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  • 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:

  • May 12, 2021 1:17 PM | Randolph Myers (Administrator)

    On May 12, 2021 the ACCG submitted its second request to Secretary of State Blinken, that there be “fair representation” on Cultural Property Advisory Committee, by adding art trade members as required by law.  Since we had received no response to our first letter dated April 1, 2021, this letter also advises of our intention to file a complaint with the Inspector General in thirty days, unless fair representation occurs.  ACCG second letter to Secretary Blinken seeking fair representation on the CPAC (RMyers 5.12.2021).pdf

  • May 04, 2021 12:54 PM | Randolph Myers (Administrator)

    The ACCG has filed a Freedom of Information Act appeal regarding the Smithsonian’s withholding of all 37 pages of responsive materials to our earlier FOIA request, where we sought information on their virtual workshop training US law enforcement "to combat trafficking in ancient coins." We believe that the public has a keen interest for this information, since we question whether anti-collecting archaeological advocacy groups were invited to participate when trade associations and collectors groups like the ACCG were not.  We are also concerned that the workshop was an indoctrination session that suggests that any unprovenanced ancient coin is illegal, when that is simply not the case. 

  • April 07, 2021 5:32 PM | Peter Tompa (Administrator)

    The ACCG has updated its "Background" page under "Legislation" to include detailed information about U.S. import restrictions on ancient coins and the paperwork necessary for legal import into the United States.  The information, current as of April 7, 2021, can be found here:

  • March 23, 2021 9:51 AM | Peter Tompa (Administrator)

    On March 17, 2021, the US Cultural Property Advisory Committee (“CPAC”) met to consider a proposed MOU with Albania and a proposed renewal of the MOU with Egypt. The following members were present: (1) Stefan Passantino (Chairman- Public); (2) Steven Bledsoe (Public); (3) Karol Wight (Museums); (4) J.D. Demming (Public); (5) Ricardo St. Hilaire (Archaeology); (6) Joan Connelly (Archaeology) and (7) Anthony Wisniewski (Collector-Sale of International Cultural Property).  Allison Davis, CPAC’s State Department Executive Director, and Andrew Cohen, State Department Lead Foreign Affairs Analyst, were also present.

    Chairman Passantino welcomed the speakers.  He indicated that the Committee had read all the comments, and as indicated in an email to the speakers, they would be allotted 3 minutes to focus on points most important to them.  Chairman Passantino called on speakers who had put in papers on Albania first, then speakers who had written about coins, and finally speakers who wrote on Egypt.  There was some overlap because some speakers put in papers on more than one topic.  He deferred questions to the end to be assured everyone who registered to speak would be heard.

    The following individuals provided oral comments:  (1) John K. Papadopoulos  (UCLA); (2) Michael Galaty (U. Michigan), (3) James Gould (RPM Nautical Foundation); (4) Randolph Myers (Ancient Coin Collectors Guild (ACCG)); (5) Peter Tompa (Peter Tompa Law-International Association of Professional Numismatists (IAPN) and Professional Numismatics Guild (PNG)); (6) Steve Benner (Ancient Numismatic Society of Washington, D.C. (ANSWDC)); (7) Kate FitzGibbon (FitzGibbon Law-Committee for Cultural Policy (CCP) and Global Heritage Alliance (GHA)); (8) Brian Daniels (Archaeological Institute of America (AIA)); (9) Mireille Lee (Vanderbilt); (10) Marcel Marée and Suzanne Veigh (British Museum); (11) Rocco Debitetto (Hahn Loeser- Association of Art Museum Directors); and (12) Katie Paul (ATHAR Project). 

    John Papadopoulos has visited in Albania periodically since the late 1990’s.  He undertook field work there from 2004-2008.  Looting was at its height in the late 1990’s.  It is not as severe today, but it is still problematic.  Looting destroys context which tells us much about how people lived in the area from the Neolithic through the Byzantine and post-Byzantine periods.  Coins are amongst the most common, easily located, and smuggled ancient objects. Albania is very welcoming to academic exchange and has made strides in cultural heritage management. 

