Up for consideration at the July 14, 2026 meeting of the Cultural Property Advisory Committee (CPAC) were renewals of Cultural Property Memoranda of Understanding (MOU) with Algeria and Nigeria, and a new MOU with Romania.  A total of 14 individuals provided oral testimony during the meeting.  Of those, 8 commented in favor of some or all of the MOUs, and 5 spoke in opposition to some or all of the MOUs; one person was not specific about being for or against.  It should be noted that the entire meeting was remote; the CPAC members in attendance were included via Zoom rather than gathered together in person.

Virtually all the comments pro and con addressed the import restrictions included in the MOUs.  Strikingly, none of the opponents provided any proof at all that such restrictions have had any demonstrable impact on the underlying issues of the looting of historic and cultural heritage sites, and illicit sales of historic and/or cultural items.  While several opponents commented that reducing the marketplace demand for such items was vital to addressing the problem – an argument made in many contexts, from antiquities to drugs to human trafficking – again, no evidence was presented to support this assertion.  Perhaps unwittingly, the comments of a few opponents either undercut this argument or pointed to entirely different problems.

The first speaker was Omur Harmansuh, Vice President for Cultural Heritage of the Archeological Institute of America.  He addressed the meeting from Turkey.  He spoke in favor of the requests, and noted that AIA had provided written testimony and letters of support.  While his primary focus was on Albania and Romania, he noted that AIA had recently presented an award to an archeologist in Nigeria, which he stated was indicative of the quality of archeological research in that country as well as the ties between archeologists in Nigeria and the United States.  Regarding Albania and Romania, there is a long history of archeological interaction between these countries and the U.S., including lending of items for museum exhibits that have helped introduce the American public to the complex early societies that existed in these countries.  He stated that archeological heritage and sites in all three countries are in danger.  He cited the theft of four important Albanian items from a museum exhibit in the Netherlands [which of course has absolutely nothing to do with anything covered by the MOU], and noted that Albania in particular is vulnerable to looting at its archeological sites.  He concluded by expressing AIA’s strong support for all three MOUs, though without making any link between the details of the agreements and the problems he described in the countries.

Second was Elias Gerasoulis, the Executive Director of the Global Heritage Alliance.  He urged rejection or at least delaying consideration of the MOU with Nigeria, citing serious concerns expressed by the United States government, including President Trump, over various activities conducted by the Nigerian government.  He specifically cited reports of mass killings of Christians and other forms of religious persecution as well as suppression of anti-government protests.  He noted that Congress is considering further sanctions against Nigeria, which is considered by many to be a failed state.  In addition to moral and ethical concerns relating to any agreement with Nigeria, there are practical concerns regarding repatriation of any items, which could potentially be seized and then sold by terrorist groups in the country.  There is evidence that members of terrorist organizations such as Boko Haram are now in the Nigerian army and government.  Consideration of this MOU should be suspended until Nigeria issues relating to religious persecution and human rights abuses have been addressed and the government is in alignment with broader U.S. priorities.

CPAC member Nii Quarcoopoune expressed shock upon hearing about religious killings and persecutions in Nigeria, of which he was apparently unaware.  He objected to the characterization of Nigeria as a failed state and claimed that if such was the case, the U.S. would not have any presence there.  Mr. Gerasoulis replied that he was merely repeating what U.S. officials, including former ambassadors to Nigeria and President Trump, have said about the country.  Mr. Quarcoopoune responded by saying that he saw no link between the political situation and the preservation of cultural heritage and property.

Next was Teresa Ngan, who detailed many discoveries relating to the existence of ancient Greek civilization in Romania.  She shared photos of many items indicating the ancient history and pre-history of Romania, and stated that preserving archeology in Romania is vital to understanding that country’s history.  She also noted that many ancient Roman sites have been found in Albania.  Because of this, she is in favor of the MOUs, though she made no link whatsoever between the details of the agreements and the information she presented.

She was followed by Peter Tompa, Executive Director of the International Association of Professional Numismatists (IAPN), an organization of small and microbusinesses in the United States and European Union.  IAPN has provided detailed comments in opposition to the MOUs.  Regarding Albania, the grossly overbroad designated list of items [to be restricted] ignores extensive research that IAPN has presented regarding the widespread circulation of ancient coins from this area.  The same is true for Romania.  Coins struck in and/or found Transylvania are more a part of Hungarian cultural heritage than Romanian.  He noted that the statute governing all these agreements requires CPAC to consider less drastic measures to achieve its objectives before imposing import restrictions.  He pointed out that Romania is part of the European Union and subject to the EU’s regulations regarding importing and exporting of ancient coins among its members, which are far less restrictive than what the MOUs contemplate and specifically allow for coins from Romania to be exported to other member nations.  Cultural property agreements should align with EU rules.  He also observed that the proposed restrictions would be painful Americans of Austrian or Hungarian descent.

