ANCIENT COIN COLLECTORS GUILD

U.S. Import Restrictions on Ancient Coins

(current as of March 13, 2022)

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  • March 14, 2022 11:22 PM | Sue McGovern-Huffman (Administrator)

    Effective Date: February 5, 2020

    Source: 85 Fed. Reg. 7204 (Feb. 7, 2020),

    The Designated List is as follows:

    The restrictions on coins include:

    10. Coins—Some of the best-known types include:

    a. Nabataean—Coins in silver, lead, copper or bronze and struck at Petra.

    They typically have cornucopiae or wreaths on the reverse and portrait of

    the ruler or rulers on the obverse.

    b. Roman Provincial—Coins in silver and bronze were struck through the

    third century A.D. at Roman and Roman provincial mints of Abila (Abel), Adraa (Daraa), Charachmoba (Al-Karak), Dium, Esbous (Heshbon), Gadara (Umm Qais), Gerasa (Jerash), Medaba (Madaba), Pella, Petra, Philadelphia (Amman), Rabbathmoba (Aroer) Capitolias/Dion (Beit Ras), and Raphana. This type also includes the pseudo-autonomous coinage of the second and first centuries B.C.

    c. Byzantine—Coins in bronze and struck at the Arab-Byzantine mint of Aylah/Elath (Aqaba).

    d. Early Islamic—Coins in bronze or silver and struck at the Umayyad mints of Adraa (Daraa), Gerasa (Jerash), Philadelphia/Rabbath-Ammon (Amman) and under the Abbasids at Philadelphia/ Rabbath-Ammon (Amman). These coins are epigraphic in design, featuring one or more lines of Arabic script. Some Abbasid bronze coins from Philadelphia/Rabbath-Ammon (Amman) feature a small flower-like design in the center of one side.

    e. Crusader—These coins appear as thin, light-weight, low-quality-silver billon. Examples usually feature crosses and/or crude portraits or buildings as central images.

    Comment: This list again includes coins that circulated in quantity outside of the confines of modern-day Jordan. Moreover, restrictions were imposed despite open sales of coins at the archaeological site of Petra as well as an annual numismatic bourse in Amman. If Jordan wants tourists to visit, it should encourage sales of such common material rather than expect CBP to seize such material purchased by tourists on their return to the United States.


  • March 13, 2022 11:24 PM | Sue McGovern-Huffman (Administrator)

    “Emergency” import restrictions

    Effective Date: December 5, 2017.

    Source: 82 Fed. Reg. 57346-57351 (Dec. 5, 2017).

    The Designated List is as follows.

    a. General--Examples of many of the coins found in ancient Libya may be found in: A. Burnett and others, Roman Provincial Coinage, multiple volumes (British Museum Press and the Biblioth[egrave]que Nationale de France, 1992-), R.S. Poole and others, Catalogue of Greek Coins in the British Museum, volumes 1-29 (British Museum Trustees 1873-1927) and H. Mattingly and others, Coins of the Roman Empire in the British Museum, volumes 1-6 (British Museum Trustees 1923-62). For Byzantine coins, see Grierson, Philip, Byzantine Coins, London, 1982.

    For publication of examples of coins circulating in archaeological sites, see La moneta di Cirene e della Cirenaica nel Mediterraneo. Problemi e Prospettive, Atti del V Congresso Internazionale di Numismatica e di Storia Monetaria, Padova, 17-19 marzo 2016, Padova 2016 (Numismatica Patavina, 13).

    b. Greek Bronze Coins--Struck by city-states of the Pentapolis, Carthage and the Ptolemaic kingdom that operated in territory of the Cyrenaica in eastern Libya. Approximate date: 4th century B.C. to late 1st century B.C.

    c. Greek Silver and Gold Coins--This category includes coins of the city-states of the Pentapolis in the Cyrenaica and the Ptolemaic Kingdom. Coins from the city-state of Cyrene often bear an image of the silphium plant. Such coins date from the late 6th century B.C. to late 1st century B.C.

    d. Roman Coins--In silver and bronze, struck at Roman and Roman provincial mints including Apollonia, Barca, Balagrae, Berenice, Cyrene, Ptolemais, Leptis Magna, Oea, and Sabratha. Approximate date: late 3rd century B.C. to 1st century A.D.

    e. Byzantine Coins--In bronze, silver, and gold by Byzantine emperors. Struck in Constantinople and other mints. From 4th century A.D. through 1396 A.D.

    f. Islamic Coins--In bronze, silver, and gold. Dinars with Arabic inscriptions inside a circle or square, may be surrounded with symbols. Struck at mints in Libya (Barqa) and adjacent regions. From 642 A.D. to 15th century A.D.

    g. Ottoman--Struck at mints in Istanbul and Libya's neighboring regions. Approximate date: 1551 A.D. through 1750 A.D.

