Bulgaria Requests the US stop Buying Looted and Smuggled Artefacts from its Soil

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Looting Matters draws attention 'CPAC: Belize and Bulgaria' to a document from the end of last month that we all seem to have missed (coineys too), but it turns out it was only published yesterday [link to the formal notice here]. After enduring having most of the accessible archaeological sites seriously looted - some of them on an industrial scale - over the past two decades, and the material smuggled out often by organized criminal groups, Bulgaria is at last seeking to impose import restrictions on archaeological and ethnological material on the massive US antiquities market which has greedily devoured this material. The legislation sought will restrict legal imports to those items which arrive in the US with the appropriate documentation confirming legal export from Bulgaria under the terms of the US CCPIA. This is the public summary of the request:

[Billing Code: 4710-05]
DEPARTMENT OF STATE [Public Notice 7599]
Notice of Receipt of Cultural Property Request from the Government of the Republic of Bulgaria.

Bulgaria, concerned that its cultural heritage is in jeopardy from pillage, [has] made a request to the Government of the United States under Article 9 of the 1970 UNESCO Convention. United States Department of State received this request in September 2011. Bulgaria’s request seeks U.S. import restrictions on archaeological and ethnological material from Bulgaria dating to the Neolithic Period (7500 B.C.) through the nineteenth century A.D. The specific contents of this request are treated as confidential government to-government information, consistent with applicable U.S. law. Information about U.S. implementation of the 1970 UNESCO Convention can be found at http://exchanges.state.gov/heritage. A public summary of Bulgaria’s request will be posted on that web site.
Date: September 30, 2011
Ann Stock, Assistant Secretary of State for Educational and Cultural Affairs,
Department of State [FR Doc. 2011-26643 Filed 10/13/2011 at
8:45 am; Publication Date: 10/14/2011]

Now, anyone who has been closely following the course of the conflict between the ACCG and the State Department can see, I think, in these two documents pretty clear signs that they've a few ideas how to deal with those pesky un-American dealers' lobbyists that want to get in the way of DoS foreign policy. Good. In fact, one wonders about the precise domestic political context of this request. Have not the coineys brought this upon themselves by kicking against the system instead of complying willingly with the law? I certainly hope so.


The metal-detector and bulldozer looting of Bulgaria and the Balkans was at the core of the expansion in the early 1990s of the US and worldwide "minor antiquities" market. The trade in ancient coins was given new impetus by the arrival in some manner of huge amounts of apparently freshly dug-up artefacts and coins from this region. This is when many of the dealers and collectors in the ACCG began to take an interest in this market. The coin trade which is now fighting import restrictions owes its existence, one might legitimately suspect, to the massive availability of coins almost certainly from the Balkans, and Bulgaria in particular, which appeared on the US market in the past two decades.

A meeting of the US Cultural Property Advisory Committee (CPAC) will be taking place on 15th-17th November to discuss this request from Bulgaria. The majority of the meetings will be closed sessions of the Committee, but on 16th November there will be a three hour public session which invites comments on the request from Bulgaria and Belize together... Methinks that's going to be a real barrel of fun when the coineys take the floor.

I expect, if they are true to the pattern established by the events surrounding the previous several MOUs, we will see the usual ACCG-promoted copy-and-paste philistinic fax-bombing campaign prompted by some amazingly crazy bluff with no basis in fact (probably penned by Peter Tompa who is good at that sort of thing) which will only showcase once again the profound intellectual limitations of the whole coiney crowd taking part. I wonder how many will note that:

"all comments must relate specifically to the determinations under Section 303(a) (1) of the Convention on Cultural Property Implementation Act, 19 U.S.C. § 2602, pursuant to which the Committee makes findings [...] You may also send written comments to the Committee. Again, your comments must relate specifically to the determinations under Section 303(a) (1) of the Convention on Cultural Property Implementation Act, 19 U.S.C. § 2602, pursuant to which the Committee must make findings."

The comments can be sent by Internet by November 2, 2011 (go to
http://www.regulations.gov and search on docket number DOS-2011-0115 for
Bulgaria). Comments by fax or by e-mail will not be accepted. Comments submitted in electronic form will be posted on the site http://www.regulations.gov.

State Department Notice of Receipt of Request from Bulgaria

Public Summary of Bulgaria Request

Vignette: Alexander Nevski Church, Sofia; Bulgaria map.