CPAC member Alex Baker asked Mr. Tompa to elaborate on the EU export controls situation, because his understanding was that individual member nations could establish stricter export rules themselves.  Mr. Tompa replied that member nations were still required to recognize the rules of the Union and of other member nations, and the U.S. Customs ignores this fact.  We have to recognize the right of some EU members to export items that other members may restrict.  Yet Customs stops items coming in from one country because they are on the restricted list of another country, which is incorrect and unfair.  This is very detrimental to legitimate trade.

Next was Kate Fitz Gibbon, Executive Director of the Committee for Cultural Policy, which has submitted detailed documents in opposition to the MOUs.  She addressed the larger failure of policy that the MOU documents represent.  The number of Cultural Property Agreements has been growing rapidly, which requires close scrutiny of them rather than routine approval.  Increasingly, the documents are overly broad and do not meet the four determinations that legally govern them.  To say that an entire nation’s cultural heritage is threatened by looting is not credible.  There is no evidence that the increasing restrictions are doing anything to reduce these problems.  The original intent of the statutes was to preserve important historical items while protecting the flow of ancient art to the Unite States.  She noted that there is no real flow of such items from Romania and Albania to the U.S.  The preservation failures exist within the originating nations; for example, in Romania, museums are purchasing items from metal detectorists.  Meanwhile, these entities are claiming the cultural heritage of minority groups within their nations as their own even as they fail to protect those minorities.  Further, the Cultural Property Implementation Act (CPIA) is not restitution legislation.  Addressing Nigeria, that country has given legal ownership and control of all repatriated cultural artefacts of Benin, and custodianship of the heritage of Benin, to a single individual rather than the people of that region.  That MOU should be suspended, not renewed.  In closing, she encouraged CPAC members to read the testimony presented to them, read the statute governing the MOUs, and apply the four requirements to these and any future documents.

She was followed by Dr. Michael Galaty, Professor of Anthropology and Classical Studies at the University of Michigan, who addressed renewal of the MOU with Albania.  He has conducted research in that country since 1998, in the course of which he has spoken to many local people and seen widespread looting, which he suspects is tied to organized crime.  He has had children offer to sell him coins, which he considers indicative of coins being sold to Western Europe.  He has observed metal detecting, much of it by hobbyists but some of which he thinks results in items being sold to European markets.  Metal detecting and looting has caused extensive damage to historical and archeological sites, though he said local authorities are working to curtail this.  He closed by stating that renewing the MOU will short-circuit market demand and strengthen the growing professional ties between Albanian and American archeologists [of course, this ignores the fact that the current MOU has apparently done nothing to “short-circuit market demand”].

CPAC member Miriam Stark asked whether coins can be excavated without destroying an archeological site.  Dr. Galaty said they could not.

Next was Dr. Britney Kyle, Professor of Anthropology, University of Northern Colorado, who studies human skeletons to increase understanding of the ancient Greek world.  She favors renewal of the MOU with Albania, where she has done extensive research on skeletons.  She has brought many students with her, resulting in turn in Albanian students coming to the U.S., so that Albanians are now able to investigate their own history.  It is necessary to preserve their archeological sites to enable this, and looting is disturbing these sites.  She noted that she was solicited by guards at Apollonia to buy ancient coins, presumably from the site [an astounding undercutting of any argument that these MOUs would do anything to protect such sites – in fact, she did not in any way connect the MOU to protecting archeological sites].

Next was D. Adria Farmer-Paellmann, the Executive Director of the Restitution Study Group.  She has worked for 25 years on issues of reparatory justice and the legacy of transatlantic human trafficking.  Her group supports the protection of Nigerian cultural heritage.  There is a need to recognize all the cultures in the country in any cultural property agreement.  She talked at length about the Benin bronzes, to which she felt Nigeria had a legitimate cultural claim.  She offered six specific recommendations for the MOU, which were a little difficult to follow but generally called for broader inclusion of people, communities and organizations in managing cultural heritage, and for doing all this in an appropriate historical context.  She did not specifically state support or opposition to the MOU, though her list of recommendations would suggest a lack of support for it in its current form.

She was followed by Ogechukwe Nkere, a Biafran-American political and human-rights activist and Prime Minister of the Biafra Republic Government in Exile, addressing the extension of the MOU with Nigeria.  He detailed the Nigerian government’s suppression of human rights and history of persecution of Biafrans, which is ongoing; this includes extrajudicial killings, torture and disappearances.  He referenced the persecution of Christians in general, citing comments by President Trump as well as U.S. sanctions.  He felt that the MOU with Nigeria should be suspended until the government of Nigeria is in alignment with U.S. priorities.