    His written testimony may be found here:

    Michael Galaty has excavated in Apollonia and North Albania.  Galatay has documented systematic metal-detecting in the Shkoder province, targeting both settlements and burial mounds. He says he has been approached by children selling coins at archaeological sites.  He also has seen people metal detecting who had learned about it in England where it is legal.  Some are hobbyists but others are in it for profit.  He also indicates European coin dealers buy coins in Albania. Over the years, he has seen the government of Albania take great strides in trying to limit looting, including expansive cultural heritage laws, a professionalized regional archaeological/heritage service, upgrades to site security, and public education about the problem.  His testimony may be found here:

    James Gould speaks for the RPM Nautical Foundation.  During the Hoxha regime, anyone diving in Albanian waters would be shot on sight.  Since the fall of Communism, underwater looting with the use of scuba gear and fast boats for a getaway have become a problem.  Amphorae are typical targets for looters.  The Albanians have been excellent collaborators and a MOU would help address looting.

    The Nautical Foundation’s written comments can be found here:

    Randolph Myers indicates the current membership of CPAC does not reflect Congressional intent because the interests of dealers and the small businesses of the numismatic trade are underrepresented. Given their wide circulation, it is impossible to assume that coins struck in Albania are necessarily found there.  Numismatic research proves far more hoards of coins struck at Apollonia and Dyrrachium are found outside Albanian than within it.

    The ACCG’s written comments may be found here:

    Peter Tompa acknowledges the passing of James Fitzpatrick, Esq., one of the drafters of the CPIA who appeared before CPAC multiple times to emphasize the need for the Committee to follow Congressional intent.  He indicates that only coins that exclusively circulated within a given country can be restricted under the CPIA’s limitations of import restrictions to archaeological objects “first discovered within” and “subject to export control” by a UNESCO State party.  He believes that the 2016 Egyptian designated list violated this requirement because it included widely circulating large denomination Greek and Roman Provincial coins.  He also indicates there is no basis to expand current import restrictions further to widely circulating Roman Imperial coins struck in Egypt.  Nor is there any basis for restrictions on silver ancient Illyrian coinage struck in what is now Albania because far more hoards of these coins are found in Romania than Albania.  He also asks CPAC to recommend that Customs no longer apply import restrictions on coins as embargoes, but rather limit detentions and seizures to situations where there is probable cause that coins were illicitly exported after the effective date of governing regulations. 

    Peter Tompa’s oral comments may be found here:

    IAPN’s and PNG’s written submissions may be found here:



    Peter Tompa’s personal written submission may be found here:

    Steve Benner indicates that collectors like himself and other members of the Ancient Numismatic Society of Washington, D.C. are interested in numismatic scholarship, not making money out of coins.  The joy of holding an ancient coin in one’s hand stimulates one’s interest even more, pushing collectors to ascertain facts about a coin’s history and composition. Taking this away would be demoralizing to collectors and detrimental to our hobby. The Roman Republic and Empire included all the countries bordering the Mediterranean Sea as well as Western Europe, Britain, the Balkans, etc. Roman coins struck at any of the mints circulated freely throughout the Empire and should not be considered the property of any single country.

    Kate FitzGibbon also invokes Jim Fitzpatrick’s efforts to ensure that the Committee complies with the law, particularly the need for a showing of substantial current looting for an agreement to be justified. She questions whether there is such a problem in Albania or if looted material is coming here in quantity given the dearth of archaeological items being imported into the United States. As for Egypt, Ms. FitzGibbon notes that Egypt fails to acknowledge much material left the country legally before the 1980’s, and even where export certificates were issued, they were so general as to be useless to show provenance. Ms. FitzGibbon suggests that Egypt has only made a token effort at self help measures to care for its own cultural patrimony. Instead of spending money on preservation efforts, it has dumped huge amounts of money on General Sissi’s museum vanity project being built in the desert.  CPAC must consider such self help measures as part of its review of MOUs.  She also notes the China MOU which should be undergoing an interim review should consider China’s intentional destruction of Uighur cultural heritage.

    The CCP’s and GHA’s written submission on the Albanian MOU can be found here:

    The CCP’s and GHA’s written submission on the Egyptian MOU can be found here:

    Brian Daniels indicates ongoing looting and violence in Egypt justify the renewal of its MOU.  Recently, two site guards were killed by looters.  Egypt has been a good collaborator with U.S. archaeologists.  There was a conference about looting in Albania in 2009. There has been excellent collaboration with Albanian colleagues.  There will be a travelling exhibition of Albanian archaeological material in the U.S. in 2022.  Archaeological preservation efforts help foster tourism.  The AIA conducts tours in both Egypt and Albania.

