Effective date: March 17, 2022

Source: 87 FR 15079-15084 (March 17, 2022), available at https://www.federalregister.gov/documents/2022/03/17/2022-05685/imposition-of- import-restrictions-on-categories-of-archaeological-and-ethnological-material-of

The Designated list of coins subject to import restrictions is as follows.

8. Coins—This category includes coins of Illyrian, Greek, Macedonian, Roman provincial, Byzantine, Medieval, and Ottoman types that circulated primarily in Albania, ranging in date from approximately the 6th century B.C. to A.D. 1750. Coins were made in copper, bronze, silver, and gold. Examples are generally round, have writing, and show imagery of animals, buildings, symbols, or royal or imperial figures.

Comment:  The designated list of coins is particularly broad and includes coins that circulated regionally as well as internationally. It goes far beyond coins that "primarily circulated" within Albania. Despite the assumption contained in the regulation, no Greek, Byzantine, and Ottoman types “primarily circulated” within Albania or were even made there. As for Illyrian coins, hoard evidence indicates that popular cow/calf coins from the Roman Republican period “circulated primarily” in Romania, not Albania. The only bright spot is that neither Roman Republican nor Roman Imperial coins seem to be restricted.

A case can be made that the “circulated primarily” standard is statutorily deficient because it is contrary to the CPIA requirement that restricted items must be first discovered within and subject to export control of a particular country. There also is a fair notice issue because how is a typical collector or dealer to know whether or not a particular issue “primarily circulated” in Albania or not?

Effective date: August 14, 2019

Source: 84 Fed. Reg. 41909-41913 (August 16, 2019).

The Designated List of coins subject to import restrictions is as follows:

Pre-Roman mints in Algeria include Cirta, Hippo Regius, Caesarea (Iol), Lix, Siga, and Timici. Roman provincial mints in Algeria include Caesarea, Cartenna, and Hippo Regius. Helpful reference books include: Corpus nummorum Numidiae Mauretaniaeque, 1955, J. Mazard, et al., Arts et metiers graphiques, Paris; Le Trésor de Guelma, 1963, R. Turcan, Arts et Métiers Graphiques, Paris; Etude sur la numismatique et l’histoire monétaire du Maroc: Corpus des dirhams idrissites et contemporains, 1971, D. Eustache, Banque du Maroc, Rabat; Corpus des Monnaies Alaouites, 1984, D. Eustache, Banque du Maroc, Rabat; The Roman Provincial Coinage, multiple volumes, 1992-, A. Burnett, et al., The British Museum Press, London. Some of the best-known types are described below:

1. Greek—In silver, bronze, and gold, struck in Algeria and in nearby mints (Cyrene, Carthage).

2. Roman Provincial—In bronze, struck at Roman and Roman provincial mints and found throughout Algeria.

3. Numidian and Mauretanian—Associated with Numidian kings such as Micipsa, Jugurtha, Hiempsal II, and Juba I, and Mauretanian kings such as Syphax, Juba II, Ptolemy II of Mauretania, Bocchus I, and Bocchus II.

4. Byzantine—In bronze, silver, and gold, struck in nearby mints like Carthage or mobile mints in Arab-Byzantine period Ifriqiya.

5. Islamic—In silver and gold struck at various mints including Algiers, Bijaya, Biskra, Qusantina, and Tlemcen. Examples include any coins of the following dynasties: Almohad, Hafsid, Marinid, and Ziyanid.

6. Ottoman—Ottoman coins of Algeria in silver, gold, billon, and copper, struck at various mints including Algiers, Qusantina, Tagdemt, and Tlemcen. Also Spanish coins of Oran in billon or copper, produced in Toledo or Madrid for use in Spanish Oran between 1618 and 1691.

Comment: This Designated List includes many coins that circulated in quantity outside of Algeria. These include Greek issues of Cyrene, Carthaginian coins, Numidian and Mauritanian coins, Byzantine, Islamic and Ottoman coins. The fact is Algeria was until the recent times part of larger Empires.

Effective Date: January 16, 2014

Source: 79 Fed. Reg. 2781-2785 (January 16, 2014).