Next was Dr. Scott MacEachern from the Society for American Archeology, speaking in support of the Nigerian MOU extension.  He also provided written comments.  He has worked in Nigeria since the mid-1990s, though his primary working site is no longer accessible due to its location in Boko Haram’s self-proclaimed capital.  Nigeria is a very diverse country, though not a failed state, with diverse cultural heritage traditions.  Its cultural materials are highly-sought by the international market, especially those from the Benin culture.  The security situation in the country is highly variable and does not necessarily correlate to areas of greatest threat to cultural heritage.  The country’s extremely porous borders facilitate smuggling of cultural heritage materials [undercutting arguments in favor of an MOU with the country].  He stated that the MOU would shut down the market demand side of the problem [which it apparently has thus far failed to accomplish].  He stated that heritage personnel in Nigeria were very committed to their work.

He was followed by Stephen Knerly, speaking for the Association of Art Museum Directors with qualified support for renewal of the Nigeria MOU.  He focused on the fourth determinant governing the MOUs, which covers cultural exchange and specifically inter-museum loans.  He addressed legal complexities resulting from the MOUs, which require transparency, predictability and adherence to legal norms.  He noted that the MOUs used to include specific goals with measurable outcomes so that performance of the MOUs could be measured.  These have been replaced by generic terms; there is a need to develop standards to support and facilitate cultural exchange.

Next was Dr. Adam Rabinowitz, Associate Professor in the Department of Classics at the University of Texas at Austin, though he noted that he was speaking on his own behalf as a working archeologist in Romania.  He recommended adoption of the MOU with that country, and also submitted a letter to that effect.  He also referenced items stolen from the museum exhibit in the Netherlands.  He noted the use of metal detectors to uncover coin hordes, stating that coins are important to dating and understanding archeological sites.  He pointed out that there are countries other than the U.S. where people purchase these coins, but this country is one of the largest markets.  Metal detecting also unearths bronze and iron age items and disturbs their sites.  Burial mounds in particular are preferred targets for looting.  He stated that Romanian officials are making strong efforts to enforce their laws and to document their heritage.

Next was Vivien Bence, representing the Hungarian Human Rights Foundation and speaking in opposition to the Romanian MOU.  The MOU’s restrictions could apply to heirlooms brought into the U.S. by Hungarian refugees.  It would also recognize the Romanian state’s ownership over Transylvanian or Hungarian diaspora cultural property.  The Roman government has been using forced assimilation, including the exploitation and destruction of Hungarian cultural patrimony, and has not repatriated many significant cultural properties.  She specifically cited the Batthyaneum Library as an example of this.

Next was John O’Shea, speaking on behalf of the Society for American Archeology in favor of the MOU with Romania.  He has worked in this area since 1976, before the existence of the European Union.  The resulting relaxing of borders has facilitated moving artifacts between countries and encouraged looting.  The subsequent destruction of archeological sites is discouraging young Romanian professionals in the field, who are moving to other countries to pursue their work.  He indicated that the EU would be imposing new restrictions soon and that North America should not remain as a loophole.  Having routine processes for how materials can move in and out of the country would protect international and Romanian researchers.

The contrast between the entirely academic concerns of the proponents of the MOUs and the sometimes-personal concerns of the opponents was striking.  The arguments for the documents were the usual statements about how the MOUs would greatly reduce market demand for looted objects, despite no evidence to support this and the failure of previous MOUs to have any measurable impact on the problem.

One final observation:  no one argues against the notion that looting important archeological sites and selling looted materials illegally is a significant problem that needs to be addressed.  However, the limited solutions suggested by MOU proponents have completely failed to solve this problem in the past, and the famous definition of insanity is to keep trying the same approach while expecting different results.  Proven solutions such as the United Kingdom’s Portable Antiquities Scheme need to be amplified greatly, and the United States needs to take the need in promoting this approach.

The Ancient Coin Collectors Guild is pleased to announce the appointment of Andy Pierucci as Executive Director. Pierucci replaces Keith Twitchell, who will remain active on the ACCG Board of Directors.

Pierucci, a resident of Riverton, Utah, is a lifelong ancient and medieval coin collector. He has served on the ACCG Board of Directors for over four years and has been actively engaged in congressional outreach on key ACCG issues. He is an experienced leader in business and the public sector, who has held leadership roles in several Fortune 100 companies, multiple nonprofit organizations, and state and local government. Pierucci is an active member in other numismatic organizations and is a Fellow with the Royal Numismatic Society.

