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  • January 13, 2022 10:34 AM | Randolph Myers (Administrator)

    On January 13, 2022, the ACCG submitted a Freedom of Information Act request to the Department of State, regarding the Designated List of restricted ancient coins from Egypt, that was published by the U.S. Customs and Border Protection on December 3, 2021. We requested eight 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 Egypt, and how they considered the public comments earlier submitted to the Cultural Properties Advisory Committee.

  • January 11, 2022 8:53 AM | Randolph Myers (Administrator)

    On January 3, 2022, the ACCG submitted a Freedom of Information Act request to the Department of State, regarding the Designated List of restricted ancient coins from Greece, that was published by the U.S. Customs and Border Protection on November 22, 2021. 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 Greece, and how they considered the public comments earlier submitted to the Cultural Properties Advisory Committee.

  • November 27, 2021 11:08 AM | Randolph Myers (Administrator)

    Our FOIA administrative appeal contends that our FOIA request, which was divided into three parts and contained almost two pages of supplementary information, did reasonably describe the records sought.  The two "art trade" members were recently posted as additions to the Cultural Property Advisory Committee, after the ACCG filed repeated complaints with Department of State and then to its Inspector General.  While the two "art trade" members purport to have expertise, however, there is nothing in the public record that they are "experts in the international sale of archaeological, ethnological, and other cultural property" as required by the Cultural Property Implementation Act.  Since the Act requires such members to be experts, and that appointments be made to ensure "fair representation" of the interests of various private sectors, the ACCG filed the FOIA request on November 26, 2021, seeking documents on how the two members qualified as experts and as "art trade" representatives.

  • November 23, 2021 4:08 PM | Peter Tompa (Administrator)

    The State Department has amended current Greek import restrictions to include "Byzantine and medieval Frankish and Venetian coins that circulated primarily in Greece...."  Please see our Background Page under Legislation for details about this and other import restrictions on coins. 

  • October 21, 2021 5:16 PM | Peter Tompa (Administrator)

    The ACCG has filed comments in response to FinCEN's Advanced Notice of Proposed Rulemaking.  Those comments argue that coin dealers should not be subject to regulations contemplated for "antiquities dealers" given the negligible risk of money laundering and/or terrorist financing. All coin dealers are micro or small businesses. Many only operate part time. Imposing expensive and time-consuming regulations on these micro and small businesses may drive many out of business, in particular those which only operate part time. Without proof of a serious money laundering problem in the industry, coin dealers should not be subject to regulations designed for antiquities dealers. We understand the United Kingdom has exempted coin dealers from such regulations, and FinCEN should do so here as well.  For ACCG's written comments, see

  • September 25, 2021 6:26 AM | Peter Tompa (Administrator)

    The ACCG has filed the following comments on the State Department's last minute efforts to impose "emergency import restrictions" on Afghan cultural goods:

    I am writing on behalf of the Ancient Coin Collectors Guild to oppose the last-minute effort to impose import restrictions on Afghan cultural goods. We join the more substantial comments of IAPN and PNG but emphasize the following points. 1. CPAC should not allow a request by the "former government of Afghanistan” to provide cover for emergency import restrictions which can only benefit the Taliban. The State Department bureaucracy is engaging in sleight of hand. The Federal Register notice indicates that the former government sought a regular cultural property agreement, but that has now morphed into a request for emergency restrictions when there is no indication that the current Taliban Government has requested any such action or is even aware of it. In any case, the Taliban would have no standing to seek any such emergency import restrictions because the US does not yet recognize that government. 2. The criteria for emergency import restrictions found in 19 USC Section 2603 cannot be met, particularly with regards to coins. Bactrian coins are not “newly discovered material.” They have been studied and collected since at least the 19th century. Nor are they identifiable as coming from “any site of recognized to be of high cultural significance.” Indeed, Bactrian coins circulated widely throughout not only Afghanistan, but what is today Tajikistan, Uzbekistan, Pakistan and India. Finally, there is no demonstrable evidence of current pillage of “crisis proportions” in Afghanistan. Instead, the Taliban have said they will protect archaeological sites, presumably by applying their harsh brand of Sharia law to any prospective looters. Speculation that looting may become a problem in Afghanistan is no substitute for facts. There is simply no hard evidence that there currently is looting of “crisis proportions” in the country. 3. Proponents of import restrictions on cultural goods often claim that they are anti-terrorist financing measures. However, perversely import restrictions could very well lead to repatriations of cultural goods to the Taliban which then can be resold to fund any Taliban supported terrorism. Proponents may claim because there are no current diplomatic relations with the Taliban items may be seized but will not be repatriated. However, repatriations to the State Party are mandated under 19 USC Section 2609, and there are certainly no guarantees repatriations will not happen soon. Unfortunately, the CPIA has no safe harbor provisions that make protection of cultural artifacts a paramount concern. Instead, there is an erroneous assumption in the UNESCO Convention and the Cultural Property Implementation Act (CPIA) that State Parties are the best stewards of cultural heritage when that is often not the case. Certainly, that is not the case here given the Taliban’s past theatrical destruction of pre-Islamic cultural heritage. The Taliban’s “unclean hands” should weigh heavily against CPAC approving any emergency import restrictions.

