Grebkesh and Tompa, the Campaign Against the Cleanup Measures

What hope of a Future is there for those
prevented from trading the paperless
past by the US 'clean-up laws'?

No ancient or antique artefacts from a whole range of countries can be imported into the United States of America, according to the campaign run by the coin dealers' paid mouthpiece Peter Tompa. The USA currently has allegedly "trade-stopping" bilateral and other cultural property agreements with the following countries  Belize, Bolivia, Bulgaria, Cambodia, Canada, China, Colombia, Cyprus, El Salvador, Greece,  Guatemala, Honduras, Iraq, Italy, Mali, Nicaragua and  Peru - See  here for details.

As a result of the draconian cleanup measures adopted by the Obama Regime, five hundred and forty three families of former US 'Mom-and-pop' antiquity and tribal art dealers are now on the bread line, living from charity handouts.

Halton Grebkesh, President of the US Philistines and Smugglers' Relief Club says "my members are desperate, we petition government day after day about this, but nobody listens. It is digusting how easily people believe the lies that to comply with these MOUs is no big deal, I bet these people have never  tried to import cultural goods into the United States, nor have they any contact with anyone who has actually imported artifacts themselves or represented those who do".

Meanwhile, US ports are jammed with antiques and antiquities seized at point of entry by US Customs from hapless people who simply do not realise that the US is now totally boycotting the import of cultural property from a large part of the world. The six giant warehouses that house Italian cultural property seized at the port of entry are like an Aladdin's cave of sculptures, armour, pottery vases and mosaics, all items now (according to Mr Grebkesh and Mr Tompa) forbidden on the US market. The Italian antiques and collectables trade used to be worth USD 4,189,800 (2012 figures), today, as a result of the MOU, it has dwindled to 19 dollars and forty-five cents.

Antiquities dealers are fed up with being silenced by the US Government and have decided to make the world aware of their plight, now totally unable to import a single old artefact into the United States.  They have started up dozens of  blogs, websites and action groups intended to inform the world about the great injustice that has been done to their industry, totally blocking access to antiquities from these source countries. The groundswell of loud protest from all these suffering dealers is threatening to jam the Internet.

Why, Mr Tompa has even dragged out and dusted off some hearsay anecdotal evidence about a few isolated cases which are supposed to bolster his case. Obviously the supporting evidence is in all those other websites saying the same thing and showing that more than 99% of cases of attempted licit import, there have been similar obstacles from persistent Customs officers unrestrained by any existing US law.

Focus on Metal Detecting: Artefact Hunting on Environmental Stewardship Land

.
Despite being Senior Countryside Officer at Sandwell MBC (Walsall, UK), metal detectorist John Stokes apparently does not really understand much about archaeological conservation. So much so that he wrote to English Nature about their environmental conservation schemes, in fact he submitted it as a FOI request.

From: John Stokes, 21 May 2011
Dear Natural England, As a local authority countryside officer and metal detectorist I was slightly puzzled by a clause in the environmental stewardship agreement banning the above. English Nature, as I understand it after 27 years as a senior officer in countryside management, exists to protect and improve habitats. Can you please explain why it is felt necessary to include any reference to metal detecting and archaeology in agreements, as it seems to me that both activities are out of your remit and terms of reference. Yours faithfully, John Stokes, countryside officer.

I find it pretty astounding that somebody who has (it says) a senior post of this nature denies the importance of the conservation of the historic record (the resource artefact hunters are looting) in sustainable landscape and environmental management - which is what English Nature does. How can one conserve one element of the environment without caring for another? Surely environmental conservation is holistic and not exclusive? Perhaps it isn't in Walsall.

No matter, English Nature treated that question with the disdain it deserved.

The Rural Development Programme for England (2007-2013), [...] identifies the protection and enhancement of landscape and the historic environment as one of the 5 key objectives of Environmental Stewardship. The schemes provide incentives to carry out land management to protect and enhance historic environment features, habitats and species, landscape, soil and water resources, and access to the countryside. Natural England [...] along with English Heritage, has an Action Plan to deliver the UK Government’s response to the European Landscape Convention. This places value on the cultural aspects of landscapes, including the historic environment. Natural England consequently has a remit for the historic environment in all its activities.

One would have thought that a "Senior countryside Officer" would have known about the RDP and the European Landscape Convention and the government's response to it. Perhaps not in Walsall.