The designated list, taken from the Federal Register, is as follows:

7. Coins – In copper, bronze, silver and gold. Many of the listed coins with inscriptions in Greek can be found in B. Head, Historia Numorum: A Manual of Greek Numismatics (London, 1911) and C.M. Kraay, Archaic and Classical Greek Coins (London, 1976). Many of the Roman provincial mints in modern Bulgaria are covered in I. Varbanov, Greek Imperial Coins I: Dacia, Moesia Superior, Moesia Inferior (Bourgas, 2005), id., Greek Imperial Coins II: Thrace (from Abderato Pautalia) (Bourgas, 2005), id., Greek Imperial Coins III: Thrace (from Perinthus to Trajanopolis), Chersonesos Thraciae, Insula Thraciae, Macedonia (Bourgas 2007). A non-exclusive list of pre-Roman and Roman mints include Mesembria (modern Nesembar), Dionysopolis (Balchik), Marcianopolis (Devnya), Nicopolis ad Istrum (near Veliko Tarnovo), Odessus (Varna), Anchialus (Pomorie), Apollonia Pontica (Sozopol), Cabyle (Kabile), Deultum (Debelt), Nicopolis ad Nestum (Garmen), Pautalia (Kyustendil), Philippopolis (Plovdiv), Serdica (Sofia), and Augusta Traiana (Stara Zagora). Later coins may be found in A. Radushev and G. Zhekov, Catalogue of Bulgarian Medieval Coins IX-XV c. (Sofia 1999) and J.Youroukova and V. Penchev, Bulgarian Medieval Coins and Seals (Sofia 1990).

a. Pre-monetary media of exchange including “arrow money,” bells, and bracelets. Approximate date: 13th century B.C. through 6th century B.C.

b. Thracian and Hellenistic coins struck in gold, silver, and bronze by city-states and kingdoms that operated in the territory of the modern Bulgarian state. This designation includes official coinages of Greek-using city-states and kingdoms, Sycthian and Celtic coinage, and local imitations of official issues. Also included are Greek coins from nearby regions that are found in Bulgaria. Approximate date: 6th century BC through the 1st century B.C.

c. Roman provincial coins – Locally produced coins usually struck in bronze or copper at mints in the territory of the modern state of Bulgaria. May also be silver, silver plate, or gold. Approximate date: 1st century BC through the 4th century A.D.

d. Coinage of the First and Second Bulgarian Empires and Byzantine Empire – Struck in gold, silver, and bronze by Bulgarian and Byzantine emperors at mints within the modern state of Bulgaria. Approximate date: 4th century A.D. through A.D. 1396.

e. Ottoman coins – Struck at mints within the modern state of Bulgaria. Approximate date: A.D. 1396 through A.D. 1750.

Comment: Another exceptionally overbroad list including many coins that circulated in quantity outside of Bulgaria, most notably Hellenistic issues in silver and bronze. These restrictions are particularly ridiculous because there is a large internal market for such coins within Bulgaria itself.

Effective Date: January 14, 2019

Source: 74 Fed. Reg. 2838-2844 (January 16, 2009).

The Designated list is as follows:

1. Coins.

a. Zhou Media of Exchange and Tool-shaped Coins: Early media of exchange include bronze spades, bronze knives, and cowrie shells. During the 6th century BC, flat, simplified, and standardized cast bronze versions of spades appear and these constitute China’s first coins. Other coin shapes appear in bronze including knives and cowrie shells. These early coins may bear inscriptions.

b. Later, tool-shaped coins began to be replaced by disc-shaped ones which are also cast in bronze and marked with inscriptions. These coins have a central round or square hole.

c. Qin: In the reign of Qin Shi Huangdi (221–210 BC) the square-holed round coins become the norm. The new Qin coin is inscribed simply with its weight, expressed in two Chinese characters ban liang. These are written in small seal script and are placed symmetrically to the right and left of the central hole.

d. Han through Sui: Inscriptions become longer, and may indicate that inscribed object is a coin, its value in relation to other coins, or its size. Later, the period of issue, name of the mint, and numerals representing dates may also appear on obverse or reverse. A new script, clerical (lishu), comes into use in the Jin.

e. Tang: The clerical script becomes the norm until 959, when coins with regular script (kaishu) also begin to be issued.

Comment: Another exceptionally overbroad list including many coins that circulated in quantity outside of China, most cash coins that helped monetize Japan and South East Asia. These restrictions are particularly ridiculous because there is an immense internal market for such coins within China itself.

Effective Date: September 19, 2023

Source: 88 Fed. Reg. 64372-64379 (September 19, 2023), available at https://www.federalregister.gov/documents/2023/09/19/2023-20335/extension-and-amendment-of-import-restrictions-imposed-on-archaeological-and-ethnological-material

The Designated List is as follows:

5. Coins

Rare coinage from the Funan area of Southern Cambodia is included. Coinage dates from the 1st through 6th centuries A.D. In gold, silver, gilded silver, or tin. Designs vary, but coins often bear the image of a rising sun, a deer, a rooster, a Garuda, a team of oxen, and other designs. Inscriptions may be present and in Kharosthi script or Sanskrit.

