On October 17, 2022, we submitted a Freedom of Information Act request to Customs and Border Protection, for the glossary to explain their SEACATS spreadsheet column headings and designations.  SEACATS stands for “Seized Asset and Case Tracking System” and details seizures of property by Federal agencies like the CBP.  This FOIA request occurred after we earlier won a FOIA administrative appeal decision on September 30, 2022, when CBP provided us with a 13-page partially redacted SEACATS spreadsheet on their seizure of various items.  But while the SEACATS spreadsheet listed 53 incidents where CBP seized coins between 2009 and 2021, their spreadsheet contained cryptic column headings and cryptic two and three letter designations that are unintelligible to the layman.  In the meantime, however, we reached out to the Institute for Justice, at ij.org, a nonprofit public interest law firm that focuses on exposing government abuses and securing constitutional rights.  The Institute, who earlier engaged in a multiyear legal battle with CBP for the SEACATS data codes, provided us with one of their reports which explained many of the SEACATS data codes.  Now that we have most of the data codes and a better understanding of SEACATS list of CBP’s seizures, we plan to further examine the circumstances and outcomes of past CBP coin seizures.

On September 30, 2022, the ACCG won its Freedom of Information Act administrative appeal, were we sought documents from Customs and Border Protection, on the creation and enforcement of the Designated Lists of import restricted ancient coins of ten nations.  Back on February 5, 2022 Customs and Border Protection had responded to our FOIA requests that they had "no documents."  We then filed a FOIA administrative appeal that contended that their response was factually inaccurate and that they failed to conduct a thorough and reasonable search.   In upholding our FOIA administrative appeal on September 30, 2022, the Department of Homeland Security’s FOIA Appeals, Policy & Litigation Branch informed us that responsive documents did exist.  As for our request for documents on the creation of Designated Lists, they provided us with 66 pages of partially redacted records, while explaining that their agency only engaged in a “ministerial” function of publication in the Federal Register, and that it was “the State Department, through the Cultural Property Committee, [that] creates the Designated Lists.”   As for our request for documents on the enforcement of Designated Lists, they provided us with 13 pages of partially redacted spreadsheets from their Seized Assets and Case Tracking System (SEACATS), that identified fifty incidents between 2009 to 2021 where they seized coins, most of which were “antique.”  

Find out more about who said what at a recent Cultural Property Advisory Committee meeting to discuss a proposed renewal of a MOU with Libya.  

http://culturalpropertyobserver.blogspot.com/2022/07/summary-of-july-26-2022-cultural.html

Effective July 14, 2022, the designated list for Cypriot coins was amended to include Byzantine and later coins that "circulated primarily" within Cyprus.  For details, see http://culturalpropertyobserver.blogspot.com/2022/07/cypriot-designated-list-expanded.html

On July 7, 2022 the ACCG filed comments with the Cultural Property Advisory Committee objecting to the proposed MOU with Libya as it impacts the importation of ancient coins  We raise one procedural objection, and five substantive objections, why import restrictions should not include ancient coins, except to the extent that it is an artifact that has been identified as looted from one of Libya’s World Heritage sites.   Details may be found here:

https://www.regulations.gov/comment/DOS-2022-0015-0002

On April 14, 2022 the Ancient Coin Collectors Guild filed comments with the Cultural Property Advisory Committee objecting to the proposed MOU with the Islamic Republic of Pakistan as it impacts the importation of ancient coins.  We raise two procedural objections, and five substantive objections, why import restrictions should not include ancient coins.   Our comments can be found here:

ACCG comments to CPAC on proposed restriction of Pakistan ancient coins (RMyers 4.13.2022).pdf

On April 11, 2022, the ACCG submitted a Freedom of Information Act request to the Department of State, regarding the Designated List of restricted ancient coins from Albania, that was published by the U.S. Customs and Border Protection on March 17, 2022. We requested seven categories of documents, including the basis of their “determinations” to legally justify such restrictions, how the restrictions can legally apply to coins that circulated outside Albania, and how they considered the public comments earlier submitted to the Cultural Properties Advisory Committee.

Our guidance for the import of ancient coins to the United States has been moved to our home page making it easier to find and access.  It also can be found here:  https://accguild.org/Ancient-Coin-Import-Restrictions

The latest version of the guidance includes information about new import restrictions on coins from Albania.  For additional details about these new restrictions, see here:  http://culturalpropertyobserver.blogspot.com/2022/03/import-restrictions-on-albanian-coins.html

Our FOIA administrative appeal contends that Customs and Border Protection does have such responsive documents, and we cite not only the agency's legal obligations under FOIA's text and caselaw to conduct thorough and reasonable searches but offered examples where such CBP documents exist.

We have updated our guidance for the import of ancient coins into the United States.  The update can be found here as well as under "Legislation" in the "Background" section of our website:  013122 Import Restrictions on Ancient Coins and Declarations for Legal Import .pdf