After the ACCG filed repeated complaints with Department of State, and then to its Inspector General, two "art trade" members were recently posted as additions to the Cultural Property Advisory Committee. Unfortunately, while the two members purport to have expertise in the international sale of cultural property, 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 a Freedom of Information Act request on November 26, 2021, that seeks any documents on how the two members qualify as experts and as "art trade" representatives.
The ACCG has asked FinCEN, a Treasury Department entity, not to impose costly and time consuming "anti-money laundering" regulations on the micro businesses of the coin trade. For more, see https://www.regulations.gov/comment/FINCEN-2021-0006-0019
The ACCG has filed formal comments opposing any effort to impose emergency import restrictions on behalf of the "former Government of Afghanistan." For more, see https://www.regulations.gov/comment/DOS-2021-0032-0040
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. ACCG comments on proposed extended and amended Cyprus MOU and Designated List RMyers 9.22.2021.pdf
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
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
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
The ACCG has filed a Freedom of Information Act appeal regarding the Smithsonian’s withholding of all 37 pages of responsive materials 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. Here is our FOIA appeal letter: ACCG RMyers FOIA appeal of Smithsonian withholding all 37 pages on virtual task force (5.4.2021).pdf
On April 20, 2021 the ACCG submitted comments on the European Commission‘s draft rules on the introduction and the import of cultural goods into the European Union. As detailed in our written comments, we requested the draft rules be clarified to confirm that its List of supporting documents, to prove licit provenance in an import license application for any ancient and modern collectors’ coins, do not apply to counties like the United States when they are a “country of interest,” when such coins have been properly located in the country for more than five years. ACCG comments on EU draft rule.pdf
The ACCG has sent a letter to the Secretary of State on getting fair representation on the Cultural Property Advisory Committee.
ACCG letter to Secretary Blinkin on CPAC composition with attached GHA letter 4.1.2021.pdf
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