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March 09, 2022 11:32 PM | Sue McGovern-Huffman (Administrator)

Effective Date: June 16, 2021

Source: 86 Fed. Reg. 114 (Feb. 16, 2021)

The list of coins is extensive. It includes:

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

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.

Comment: These restrictions are breathtakingly broad. However, they are qualified to only include coins that “circulated primarily in Turkey.” If this phraseology is meant to comply with the CPIA, it only pays “lip service” to the statutory provision limiting any restrictions to archaeological objects “first discovered within” and “subject to export control by” Turkey. (19 U.S.C. § 2601.) Moreover, what coins “primarily circulated in Turkey” is undefined putting the importer in the position of gambling whether the coins they import will be deemed to be covered by the restrictions or not. On a positive note, Roman Imperial coins remain exempted from the restrictions.


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