But then the information supplied 15th June 2011 in reply to the request (Request No 1146; RFI#1146) by one Jez Bretherton, Historic Environment Senior Specialist in English Nature was pretty thought-provoking. Fittingly, the reply was published on the "What do they Know?" website (WhatDoTheyKnow.com). The first part is not - from the Preservationist point of view - particularly controversial:

The holder of an ES Agreement is responsible for protecting and retaining archaeological sites and other environmental features on Scheme land. Compliance with the Entry Level Scheme Handbook (version 3, 2010 cited here) ensures activities such as metal detecting on known archaeological sites in grassland, overwintering of stock on sensitive sites, and others that can cause damage to environmental features are subject to appropriate measures to ensure their impact is not negative. The Handbook states: ‘With the exception of Scheduled Monuments (SMs), Sites of Special Scientific Interest (SSSIs) and known archaeological sites under grassland, metal detecting is allowed on land within an ELS agreement, provided that it is undertaken in accordance with the principles of best practice laid down in the most up-to-date Code of Practice for Responsible Metal Detecting in England and Wales and that you agree that all finds are reported to the Portable Antiquities Scheme.’

One would of course have expected nothing less. This means, if these rules are adhered to, that there should be a clear concentration of reported archaeological finds on Environmental Stewardship (ES) land. Sadly there appears to be no obligation on a landowner receiving ES subsidies to ensure that metal detectorists using this land as a source of collectables are complying with this requirement - for example verifying all finds are reported on the PAS database, or even incorporating in their land access agreement with artefact hunters the requirement to report ALL finds under penalty of revoking permission, still less the placing of such agreements on file with the administrators of ES conservation funds.

Equally uncontroversial (if it means that the event can be stopped or the damage done effectively mitigated) is the requirement:

Natural England must be notified of the details of large scale metal detecting events, including metal detecting rallies, on any ELS agreement land at least 12 weeks before the event.’

Under Higher Level Stewardship the requirement is:

‘Do not carry out or permit metal detecting or archaeological fieldwork on any of the archaeological sites on your holding identified in your FEP, unless agreed with your Natural England adviser in writing.’

The next bit of Historic Environment Senior Specialist Jez Bretherton's text however raises eyebrows. I'll discuss it in the text below.

Vignette: Sandwell's countryside.

Minelab Against Protection of the US Archaeological Resource

.
Minelab, the firm that creates metal detectors allowing artefact hunters to mine the archaeological record for collectables for personal entertainment and profit, has become a supporter of the US lobby group Task Force for Metal Detecting Rights Foundation. The "Task Force is a not-for-profit organization with the singular mission to promote and defend the lawful hobby of recreational metal detecting on public lands and waterways across America". Well, actually as we have seen, it's not so much about following the existing law, still less instilling "best practice" but about getting the law changed to favour the removal of archaeological and historical finds from the ground for personal entertainment and profit. Minelab obviously see some profit to be had here for themselves too.

Minelab has recently raised over $41,000 in funds for the Task Force for Metal Detecting Rights Foundation :

"This funding will continue to help support their efforts to educate and rally detectorists across North America to positively and effectively help protect all the lands and waterways from which we strive to discover history".

"Protect" them, that is from being turned into areas where the buried history is protected from exploitation by artefact hunters. Minelab should be ashamed of themselves. Truly responsible metal detector users would boycott firms which support such groups. (But then don't Minelab, anyway, produce machines with backlit screens, for use on remote sites at night? Who'd buy one of them?)

Vignette: Minelab - "Treasure Through technology"

Coveting Others' Property

.
When they are not maliciously sniping at fellow numismatists who raise the alarm about the damage done by the atavistic attitudes of the no-questions-asked antiquity collector, we have seen the coiney makes all sorts of excuses for what they do. All of this is aiming to deflect attention away from one simple fact, what they want to take is not theirs to take. They proclaim all laws and mores which stand in the way of them getting their hands on what they want as illogical, ill-conceived and in some way not applicable to them and what they want to take. Thus it is we learn the view of US coin collector Jorg ( "put the ethical argument aside") Lueke that the "pot hoards" containing the antiquities he would like to add to his personal hoard of geegaws

are usually not found in places excavated, based on the archaeological reports I have read coins when found are not often what anyone would consider treasure.

So up for grabs. This ignores the fact that more often than not, the cultural property laws of the place where these "pot hoards" and other coins are dug up do indeed "consider them as Treasure", and removing them to private possession is illegal, is theft. Not that such a thing would concern a selfish US collector of course.

