Coins of Roman Egypt Included in Import Ban Proposals
Please comment now!
In the face of all evidence, legalities, politics and common sense, the Cultural Property Advisory Committee (CPAC) -- still stocked with appointees from the Biden administration -- will be meeting on March 3 to consider renewals of Memoranda of Understanding (MOU) with Egypt, Greece and Bolivia. The timing is also suspect, as the current MOUs do not expire until much later this year.
The Egypt and Greece MOUs are particularly alarming. Coins identified as "Greek" were in fact minted over vast areas of Europe and Asia, yet neither the State Department nor U.S. Customs seems to display any understanding of this fact as they continue to infringe on the rights of ancient coin collectors. Coins of Roman Egypt circulated throughout the Roman empire, making it virtually impossible to determine where any individual specimen was found; yet these too are widely swept up in the import restrictions.
Further, it makes no diplomatic or political sense to prioritize the authoritarian dictatorship of Egypt over the legitimate rights of American collectors, dealers, museums and historians.
As for Greece, that country is part of the European Union (EU) -- something else that Customs seems not to understand. EU rules govern all exports from all EU countries. Those rules explicitly allow EU members to export most cultural goods, with or without a permit. Most EU members allow exports of coins, again usually without a permit. However, Customs thinks it can seize any coin on the designated list for Greece, or the other EU countries with MOUs (Bulgaria, Cyprus, and Italy) even where the coins were legally exported from another EU country.
Regarding Bolivia, the current MOU only covers pre-Colombian artifacts. However, there have been previous requests to impose import restrictions on Spanish colonial and early Republican coinage from Latin America, despite the fact such coins were legal tender in the United States until 1857.
The window for public comments on these MOUs is short, lasting only until February 20, so we need you to weigh in now. The number of comments seems to dwindle with each new hearing; yet we simply must flood CPAC with our comments, or we risk losing one of the most important sources for our hobby.
Below are key points you can make if you can create your own comments, as well as information on how to submit them. A sample comment template is also provided, but we must stress that individual comments are more impactful.
The key arguments against the Egypt MOU are:
- Coins of Roman Egypt circulated over a very wide area, making it impossible to discern whether any specific coin was “first discovered within” and “subject to the export control” of Egypt, as the Cultural Property Implementation Act (CPIA) mandates.
- Many of these coins were minted in vast numbers and are so common that they can be purchased for very minimal sums of money. By no means are they critical to the historical and cultural heritage of Egypt.
- It makes no diplomatic sense to put the whims and wishes of an authoritarian dictatorship over the rights and interests of American coin collectors, dealers, students, historians and museums.
Key arguments against the MOU with Greece are:
- "Greek" coins were in fact minted widely across Europe and western Asia, and many of them circulated across a similarly broad area. For example, the coins of Athens were virtually a global currency for several centuries. Again, it is virtually impossible to determine whether any specific coin was “first discovered within” and “subject to the export control” of Greece, as required by the CPIA.
- As a member of the European Union, Greece is subject to the EU's export rules, which generally allow coin exports, both within the EU and from EU nations. Preventing their importation to the United States is unfair to American citizens, while contributing nothing to the CPIA’s goals of protecting cultural heritage.
Further arguments against all three MOUs include:
- The Trump administration has not yet appointed its preferred members to CPAC. Proceeding on these agreements with appointees from the previous administration does not make sense, especially in light of the fact that the President recently withdrew the United States from International Centre for the Study of the Preservation and Restoration of Cultural Property, clearly indicating that he does not support this approach to international diplomacy.
- The current MOUs with these nations do not expire until much later this year. Considering a renewal at this time, especially given the changed priorities of the current administration, is completely unwarranted.
- When it was originally adopted, the State Department expressly stated that it did not foresee ever including ancient coins in any import restrictions.
In order to submit your own comments, click here https://www.regulations.gov/document/DOS-2026-0133-0001: and follow the fairly simple instructions. For reference, the docket number is DOS-2026-0133-0001. Please do remember that your comments are part of the public record; and again, that the deadline for comments is February 20.
Template for Comments
If you prefer to submit something already written, here is some sample text. To the degree that you can at least customize it slightly, please do; but the most important thing is simply to make sure that all of our voices are heard by CPAC.
Dear Cultural Property Advisory Committee:
I am writing in strong opposition to renewal of the MOUs with Egypt, Greece and Bolivia.
To start with, the MOU with Egypt places the interests of an authoritarian, repressive dictatorship ahead of the legitimate rights of American citizens. This serves no valid diplomatic, cultural or historical purpose. Further, the restriction on importing coins from Roman Egypt is completely misguided. These coins were minted in huge numbers and circulated over vast areas. Thus it is virtually impossible to discern whether any specific coin was “first discovered within” and “subject to the export control” of Egypt, as the Cultural Property Implementation Act "CPIA" mandates. At a bare minimum, any renewal of this MOU should remove all reference to coins of Roman Egypt. After all, when originally adopted, it was never the intent of the CPIA to include ancient coins in the first place.
Regarding the MOU with Greece, "Greek" coins were minted, and circulated, over vast areas of Europe and western Asia, so again it is virtually impossible to determine whether any specific coin meets the CPIA mandate of being “first discovered within” and “subject to the export control” of Greece. Indeed, as a European Union member, exports from Greece are governed by EU export regulations. These rules generally allow coin exports, both within the EU and from EU nations. Preventing their importation to the United States is unfair to American citizens, while contributing nothing to the CPIA’s goals of protecting cultural heritage.
These MOUs do not expire until much later this year, so there is no reason to rush to renew them at this time -- especially in light of the fact that President Trump recently withdrew the United States from International Centre for the Study of the Preservation and Restoration of Cultural Property, clearly indicating that he does not support this approach to international diplomacy.
Underlying all of this, it needs to be stated once again that the original CPIA was never intended to include coins, as State Department testimony by Deputy Legal Adviser Mark Feldman given to Congress at that time made abundantly clear.
Sincerely,
[add your name]
For a more detailed commentary on these items, please read this blog by ACCG Board Member Peter Tompa: Cultural Property Observer: Time Again to Tell the Cultural Property Advisory Committee What You Think About Import Restrictions on Coins for Authoritarian Egypt, Greece and Bolivia. This can help if you have time yourself to submit more expansive comments to CPAC. More detailed comments can be helpful, but what is most important is that CPAC receives as many comments from our side as possible.
