbekistan must be received by January 23, 2023 at http//www.regulations.gov, enter docket DOS-2022-0048, then follow the prompts.

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