Numismatic News Nonsense on Bulgaria

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Mark Fox ('Bulgaria Seeks Import Restrictions', Numismatic News/Numismaster October 31, 2011) writes about the Bulgaria bilateral cultural property agreement request. I cannot say it is a very impressive summary:

Several prominent coin dealers and auction houses, including Classical Numismatic Group (CNG) and Harlan J. Berk, Ltd., have already alerted their customers about Bulgaria’s request for an MOU with the U.S. and its possible implications on the hobby if implemented. Use of this public venue to influence the outcome of the upcoming deliberations is also supported and urged by the American Numismatic Association. Without proper records tracing their chain of ownership to before the dates the MOUs were implemented, ancient Cypriot and Chinese coins, including some issues of medieval Chinese, as well as ancient coins of “Italian type,” are all subject to possible confiscation if imported into the US. In practice, it matters little if, for example, a collection of ancient Cypriot coins assembled a century ago in Germany are shipped to the U.S. If there is no paperwork to prove that they had left Cyprus before July 16, 2007, (the date the latest MOU with Cyprus went into effect), then the coins are vulnerable to seizure.

But, the CCPIA states very clearly what paperwork is needed to enable this without a hitch. Dealer Dave Welsh says it cannot be "blue crayon on the back of an envelope", but what is needed is not much more sophisticated than that. More to the point, Fox points out that:

"The area of what now is Bulgaria was home to numerous ancient peoples who struck coinage under the direction of early Greek cities (such as Apollonia Pontika, Mesambria, and Odessus), Thracian tribes (as in the Derroni and Orreski) and kings (Kotys I, Seuthes III, Lysimachus, etc.), various Roman emperors, and later by Byzantine and other medieval rulers. For many new collectors, the first ancient coins in their collections were likely unearthed in Bulgaria, whether they were coins of Lysimachus, Roman provincial issues struck for the city of Marcianopolis, Nicopolis ad Istrum, Serdica, or Philippopolis, or Roman imperial bronzes minted during the time of Constantine or later.

And it is precisely the scale of the looting and smuggling which has led to this proliferation of these coins in foreign markets which is the source of this concern. How many of them were excavated and exported in accordance with the law of the country they were dug up in? Fox admits the aim of the MOU is laudable, but "to hinder important numismatic research afforded by coin collecting is a hard pill to swallow for most". This serious research surely can be carried out on the hundreds of thousands of freshly dugup coins that have already entered the US market (or are they all useless for research purposes, if so, why?) or those that enter it from legitimate, documented sources. What other "serious research" relies on data of illegal origin?