Pierucci stepped into the position on July 1. In addition to maintaining the vital legislative actions ACCG is pursuing to preserve the rights of collectors in the United States, his top priorities will be to enhance and expand ACCG communications, strengthen strategic U.S. and international partnerships, and focus on ACCG’s advocacy efforts.

Founded in 2004, the Ancient Coin Collectors Guild is a nonprofit organization comprised of collectors, dealers, educators, historians, and others who share a passion for ancient history. ACCG is dedicated to preserving history, culture, and the rights of those who study them.

On May 6, 2026, the Ancient Coin Collectors Guild submitted Freedom of Information Act requests to the Department of State and to Customs & Border Protection regarding two recent incidents, where ancient coins seized by Customs were “repatriated” to Greek and Italian officials by the State Department.  The Greek City Times (April 25, 2026) reported that “Greek” ancient coins had been seized “due to missing legal documentation,” while Art News (April 30, 2026) reported a “cache of Roman coins” had been seized by the agency but then failed to respond to press inquiries about the seizure.  The Guild’s FOIA requests raises issues whether these ancient coins, that were apparently seized while being imported into our country, was the proper subject of import restrictions, whether the importing owners were given any notice so they could respond, which then raises a fundamental question about the ancient coins “repatriation.”  

On behalf of the Ancient Coin Collectors Guild, this responds to the Notice of a “Initiation of Section 301 Investigations: Acts, Policies, and Practices of Certain Economies Relating to Structural Excess Capacity and Production in Manufacturing Sectors” published at 91 Federal Register 12886 (March 17, 2026).  Specifically, we request that the Section 301 Committee recommends that Harmonized Tariff Schedule (HTS) Heading 9705 (Collections and Collector’s Pieces) and HTS Heading 9706 (Antiques) be removed from consideration for any 301 tariff application. 

The Ancient Coin Collectors Guild is a nonprofit organization, whose mission is to promote and nurture the free and independent collecting of coins from antiquity through education, political action and consumer protection.   The Guild’s goal is to foster an environment in which the general public can confidently and legally acquire and hold, for personal or professional use, any numismatic item of historical interest regardless of date or place of origin.  It has twenty-four affiliate member organizations and advocates for the interests of thousands of ancient coin collectors and hundreds of small businesses of the numismatic trade.  More information regarding the Guild may be found at our website at accguild.org.

We make this request to remove any 301 tariff application for such historical coins and antiques – which were produced hundreds of years ago -- because it does not deal with or impact current American manufacturing.  These coins and antiques are clearly not related to the issues targeted in the Section 301 Commission Investigation, since they are clearly not part of either the current “manufacturing sectors” or “structural excess capacity.”   

Indeed, imposing duties on historical coins, that have previously been exempt from such customs duties, will cause disproportionate harm to the micro, small or medium sized businesses that make up the America’s multi-billion dollar numismatic trade as well as to individual American collectors, by disadvantaging them compared to foreign market businesses and collectors who would not need to pay tariffs on these same items.

Imposing tariffs on these categories would also directly conflict with nearly a century of Congressional policy, which was deliberately designed to ensure the duty-free movement of cultural and historical materials. Historical coins, like other cultural goods, are not typically subject to customs duties because our government has generally sought to encourage cultural exchange.  Almost 90 years ago, Congress exempted antiques in order to encourage the free flow of artistic and cultural materials into our country. 

As detailed in the comments submitted by the International Association of Professional Numismatists of March 23, 2026 -- whose comments we fully support -- the HTS for the U.S. Tariff Act of 1930 established the concept of an “antique” as a handcrafted object 100 years old or older.  Thus, the U.S. exempted antiques from duty even before the UNESCO Florence Agreement of 1952, which was intended to “facilitate the free flow of educational, scientific and cultural materials by the removal of barriers that impede the international movement of such materials.”  Finally, the long-standing exemption for historical coins under HTS Code 9705 has not change under either President Trump’s reciprocal tariffs or the more recent temporary import surcharge.  Rather, historical coins have been treated as exempt “informational materials” under HTS Codes 9903.01.31 and 9903.03.11

In conclusion, we request that the Section 301 Committee recommends that HTS Heading 9705 (Collections and Collector’s Pieces) and HTS Heading 9706 (Antiques) be removed from consideration for any 301 tariff application.

Dear Members,

ACCG is aware that most of the emails you receive from us are requests for your help with things like commenting to CPAC about the latest proposed MOU disaster – usually with some gloom and doom thrown in for motivational purposes. So it seems more than fair that we share some recent achievements and good news with you, especially since this only happens with your participation and support.

