ANCIENT COIN COLLECTORS GUILD

Albania

March 15, 2022 2:02 PM | Sue McGovern-Huffman (Administrator)

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?


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