    Comment: The restrictions explicitly encompass Greek, Carthaginian, Roman, Byzantine and Ottoman coins struck outside Libya that are found within Libya. This is a major departure from prior restrictions that listed coins based on where the coins were made hundreds, if not thousands of years ago, rather than where they were found today. While this phraseology is more consistent with applicable statutory language, it remains to be seen how it is applied.


  • March 12, 2022 11:28 PM | Sue McGovern-Huffman (Administrator)

    Effective Date: January 15, 2021

    Source: 86 Fed. Reg. 6562—6566 (Jan. 21, 2021).

    The Designated List is as follows:

    10. Coins—This category includes coins of Numidian, Mauretanian, Greek/Punic, Roman, Byzantine, Islamic, and Medieval Spanish types that circulated primarily in Morocco, ranging in date from the fifth century B.C. to A.D. 1750. Coins were made in copper, bronze, silver, and gold. Examples may be square or round, have writing, and show imagery of animals, buildings, symbols, or royal figures.

    Comment: This designated list is peculiar because other than some bronze coins of the Mauritanian Kingdom struck at Lix and Roman Provincial issues of cities of Tingis (Tangier), Lix, and Tamuda, no Numidian, Mauritanian, Greek/Punic, Roman, Byzantine, and Medieval Spanish coins “primarily circulated” there. Instead, the only coins most associated with Morocco are Islamic ones struck within the confines of modern-day Morocco like Marrakesh, Fez, Misknash, Nul, Sijilmasa, Tangier, Cueta, Aghmar, Sala and Bani Tavula. As large gold issues were struck there, it is also debatable whether such coins “primarily circulated” within Morocco or not.


  • March 10, 2022 11:29 PM | Sue McGovern-Huffman (Administrator)

    Effective Date: August 15, 2016 but regulations retroactive to March 15, 2011

    Source: 81 Fed. Reg. 2016-19491 (Aug. 15, 2016)

    “Below is the Designated List of Archaeological and Ethnological Material of Syria that describes the types of objects or categories of archaeological or ethnological material that are subject to import restrictions, if unlawfully removed from Syria on or after March 15, 2011.”

    I. Coins--In copper or bronze, silver and gold.

    1. Coins in Syria have a long history and exist in great variety, spanning the Achaemenid Persian, Hellenistic Seleucid and Ptolemaic, Roman, Sasanian, and Islamic periods. Coins from neighboring regions circulated in Syria as well. Some major mints for coinage that circulated in Syria in various periods include Emesa, Antioch, Apamea, Damascus, Beroea, and Laodicea.

    2. Achaemenid coins include silver drachms stamped on the obverse with the head of the king and on the reverse with an altar.

    3. Coin types and materials for coins minted or circulated in Syria during the Hellenistic Seleucid and Ptolemaic periods include gold and silver staters and obols, bronze or silver drachms, hemidrachms, tetradrachms, and smaller bronze and lead coins. These coins have a wide variety of decorative elements. Male and female busts (of kings, such as Seleucus, and queens, such as Cleopatra, or sometimes deities) are usually found on the front. Seated archers, seated gods such as Zeus, winged Victory, Tyche, and Herakles, other Greco-Roman mythological subjects, animals such as lions and elephants, palm trees, and ships are usually on the reverse of the Seleucid and Ptolemaic coins, which are often inscribed in Greek.

    4. Roman coins minted and circulated in Syria during the Roman period come in a variety of denominations and weights and were struck primarily in silver and bronze, though examples (sesterces) of brass also appear. The front usually has an image of the emperor; sometimes, other notable personages (e.g., Julia Domna) might appear. Subjects shown on the reverse include seated and standing deities, wreaths, temples and altars, mythological scenes, and eagles. Inscriptions are usually in Latin, but sometimes also in Greek. Late Roman (Byzantine) coins are similar, but the reverse often shows Christian iconography (e.g., crosses), and inscriptions are in Greek.

    5. Sasanian period coins are typically silver drachms with an image of the ruler on the obverse and a religious scene with a fire altar on the reverse.

    6. Islamic coins are of gold, silver, bronze, and copper and include examples from the Ummayad, Abbasid, Ghaznavid, Fatimid, Ayyubid, Seljuq (including Zengid), Timurid, Mamluk, Safavid, and Ottoman periods. Most are stamped on both sides with inscriptions in Arabic, although a few types have an image on one side and an inscription on the other.

    Comment: These restrictions were imposed by statute. The breathtakingly broad restrictions with a retroactive date to 2011 also include a specific provision that the coins in question were unlawfully removed from Syria after that March 15, 2011 date. As such, they are much more in keeping with the CPIA’s limitations of restrictions to items “first discovered within” and “subject to” the export control of the country for which restrictions were granted then many other import restrictions.


