On November 7, 2022 the ACCG submitted comments regarding the Draft UNESCO Model Provisions on the Prevention and Fight against the Illicit Trafficking of Cultural Property. Besides joining the comments of International Federation of Art and Antique Dealer Associations and the International Association of Professional Numismatists, we wrote separately to emphasize several points as applied to ancient coins. Specifically, we commented that it was unreasonable and unrealistic to require export certificates for ancient coins or to require licenses for coin dealers, that the United Kingdom’s Treasure Act and Portable Antiquities Scheme provides a more positive and reasonable alternative regulatory approach at least as for ancient coins, and that there is a need for better meaningful consultation in developing the Draft UNESCO Model Provisions.