Lueke considers that the coins dug out of archaeological sites which he dismissively calls "Roman junkers" are "ultra common" (in the soil of his OWN country, surely not) and thus

one wonders if they can really be considered cultural property at all.

But they are, aren't they? In the law of the source countries they, like any archaeological find, are considered to be cultural property - a view to which the citizens of those countries are perfectly entitled (as embodied in, among other places, Article 1 of the 1970 UNESCO Convention), whether or not the US collector thinks it is "fair" to foreign would-be collectors. The collector assures us that he would "look after" at home such coins as "certainly wouldn't be found in any museum", whether or not the laws of the country they come from allow that or not. It does not concern the self-centred foreign collector that removing such items from the archaeological record to private possession is illegal, is theft. Not that such a thing would concern a US collector of course.

Where do such attitudes of entitlement to the property of others come from? When is theft not theft? I am sure many common thieves can come up with excuses as good as any coiney why they steal. The two do not really seem so far apart do they? Who'd feel comfortable however attempting to be an advocate for tolerating culture theft in a state where criminal court cases can be checked online? After all, somebody could do a search for such people who may (or may not) already be on a Gubn'mint watch-list, and find that it is public record that somebody with that same Christian and surname apparently has a 1994 conviction for theft (Case No. 55-K1-94-001769, it does not say what of, but a guilty plea apparently warranted a sentence of ten months so it was not a packet of fags).

Coincidence, no doubt, a case of mistaken identity perhaps. Nevertheless it seems to me that those individuals who indulge in trying to trash the reputations of fellow (though academically better qualified) coin scholars ought to watch out in which direction they are hurling their mud and rocks, lest they find themselves getting injured by flying glass.

Vignette: Glass houses.

ANS: "Within the World of Artifacts, Coins as a Class do, in fact, Stand Apart"

.
The Chasing Aphrodite blog draws attention to the "American Numismatic Society Statement on Cultural Property Concerns" approved by its board of trustees October 22, 2005. It might be worth looking at it again seven years later in the light of subsequent events. Well, of course what we find is the usual coiney moaning about how ensuring hygiene of collections measures like checking the lawful origins of potential purchases can in the words of the Trustees place "an undue burden on lawful collecting, legitimate numismatic trade, and scholarly research". The ANS therefore urges that in deliberations over the importation of artefacts, full attention should be given to the "exceptional factors that pertain to historical coins" in order to "ensure the continuance of legitimate collecting, the protection of the cultural heritage of countries negatively affected by the ongoing trade in illicit antiquities, and the preservation, analysis and dissemination of knowledge of the past". I suppose that really depends on how the ANS defined "lawful collecting" in 2005 and whether that term can be used in the same way for the same practices seven years on. I think that recent events in the US are beginning to suggest that by the end of this year, the collecting of dugup ancient coins in the US collecting may well be on a different footing than it was in 2005.

It is therefore worth looking again at those "exceptional factors that pertain to historical coins". These of course are the usual tired old coiney mantras:
1) "Historically, coins were produced by the millions and they survive by the hundreds of thousands".
2) "Since the Renaissance coins have been avidly collected and studied by princes, scholars, and historically-minded hobbyists alike".
3) "Collecting and dealing in coins that have been in private hands for many years does not contribute to the destruction of cultural heritage".
4) "Likewise, because most coins in private collections have been traded and held without any provenance, it is unreasonable to assume that a coin is stolen, illegally exported, or illegally imported merely because the holder cannot establish a chain of custody beyond receipt from a reputable source". This litany concludes:

Taken together, such considerations argue that within the world of artifacts, coins as a class do, in fact, stand apart.

Well, do they?
a) "Historically, ancient Greek pottery vessels were produced by the millions and they survive by the hundreds of thousands".
2) "Since the Renaissance, ancient Greek pottery vessels have been avidly collected and studied by princes, scholars, and historically-minded hobbyists alike".
3) "Collecting and dealing in ancient Greek pottery vessels that have been in private hands for many years does not contribute to the destruction of cultural heritage".
4) Likewise, because most ancient Greek pottery vessels in private collections have been traded and held without any provenance, it is unreasonable to assume that an ancient Greek pottery vessel is stolen, illegally exported, or illegally imported merely because the holder cannot establish a chain of custody beyond receipt from a reputable source.