  • September 23, 2021 8:56 AM | Randolph Myers (Administrator)

    The ACCG submitted its response, that objects to the proposed extension and amendment of the MOU and associated import restrictions with the Republic of Cyprus, as it impacts ancient coins.  In our response dated September 22, 2021, we raised three procedural objections that the public notice failed to give the public a meaningful opportunity to submit comments or participate in the Cultural Property Advisory Committee's open session, failed to inform the public whether ancient coins may be subject to import restrictions, and that the Committee has failed to include three art trade representatives as members as required by Cultural Properties Implementation Act We also made four substantive objections under the Cultural Properties Implementation Act.  Our comments can be found here:

  • July 20, 2021 10:39 AM | Randolph Myers (Administrator)

    On July 15, 2021, the ACCG submitted a Freedom of Information Act request to the Department of State, regarding the Designated List of restricted ancient coins from the Republic of Turkey that was published by the U.S. Customs and Border Protection. 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 primarily in Turkey, and how they considered the public comments earlier submitted to the Cultural Properties Advisory Committee.   ACCG FOIA request to Dept of State on Turkish coins 7.15.2021 RMyers.pdf

  • June 21, 2021 2:51 PM | Randolph Myers (Administrator)

    The ACCG has filed a complaint with the Inspector General of the Department of State, that the Cultural Property Advisory Committee fails to include three art trade members as required by law and its Charter.   Our complaint seeks the Inspector General’s investigation, that they confirm that the Committee lacks the legally-required “fair representation,” and that adequate correction steps occur.  ACCG complaint to the IG on lack of fair representation on the CPAC (RMyers 6.21.2021).pdf

  • June 18, 2021 12:25 PM | Peter Tompa (Administrator)

    The June 16, 2021  Federal Register ( announced regulations implementing the Trump Administration’s January 19, 2021, Memorandum of Understanding (MOU) with the Republic of Turkey.   This MOU is the latest in a series of recent agreements with authoritarian Middle Eastern and North African (MENA) Governments engineered with behind the scenes help from archaeological advocacy groups.  (

    Following a pattern established in these other recent MENA MOUs, the restrictions being imposed are of exceptional breadth, including virtually all Turkish archaeological and ethnological material dating from 1.2 million B.C. to the founding of the Turkish Republic in 1924.

    The new restrictions encompass a wide variety of ancient coins which “circulated primarily in Turkey.”  Additionally, In a blow to advocacy groups representing displaced religious and ethnic Greek, Jewish, Armenian, and Kurdish minorities, the regulations explicitly list religious artifacts associated with these groups that were either forcibly deported/and or encouraged to leave Turkey during the troubled 20th century. 

    The restrictions on coins are as follows:

    9. Coins

    a. Greek coins – Archaic coins, dated to 640 – 480 B.C., in electrum, silver and billon, that circulated primarily in Turkey; Classical coins, dated to 479 – 332 B.C., in electrum, silver, gold, and bronze, that circulated primarily in Turkey; and Hellenistic coins, dated to 332 – 31 B.C., in gold, silver, bronze and other base metals, that circulated primarily in Turkey. Greek coins were minted by many authorities for trading and payment and often circulated all over the ancient world, including in Turkey. All categories are based on find information provided in Thompson, M., Mørkholm, O., Kraay, C., Inventory of Greek Coin Hoards, 1973 (available online at and the updates in Coin Hoards I-X as well as other hoard and single find publications. Mints located in Turkey and surrounding areas are found in Head, B. V., Historia Numorum, A Manual of Greek Numismatics, 1911 (available online at

    b. Roman provincial coins – Roman provincial coins, dated from the end of 2nd century B.C. to the early 6th century A.D., in gold, silver, and bronze and copper that circulated primarily in Turkey.

    c. Byzantine period coins – Byzantine period coins, in gold, silver, bronze, copper coins, and sometimes electrum, dating from the early 6th century to the 15th century A.D., that circulated primarily in Turkey, (e.g., coins produced at mints in Nicaea and Magnesia under the Empire of Nicaea).

    d. Medieval and Islamic coins – Medieval and Islamic coins, in gold, silver, bronze, and copper coins from approximately A.D. 1077 – 1770, that circulated primarily in Turkey.

