Collectors in the United States may not be aware that the governments of Morocco and Yemen have requested Memorandums of Understanding (MOUs) that will restrict importing some antiques from those countries. It isn't clear if the governments specifically requested coins. Previous MOUs with other countries have included coins. These memorandums are intended to be emergency measure to block importing of looted goods. Unfortunately the MOU's restrictions are not enforced just on looted goods. They can be applied to anything that doesn't have a paper trail. Peter Tompa, a lawyer who works with the Ancient Coins Collectors Guild, has written an article about the request that explains how to comment. http://culturalpropertyobserver.blogspot.com/2019/10/short-comment-period-for-proposed-mous.html Tomorrow is the last day to leave comments on the US government web site. I left comments today. Not everyone has seen an ancient coin from Yemen. I have one in my collection: HIMYARITES. Amdan Bayyin Yanuf, 2nd century AD. AR Scyphate Quinarius (1.16 gm) of Raidan mint. 13mm Obv: Male head right, within torc Rev: Himyarite/Sabatean legend ʿMDN | BYN (=ʿaMDaN BaYyiN), (RYDN or RaYDaN); Small male head, YaNaF monogram to left, scepter symbol (or monogram?) to right. Ref: Sear, GIC 5717. Munro-Hay 3.2ai. Plant, Greek, Semitic, Asiatic #135. ex-Pegasi Numismatics, Auction XXXIV, May 2016, lot 243 (unsold)
Thanks for the heads-up, @Ed Snible . Curious if there will be a reciprocal MOU for the billions of expatriated $100 bills ? Arabia Felix Himyarite AR Quinarius Head torque Head South Arabian script Ref Munro-Hay 3.25
I clicked the Tompa article and the links within and am having trouble finding where I can read the summary and comments, much less where to actually comment. Typical bureaucratic morass .
I sent in a long comment opposing the MOU's (below). I hope you will make a short comment. I don't think length is helpful, but I had a lot to say. I strongly oppose the proposed MOU's with Morocco and Yemen. They cover coins that have no cultural connection with their present-day governments and they cover coins that may have left the country legally long ago. Ancient coins should not be included. I suspect the proposal is being promoted by those sympathetic to the arguments of the archaeological community who oppose collecting. But those arguments are wrong and misguided and MOU's will not have the consequences they hope for. I have been told I am the most-cited scholar in the area of ancient coins. I am an elected Fellow of The American Numismatic Society. My interest was kindled by collecting and my contributions would not have occurred without collecting. Furthermore, my area of speciality (die-study statistics) relies on numerous published examples of coins, the great majority of which were published by dealers for collectors. Without easy access to ancient coins on the market, I venture to say more than half the Ph.D.s in ancient numismatics could not have been written! So, *collecting is good for scholarship*. A substantial percentage of the scholarly works on ancient-coins were written by amateurs who became experts because of their collections. (I am actively consulting with one this week.) If the objective is to preserve archaeological information then suppressing collecting is a misguided approach that will inevitably fail. Furthermore, it will have negative unintended consequences that will far outweigh the potential (but illusory) positives. After paying attention to this for a long time I still wonder why very intelligent people in the archaeological information game remain PC and don't risk saying the obvious "This approach won't work!" The full line of thought is something like this. "Archaeology provides valuable information. Looting of archaeological sites causes information to be lost. Looting occurs because looters hope to find things of value. Collecting causes objects to have value. Therefore, shutting down collecting, or at least making it much more difficult, will increase archaeological information." The last step in the argument is simply false. Here are just a few points I could expand upon: There is an assumption that laws somehow force behavior to accord with the laws. You might as well pass laws against pre- and extra-marital sex (or alcohol). Perhaps a good idea, but it goes on anyway. Far less academic information comes out of countries with restrictive laws than countries that support collecting. That's a fact. In the chain of economics from looter to collector there are already strong laws agains looting. We, in the US, would like to think that a person is who he is, which is not determined by his fore-bearers. The creators of ancient coins are long gone. Cultural patrimony belongs, not to the state happening to occupy certain territory (often of an unrelated culture), but to the world. Recall that Turkey claims Greek coins found on its soil, and Greece claimed an EID MAR Roman denarius arguably found on its soil. Claims of cultural patrimony are hypocritical. Governments regard coins as having value and are as greedy as any collector. People have sought treasure and defiled archaeological sites for thousands of years--long before there was a market in antiquities and numismatic coins. Information that hoards have beyond just the existence of the coins may be lost--not because coins are found by treasure seekers, but because governments claim ownership and do not adequately reward finders. Only England, with its rational Treasure Trove law, has many well-recorded hoards. For example, Italy, with it's draconian laws about hoards, has few well-recorded hoards. (Duncan-Jones, in an article on the mobility of coins from place to place, stated he had to leave out Italy because there were too few recorded hoards!) There are relatively few academics and a large number of amateurs (in the best sense of the word) making contributions to scholarship about ancient coins. Professional scholars are not able to deal with the volume of information and the amateurs who do are collectors and most would not be involved if collecting were not a motivation. For example, it took academics over 50 years to publish the very limited amount of material in the Dead Sea Scrolls! *Please do not include ancient coins in any MOU.* The "scholarly" reasons to include them do not hold up under scrutiny. It may be that those governments think they have value (they do) and want to confiscate coins. There are many instances of local officials, including museum curators, illicitly selling coins they were supposedly responsible for. Outlawing traffic means criminals take it over (It doesn't go away). Collectors are far better custodians of ancient coins than those governments. Let coins come into the US where any information they contain will have a much better chance of becoming public.