    The AIA’s written submissions for both Albania and Egypt can be found here:

    Mireille Lee has used travelling exhibits as teaching tools.  It is important to question how an object got there. There are also ethical questions related to exhibiting mummies.  Hopefully, after the pandemic students will be able to visit exhibitions in person, but in the meantime, they have taken advantage of the Internet.

    Marcel Marée and Suzanne Veigh work with the British Museum’s CircArt project.  The project, made possible by grants from the British Council’s Cultural Protection Fund, is generating a digital knowledge base of Egyptian and Sudanese antiquities in the trade.  CircArt examines objects offered for sale on the ‘official’ open market as well as on social media. CircArt and the ATHAR Project work closely together, as there are many synergies between the projects.

     The first results of their research show clearly that the scale of ongoing looting and trafficking is far greater than is generally assumed. Since its inception in 2018, CircArt has recorded some 50,000 circulating artefacts from Egypt on the market, of which at least 15% were demonstrably excavated and exported illegally. A group of dealers in the USA remain heavily involved in the release of such objects onto the open market. They show images of broken off faces from mummy cartonnages where the rest of the coffin was discarded.  They indicate all these faces were offered by one U.S. dealer.  Dealers in Turkey have also been active with trans-shipment points in the Middle and Far East.  Much material also shows up on eBay or Facebook.  The data show with increasing urgency the true scale of illicit trade in cultural artefacts, indicating not only a need to renew the MOU between the US and Egypt, but ideally to reinforce the present import restrictions and to enact more robust regulation of the trade.

    The British Museum’s CircArt project’s submission may be found here:

    Its website may be found here:

    Rocco Debitetto indicates that CPAC must consider whether Egypt has met all the four determinations before its MOU is renewed.  The renewal should not be used to expand the designated list beyond the 250-year-old threshold for archaeological objects.  Ethnological objects need not be 250 years old, but Egyptian ethnological objects do not fit the criteria under the CPIA.  Egypt was not a tribal society in the 19th century but a major power. If anything, the current designated list should be narrowed.  In addition, the MOU needs to be reformed to require Egypt to make available more objects for loan without attendant high fees.  Since the 2016 MOU, Egypt has only sent two travelling exhibitions to the United States, both of which were only available to museums willing to pay high fees.

    The AAMD’s written submission can be found here:

    Katie Paul states that the ATHAR project is devoted to fighting trafficking on Facebook.   Research conducted by ATHAR Project illustrates a trafficking crisis in Egypt that is feeding material to black market groups on Facebook. This material includes items as small as coins and as large as coffins. She has tracked material from “trafficker groups” on Facebook that have ended up in the United States. She indicates this trade is hard to track because the buyers frequently try to cover their tracks.

    The ATHAR Project’s written submission can be found here:

    Question and Answer Period

    Anthony Wisniewski asks Marcel Marée to explain the difference between Alexander the Great and Hellenism. He indicates the Hellenistic period is generally thought to have started after Alexander died and his Empire was divided amongst his generals.

    Anthony Wisniewski asks Randy Myers to confirm that Alexander the Great coins as well as Roman and Byzantine coins from Egyptian mints are found in quantity outside of Egypt.  He points to the ACCG’s research online and within the Royal Numismatic Society’s Coin hoard series of books.

    Anthony Wisniewski asks Peter Tompa to confirm there were no Roman Imperial mints in Albania.  He does so.

    Anthony Wisniewski asks Brian Daniels if there is sufficient evidence to establish the 4 required determinations for a MOU with Albania.  He says he believes so because the totality of the evidence shows that there is ongoing looting, and that Albania has also undertaken sufficient self-help measures and efforts at collaboration with American archaeologists to satisfy the statutory criteria.

    Ricardo St. Hilaire notes that we should also acknowledge the passing of Nancy Wilkie, a long-term member of CPAC.  He asks Brian Daniels if archaeologists have had problems dealing with Egypt during the pandemic.  He says there have been issues, but they have been understandable ones given the circumstances. 

    Joan Connelly elicits information from Michael Galaty and John K. Papadopoulos about a 1991-coin hoard containing coins from Aegina (in Greece).  She posits that the hoard shows that Albania was important cross-roads and that it suggests the presence of a city thought to be in the area.  They suggest we only know this information because the hoard was professionally excavated.

    Stefan Passantino then closed the public meeting with thanks to all those who testified.


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