    The regulations will have a significant impact on millions of coin collectors and thousands of small businesses here and abroad that trade in historical coins.   The restrictions on coins are as follows:  While the regulations continue a current exemption for widely collected Roman Imperial coins, everything else down to 1770 is included, subject to the qualification that the coin type “circulated primarily in Turkey.”   This qualification apparently stems from the acknowledgement found in the regulations themselves that ancient coins as a general rule circulated far from where they were minted.  Before the controversial decision to first impose import restrictions on Cypriot coins in 2007, the wide circulation of such coins, as well as the fact that individual types have often come down to us in hundreds or thousands of examples, was enough to keep ancient and early modern coins from being placed on the designated lists. Since that time, coins have usually been included, often misleadingly simply based on the fact that they were minted within the confines of what is today a modern nation state.  

    If the phraseology here is meant to better comply with the Cultural Property Implementation Act’s (CPIA’s) language, it still only pays “lip service” to the statutory provisions.   Indeed, the “plain meaning” of the CPIA requires far more.  Import restrictions only apply to “designated archaeological material” under 19 U.S.C. §   2606.  This “designated archaeological material” is that “covered by an agreement” and “listed” under Section 2604.  19 U.S.C. § 2601 (7).  Section 2604 states that U.S. Customs and Border Protection (CBP) and/or the Treasury Department “may list this such material by type or other appropriate classification, but each listing made under this section shall be sufficiently specific and precise to insure that (1) the import restrictions under Section 2606 are applied only to the archaeological . . . material covered by the agreement . . . ; and (2) fair notice is given to importers . . . as to what material is subject to such restrictions.”  19 U.S.C. § 2604 (emphasis added).  The word “only” emphasizes the requirement that “designated archaeological material” must be only that covered by the agreement, i.e., “first discovered within” and “subject to export control by, the State Party.”   19 U.S.C. § 2601 (2).   The word “shall” emphasizes the mandatory nature of this Congressional direction; there is simply no discretion allowed.     See, e.g., Black's Law Dictionary 1407 (8th ed. 2004) (defining "shall" as "has a duty to; more broadly, is required to").  Therefore, under the CPIA, the proper standard is not whether a coin type “primarily” circulated within the confines of a given, modern nation state, but whether it can only be found there.  Moreover, even assuming the “circulated primarily” phraseology were correct, the regulation’s failure to identify which coins “circulated primarily in Turkey” raises the question whether the regulation may be constitutionally void for vagueness. 

    In any event, the real problem with such a broad MOU with Turkey is that in seeking to “protect” all “Turkish Cultural Patrimony” from looting, the U.S. Government will further harm minority communities living abroad as well as the legitimate trade in “Turkish” artifacts with our major trading partners in the European Union and the United Kingdom.  The cumulative impact of import restrictions on behalf of authoritarian MENA governments has been very problematical because most minor artifacts (like coins) and family keepsakes simply lack the document trail necessary for legal import under the “safe harbor” provisions of CPIA, 19 U.S.C. § 26061. The CPIA only authorizes the government to impose import restrictions on artifacts first discovered within and subject to the export control of a particular country. (19 U.S.C. § 2601.) Furthermore, seizure is only appropriate for items on the designated list exported from the State Party after the effective date of regulations. (19 U.S.C. § 2606.) Unfortunately, the Department of State and CBP view this authority far more broadly. CBP has promulgated designated lists based on where items are made and sometimes found, not where they are actually found and hence are subject to export control. Additionally, restrictions are not applied prospectively solely to illegal exports made after the effective date of regulations, but rather are enforced against any import into the U.S. made after the effective date of regulations, i.e., an embargo, not targeted, prospective import restrictions.

    The ACCG has updated its guidance on import restrictions to reflect the new regulations on Turkish coins.  This update can be found in the "Background" section of our website under "Legislation."

    A longer version of this post can be found on the "Cultural Property Observer" blog here:


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