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ANCIENT COIN COLLECTORS GUILD

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  • March 06, 2023 1:22 PM | Peter Tompa (Administrator)

    In response to allegations in a criminal complaint filed in New York City alleging that certain valuable coins were sold with false provenances, the ACCG has updated its ethics rules to make clear that it condemns the use of unsubstantiated provenances to sell historical coins.  The ACCG’s ethics rules already urge that “sellers will not knowingly purchase coins stolen from private or public collections or reasonably suspected to be the direct products of illicit excavations in contravention of national patrimony laws. Coin collectors and sellers will also comply with all applicable customs laws.”  For more, see https://accguild.org/CodeOfEthics

  • February 24, 2023 5:28 PM | Peter Tompa (Administrator)

    ACCG Board Member Andy Pierucci has written an opinion piece explaining how collecting Roman Imperial coins is now in danger.  It was published on-line by the Deseret News, Utah's oldest newspaper.  You can read it here:  

    https://www.deseret.com/opinion/2023/2/18/23604528/ancient-coin-collecting-us-import-restrictions

  • February 03, 2023 9:23 AM | Peter Tompa (Administrator)

    By Keith Twitchell

    February 3, 2023

                After watching the most recent meeting of the Cultural Property Advisory Committee, it’s easy to draw the conclusion that coins – and coin collectors – are collateral damage in the battle over importation of culture and historical artifacts in general.

                The Committee met in open session on January 30, 2023 to consider Memorandums of Understanding relating to proposed import restrictions on cultural goods with three countries:  Cambodia, North Macedonia and Uzbekistan.  The latter two would be new agreements, while the Cambodia proposal would extend and expand a current MOU.  The meeting’s purpose was to receive public input on these documents.

                As proposed, all three are extraordinary in their scope, in time frame and types of items covered.  Since this is not the forum for going into great detail, here is a very brief overview of the proposed agreements.

    • -          Cambodia:  depending on the type of artefact, the MOU would reach as far back as circa 2500 BC, and for some items, through 1891.  Requested for inclusion in the new agreement are items made of stone, ceramic, glass, bone, wood, and metal, including coins.  Architectural elements, manuscripts, and religious and funerary objects would be covered.
    • -          North Macedonia:  the proposed period for the agreement is 300,000 BC to the 1950s.   Coverage is requested for archaeological items made from ceramics, stone, bone, ivory, glass, faience, and metal, including coins.  Some specific items are listed, including musical instruments, pipes, mosaics, textiles, and artworks.
    • -          Uzbekistan:  maximum time frame is 50,000 BC to 1917.  Materials include those in the two other proposals, along with plaster, stucco, unfired clay, birch bark, vellum, and shell, among others.  Also included in this MOU would be human remains.

                While there are important, legitimate issues relating to looting of archeological sites and illegal exporting of artefacts from each of these countries, the proposed MOUs are so vast in scope that they may well cause as many problems as they solve.  That did not deter a number of individuals from testifying in their favor during the meeting.  Speaking in opposition were Randy Myers on behalf of the Ancient Coin Collectors Guild and Peter Tompa, officially representing the International Association of Professional Numismatists. The American Numismatic Association joined the ACCG’s written comments but was not present at the open session. 

                The majority of oral comments addressed only the MOU with Cambodia.  Along with people speaking from an institutional vantage point, several individuals, primarily displaced Cambodian citizens, addressed the Committee.  They spoke movingly of the damage to great, ancient structures, and to the subsequent damage to history and religion within Cambodia, that is caused by looting.

                The institutional representatives addressing the Cambodia MOU tended to speak very generally, while in the process pointing out other as-yet untaken measures that would help solve the problems, and even acknowledging that the current MOU has been limited in its effectiveness.  For example, Stephen Acabado, of the Society for American Archeology, pointed out that the lack of surveys and inventory listings of sites and items in Cambodia contributes substantially to the problem.

                Tess Davis, the Executive Director of the Antiquities Coalition, freely acknowledged that looting and illegal exporting has continued despite the current MOU.  Davis also stretched so far as to suggest that the MOU should be extended in order to protect potential buyers of these items in the United States.

                The only person to speak in favor of the Uzbekistan proposal was Soeren Stark, a professor at New York University.  Yet he also acknowledged that looting of Uzbek archeological sites has “happened with the knowledge and silent consent of local authorities,” and that “Uzbekistan has the legal framework to protect this local heritage.”  In the process, he pointed out the need for local community education efforts to address these issues.

                To summarize, several speakers identified actions that could be taken within these countries to address these problems.  No one argued that the MOUs themselves would solve the problems, and there was even acknowledgment that the existing MOU with Cambodia has not deterred illegal looting and exporting.