  • March 09, 2022 11:32 PM | Sue McGovern-Huffman (Administrator)

    Effective Date: June 16, 2021

    Source: 86 Fed. Reg. 114 (Feb. 16, 2021)

    The list of coins is extensive. It includes:

    9. Coins

    a. Greek coins – Archaic coins, dated to 640 – 480 B.C., in electrum, silver and billon, that circulated primarily in Turkey; Classical coins, dated to 479 – 332 B.C., in electrum, silver, gold, and bronze, that circulated primarily in Turkey; and Hellenistic coins, dated to 332 – 31 B.C., in gold, silver, bronze and other base metals, that circulated primarily in Turkey. Greek coins were minted by many authorities for trading and payment and often circulated all over the ancient world, including in Turkey. All categories are based on find information provided in Thompson, M., Mørkholm, O., Kraay, C., Inventory of Greek Coin Hoards, 1973 (available online at http://coinhoards.org/) and the updates in Coin Hoards I-X as well as other hoard and single find publications. Mints located in Turkey and surrounding areas are found in Head, B. V., Historia Numorum, A Manual of Greek Numismatics, 1911 (available online http://snible.org/coins/hn/).

    b. Roman provincial coins – Roman provincial coins, dated from the end of 2nd century B.C. to the early 6th century A.D., in gold, silver, and bronze and copper that circulated primarily in Turkey.

    c. Byzantine period coins – Byzantine period coins, in gold, silver, bronze, copper coins, and sometimes electrum, dating from the early 6th century to the 15th century A.D., that circulated primarily in Turkey, (e.g., coins produced at mints in Nicaea and Magnesia under the Empire of Nicaea).

    d. Medieval and Islamic coins – Medieval and Islamic coins, in gold, silver, bronze, and copper coins from approximately A.D. 1077 – 1770, that circulated primarily in Turkey.

    Comment: These restrictions are breathtakingly broad. However, they are qualified to only include coins that “circulated primarily in Turkey.” If this phraseology is meant to comply with the CPIA, it only pays “lip service” to the statutory provision limiting any restrictions to archaeological objects “first discovered within” and “subject to export control by” Turkey. (19 U.S.C. § 2601.) Moreover, what coins “primarily circulated in Turkey” is undefined putting the importer in the position of gambling whether the coins they import will be deemed to be covered by the restrictions or not. On a positive note, Roman Imperial coins remain exempted from the restrictions.


  • March 03, 2022 11:34 PM | Sue McGovern-Huffman (Administrator)

    Effective Date: February 7. 2020

    Source: 85 Fed. Reg. 7209 (Feb. 7, 2020)

    The list of coins is extensive. It includes:

    9. Coins—A reference book for ancient, pre-Islamic material in Yemen is M. Huth, Coinage of the Caravan Kingdoms: Ancient Arabian Coins from the Collection of Martin Huth, New York, 2010, pp. 68-152. A reference book for Islamic coinage to A.D. 1750 is S. Album, Checklist of Islamic Coins, Santa Rosa, 2011, pp. 116-127. Some of the best-known types are described below:

    a. Ancient—In gold, silver, and bronze/copper, with units ranging from tetradrachms down to various fractional levels.

    i. Earliest coins from Yemen are imitations of silver tetradrachms from Athens; feature a bust of Athena on the obverse and an owl on the reverse. The style of these imitations is distinctive, and they are usually marked with Arabian monograms or graffiti. Approximate date: 500 B.C. and later.

    ii. Minaeans produced schematic imitations of the Athenian coinage; these coins have angular shapes, often triangular. Style is distinctive with monograms with Arabian letters. Approximate date: 200 B.C.

    iii. Sabaeans struck distinctive local imitations of Athenian tetradrachms, with or without monograms, often with the curved symbol of Almaqah to the right of the owl, and of smaller units than previously. In the 1st century A.D., the head of Athena is replaced with a male bust resembling Augustus; owl on the reverse continues, as do monograms and the curved symbol. In the 2nd and 3rd centuries A.D., a beardless male head appears on the coins with the curved symbol, and a facing bucranium (a bull's head) appears on the reverse with the curved symbol and monograms. Approximate date: 400 B.C.-A.D. 300.

    iv. Himyarite coins feature beardless male heads on the obverse coupled with bearded male heads on the reverse. Various South Arabian monograms appear on the coins. Rulers include Yuhabirr, Karib'il Yehun`im Wattar, Amdan Yuhaqbid, Amdan Bayan, Tha'ran Ya`ub, Shamnar Yuhan`am, and unknown kings. Approximate date: 110 B.C.-A.D. 200.