In fact we could certainly say more or less the same about - for example - ancient Egyptian shabti figures, scarabs, faience eyes of Horus, and mummy cases and their fragments, Roman intaglios with and without their rings, glass lachrymatories, ancient Near Eastern seals, whole archives of cuneiform tablets, erotic samian (both whole vessels and their fragments), knocked off heads of various statues such as Tanagra figurines etc etc. I really do not accept the four arguments above as in any way differentiating coins from other artefact types.

The fourth deserves some attention and poses a question. It is wholly unclear in the context of US law (remember this is the American Numismatic Association) why, and in what context, an assumption is made that an ancient Greek pottery vessel (or coin) "is stolen, illegally exported, or illegally imported merely because the holder cannot establish a chain of custody beyond receipt from a reputable source". In US law, the main problem collectors have (the document addresses "cultural property deliberations over the importation of artifacts") is with the flow of fresh material onto the already massive US market from abroad (ancient coins are as a rule not dug up on North American soil). So this poses the question: what "chain of custody" is required for the passage of an item across US borders? Neither the CCPIA nor the various other pieces of unrelated legislation relating to lawful importation of goods into the USA require proving a chain of custody. They do however require documentation of a entirely different nature - documentation on which the "American Numismatic Society Statement on Cultural Property Concerns" for some reason maintains a complete silence - doesn't it?

The ANS has its own policy on the "Acquisition and Disposal of Numismatic and Library Material". There is nothing terribly remarkable in it, they of course assure us all that they support "the spirit and intent" of the 1970 UNESCO Convention (all of it?) and thus:

The Society will not purchase or exhibit numismatic objects or other items that the Society reasonably suspects to have been unlawfully removed from archeological sites, stolen from public or private collections, removed from their country of origin in contravention of that country's laws declaring them state property or otherwise imported in contravention of the laws of the United States.

These are fine words, but are they any more than that? What is "reasonable suspicion" if the absence of even a single piece of information on where an object came from (and by what chain of custody it left the ground, left the source country and came into the US) is not considered (above) in any way a hindrance to its acquisition on such grounds? Would an object have to have "I am stolen" written right across it before the ANS buyer's reasonable suspicion is aroused? Or is it enough to have enough soil and grot adhering to it that it is clear its not from an old collector's mahogany cabinet?

Since the ANS suggestion that lack of any kind of collecting history is not a hindrance to responsible acquisition (really?) is less than helpful, perhaps they would be so kind as to get the Trustees together in 2012 and actually provide a proper ANS definition of "reasonable suspicion" that an object could have been:
a) unlawfully removed from archeological sites (closer definition?),
b) stolen from public or private collections,
c) removed from their country of origin in contravention of that country's laws [actually export laws as per 1970 UNESCO Convention which the ANS "supports", as well as]
d) removed from their country of origin in contravention of that country's laws
declaring them state property
e) or otherwise imported in contravention of the laws of the United States.
It seems to me that creating such definitions is pretty near impossible while holding to the view that the purchaser does not need to know from the "holder" anything which would allow the establishment of "a chain of custody beyond receipt from a reputable source". But I could be wrong, it would be interesting to see what the ANS Board of Trustees could come up with if they put their coiney minds to it.

While they are at it, perhaps the ANS trustees could create a definition of what constitutes a "reputable source". Is it one that sells reasonably priced coins and dispatches them as soon as he gets the customer's money? Is it one who has never been caught selling fakes? Is it one who not only merely assures everyone of the legitimate sources of his material but can demonstrate that with documentation, or one who merely covers his tracks so well "they can't touch you for it"?

I think that if the ANS really want to show that within the world of dugup antiquities, coins as a class and those who trade in them and collect them, "do in fact, stand apart" will have a try a good deal harder now than in 2005. Are they up to the task? Or will they let matters slide and just stay with their original outdated wishy-washiness?

"It's Your own Fault": Chasing Aphrodite on the Significance of the Weiss Investigation for Militant US Coineyism

.
The "Chasing Aphrodite" blog has some details of the allegations against Arnold-Peter C. Weiss in relation to transactions involving two Greek coins from Sicily. After noting that the investigation was in its early stages, the blog authors surmise that "given Weiss’ prominence in the numismatic community" (the former treasurer of the American Numismatic Society, chairman of the board at Rhode Island School of Design’s art museum and on the collecting committee of the Harvard Arts Museums), the case:

bears some early similarities to the criminal case against Fred Schultz, the head of the national antiquities dealers association, who was convicted in 2002 of knowingly trafficking in looted antiquities from Egypt. The Schultz case proved a watershed in the art world, underscoring the fact that trafficking in looted antiquities was a violation of American law.

