Coin Collectors Challenge US Import Restrictions

"Arbitrary and capricious"?
With regard to the stunt the ancient coin dealers’ advocacy group the ACCG staged with the import of “unprovenanced coins of Cypriot and Chinese type” for purposes of a test case, Peter Tompa announces:

As I state in the ACCG press release, “Research and discovery to date in a separate ongoing Freedom of Information Act case strongly
suggests that State Department bureaucrats acted improperly by adding coins to import restrictions on Chinese cultural goods without any formal request from PRC officials. Even more troubling, is their July 2007 decision to impose import restrictions on coins of Cypriot type, which appears to have been adopted contrary to the recommendations of CPAC.” My firm [Bailey & Ehrenberg PLLC] will be pursuing this matter on behalf of the ACCG. [...] In addition, the ACCG is also receiving legal advice and counsel from the well-known customs law firm of Serko, Simon, Gluck & Kane LLP for purposes of this litigation. [...] The ACCG hopes that this Customs action will allow a Court to ultimately determine whether the Department of State's actions are arbitrary and capricious.

I suggest that what is arbitary and capricious is the USA’s interpretation of the provisions of the 1970 UNESCO Convention on the Means of Prohibiting and Preventing the Illicit Import, Export and Transfer of Ownership of Cultural Property embodied in their 1983 Convention on Cultural Property Implementation Act which totally ignores its Article 13.