Comment: The designated list is far narrower than other designated lists and hence is more in keeping with the intent of the governing statue. Later coins that had wider circulation patterns have been left off the designated list for Cambodia.

Effective Date: July 16, 2007

Amended: July 18, 2022 (effective July 14, 2022)

Source: 72 Fed. Reg. 38,470-73 (July 16, 2007); 87 Fed. Reg. 42,636-42 (July 18, 2022)

The Designated List is as follows:

D. Coins of Cypriot Types

Coins of Cypriot types made of gold, silver, and bronze including but not

limited to:

1. Issues of the ancient kingdoms of Amathus, Kition, Kourion, Idalion, Lapethos, Marion, Paphos, Soli, and Salamis dating from the end of the 6th century B.C. to 332 B.C.

2. Issues of the Hellenistic period, such as those of Paphos, Salamis, and Kition from 332 B.C. to c. 30 B.C.

3. Provincial and local issues of the Roman period from c. 30 B.C. to 235 A.D. Often these have a bust or head on one side and the image of a temple (the Temple of Aphrodite at Palaipaphos) or statue (statue of Zeus Salaminios) on the other.

4. Byzantine, Medieval Frankish, Lusignan, Venetian and Ottoman types that circulated primarily in Cyprus, ranging in date from AD 235-1770.  Coins were made in copper, bronze, silver, and gold.  Examples are generally round, have writing, and show imagery of animals, buildings, symbols, or royal or imperial figures.

Comment: The first import restrictions on coins, imposed against the recommendations of the Cultural Property Advisory Committee. CPAC’s chairman at the time, the late Jay Kislak, confirmed in an affidavit that the decision was made against his Committee’s recommendations, and that the State Department misled the public and Congress about it in official government documents. The Designated List includes early issues found in the famous Asyut Hoard from Egypt, Hellenistic coins that circulated throughout the Ptolemaic Empire, and Roman Provincial coins that circulated in quantity in nearby Turkey.  The list was amended effective July 14, 2022, to include Byzantine and later types that "circulated primarily" in Cyprus.

Effective date: December 5, 2016. Amended and expanded effective December 1, 2021

Source: 81 Fed. Reg. 87805- 87809 (December 6, 2016); and 86 Fed. Reg. 68546-68553 (December 3, 2021)..

The Designated List is as follows:

Coins In copper or bronze, silver, and gold.

1. General—There are a number of references that list Egyptian coin types. Below are some examples. Most Hellenistic and Ptolemaic coin types are listed in R.S. Poole, A Catalogue of Greek Coins in the British Museum: Alexandria and the Nomes (London, 1893); J.N. Svoronos, Τα Nομισματα του Κρατουσ των Πτολe μαιων (Münzen der Ptolemäer)(Athens 1904); and R.A. Hazzard, Ptolemaic Coins: An Introduction for Collectors (Toronto, 1985). Examples of catalogues listing the Roman coinage in Egypt are J.G. Milne, Catalogue of Alexandrian Coins (Oxford, 1933); J.W. Curtis, The Tetradrachms of Roman Egypt(Chicago, 1969); A. Burnett, M. Amandry, and P.P Ripollès, Roman Provincial Coinage I: From the Death of Caesar to the Death of Vitellius (44 BC-AD 69) (London, 1998—revised edition); and A. Burnett, M. Amandry, and I. Carradice, Roman Provincial Coinage II: From Vespasian to Domitian (AD 69-96) (London, 1999). There are also so-called nwb-nfr coins, which may date to Dynasty 30. See T. Faucher, W. Fischer-Bossert, and S. Dhennin, “Les Monnaies en or aux types hiéroglyphiques nwb nfr,” Bulletin de l'institut français d'archéologie orientale 112 (2012), pp. 147-169.

2. Dynasty 30 —Nwb nfr coins have the hieroglyphs nwb nfr on one side and a horse on the other.

3. Hellenistic and Ptolemaic coins—Struck in gold, silver, and bronze at Alexandria and any other mints that operated within the borders of the modern Egyptian state. Gold coins of and in honor of Alexander the Great, struck at Alexandria and Memphis, depict a helmeted bust of Athena on the obverse and a winged Victory on the reverse. Silver coins of Alexander the Great, struck at Alexandria and Memphis, depict a bust of Herakles wearing the lion skin on the obverse, or “heads” side, and a seated statue of Olympian Zeus on the reverse, or “tails” side. Gold coins of the Ptolemies from Egypt will have jugate portraits on both obverse and reverse, a portrait of the king on the obverse and a cornucopia on the reverse, or a jugate portrait of the king and queen on the obverse and cornucopiae on the reverse. Silver coins of the Ptolemies coins from Egypt tend to depict a portrait of Alexander wearing an elephant skin on the obverse and Athena on the reverse or a portrait Start Printed Page 87808of the reigning king with an eagle on the reverse. Some silver coins have jugate portraits of the king and queen on the obverse. Bronze coins of the Ptolemies commonly depict a head of Zeus (bearded) on the obverse and an eagle on the reverse. These iconographical descriptions are non-exclusive and describe only some of the more common examples. There are other types and variants. Approximate date: ca. 332 B.C. through ca. 31 B.C.

