On September 15, 2025, the State Department’s Cultural Property Advisory Committee (CPAC) met to consider four potential agreements with foreign governments:
- Renewal of an “emergency” import restrictions agreement with Taliban-led Afghanistan
- Renewal of Cultural Property Agreement (CPA) or Memorandum of Understanding (MOU) with Colombia
- Renewal of a CPA with Turkey
- A new MOU with Cameroon
Looking briefly at each of these, the agreement with Afghanistan would include different types of items dating from 50,000 BCE to 1912 CE. Given that the country is currently ruled by a terrorist group with a thoroughly documented history of cultural and historical destruction – not to mention the suppression and even murder of its own citizens – it is extremely difficult to fathom why the United States would even begin to consider any agreement with this nation, let alone the renewal of one that does not even expire until the first quarter of next year.
As for Colombia, the agreement proposed to renew existing restrictions on items that, again depending on type, date from approximately 1500 BCE through 1830 CE. Currently, the U.S. government is in open dispute with the Colombian government over issues including immigration and illegal drugs, while that government draws ever closer to China. Again, the current agreement does not expire until next year.
Regarding Turkey, the renewal would pertain to material dating as far back as 1.2 million years ago and as recently as 1923. Turkey is currently run by an iron-fisted dictator who actively suppresses minority ethnic groups and individuals, rigs elections, actively supports Russia, and meddles constantly in countries like Syria and Libya to the detriment of U.S. interests. Yet again, the current agreement does not expire until well into 2026.
The proposed new MOU with Cameroon would cover items from 100,000 BCE into the 19th century CE. Meanwhile, the current government of this nation is actively suppressing its English-speaking citizens.
To say that none of these agreements would seem in any way to beneficial to the United States, and especially to its law-abiding citizens who happen to be collectors, dealers and students of ancient coins, is putting it mildly. Further, the current members of CPAC all date from the previous administration. With none of the agreements proposed for renewal expiring until next year, there seemed to be no justification for rushing this hearing forward; yet despite the best efforts of the Ancient Coin Collectors Guild (ACCG), the International Association of Professional Numismatists (IAPN), and many other respected organizations (including, in the case particularly of Turkey, groups representing displaced and persecuted ethnic minorities), the hearing was conducted – virtually – as announced.
Multiple speakers testified in opposition to some or all of the agreements. Leading off was Peter Tompa, Executive Director of IAPN and a board member of ACCG. Backing up written comments he had submitted previously, Mr. Tompa referenced the Taliban’s previous and ongoing destruction of historic and cultural items and sites. Not only does this undermine the intent of these agreements, the extent and duration of these actions contradict the notion of any need for an “emergency” agreement. Regarding Turkey, he noted the government’s encouragement of looting at Christian and Jewish sites as well as conversion of important historical structures, such as the Hagia Sophia, into mosques. In particular, the inclusion on the lists of restricted items should never include coins that circulated widely both in ancient and more recent times.
Kate FitzGibbon, Executive Director of the Committee on Cultural Policy (CCP), spoke specifically against the agreement with Afghanistan, raising four main points. First, the renewal is contrary to the statutory intent of the Cultural Property Implementation Act (CPIA), which for an “emergency” only authorizes narrow, time-limited, exceptional measures in an immediate crisis. Second, renewal would require, under the CPIA, the return of items to the Taliban terrorists. Third, the Taliban itself is the major threat to the cultural and historical heritage of Afghanistan, not the U.S. art and coin market. Finally, the definition of “emergency” has been stretched beyond plausibility. The proposed renewal hurts only legitimate trade, while threatening the seizure and repatriation of personal items belonging to the Afghani diaspora.
ACCG board member Randy Myers spoke on behalf of that organization as well as the American Numismatic Association (ANA). He began by questioning the legality of the limited time allowed for public comment allowed on these proposed agreements. He noted that current import restrictions on coins ignore the statutory provisions that limit the restrictions to objects of “cultural significance” that were “first discovered within” and “subject to export control” of a given country. He emphasized that unlike most other ancient artifacts, coins are mass produced, with dies used to strike approximately 13,000 coins each. This large production of coins combined with their wide dispersion means that one cannot assume that particular coin types are found in a given country. For example, coins on the current designated list for Turkey are found as far west as Spain and as far east as India. Finally, he noted that the State Department has produced no information to suggest that the MOU with Turkey has been effective.
