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.