First, despite the ongoing Washington insanity, we have managed to get fifteen bi-partisan co-sponsors for our HR 595, a bill to facilitate the lawful trade of historical coins. In the current climate, this is a significant achievement. We are generally getting a good response to our efforts to attach the bill’s language to Customs legislation in the Senate. Whether any of this goes anywhere in this election year is certainly an open question; but things move incrementally in Washington (some might say glacially), and even if we are back in the same place next year, this year’s progress matters and positions us well for the next Congress. Several ACCG members have helped with this by contacting their Representatives; if you can help in this regard, please email us at accg@accguild.org to discuss further.

For more information about this legislation, please see https://www.congress.gov/bill/119th-congress/house-bill/595/cosponsors and https://accguild.org/news/13463512. And on a related note, discussions are under way on a key international trade agreement that may well offer an opportunity to advance this work; we are already working with several Congressional offices to include the necessary language in the agreement.

While it may seem that our never-ending fights against the Memorandums of Understanding that continue to plague our hobby are almost Sisyphusian in nature, we secured an extremely important victory when we successfully prevented late Roman Republican and Roman Imperial coins from being added to the designated list for the latest Italy MOU. This outcome was achieved as a result of ACCG Board members Randy Myers and Peter Tompa meeting with Italy’s Cultural Attache. Ensuring that collectors continue to have access to these coins from one of the most important European sources is a big win.

ACCG played a big role in funding the purchase of a Roman coin hoard by the Oxfordshire Museum, accomplished under the United Kingdom’s Treasure Act (see https://accguild.org/news/13439566). Not only is this good for relations with our English colleagues, it helps with our ongoing efforts to highlight the success of the Treasure Act and the related Portable Antiquities Scheme as far more successful approaches to combatting looting of historical sites and illicit sales of ancient coins and antiquities. As we fight the MOUs and similar, pointless restrictions, having a viable alternative to propose greatly strengthens our case.

Related to this, ACCG executive director Keith Twitchell had a Guest Editorial on this subject published in the November 2025 issue of The Numismatist. ANA members can access it here.

Also helping us in the fight against unfair, overbroad restrictions on importing historic and cultural items are the partnerships we are developing with a wide variety of like-minded organizations. Among those we have collaborated with recently on these issues are American Numismatic Association, B’nai B’rith, CINOA, Committee for Cultural Policy, Global Heritage Alliance, the International Association of Professional Numismatists and JIMENA (Jews Indigenous to the Middle East and North Africa). The more allies we enlist, the stronger our collective voice will be as these battles continue. If you are part of an organization that might be willing to join in, please email us at accg@accguild.org to discuss further.

Last but hardly least, after being stagnant for a while, our membership is growing again, to the point where we have actually had to upgrade our plan with our website host in order to accommodate the increased number of members. Look for word soon on a membership contest ACCG will be running this spring and summer. Again, there is strength in numbers, and we want to keep this momentum going.

We appreciate your engagement with ACCG tremendously. For more than twenty years, ACCG has been a collector-run, collector focused nonprofit advocating for ancient coin collectors against government overreach. The time you spend making those CPAC comments, your financial support with your dues, the comments we receive from many of you – these all help demonstrate that ours is a vital, valuable organization that makes a difference, at every level from national politics to your individual experience with this hobby we all love. Thank you for being a part of the solution.

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.

            On September 15, 2025, the State Department’s Cultural Property Advisory Committee (CPAC) met to consider four potential agreements with foreign governments:

-          Renewal of an “emergency” import restrictions agreement with Taliban-led Afghanistan

-          Renewal of Cultural Property Agreement (CPA) or Memorandum of Understanding (MOU) with Colombia

-          Renewal of a CPA with Turkey

-          A new MOU with Cameroon

Looking briefly at each of these, the agreement with Afghanistan would include different types of items dating from 50,000 BCE to 1912 CE. Given that the country is currently ruled by a terrorist group with a thoroughly documented history of cultural and historical destruction – not to mention the suppression and even murder of its own citizens – it is extremely difficult to fathom why the United States would even begin to consider any agreement with this nation, let alone the renewal of one that does not even expire until the first quarter of next year.

      As for Colombia, the agreement proposed to renew existing restrictions on items that, again depending on type, date from approximately 1500 BCE through 1830 CE.  Currently, the U.S. government is in open dispute with the Colombian government over issues including immigration and illegal drugs, while that government draws ever closer to China.  Again, the current agreement does not expire until next year.