Elias Gerasoulis spoke as Executive Director of the Global Heritage Alliance (GHA), and also as a board member of the American Hellenic Institute, to oppose the Turkish renewal. A renewal will only further encourage Turkey to continue erasing the cultural heritage of its displaced Christian and Jewish populations. The government has engaged in multiple instances of religious persecution, destruction and looting, both in Turkey and in occupied Cyprus.
Lucy Varpetian appeared on behalf of the Armenian Bar Association. The Association had submitted written comments, so Ms. Varpetian read a letter to CPAC from Congressman Gus Bilirakis (R-Florida. Co-Chair of the Congressional international Religious Freedom caucus) opposing a renewal of the MOU with Turkey. Noting that Turkey had failed to protect the rights of its religious minorities, Rep. Bilirakis’ letter concluded that “[t]he government that destroys its minorities’ historical property should not have the right to repatriate them at their pleasure.”
After her presentation, one CPAC member noted that he was Jewish and indicated to Ms. Varpetian that she could be assured that the concerns of religious minorities would be considered.
Rabbi Eric Fusfield, Deputy Director, International Center for Human Rights and Public Policy, Director of Legislative Affairs, B'nai B'rith International, argued that there should be a carve-out from current import restriction for Turkey for ritual and ceremonial objects. These really belong to Jewish and Christian communities, not the Turkish state. Many members of these communities were forced to flee that nation and were not able to bring family items that are now on the restricted lists with them.
Dr. Elizabeth Prodromou, a visiting professor in the international studies program at Boston College, served a diplomatic appointment on the U.S. Commission on International Religious Freedom (2004-2012), and was a member of the U.S. Secretary of State’s Religion & Foreign Policy Working Group (2011-2015). She urged rejection of the Turkey MOU renewal as being in violation of Article 9 of the UNESCO Convention because it can be seen as “green lighting” Turkey’s erasure of minority cultures.
Dr. Simon Maghakyan, a postdoctoral fellow at the University of Oxford, indicated his support of the comments of the Armenian Bar Association. He added that another reason the MOU should be rejected is due to Turkey’s support for Azerbaijan in its war to erase an Armenian presence and Armenian cultural heritage in Nagorno-Karabakh. He has studied state-sanctioned treasure hunting of former Armenian areas in Turkey and written an article on that subject for Newsweek.
A small number of speakers testified in favor of renewing specific agreements. The first of these was Dr. John Hoopes (University of Kansas), who spoke in support of a renewal of the MOU with Colombia. He has excavated in the country for the past 30 years. Pottery and gold artifacts are sought by looters, making the renewal of the current MOU essential in helping to protect Colombia’s cultural heritage. There are numerous sites yet to be excavated, many of which are just being discovered with the help of modern remote imaging techniques. He made no mention of coins.
Dr. Peri Johnson, an archaeologist teaching at the University of Illinois Chicago, supported renewal of the CPA with Turkey because she believes that looting is still a major problem there. She has seen instances where heavy machinery was brought in to help loot sites. Around 50% of the archaeological digs in Turkey are meant to rescue items before they can be taken by looters. Again, coins were not mentioned.
Dr. Brian Rose, Professor of Archaeology at the University of Pennsylvania and Curator-in-Charge of the Mediterranean Section of the Penn Museum, supported renewal of the MOU with Turkey. He stated that it is essential to help combat continued looting in the country, which he believes has taken adequate measures to protect its cultural heritage. He also made no mention of coins.
The same CPAC member who had spoken previously asked Dr. Rose about Turkey’s aggressive efforts to erase minority cultures. Dr. Rose could only state that he had not personally seen any such activities. He also indicated that he is aware of Turkey’s efforts to turn Hagia Sophia into a mosque.
That the hearing should never have taken place to begin with is obvious, given that the agreements up for renewal do not expire until next year, and that a new administration has the right to place members on bodies such as CPAC before important policy decisions are made. That these specific agreements should be rejected was even more obvious, given the state actors involved, their treatment of their culture, history and citizens, and their fraught relationships with the U.S. government. Whether any of these will actually go forward remains undetermined.