4. Roman coins—Struck in silver or bronze at Alexandria and any other mints that operated within the borders of the modern Egyptian state in the territory of the modern state of Egypt until the monetary reforms of Diocletian. The iconography of the coinage in the Roman period varied widely, although a portrait of the reigning emperor is almost always present on the obverse of the coin. Approximate date: ca. 31 B.C. through ca. A.D. 294.

Effective December 1, 2021, the Designated list was amended to add additional categories of Roman Imperial and later coins. Here are the additions.

iv. Roman—Coins of this type are struck in bronze, silver, or gold at Alexandria and any other mints that operated within the borders of the modern Egyptian state until approx. A.D. 498. The iconography of the coinage in the Roman period varied widely, although a portrait of the reigning emperor is almost always present on the obverse of the coin. Approximate dates: ca. 31 B.C. through ca. A.D. 498.

v. Byzantine and Arab Byzantine—Coins of these types are struck in bronze and gold at Alexandria, Fustat, and other mints that operated within the borders of the modern Egyptian state between A.D. 498 and ca. A.D. 696. Iconography may include one, two, or three persons (busts or standing figures); large letters in Latin script (sometimes with smaller Latin, Greek, or Arabic letters along the edge); and crosses, stars, moons, and other symbols.

vi. Islamic/Medieval and Ottoman— Coins of this type are struck in copper, bronze, silver, and gold at Cairo, Fustat, Alexandria, and other mints that operated within the borders of the modern Egyptian state under the Umayyad, ‘Abbasid, Tulunid, Ikhshidid, Fatimid, Ayyubid, Mamluk, and Ottoman (up to A.D. 1750) dynasties. Iconography is mostly writing in Arabic script, sometimes with stars, circles, flowers, or other ornaments placed at center or among the text, and rarely with human figures or trees

Comment: The current and amended designated list for Egypt ignores the statutory requirement that restricted objects must both be “first discovered within” and subject to Egyptian “export control.” Only coins that “exclusively” circulated within Egypt can meet both requirements, but larger denomination gold and silver Alexander the Great, Ptolemaic and Roman Egyptian, and now Roman Imperial and Byzantine coins from the Alexandria mint that circulated in quantity outside the modern borders of Egypt nonetheless ended up on the 2016 and 2021 designated lists. Proponents may have raised Egypt’s so-called “closed monetary system” under the Ptolemies and Roman Provincial authorities to justify these restrictions, but that system was meant to keep foreign coins "out" and not Egyptian coins “in.” Moreover, the borders of ancient Egypt stretched well beyond its modern borders, and larger denomination Greek and Roman Egyptian Provincial coins with Greek legends are found in quantity well outside of Egypt. The additional concern is that the amendment is the first time that restrictions were explicitly placed on Roman Imperial coins, here coins struck after Diocletian’s reform which were identical to other Roman Imperial coins except for a mint mark. Hopefully, this is not the beginning of a trend to place restrictions on such common coins form other more prolific later Roman Imperial mints.

Effective Dates: December 1, 2011 (ancient coins) and November 21, 2021 (Byzantine and Medieval)

Sources: 76 Fed. Reg. 74691-74695 (December 1, 2011); 86 Fed. Reg. 66164-66169 (November 22, 2021)

The Designated List is as follows:

7. Coins—Many of the mints of the listed coins can be found in B.V. Head, Historia Numorum: A Manual of Greek Numismatics (London, 1911) and C.M. Kraay, Archaic and Classical Greek Coins (London, 1976). Many of the Roman provincial mints in Greece are listed in A. Burnett et al., Roman Provincial Coinage I: From the Death of Caesar to the Death of Vitellius (44 BC–AD 69) (London, 1992) and id., Roman Provincial Coinage II: From Vespasian to Domitian (AD 69–96) (London, 1999).

a. Greek Bronze Coins—Struck by city-states, leagues, and kingdoms that operated in territory of the modern Greek state (including the ancient territories of the Peloponnese, Central Greece, Thessaly, Epirus, Crete and those parts of the territories of ancient Macedonia, Thrace and the Aegean islands that lay within the boundaries of the modern Greek state). Approximate date: 5th century B.C. to late 1st century B.C.

