On January 10, 2023, the Ancient Coin Collectors Guild joined by the American Numismatic Association, filed commentswith the Cultural Property Advisory Committee, to object to proposed MOUs with the Governments of North Macedonia and Uzbekistan, as it applied to the import restriction of ancient coins.
While the public notice was published in the Federal Register on December 21, 2022, the CPAC’s website failed to state that they were considering import restrictions on coins until January 2f2023. Our comments raised a number of procedural and substantive objections.
Our procedural objections complained that the public notice was untimely, vague and inadequate, which effectively denied the public the ability to submit meaningful comments. Our substantive objections focused on the Cultural Property Implementation Act, where we argued that ancient coins did not qualify as artifacts of “cultural significance,” that ancient coinage cannot be assumed to have been “first discovered within” and “subject to the export control” of the two counties, that other available “less drastic remedies” existed, that neither country submitted a statement of facts for the CPAC’s “determination,” and that coins minted after 1773 cannot be restricted since the Act requires objects be “at least two hundred and fifty years old.” ACCG and ANA comments objecting to North Macedonia coin restrictions RMyers 1.10.2023.pd. ACCG and ANA comments objecting to Uzbekistan coin restrictions RMyers 1.10.2023.pdf
Written comments on the new proposed MOUs with North Macedonia and Uzbekistan must be received by January 23, 2023 at http//www.regulations.gov, enter docket DOS-2022-0048, then follow the prompts.