                Left completely unaddressed was the fact that these would be bilateral agreements, meaning that only importation of artefacts into the United States would be restricted.  Illegal trade could continue in pretty much the entire rest of the world, meaning that even if the restrictions could be reasonably enforced (a major, separate issue), there would still be a vast market for these items.  Meanwhile, legitimate collectors, dealers and institutions in the U.S. would be unfairly faced with onerous, confusing and inconsistent processes.

                In countering these arguments, Myers cited the regional nature of coins and of the history of countries whose borders today do not match anything from any previous period of history.  For example, North Macedonia is a new nation altogether, and there are legitimate questions as to whether coins were ever minted within its borders.

                Tompa pointed out that the Convention on Cultural Property Implementation Act (CPIA), under whose aegis the MOUs are being proposed, requires correlation between where an item was made and where it was found.  Very few coins are ever found where they were minted, since the definition of coinage is to be circulated via commerce.  This is especially true of ancient coins; Tompa noted that Roman coinage served as world currency, and Roman coins have been found from England to Sri Lanka.

                While Committee members had few questions for other speakers, CPAC member Anthony Wisniewski directed a number at Tompa, affording him the opportunity to elaborate on several key points, and to further distinguish coins from the other items covered in the proposed MOUs.  Specifically, he noted that coins are not “ethnographic objects”, whose protection is the purpose of CPIA.  Tompa has written and spoken extensively on these issues, and those interested in the subject should read his considerably more detailed observations.

                After observing the Committee meeting, it seems clear that if collecting ancient and world coins is to be protected from unnecessary restriction and overreach, coins simply must be distinguished from art, artefacts and antiquities.  Coins are a category unto themselves.  Their purpose was commerce; as such, they were intended to circulate over wide areas.  They are not parts of physical structures, nor are they associated with religious and/or cultural heritage.

                The ongoing trend is towards more, and broader, MOUs of this nature.  That tide seems unlikely to turn soon, and if coins are not to be swept up in it, they absolutely must be separated out of the discussion to the highest possible degree.

                Keith Twitchell is a writer, nonprofit consultant and coin collector living in New Orleans.  He enjoys music, tennis, travel, people, and the ancient world, and writing about all of them.  He has been an ACCG member since 2017.  

    ACCG Article 020023 re CPAC meeting.pdf


  • January 10, 2023 9:39 AM | Randolph Myers (Administrator)

    On January 10, 2023, the Ancient Coin Collectors Guild joined by the American Numismatic Association, filed comments with the Cultural Property Advisory Committee, to object to proposed MOUs with the Governments of North Macedonia and Uzbekistan, as it applied to the  import restriction of ancient coins.  While the public notice was published in the Federal Register on December 21, 2022, the CPAC’s website failed to state that they were considering import restrictions on coins until January 2, 2023. 

    Our comments raised a number of procedural and substantive objections.  Our procedural objections complained that the public notice was untimely, vague and inadequate, which effectively denied the public the ability to submit meaningful comments.  Our substantive objections focused on the Cultural Property Implementation Act, where we argued that ancient coins did not qualify as artifacts of “cultural significance,” that ancient coinage cannot be assumed to have been “first discovered within” and “subject to the export control” of the two counties, that other available “less drastic remedies” existed, that neither country submitted a statement of facts for the CPAC’s “determination,” and that coins minted after 1773 cannot be restricted since the Act requires objects be “at least two hundred and fifty years old.”  

    Our full comments can be found here:

    ACCG and ANA comments objecting to North Macedonia coin restrictions RMyers 1.10.2023.pdf

    ACCG and ANA comments objecting to Uzbekistan coin restrictions RMyers 1.10.2023.pdf

    Written comments on the proposed MOUs with North Macedonia and Uzbekistan must be received by January 23, 2023 at http//www.regulations.gov, enter docket DOS-2022-0048, then follow the prompts.

  • December 16, 2022 9:36 AM | Peter Tompa (Administrator)

    On December 15, 2022, the Smithsonian Institution partially granted our Freedom of Information Act administrative appeal and provided us with a list of organizations that participated in a March 2021 online Workshop to train US law enforcement "to combat trafficking in ancient coins."   Back on May 4, 2021, the ACCG filed a FOIA administrative appeal, after the Smithsonian withheld all 37 pages of responsive materials.  In our FOIA request we sought to shine light on the identity of participating organizations, what was being taught, and whether there was any suggestion that just because a coin was unprovenanced it should be treated as “stolen,” an inaccurate assumption that is being made by proponents of import restrictions on coins.  While the Smithsonian’s FOIA appeal decision declined to provide us with the training material as law enforcement sensitive, it did provide us with the list of participating organizations to the Workshop.  The invited organizations included the American Numismatic Society, Baylor University and Shenyang Financial Museum from the People’s Republic of China, but did not include the American Numismatic Association, the International Association of Professional Numismatists, the Professional Numismatists Guild, the Ancient Coin Collectors Guild or other collector groups.  This unfortunately ensured that Customs officials received information only from those entities and individuals who have advocated for broad import restrictions on coins in the past. 