The blog's authors also note the "on-going battles over whether coins should be included in bilateral agreements between the US and foreign nations aimed at preventing the traffic in looted antiquities" and suggest that if brought to court, this case could potentially have a profound effect on the US discussions on this topic. As they note:

Numismatists have long argued that coins should be exempted from import restrictions. As the American Numismatic Society states on its website, “…Because most coins in private collections have been traded and held without any provenance, it is unreasonable to assume that a coin is stolen, illegally exported, or illegally imported merely because the holder cannot establish a chain of custody beyond receipt from a reputable source.” That position may be more difficult to maintain in the face of a criminal case against Weiss, who was treasurer of the ANS from 2005 – 2009.

There is as yet no mention of this series of events in the "News" section of the Ancient Coin Collectors' Guild website, which is a bit odd, isn't it? Certainly, given the intransigence of the ancient coin collecting (scil. dealing) community led by lobbyists employed by the PNG, IAPN and ACCG to attempts to clean up the US numismatic and antiquities market, and their blatant and damaging opposition to US policies on the matter (including an attempt to sue their own government), a high profile arrest or two were on the cards. I guess collectors will be left waiting to know whether there will be any more, and who is next. Who could be on the watch list?

There is an interesting coincidence in the timing of this event. As all coineys will know, midnight of January 3rd was the deadline on the Regulations.gov website for the final public comments to existing laws on import controls on unlawfully exported artefacts from Cyprus (including coins like those many of the people expressing their objections themselves collect). I suppose conspiracy theorists might wonder whether there was a connection between this and the rather late intervention of Federal law enforcement authorities in this matter - also on 3rd January (but at two in the afternoon, rather late for the news to reach all those planning to voice their support for the import of unlawfully exported coins on the last day). Could there have been an ulterior motive for the delaying of the intervention? That might give some coiney conspiracy theorists pause for thought, I guess.

"The most amoral and dangerous individuals in the world"

.
"the most amoral and dangerous individuals in the world" is how a Californian dugup dealer characterises those who wish to impose restrictions on the import into the USA of archaeological and ethnographical artefacts without documentation of lawful export. In other words take away "from the longstanding and traditional rights of US collectors -- without any compensation whatsoever". Long-standing RIGHTS to import illicitly exported artefacts? Surely any such illusions ended when the USA became a state party to the 1970 UNESCO Convention back in 1983? What are these dealers thinking?

Peter Tompa continues his incessant moaning about how hard-done-by are US collectors (already in possession of a huge chunk of the above-ground resources of portable antiquities from all over the ancient world - but still want "more and more"). He attempts to assign "winners and losers" to the Greek Import Restrictions (restrictions, let us remind ourselves on illicitly exported items).

"Winners" according to Tompa are:
The Greek Cultural Bureaucracy ("poorly managed" and "corrupt")
The Greek Government ("poorly managed" and "corrupt")
"The Obdurate State Department Cultural Bureaucracy" ("obdurate", "entrenched")
"The AIA and its Archaeological Fanatics" ("anti-collecting", "fanatics")
"Wealthy Greek Collectors".

One wonders just how long the buffoonery of pretending that the archaeologists (institutional or otherwise) are all "fanatics" (was "radicals") who are to a man rabidly "anti-collecting" can persist. The evidence is very clear that the AIA is not against collecting per se, but - in line with US legislation since the early 1980s - against collecting of ILLICITLY exported cultural artefacts. No more, no less - and it is all in black and white for any dealer, lawyer or collector with more brain cells than my cat to check. Of course such nonsense suits well the yapping dogs that try to frighten, huddle and herd as many ovicaprid collectors onto the barren thistle patches of indignant opposition as possible, but it is not the truth. But then what evidence has there been from the ongoing dialogue of the deaf that dealers' lobbyists or collectors are even a bit concerned about the truth?

According to Tompa:

These fanatics hold that the only legitimate exchange of archaeological artifacts is a museum loan.

Well, since the law stipulates documentation of licit importation, it would be more truthful (see above) to say that they hold that the only legitimate exchange of archaeological artefacts is with documentation of licit export.

As for those "Wealthy Greek Collectors" (where the adjective wealthy magically become pejorative...). Surely there is a huge faultline running through the ACCG logic here. The whole point the collectors opposed to import controls are making is that the vast majority of the artefacts affected are too cheap (on the US market) for it to be at all "economical" to get documentation of licit origins and transfer. So they are not the kind of things one has to be inordinately "wealthy" to buy.

