Why US coin collectors are opposing the Cyprus MOU

A few days ago Dave Welshthe Chairman of the International Affairs Committee and Officer of the Ancient Coin Collectors’ Guild, posted on the Britarch forum a summary of what the fuss over the State Department’s ruling over import restrictions on archaeological artefacts is all about. I found this a useful sstatement of the ACCG position and reproduce it here for those getting a bit lost in the twists and turns of the conspracy theories being developed in various blog posts:

1) The ACCG is actually arguing that it is improper to consider every coin type claimed by Cyprus as "cultural property" because there is no evidence that every such coin was probably discovered in Cyprus. Coins of the claimed types have in demonstrable fact been discovered in large numbers in numerous locations outside Cyprus. Furthermore, it is relevant to observe that the legal origin of coins is their find spot, not the place of manufacture, so the argument that coins struck in Cyprus are thereby "of Cypriot origin" rests on very dubious foundations. Ancient coins travelled widely.

2) US coin dealers and collectors (who are also affected) importing coins of Cypriot types do not have to get an export license, since they are not the exporters. To receive their shipments, which may be arbitrarily detained by Customs at the importer's risk and expense, they may instead be required to present documentation obtained from the party exporting the coins, which may or may not include an export license (there are other ways to establish "licit origin" - which here does not mean the same thing as Barford's interpretation).

3) The actual reason collectors and the trade object to this requirement is that it is viewed as unreasonably burdensome. The major concern is that many shipments will be detained and perhaps confiscated whose coins did not originate in Cyprus, due to ignorance on the part of those charged with enforcement. Contesting a detention appears to be so expensive that many importers, such as collectors, could not afford to do so. There is also concern that getting the required documentation may be difficult for reasons not involving illicit export.

4) The CPAC (the President's advisors) was not charged with determiningwhether these coins were archaeological artifacts.

5) Members of the CPAC are chosen to provide a representative cross section of experts from the community interested in trade in cultural property. That includes archaeologists, museum staff, academics and experts in the trade.

6) The sole responsibility of the CPAC is to determine whether complying with a request for import restrictions is in the best interests of the United States.

7) The ACCG has reason to believe that serious improprieties, including what apparently amounted to "back room deals" with the archaeology lobby and with Cypriot interests, were committed by responsible State Department staff during consideration of the Cypriot request. There appears to be reason to suspect that State Department secretiveness is motivated by an effort to cover up what may have amounted to a scandal.

8) The ACCG also has reason to believe that the CPAC actually voted against including coins in the Restricted List.

9) The ACCG also has reason to believe that State Department staffadministereing the US response to UNESCO 1970 are ideologically aligned with the archaeology lobby, and are not dealing with cultural property issues in an even-handed manner making fairness to all Americans and the best interests of American citizens their highest priority.

10) The ACCG has filed a lawsuit against the State Department demanding fair, open disclosure of all documents and other records related to the Cyprus request and several other requests for import restrictions involving coins, including that of China where there is reason to think that the Chinese government actually did not include coins in their request, and that coins were added by the State Department as an "administrative measure." Thus far the State Department has not made such a disclosure, and the case is headed toward a trial.

11) The ACCG has reason to believe that State Department staff may intend to add coins (and perhaps other artifacts) to existing import restrictions "as an administrative matter" decided solely by presumably biased staff members, without any further review, public input, findings by the CPAC etc.

The issue in fact boils down to the fact that dealers and collectors think documenting the origin of objects of a type known to be being looted is a "bothersome" and meaningless formality (though see point number two). The key though to their challenge of the US State Department seems to be whether, if a foreign nation asks the US to honour international agreements and impose temporary import restrictions on "archaeological finds", ancient coins should be included among them.

I am an archaeologist who has worked in several countries where ancient coins turn up as archaeological finds all over the place. To me it never occurred that I should not be treating them as archaeological finds, and I am at a loss why anyone should begin. They are for example among the archaeological finds which the Portable Antiquities Scheme asks members of the public who come across them to report to them. Also one of the arguments coin collectors invariably offer in support of their hobby is that coins are a material source of information about the past - in other words they are treating coins as archaeological evidence.

Instead of needing an "administrative decision" to include coins on a list alongside other types of archaeological material, I would say it would need an administrative decision - which (from archaeological and resource conservation grounds) can only be seen as one of very dubious justification to exclude them. Now maybe President Bush's CPAC did that or not, I could not say, I know what I any educated person who is neither a coin collector or dealer ought to think about the CPAC if it did. There is nothing at all "biased" in treating ancient coins as archaeological finds, they simply are.

No matter how hard the culprits try to deny it, the current pseudo-discussion in the States on "where ancient coins come from" and their "not really being archaeological finds at all" clearly has an entirely political and commercial motivation and has absolutely nothing to do with real scholarship and their proponents are kidding themselves if they think they have.I'd like to see these polemecists try to publish their ideas in peer-reviewed and reputable numismatic journals.

Anyway, this court case should be an interesting, but probably not very edifying, spectacle. The collecting community may well find out that they've shot themselves in both feet.