b. Greek Silver Coins—This category includes the small denomination coins of the city-states of Aegina, Athens, and Corinth, and the Kingdom of Macedonia under Philip II and Alexander the Great. Such coins weigh less than approximately 10 grams and are known as obols, diobols, triobols, hemidrachms, and drachms. Also included are all denominations of coins struck by the other city-states, leagues, and kingdoms that operated in the territory of the modern Greek state (including the ancient territories of the Peloponnese, Central Greece, Thessaly, Epirus, Crete, and those parts of the territories of ancient Macedonia, Thrace and the Aegean islands that lie within the boundaries of the modern Greek state). Approximate date: 6th century B.C. to late 1st century B.C.

c. Roman Coins Struck in Greece—In silver and bronze, struck at Roman and Roman provincial mints that operated in the territory of the modern Greek state (including the ancient territories of the Peloponnese, Central Greece, Thessaly, Epirus, Crete, and those parts of the territories of ancient Macedonia, Thrace and the Aegean islands that lie within the boundaries of the modern Greek state). Approximate date: late 2nd century B.C. to 3rd century A.D.

d. Coins from the Byzantine and Medieval Periods —This category includes coin types such as those of the Byzantine and medieval Frankish and Venetian states that circulated primarily in Greece, ranging in date from approximately the 3rd century A.D. to the 15th century A.D.

Comment: The Greek designated list is one of the few that tries to distinguish between widely circulating coins and other local issues that are more likely to be found within the confines of modern-day Greece. While we can debate whether larger denomination coins from most Greek city states should have been included, the list at least recognizes the fact that large denomination coins of Aegina, Athens, Corinth, and the Macedonian Kingdom circulated far outside the confines of modern-day Greece. In November 2021, the designated list was amended to include coins from the Byzantine and Medieval periods that “circulated primarily in Greece.” This formulation is inconsistent with the statutory requirements that only authorize import restrictions on archaeological objects which were “first discovered within, and …subject to export control by” Greece. Moreover, placing restrictions on coins that “circulated primarily in Greece” does not provide sufficient notice to the importer which coins are restricted, and which are not.

Effective Date: April 30, 2008 or August 9, 1990 (see comment below)

Source: 73 Fed. Reg. 23334-23342 (April 30, 2008).

The Designated List is as Follows:

B. Coins

1. Coins in Iraq have a long history and great variety, spanning the Achaemenid Persian, Hellenistic Seleucid, Parthian, Sasanian, and Islamic periods. Coins from neighboring regions circulated in Iraq as well. Early coins are hand-stamped, so that the design is usually off-center.

2. Achaemenid coins are the gold daric and silver siglos, and fractional and multiple denominations. Both are stamped on the front with an image of the king holding a bow, and on the back with a non-figural oblong mark.

3. Coin types and materials for coins minted or circulated in Iraq during the Seleucid, Parthian, and Sasanian periods include gold staters and dinars, bronze or silver drachms, tetradrachms, and hemidrachms, and smaller bronze and lead coins. These coins usually have male and female busts (of kings and queens) on the front. Seated archers, seated gods such as Zeus, winged Victory, and other Greco-Roman mythological subjects, are usually on the reverse of the Seleucid and Parthian coins, which are inscribed in Greek or Parthian. Sasanian period coins typically feature a fire altar on the back, either with or without figures, and are inscribed in Middle Persian.

4. Early Islamic coins are of gold, silver, and copper. Most are stamped on both sides with inscriptions in Arabic, though a few types have an image on one side and an inscription on the other.

Comment: Another all-encompassing list that includes many coins that circulated far outside of Iraq. These restrictions were made under separate statutory authority justified by looting in Iraq after the First Gulf War. The effective date of this regulation is ambiguous. The regulations themselves give April 30, 2008, as the effective date. However, the enabling statute states “the term ‘archaeological or ethnological material of Iraq'’ means cultural property of Iraq and other items of archaeological, historical, cultural, rare scientific, or religious importance illegally removed from the Iraq National Museum, the National Library of Iraq, and other locations in Iraq, since the adoption of United Nations Security Council Resolution 661 of 1990.” Emergency Protection for Iraqi Cultural Antiquities Act of 2004 (title III of Pub. L. 108-429), Sec. 3002 (b). Even more confusingly, the statute also indicates that the authority lapsed as of September 30, 2009. Id. However, the State Department takes the position that it still has authority to regulate Iraqi cultural artifacts.