    Responsive document.pdf


  • November 17, 2022 9:16 AM | Randolph Myers (Administrator)

    On November 15, 2022, the ACCG filed another Freedom of Information Act administrative appeal, this time for Customs and Border Protection’s refusal to produce any documents regarding three coin seizure incidents.  Based on CBP’s earlier production to us of seized asset spreadsheets, our FOIA request centered on 24 coin seizure incidents, which was later reduced to nine incidents to avoid duplication.  After CBP referred our FOIA request for six of the incidents to the Immigration and Customs Enforcement for their response to us, the CBP then declined to produce any documents regarding their own three coin seizure incidents by asserting various FOIA Exemptions. 

    Our FOIA administrative appeal argues that the CBP's denial violates their own regulations and that the FOIA Exemption withholdings was erroneous.  We also argue that the CBP failed to abide by FOIA’s requirement to provide “reasonably segregable” documents, since they could have produced the documents with limited redactions.  We are concerned that the CBP’s FOIA blanket denial basically allows the CBP to seize property secretly, without an administrative or judicial forfeiture, while denying the public’s ability to know of the agency’s actions.  It would defeat the very purpose of FOIA, which the Supreme Court states is intended to give citizens the means to know “what their Government is up to," which is “a structural necessity in a real democracy."  Besides our FOIA administrative appeal, the ACCG has also filed a request to the Office of Government Information Services, which offers dispute resolution services between FOIA requesters and Federal agencies.


  • November 07, 2022 10:49 AM | Randolph Myers (Administrator)

    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.

  • October 19, 2022 2:49 PM | Randolph Myers (Administrator)

    On October 17, 2022, we submitted a Freedom of Information Act request to Customs and Border Protection, for the glossary to explain their SEACATS spreadsheet column headings and designations.  SEACATS stands for “Seized Asset and Case Tracking System” and details seizures of property by Federal agencies like the CBP.  This FOIA request occurred after we earlier won a FOIA administrative appeal decision on September 30, 2022, when CBP provided us with a 13-page partially redacted SEACATS spreadsheet on their seizure of various items.  But while the SEACATS spreadsheet listed 53 incidents where CBP seized coins between 2009 and 2021, their spreadsheet contained cryptic column headings and cryptic two and three letter designations that are unintelligible to the layman.  In the meantime, however, we reached out to the Institute for Justice, at ij.org, a nonprofit public interest law firm that focuses on exposing government abuses and securing constitutional rights.  The Institute, who earlier engaged in a multiyear legal battle with CBP for the SEACATS data codes, provided us with one of their reports which explained many of the SEACATS data codes.  Now that we have most of the data codes and a better understanding of SEACATS list of CBP’s seizures, we plan to further examine the circumstances and outcomes of past CBP coin seizures.

  • October 02, 2022 4:55 PM | Randolph Myers (Administrator)

    On September 30, 2022, the ACCG won its Freedom of Information Act administrative appeal, were we sought documents from Customs and Border Protection, on the creation and enforcement of the Designated Lists of import restricted ancient coins of ten nations.  Back on February 5, 2022 Customs and Border Protection had responded to our FOIA requests that they had "no documents."  We then filed a FOIA administrative appeal that contended that their response was factually inaccurate and that they failed to conduct a thorough and reasonable search.   In upholding our FOIA administrative appeal on September 30, 2022, the Department of Homeland Security’s FOIA Appeals, Policy & Litigation Branch informed us that responsive documents did exist.  As for our request for documents on the creation of Designated Lists, they provided us with 66 pages of partially redacted records, while explaining that their agency only engaged in a “ministerial” function of publication in the Federal Register, and that it was “the State Department, through the Cultural Property Committee, [that] creates the Designated Lists.”   As for our request for documents on the enforcement of Designated Lists, they provided us with 13 pages of partially redacted spreadsheets from their Seized Assets and Case Tracking System (SEACATS), that identified fifty incidents between 2009 to 2021 where they seized coins, most of which were “antique.”  


  • August 05, 2022 3:23 PM | Peter Tompa (Administrator)

    Find out more about who said what at a recent Cultural Property Advisory Committee meeting to discuss a proposed renewal of a MOU with Libya.  

    http://culturalpropertyobserver.blogspot.com/2022/07/summary-of-july-26-2022-cultural.html

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