    v. Qatabians produced imitations of Athenian coins also in 2nd-4th century B.C., with or without monograms; distinctive style. From the 2nd century B.C. to the 2nd century A.D., head of Athena is replaced with male ruler portraits, including those of Yad'ab Dhubyan Yuhargib, Dhub, Hawfi`Amm Yuhan`am III, Shahr Yagul, Waraw'il Ghaylan, Shahr Hilal, Yad`ab Yanaf, and various unknown rulers. Reverses of early types have the owl, while later types have a second portrait on the reverse. Approximate date: 400 B.C.-A.D. 200.

    vi. Bronze coins from Hadramawt have radiate male portraits in a circle on the obverse and a standing bull on the reverse; Arabian symbols appear. Approximate date: A.D. 200-400.

    vii. Various South Arabian types imitate Athenian coins, Hellenistic Alexander tetradrachms with a head of Herakles on the obverse and Zeus seated on the reverse, and Ptolemaic coins with a cornucopia on the reverse. Style is distinctive; designs are accompanied by Arabian monograms.

    b. Islamic Period—In gold, silver, and bronze, and including anonymous mints in Yemen, and coins of unknown rulers attributed to Yemen. Non-exclusive mints are the primary manufacturers of the listed coins, but there may be other production mints.

    i. `Abbasid coins struck in gold, silver, and bronze, at non-exclusive mints San`a, Zabid, `Adan, Dhamar, `Aththar, and Baysh mints. Approximate date: A.D. 786-974.

    ii. Coins of the Amirs of San`a, struck in gold, at the mint of San`a. Approximate date: A.D. 909-911.

    iii. Rassid (1st period) coins struck in gold and silver at Sa`da, San`a, Tukhla', and `Aththar. Approximate date: A.D. 898-1014.

    iv. Coins of the Amirs of Yemen, struck in silver, at an uncertain mint. Approximate date: A.D. 1000-1100.

    v. Coins of the Amirs of `Aththar, struck in gold, at the mint of `Aththar. Approximate date: A.D. 957-988.

    vi. Tarafid coins, struck in silver, at the mint of `Aththar. Approximate date: A.D. 991-1004.

    vii. Ziyadid coins, struck in gold and silver, at non-exclusive mint Zabid. Approximate date: A.D. 955-1050s.

    viii. Khawlanid coins, struck in silver, at the mint of San`a. Approximate date: A.D. 1046-1047.

    ix. Najjahid coins, struck in gold, at the mints Zabid and Dathina. Approximate date: A.D. 1021-1158.

    x. Sulayhid coins, struck in gold and debased silver, at non-exclusive mints Zabid, `Aththar, `Adan, Dhu Jibla. Approximate date: A.D. 1047-1137.

    xi. Zuray'id coins, struck in gold, at the mints of `Adan and Dhu Jibla. Approximate date: A.D. 1111-1174.

    xii. Coins of Mahdid of Zabid, struck in silver, at the mint of Zabid. Approximate date: A.D. 1159-1174.

    xiii. Rassid (2nd period) coins, struck in gold and silver, at non-exclusive mints Zufar, San`a, Sa`da, Huth, Dhirwah, Kahlan, Muda', `Ayyan, Bukur, al-Jahili, and Dhamar. Approximate date: A.D. 1185-1390.

    xiv. Ayyubid coins, struck in gold, silver, and bronze, at the mints of Zabid, `Adan, Ta`izz, San`a, al-Dumluwa, Bukur, and Mayban. Approximate date: A.D. 1174-1236.

    xv. Rasulid coins, struck in gold, silver, and bronze, at non-exclusive mints `Adan, Zabid, al-Mahjam, Ta`izz, San`a, Tha'bat, and Hajja. Approximate date: A.D. 1229-1439.

    xvi. Tahirid coins, struck in silver, at the mint of `Adan. Approximate date: A.D. 1517-1538.

    xvii. Rassid (3rd period) coins, struck in silver and bronze, at the mints of San`a, Zafir, and Thula. Approximate date: A.D. 1506-1572.

    xviii. Ottoman coins, struck in gold, silver and bronze, at the mints of Zabid, San`a, `Adan, Kawkaban, Ta`izz, Sa`da, al-Mukha, and Malhaz. Approximate date: A.D. 1520-1750.

    Comment: Ironically, both Martin Huth and Stephen Album's firm have expressed concerns about import restrictions on coins to the Cultural Property Advisory Committee (CPAC) in the past. Yet, here their scholarly works on these coins are being cited as a basis for the restrictions! Once again, the restrictions include issues that would have circulated outside of the confines of modern Yemen, including many pre-Islamic silver and Islamic silver and gold coins.


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