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  • June 07, 2024 4:10 PM | Peter Tompa (Administrator)

    On June 6, 2024, the ACCG conducted a webinar on the United Kingdom’s Treasure Act and its Portable Antiquities Scheme, on how they protect the rights of ancient coin collectors, educators, historians, and dealers, while simultaneously protecting the country’s historical and cultural sites and artifacts.  Understanding the UK’s successful approach to preserve its history while acknowledging the rights of land owners and coin hoard discoverers is a must for all those who are fascinated by times past.  With the conclusion of the ACCG’s webinar, the ACCG's board has voted to make a $1,000 grant  to the Oxfordshire Museum Service, to assist them in acquiring and displaying ancient coinage for its museum.    We are now seeking donations to help cover this donation with any excess over this amount going to the ACCG general fund.  

    The ACCG’s June 6 webinar included presentations by Professor Michael Lewis of the British Museum and Head of the Portable Antiquities Scheme and Angie Bolton who is Curator of Archeology at the Oxfordshire Museum Service.  Randy Myers, who is a Board Member of the Ancient Coin Collectors Guild, also spoke.  Professor Lewis’s presentation provided valuable details of the UK’s Treasure Act and the Portable Antiquities Scheme and how it works in his country. Ms. Bolton discussed how her museum acquires and handles ancient coinage and other artifacts that it receives via the Portable Antiquities Scheme.  Mr. Myers’ presentation compared relevant U.S. laws, discussed that other countries should adapt the UK approach before the United States needs to consider import restrictions, and concluded with a case study on a coin hoard uncovered in Somerset in 2013.  The PowerPoint presentations of each of the three speakers is attached as pdfs.

    (2) UK Treasure Act and PAS MLewis 6.6.2024.pdf

    (2) OXON Museum AACCG Museum Presentation ABolton 6.6.2024.pdf

    ACCG PowerPoint for 6.6.2024 RMyers 4.21.2024.pdf

  • May 15, 2024 11:23 AM | Keith Twitchell (Administrator)

    On May 13, 2024 the Ancient Coin Collectors Guild and the American Numismatic Association filed joint comments to the Cultural Property Advisory Committee, which raise concerns about the proposed MOUs with the governments of Ukraine and Jordan, as they may impact import restrictions on ancient coins.

    For the Ukrainian MOU, we strongly condemn the Russian invasion, but contend that the Federal Register’s notice failed to give the public the opportunity to submit timely and meaningful comments. Among the substantive matters under the Cultural Property Implementation Act, we question whether “Ukrainian coinage” meets the definitions of “archaeological or ethnological material of a State Party,” and that even if they do, whether such coins were “first discovered within, and . . . subject to export control by” Ukraine. We also ask the Committee to consider whether Ukrainian coinage is danger from looting, when the Ukrainian government allows the sale of ancient and other historic coins and medals within their country.

    We also ask whether “self-help” measures and related “less drastic remedies” exist, since we contend that “less drastic remedies” exist in the form of regulating metal detectors, a portable antiquities scheme and a functional export system. Finally, we contend that any import restrictions must be applied prospectively and not in the form of a retroactive embargo.

    For the Jordan MOU, our joint comments raise concerns to the proposed extension of the MOU. As a substantive matter, we join the comments that have been submitted by the International Association of Professional Numismatists dated April 30, 2024, that highlight several critical provisions from the Cultural Property Implementation Act as it impacts ancient coinage. As a procedural matter, we contend that the Federal Register’s public notice failed to give the public the opportunity to submit timely and meaningful comments.

  • April 28, 2024 3:57 PM | Peter Tompa (Administrator)

    The U.S. State Department and U.S. Customs have imposed very extensive import restrictions on behalf of Pakistan that include coins that circulated regionally, and internationally, including Roman Imperial types.  The designated list also includes Mughal coins which are also associated with India.  For more about the designated list, see the Cultural Observer Blog here.  We hope to update our list of import restrictions to include these new import restrictions for Pakistan shortly.  

  • March 23, 2024 4:37 PM | Peter Tompa (Administrator)

    The ACCG has submitted a Freedom of Information (FOIA) request to the US State Department seeking information about a "closed roundtable" ( with State Department officials (including Assistant Secretary, Educational and Cultural Affairs, Lee Satterfield, the decision maker for cultural property MOUs), representatives of archaeological advocacy groups, law enforcement, and officials of a Saudi-supported faction in Yemen’s ongoing civil war.  The roundtable was set up by the Antiquities Coalition, a mysteriously well-funded archaeological advocacy group which has described itself as a “partner” of both the State Department and several authoritarian Middle Eastern governments, including that of a Saudi-supported faction in Yemen, which only controls a limited part of the country. 

    Immediately following the roundtable, Satterfield signed an MOU with that government, which was then announced on social media by the Antiquities Coalition. Representatives of collectors and of the Jewish diaspora from Yemen and other Middle Eastern countries have criticized the MOU for being completed without input from the Cultural Property Advisory Committee or the opportunity for public comment.  See The MOU substituted regular import restrictions on Yemeni cultural goods for an emergency action taken in 2020.  Those emergency import restrictions were ordered after the public was given only two weeks to comment on the proposal.  Despite the short time frame afforded for public comment, the proposal received considerable opposition, including negative press reports.  See  Presumably, despite statutory requirements, the State Department and its “partners” wanted to avoid similar negative publicity before an agreement was completed so it was instead presented as a “fait accompli.”

    ACCG condemns this effort to stifle debate by excluding impacted American interest groups from government decision making.  This decision follows other agreements or emergency actions with authoritarian governments like China (2009 MOU), Egypt (2016 MOU), Libya (2017, emergency action, 2018 MOU), Algeria (2019 MOU), Jordan (2020 MOU), Turkey (2021 MOU), Afghanistan (2022 emergency action), Uzbekistan (2023 MOU), and Pakistan (2024 MOU) also engineered with the help of the Antiquities Coalition and other archaeological advocacy groups.  ACCG calls for a Congressional inquiry into such “partnerships” between the State Department’s Bureau of Cultural Affairs and its Cultural Heritage Center and archaeological advocacy groups with ties to such regimes. See

    FOIA Request re Yemen round table.pdf

  • 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:

  • 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 “,” 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:

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