      Regarding Turkey, the renewal would pertain to material dating as far back as 1.2 million years ago and as recently as 1923.  Turkey is currently run by an iron-fisted dictator who actively suppresses minority ethnic groups and individuals, rigs elections, actively supports Russia, and meddles constantly in countries like Syria and Libya to the detriment of U.S. interests. Yet again, the current agreement does not expire until well into 2026.

      The proposed new MOU with Cameroon would cover items from 100,000 BCE into the 19^th century CE.  Meanwhile, the current government of this nation is actively suppressing its English-speaking citizens.

      To say that none of these agreements would seem in any way to beneficial to the United States, and especially to its law-abiding citizens who happen to be collectors, dealers and students of ancient coins, is putting it mildly.  Further, the current members of CPAC all date from the previous administration.  With none of the agreements proposed for renewal expiring until next year, there seemed to be no justification for rushing this hearing forward; yet despite the best efforts of the Ancient Coin Collectors Guild (ACCG), the International Association of Professional Numismatists (IAPN), and many other respected organizations (including, in the case particularly of Turkey, groups representing displaced and persecuted ethnic minorities), the hearing was conducted – virtually – as announced.

      Multiple speakers testified in opposition to some or all of the agreements.  Leading off was Peter Tompa, Executive Director of IAPN and a board member of ACCG. Backing up written comments he had submitted previously, Mr. Tompa referenced the Taliban’s previous and ongoing destruction of historic and cultural items and sites.  Not only does this undermine the intent of these agreements, the extent and duration of these actions contradict the notion of any need for an “emergency” agreement.  Regarding Turkey, he noted the government’s encouragement of looting at Christian and Jewish sites as well as conversion of important historical structures, such as the Hagia Sophia, into mosques.  In particular, the inclusion on the lists of restricted items should never include coins that circulated widely both in ancient and more recent times.

      Kate FitzGibbon, Executive Director of the Committee on Cultural Policy (CCP), spoke specifically against the agreement with Afghanistan, raising four main points.  First, the renewal is contrary to the statutory intent of the Cultural Property Implementation Act (CPIA), which for an “emergency” only authorizes narrow, time-limited, exceptional measures in an immediate crisis.  Second, renewal would require, under the CPIA, the return of items to the Taliban terrorists.  Third, the Taliban itself is the major threat to the cultural and historical heritage of Afghanistan, not the U.S. art and coin market.  Finally, the definition of “emergency” has been stretched beyond plausibility.  The proposed renewal hurts only legitimate trade, while threatening the seizure and repatriation of personal items belonging to the Afghani diaspora.

      ACCG board member Randy Myers spoke on behalf of that organization as well as the American Numismatic Association (ANA).  He began by questioning the legality of the limited time allowed for public comment allowed on these proposed agreements.  He noted that current import restrictions on coins ignore the statutory provisions that limit the restrictions to objects of “cultural significance” that were “first discovered within” and “subject to export control” of a given country. He emphasized that unlike most other ancient artifacts, coins are mass produced, with dies used to strike approximately 13,000 coins each. This large production of coins combined with their wide dispersion means that one cannot assume that particular coin types are found in a given country. For example, coins on the current designated list for Turkey are found as far west as Spain and as far east as India. Finally, he noted that the State Department has produced no information to suggest that the MOU with Turkey has been effective.

      Elias Gerasoulis spoke as Executive Director of the Global Heritage Alliance (GHA), and also as a board member of the American Hellenic Institute, to oppose the Turkish renewal. A renewal will only further encourage Turkey to continue erasing the cultural heritage of its displaced Christian and Jewish populations.  The government has engaged in multiple instances of religious persecution, destruction and looting, both in Turkey and in occupied Cyprus.

      Lucy Varpetian appeared on behalf of the Armenian Bar Association.  The Association had submitted written comments, so Ms. Varpetian read a letter to CPAC from Congressman Gus Bilirakis (R-Florida. Co-Chair of the Congressional international Religious Freedom caucus) opposing a renewal of the MOU with Turkey.  Noting that Turkey had failed to protect the rights of its religious minorities, Rep. Bilirakis’ letter concluded that “[t]he government that destroys its minorities’ historical property should not have the right to repatriate them at their pleasure.”

      After her presentation, one CPAC member noted that he was Jewish and indicated to Ms. Varpetian that she could be assured that the concerns of religious minorities would be considered.

      Rabbi Eric Fusfield, Deputy Director, International Center for Human Rights and Public Policy, Director of Legislative Affairs, B'nai B'rith International, argued that there should be a carve-out from current import restriction for Turkey for ritual and ceremonial objects. These really belong to Jewish and Christian communities, not the Turkish state.  Many members of these communities were forced to flee that nation and were not able to bring family items that are now on the restricted lists with them.

