The Cultural Property Advisory Committee has recommended, and the State Department has issued an import ban on Cypriot coins. Here is an excerpt from the Federal register notice outlining the new import restrictions:
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.
Jeremy Kahn of the New York Times has a summary in today’s paper here. The new restriction is noteworthy because the Cultural Property Advisory Committee has never placed restrictions on ancient coins before. However, no request for restrictions by another nation has never been refused, so this was the likely outcome. To trigger a recommendation for import restrictions, a source nation must show it is working to police its archaeological sites, and the ancient sites are in danger of being pillaged. It seems Cyprus was able to make that claim, though we won’t be able to know the actual deliberations which went on because the deliberations of the CPAC are secret.
Cyprus’ ambassador Andreas Kakouris said in the NYT article “We are very pleased coins have been added to this … Coins constitute an inseparable part of our own cultural heritage, and the pillage they are subjected to is the same as other archaeological material.”
Representing the other side though is Peter Tompa who said “This decision shows that the Department of State is putting the narrow interest of the cultural bureaucracies of foreign states and the archaeological community over those ordinary Americans who believe that collecting increases appreciation of the past and helps preserve artifacts.”
It’s a difficult issue I think. The work of numismatists has helped archaeologists to be able to date their finds. However, ancient coins are found in the same areas as other archaeological materials. I argue in my thesis that the bilateral implementation of the 1970 UNESCO Convention which the US and Switzerland have undertaken can be quite effective, and at least gives a voice to the interests of antiquities dealers. They may not think their views are taken into account in the CPAC, but it is a much stronger voice than they have in other nations. The restrictions are limited as well, they extend for five years only, and have to be renewed.
In my view the solution is a compromise which strongly restricts the trade in the most important objects, but allows a limited and licit trade in surplus and other objects. To fund these efforts I propose antiquities leasing and other initiatives. The magic bullet which could end all of these problems though is the publication of detailed provenances for all sales. Unfortunately the current climate does not promote the sharing of that information.
What makes you think that CPAC departed from its prior recommendations to exclude coins? Isn’t it more reasonable to assume that the State Department substituted its judgment for the experts on the State Department’s Cultural Property Advisory Committee to please the over agressive and prickly Cypriots? That is a more reasonable assumption given the record of the State Department’s ECA.
I’m not sure what the State Department ECA might be. I do know this is the first time import restrictions have been imposed on coins, and numismatists are quite unhappy about it. We also don’t know what the deliberations were in the CPAC because they are secret. Also, I don’t know of any evidence indicating the State Department went beyond the advice of the CPAC.
It is my understanding though that foreign nations make requests for restrictions, and then the CPAC makes a recommendation. I don’t think the State Department ever acts unilaterally. Another nation has to first make a request.
I find it hard to imagine a customs inspector being able to differentiate between a Cypriot coin from a Greek coin from a Roman coin. This whole import restriction is amazing in its unintended breadth and its potential impact on the coin market and coin collectors.
Is it really much of a burden to have your shipment of Roman coins delayed for a few days? ICE agents have a lot on their plate to be sure. You may be right we are asking too much of them if we expect them to differentiate between Cypriot and other coins. However I think that what usually happens is they delay a shipment and call in an outside expert who can look at something. Cypriot coins will probably still be smuggled in to the country, but I think you make a mistake if you think ICE agents are the first and last regulatory hurdle.
I would expect more scrutiny if Cypriot coins come up for sale at auction. If an owner can’t demonstrate they entered the country before July ’07, then an investigation could ensue. It puts more of a burden on buyers and sellers to make sure the objects they are buying have clean provenance.
Of course, the real issue here is why the change from the current rule of no restrictions? The issue of coins has already come up before CPAC on several occasions, including the last time CPAC looked at import restriction on Cypriot cultural artifacts. There has been no change in the underlying facts. There are either one of two possiblities. Either CPAC changed its recommendations without any change in the underlying facts or the State Department rejected CPAC’s recommendations.
If anything, the latter seems probable based on this odd formulation on the Cultural Heritage Center of the Bureau of Educational and Cultural Affairs (ECA) Web site. The language can be taken to suggests that ECA may have bypassed CPAC and done so as an “administrative matter”
See http://exchanges.state.gov/culprop/whatsnew.html
Questions and Answers
The Government of the Republic of Cyprus requested an amendment to the Designated List of categories of objects restricted from entering the United States to include coins because they are part of the Cypriot archaeological record and subject to pillage and illicit trafficking.
Q. What was the response?
A. The Cultural Property Implementation Act places the authority for the Designated List with the Department of Homeland Security (DHS) in consultation with the Department of State. On July 13, 2007, DHS published a Federal Register notice concerning the extension of the agreement and amending the Designated List to include certain coins from Cyprus, effective July 16, 2007.
The implications of such a move would be breath taking, and should be of concern to anyone interested in the international exchange of artifacts. Just think, no need to deal with pesky coin collectors (or others) commenting to CPAC or for that matter CPAC recommendations on import restrictions on specific categories of cultural goods. Rather, once CPAC makes general findings, you can go back and add to the designated list at will.
Sound preposterous? Don’t be too sure. The State Department ECA’s unyielding secrecy acts as a cover for giving the bureacrats license to do pretty much what they want.
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