A direct link to the comment start page can be found at https://www.regulations.gov/docket?D=DOS-2019-0031 . Click "Comment Now". If you choose to leave your name and address, you don't have to fill in all of the fields. I could not find the actual requests, just notices of the requests. The comments are public. Eventually they appear on the web site. As of last week there were 19 comments. Nearly all comments were about Jewish religious artifacts. We should show that coin collectors are also paying attention.
Thanks to all who commented. There still is time to do so though the comment period ends today. Here is my personal comment: https://www.regulations.gov/document?D=DOS-2019-0031-0054 Comment View document: Dear CPAC, Ive already written separately on behalf of IAPN and PNG. Please also consider these additional personal comments. 1. The ANS kindly provided me a forum to detail my own views about import restrictions on coins and their detrimental impact on legitimate collecting, the appreciation, study and preservation of historical coinage and the people to people contacts coin collecting brings. See http://numismatics.org/wikiuploads/DigitalPublications/WitschonkeTompaFinal.pdf 2. Since that article has been published, collecting has even become more challenging given a rush of new import restrictions, most significantly ones of highly collected coins from Italy, Greece, Bulgaria, and Egypt. 3. These restrictions are highly problematic because the way are applied. My reading of the CPIA is that import restrictions are meant to only apply prospectively to items illicitly exported from the country for which import restrictions were granted after the effective date of the governing regulations. The problem is that they are instead applied far more broadly as an embargo on all items on designated lists imported into the US after the effective date of applicable regulations. The one federal court that has been asked to look at the issue refused to get involved, claiming that it was a foreign policy issue. 4. If restrictions were applied as contemplated by Congress, the impact on trade between the US and fellow collectors in Europe would be limited. However, embargoes make it impossible to legally import coins of types on designated lists because most coins simply lack sufficient information as far as Customs is concerned to import under the CPIAs safe harbor provisions. 5. Let me provide an example. I purchased a Himyarite coin from Spink, a UK seller, back in 2009 for $70. It has wonderful old collection toning so was likely in a collection in the UK for many years before it was purchased. However, Spink did not provide me with any collection history for the coin, probably because they had none. It simply was not thought important to retain for coins at the time, and there still is no legal requirement that documentation is retained for such items. Moreover, even when it is retained, it is quite easy for it to be lost over time. For more, see https://culturalpropertynews.org/the-international-art-market-as-cultural-bogeyman-part-1/. I know I must have an invoice for my coin somewhere, but it is not easily at hand. Moreover, there was no reason for me to think I would need to keep an invoice when I purchased the coin. And, in any case, the invoice would not have an image on it so it is quite possible a customs official would not accept it as conclusive proof I purchased this coin in 2009 anyway. 6. Such restrictions only harm honest collectors and dealers because as should be apparent from the attached pictures, such coins are so small that they may easily be smuggled. This makes CPIA import restrictions as applied by Customs the epitome of a poor regulatory scheme one that only punishes honest people importing coins from legitimate source in Europe, and which does nothing really to deter smugglers of such small items from todays war torn Yemen. 7. Over time, the ever increasing number of embargoes placed on all sorts of coins has really harmed ancient coin collecting which provides most, if not all, support for the scholarly study of coins (Numismatics). 8. A great example of how collecting supports academic study is the Caravan Kingdoms book written by a German collector of coins from the area along with an ANS academic, and published at the ANS. The ANS, and its publications are collector and dealer supported. The ANA, the other major center for the study of coins in the US, is also collector and dealer supported. In contrast, the Smithsonian, though it has a large collection, does little or no academic work and recently even discharged collectors helping to catalogue the collection as part of a Smithsonian wide move limiting the activity of volunteers. 9. Without a strong collecting base, there will no longer be the necessary level of support for the ANS, the ANA and the study of numismatics in the US. So, although import restrictions have been pitched in the past as necessary to promote academic study of archaeological objects, that simply is not the case with respect to coins. In fact, if anything, over time import restrictions will have the opposite effect on Numismatic study in the US. Sincerely, Peter Tompa
