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.

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.

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.

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