      Dr. Elizabeth Prodromou, a visiting professor in the international studies program at Boston College, served a diplomatic appointment on the U.S. Commission on International Religious Freedom (2004-2012), and was a member of the U.S. Secretary of State’s Religion & Foreign Policy Working Group (2011-2015). She urged rejection of the Turkey MOU renewal as being in violation of Article 9 of the UNESCO Convention because it can be seen as “green lighting” Turkey’s erasure of minority cultures.

      Dr. Simon Maghakyan, a postdoctoral fellow at the University of Oxford, indicated his support of the comments of the Armenian Bar Association. He added that another reason the MOU should be rejected is due to Turkey’s support for Azerbaijan in its war to erase an Armenian presence and Armenian cultural heritage in Nagorno-Karabakh.  He has studied state-sanctioned treasure hunting of former Armenian areas in Turkey and written an article on that subject for Newsweek.

      A small number of speakers testified in favor of renewing specific agreements. The first of these was Dr. John Hoopes (University of Kansas), who spoke in support of a renewal of the MOU with Colombia. He has excavated in the country for the past 30 years. Pottery and gold artifacts are sought by looters, making the renewal of the current MOU essential in helping to protect Colombia’s cultural heritage. There are numerous sites yet to be excavated, many of which are just being discovered with the help of modern remote imaging techniques.  He made no mention of coins.

      Dr. Peri Johnson, an archaeologist teaching at the University of Illinois Chicago, supported renewal of the CPA with Turkey because she believes that looting is still a major problem there. She has seen instances where heavy machinery was brought in to help loot sites. Around 50% of the archaeological digs in Turkey are meant to rescue items before they can be taken by looters.  Again, coins were not mentioned.

      Dr. Brian Rose, Professor of Archaeology at the University of Pennsylvania and Curator-in-Charge of the Mediterranean Section of the Penn Museum, supported renewal of the MOU with Turkey.  He stated that it is essential to help combat continued looting in the country, which he believes has taken adequate measures to protect its cultural heritage.  He also made no mention of coins.

The same CPAC member who had spoken previously asked Dr. Rose about Turkey’s aggressive efforts to erase minority cultures. Dr. Rose could only state that he had not personally seen any such activities. He also indicated that he is aware of Turkey’s efforts to turn Hagia Sophia into a mosque.

That the hearing should never have taken place to begin with is obvious, given that the agreements up for renewal do not expire until next year, and that a new administration has the right to place members on bodies such as CPAC before important policy decisions are made.  That these specific agreements should be rejected was even more obvious, given the state actors involved, their treatment of their culture, history and citizens, and their fraught relationships with the U.S. government.  Whether any of these will actually go forward remains undetermined.

Trump State Department Takes From Americans, Gives to Terrorists and Tyrants

            The U.S. Department of State continues to put the interests of foreign despots, terrorist groups and hostile nations over the interests of the American people.

            The latest example of this is the recently-announced consideration of renewing an “emergency import restrictions” agreement with Taliban-led Afghanistan.  This will be on the agenda of the September 15, 2025 meeting of the Cultural Property Advisory Committee (CPAC).  Public notice of this meeting was issued on August 7, when Congress is out of session and most of Washington, DC is enjoying summer vacation, meaning the attempt to collaborate with the Taliban is likely to fly well under the public radar.

            If renewed, this agreement would continue the State Department’s Biden-era practices of prioritizing the interests of questionable state actors over those of American museums, historians, students and collectors.  While many in the research and collecting community had hopes that the new administration would put a halt to these practices, in reality the pace of advancing these disadvantageous agreements has actually accelerated.  To cite a few recent examples:

- The administration has moved to implement a Biden-era Memorandum of Understanding (MOU) with India that imposes severe import restrictions on a wide variety of art, artifacts, coins and similar items.  Yet India has publicly proclaimed that they will continue to purchase oil from Russia, and also has a long history of destroying these very items within its own borders.

- Similarly, implementation is moving forward on another “emergency” agreement with Hezbollah-dominated Lebanon.  Repatriating objects already in the possession of U.S. museums, universities and private collectors hardly ensures their safety, and there have even been reports that such items are being sold by Hezbollah to fund their terrorist activities.

- Already in 2025, the Biden-era holdovers that dominate CPAC have advanced new or renewed agreements with five nations, including Communist Vietnam.  Several of the renewed agreements did not even expire until next year, but CPAC seems intent on ramming these through before President Trump can make his own appointees to the panel.

- Also on the September 15 agenda is new agreement with Cameroon, whose authoritarian government is widely accused of mistreating citizens of its English-speaking minority.

