The Next US Coin Collectors' Comedy Turn

It is rather difficult these days to tell whether US ancient coin collectors are jackassing around or are trying to make a serious contribution to the heritage debate. The net result though is more or less the same, their spokesmen end up each time making a laughing stock of the whole community.

The US has at long last signed a cultural property MOU with Bulgaria (its the way they think the 1970 UNESCO Convention should be implemented in this case). There is a designated list of the sort of things US Customs should be on the lookout for published in the federal Register,"Import Restrictions Imposed on Certain Archaeological and Ecclesiastical Ethnological Material From Bulgaria". This is preceded by a text which no coin collector is ever going to read which says "why" stopping illegal exports is so important.  There is then a long list of ancient and antique objects which the US has agreed it is going to be scrutinising as it comes into the US from Bulgaria, so the Archaeological Material includes items of:

• A. Stone
• 1. Sculpture
• B. Metal
• 1. Sculpture
• C. Ceramic
• 1. Sculpture
• 2. Vessels
• D. Bone, Ivory, Horn, and Other Organics
• E. Glass and Faience
• F. Paintings
  

Note it also says:

The bilateral agreement between the United States and Bulgaria includes, but is not limited to, the categories of objects described in the designated list set forth below. These categories of objects are subject to the import restrictions set forth above, in accordance with the above explained applicable law and the regulation amended in this document (19 CFR 12.104(g)(a)).

Where the objects on the list are not "archaeological or ethnological material of the State Party"  then they are not of course subject to import restrictions.

Now, as far as I am aware, its only the collectors of ancient (not world) coins kicking up a fuss about this list. That tells you something from a start. None of the dealers in any other of the 122 categories are at all phased by this list. When they  import this sort of thing into the US, they are prepared to be asked about export documentation. It stands to reason that you need some.  Not so ancient coin dealers...

So it is we learn that "The ACCG has filed Freedom of Information Requests with the State Department and US Customs with regard to the new restrictions on on all Celtic, Greek, Roman,  Bulgarian and Byzantine Imperial, and Ottoman coins made in Bulgaria as recently as 1750"  ("The Ancient Coin Collectors Guild has served Freedom of Information Requests on the State Department and U.S. Customs seeking information about the preparation of  the designated lists for coins").  

When however you try to find out why these clowns are prancing around, the motivations become less clear. On the ACCG website they say

"The ACCG is particularly interested in learning the basis for the State Department’s apparent conclusion that all coins produced in Bulgaria from ancient times to 1750 must be considered local issues that only circulated within the confines of the modern Bulgarian nation state".

This relates to their mistaken interpretation of the function of the Designated List. 

On the Cultural property Observer blog, however, a totally different motivation is cited: 

Did State and U.S. Customs undertake a principled review of the numismatic scholarship about the find spots of Bulgarian coins [...] Or, did they merely seek to justify their efforts to impose the broadest restrictions possible by relying upon information supplied by archaeologists with an ax to grind against collectors who claim that all Bulgarian coins (including those of gold and silver) are "local issues?" 

This really relates (as the link makes clear) the anti-academic and personal prejudices of the dealers running the "collectors' guild". 

I asked their lobbyist (who one assumes is responsible for both texts):

could you provide a reading list of this "numismatic scholarship" you are on the lookout for? Does it include titles in Bulgarian, or is only evidence of use of the scholarship of US coin collectors (private and institutional) on the findspots of coins in their own collections sought? Or on the contrary, is the latter not expected to be used as documenting findspots seem of rather little interest to US collectors and the dealers who supply them?  And what if you find evidence that an archaeologist or two was consulted here? Are not coins archaeological objects (hence their coverage by the CCPIA)?

That comment received the most skimpy of answers. The source of the findspot information the ACCG are expecting the State Department to have used is left unclear. Another question concerns the procedure laid down in Section 305 , which does not stipulate anything at all about the need to consult anything with anyone, so I really fail to see what the point is of this FOI. It seems like another way for the ACCG to make collectors think they are doing "something important for collectors - so give us more of your money". Actually what the ACCG could do important for collectors is help clean up the no-questions-asked antiquities market instead of jackassing around getting on everybody's nerves, getting ancient coin collectors a bad name, and wasting an awful lot of collectors' and public money.  But the ACCG does not give a hoot about any of that, the ACCG is trying to stave off the inevitable by playing a stalling game, isn't it?