My Cyprus MOU Comment: Have You Sent Yours?

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Although the State Department seems to be on a long holiday and is not posting up any new comments on the Regulations.gov website, it seems that unless there was a huge spurt over the Christmas break that there will a rather shallow public response to this one, I guess a few hundred at the most. Sadly, most of them will be crazed coineys alarmed by something or other and all of them opposing the continued scrutiny of fresh coins coming to the US market from abroad. It is interesting to speculate on why the numbers of those roused by the ACCG campaigns is dropping quite sharply from several thousand a while back to mere hundreds recently. Is it because it is gradually dawning on collectors that they really have been led by the nose by alarmist projections and fantasies and conned into giving a knee-jerk reaction to an imagined threat? Is it because one by one they've actually been reaching for the actual wording of the CCPIA and having a moment of realisation what it actually regulates? Let's hope so, and that 2012 represents a change in the so-called Guild of collectors that is actually going to start giving collectors real facts about the CCPIA and not made-up ones and alarmist rabble-rousing projections (OK, that's a really slim hope, isn't it?).

Anyway, I thought I'd add my voice alongside theirs, so as not to let the side down.

As somebody deeply concerned about the illicit international trade in antiquities and other cultural property and the role of US dealers and collectors in this, I support the renewal of the MOU with Cyprus to help curb the movement of illicit antiquities across US borders by increased scrutiny of imports as per Art. 3 of the 1970 UNESCO Convention and the CCPIA. It gives out a strong message of US commitment to equitable relations with the international community in such matters.

The rich cultural heritage of Cyprus continues to be seriously threatened by looters who, in defiance of antiquity preservation laws, are systematically and clandestinely stripping sites of collectable items many of which are destined for sale on foreign markets. Cyprus applies the measures envisaged in the Convention to attempt to combat this looting but the financial temptations of the international no-questions asked market for smuggled goods (and the US market plays a potentially big role) encourage criminals to try and subvert these efforts.

I would ask the CPAC to urge the appropriate US authorities to pay especial attention to the US trade (both across the country’s borders as well as internally) in what the trade persists in calling “minor antiquities”, and in particular in dug-up coins. Coins like any other archaeological artefacts illegally taken out of the archaeological record and unlawfully exported cannot be exempt from scrutiny. Yet this is what the people who profit from trading this type of material would apparently like to see. It cannot fail to escape the notice of the CPAC that US coin dealers and their lobbyists are currently engaged in active opposition to the imposition of import controls on items without documentation of lawful export (19 U.S.C. 2606) which can only draw attention to the current form of the market for such items in the US. The comments in this docket include those of a few hundred collectors (among the 50 000 collectors of ancient coins the lobby group the Ancient Coin Collectors’ Guild claims). They, fired up by the alarmist rhetoric of the dealers’ lobbyists, oppose restricting imports onto the US market to only those with documentation of what the CCPIA considers to be lawful export. Their collective voice in favour of the reintroduction of an unrestricted flow onto the US market of freshly imported archaeological artefacts such as ancient coins without documentation of lawful export shows why it is so important that US vigilance is maintained.

The US needs to maintain their tough stance with anyone attempting to abuse the system and continue to seize illicitly-exported material of this type at the US borders (in accordance with the measures envisaged by the 1970 Convention), and in doing so help make international controls on the movement of illicit artefacts more effective.

Closer scrutiny of archaeological and ethnographic material of Cypriot origin crossing US borders is a non-drastic means of providing this help and respecting the obligations of the USA and other states parties under the 1970 UNESCO Convention.

There are still two days for you, gentle reader to put on the White Hat and stand up against cultural property philistinism. Cut and paste if you like, the coineys are convinced nobody at the State Department ever reads this stuff or passes it on to the CPAC.