 - That agenda also includes MOU renewals with the repressive government of Turkey and with Columbia, with whose government the Trump administration and State Department are openly feuding.  Yet neither of these agreements expires until 2026.

It is exceedingly difficult to understand why the Trump State Department is so interested in making deals with the Taliban and Hezbollah, supporting authoritarian regimes around the world, and rewarding governments that support adversaries such as Russia – all at the expense of United States citizens and institutions.  The administration needs to be held accountable for allowing this unchecked power of Biden-era appointees and their agendas – and to make its own CPAC appointments so that more rational approaches to legitimate cultural and historical protection can advance without inhibiting the rights of American researchers, students and collectors.

Comments about these and other items on the September 15 CPAC meeting may be submitted via this link: https://www.regulations.gov/document/DOS-2025-0203-0001.  Comments may be submitted through September 8.

The ACCG has updated its guidance on import restrictions to include new restrictions on "Indian" coins that circulated regionally and internationally.  To review this guidance, current as of July 28, 2025 see 072825 Import Restrictions on Ancient Coins and Declarations for Legal Import .pdf

The new "Indian" import restrictions cover all coins found or made in India to 1770 AD.  

The new "designated list" is as follows:

(5) Coins—Ancient coins include gold, silver, copper, lead, and copper alloy coins in a variety of sizes and denominations. Includes gold and silver ingots and commemorative coins. Coins may be circular, oval, square, or polygonal in shape, may be punch-marked, hammered, cast, molded, and/or gilded. Coins may include designs on one or both sides, including edges. Designs may include portraits, crests, deities, and animal, floral, architectural, geometric, and/or vegetal motifs, and/or may be inscribed in various languages and scripts. Includes depictions of symbols and figures from Buddhist, Jain, Hindu, Christian, Sikh, and Zoroastrian religious traditions, among others. Includes Roman, Persian, Greek or Hellenistic, Gandharan, Central Asian, and other coins found in India. Includes coins that were reused or converted into decorative objects or objects of personal adornment. Approximate Date: 600 B.C.E.-1770 C.E.

a. Early Historic Period includes punch-marked coins, discs, tokens, among others in gold and silver. May include depictions of animals, geometric, floral, and/or vegetal motifs.

b. Historic Period includes, but is not limited to, Mauryan punch marked coins ( karshapana) with various symbols such as suns, crescents, six-arm designs, hills, peacocks, human figures, animals, and others, and inscriptions in Brahmi script; Roman silver and bronze coins; Hellenistic and Gandharan drachms, tetradrachms, and gold staters featuring iconography of Hellenistic deities and human portraiture and inscriptions in Greek and Kharoshti; Kushan dinars, tetradrachms, and copper alloy denominations with iconography from Persian, Zoroastrian, Buddhist, and Hindu traditions; Western Satraps coins with bull-and-hill or elephant-and-hill images; Indo-Scythian coins; Satavahana coins with Prakrit inscriptions and animal, floral, geometric, star, Buddhist shrines or stupas, human, wheel, and/or maritime motifs; Ashokan stambha coins featuring a central pillar; Gupta dinaras and drachms and others with images of animals, human figures, mythological birds, archery, javelins, battle-axes, wheels and scepters, deities, and portraiture along with floral, geometric, and/or vegetal motifs, including inscriptions in Brahmi script.

c. Medieval Period includes, but is not limited to: Gurjara-Pratihara, Pallava, and other dynastic coins or tokens with portraiture and geometric, animal, and religious motifs; Chola coins with crests of animals and weapons, mythological icons, and inscriptions in the Nagari script; Vijayanagara pagoda coins featuring Hindu deities and related symbols; Delhi Sultanate tankas and jitals with animal, religious, floral, geometric, and/or vegetal motifs and calligraphic inscriptions in various languages and scripts such as Arabic.

d. Mughal Empire or Early Modern Period includes, but is not limited to, rupiya, dam, and mohur coins primarily featuring calligraphy and literary or religious verses, but also figures and portraits of rulers, zodiac signs, birds, animals, and other icons.

For a critique of the new restrictions see the "Cultural Property Observer" blog here:  https://culturalpropertyobserver.blogspot.com/2025/07/not-maga-trump-administration.html

May 22, 2025.  The ACCG has updated its guidance for collectors about importation of coin types that have appeared on increasing numbers of overlapping designated lists for import restrictions. You can find that updated guidance which includes new import restrictions on "Lebanese" coins here:  052225 Import Restrictions on Ancient Coins and Declarations for Legal Import .pdf

For a critique of the new restrictions, see the Cultural Property Observer blog here:  https://culturalpropertyobserver.blogspot.com/2025/05/not-maga-new-emergency-import.html