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ACCG, ANA File Comments on Upcoming MOUs

May 15, 2024 11:23 AM | Keith Twitchell (Administrator)

On May 13, 2024 the Ancient Coin Collectors Guild and the American Numismatic Association filed joint comments to the Cultural Property Advisory Committee, which raise concerns about the proposed MOUs with the governments of Ukraine and Jordan, as they may impact import restrictions on ancient coins.

For the Ukrainian MOU, we strongly condemn the Russian invasion, but contend that the Federal Register’s notice failed to give the public the opportunity to submit timely and meaningful comments. Among the substantive matters under the Cultural Property Implementation Act, we question whether “Ukrainian coinage” meets the definitions of “archaeological or ethnological material of a State Party,” and that even if they do, whether such coins were “first discovered within, and . . . subject to export control by” Ukraine. We also ask the Committee to consider whether Ukrainian coinage is danger from looting, when the Ukrainian government allows the sale of ancient and other historic coins and medals within their country.

We also ask whether “self-help” measures and related “less drastic remedies” exist, since we contend that “less drastic remedies” exist in the form of regulating metal detectors, a portable antiquities scheme and a functional export system. Finally, we contend that any import restrictions must be applied prospectively and not in the form of a retroactive embargo.

For the Jordan MOU, our joint comments raise concerns to the proposed extension of the MOU. As a substantive matter, we join the comments that have been submitted by the International Association of Professional Numismatists dated April 30, 2024, that highlight several critical provisions from the Cultural Property Implementation Act as it impacts ancient coinage. As a procedural matter, we contend that the Federal Register’s public notice failed to give the public the opportunity to submit timely and meaningful comments.

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