How shocking to the American psyche that:

Greek collectors will gain a competitive advantage over their American counterparts who can no longer import undocumented cultural goods.

They will stay in Greece, rather the best items being constantly and illegally siphoned off to a voracious and well-financed foreign market. How curious though that an American collector (and Peter Tompa, who is if I am not mistaken of Hungarian Jewish stock, collects dugup ancient Greek coins) feels he has MORE right to Greek cultural property than the citizens of that country (even if these items are illicitly exported?) and considers it a matter of regret that fellow collectors (though of a different nationality) will be able more easily to collect items which reflect their own cultural heritage.

For Tompa, the "losers" are:
"Greece's Cultural Patrimony" [too much stuff to look after as it is],
"The CPIA and the Process Congress Contemplated" back in 1983 (sic)
"The Small Businesses of the Antiquities and Numismatic trade" [who are now going to have to document licit export to allow legal import into the US: "This is particularly a problem for the small businesses of the numismatic trade". This is because the objects available for import are typically lacking such documentation]
"US Collectors" [who will be forced to buy material which has been licitly exported, rather than the other type that was on the market formerly].
"US Museums" who will not be able to carry on purchasing items without any kind of documentation of licit export [not, I think that they are likely to be wanting to in the coming years anyway].
"US Customs" [because they are going to have to do something connected with the fact that in 1983 the USA became a state party to the 1970 UNESCO Convention, too bad, but the idyll of US hypocrisy in this regard could not go on for ever]

What is not explained is the manner in which having mainly material which has passed scrutiny with regard to licit export on the US market as a matter of course is allegedly a "bad" thing for collectors, museums, and responsible (responsible) dealers. What is clear that the persons who have lost (not mentioned for some reason by Tompa) are the smugglers (possibly related in some way to organized criminal groups) and looters, who will have their US markets fundamentally curtailed by these measures if they are applied effectively by all involved. These people are on the losing side and among those who actively regret that we'd expect to find a number who are "amoral and dangerous". What nasty company the no-questions-asked antiquity dealers keep.

The First Coiney Contributions to the Debate

.
The first forty or so contributions have appeared on 19th October in the public consultation of the CPAC deliberations on Bulgaria's request for a bilateral cultural property agreement in response to the smuggling of looted artefacts on a massive scale. So far ALL of them have been from coin collectors and dealers, and ALL of them have been AGAINST THE Bulgarian MOU. I'd like to briefly discuss the trends they demonstrate, and consider these comments in two groups. The public were specifically and exclusively requested to share their reflections on issues raised in Section 303 (a).1 of the CCPIA and so I propose dividing the comments into two groups, those that do, and those that do not. The latter is the larger group so I'll begin with them.

Missing the 303 mark:
Norris Haden, MD ("common artifacts, often inexpensive, that have circulated in the coin market for many, many years")
John Robert Aitken ("millions and millions")
Brian Rowe a dealer from Canada (misunderstands what the purpose of the 1970 UNESCO Convention - sarcasm)
Wayne Melville (Texas) ("I have been privileged to have obtained many [coins] from suppliers in Bulgaria" - since the US became a state party of the 1970 Convention, has he the paperwork to show legal export? He does not say).
Spero Kinnas (coins circulated in the past, so why not now argument)
Robert Leonard (coins circulated in the past, so why not now argument),
Doug Hill (writes like an eleven year old, millions and millions)
Richard Bender (fails to understand the Convention, "Numismatism is an ancient, popular and harmless hobby")
Gary Niditch MD ("These are not rare art forms but dirt cheap common objects by and large")
Frank Robinson (Collecting [...]does no harm to archaeology, as the numbers of ancient coins discovered has been incredibly VAST. There is plenty for both archaeologists and coin collectors. ")
Eric Feder (a virulent anti-archaeological rant you can read for yourselves... totally missing the point being debated of course)
Traughber, P. (better argued than most, but misses the point)
Jack Brigham (in praise of coin collecting, misses the point)
Frederick Thies (brief, no reasons given, misses the point)
Bard Geoffrey ("coins [...] cannot be considered in the same light as unique archaelogical artifacts. In lower grades they typically trade for just over their melt value.")
Lawrence Hageman, somewhat inarticulate: "this restriction, if imposed on coinage, would make it impossible to legally import any coinage for collector purposes" - eh? The restriction would be to coins which HAD been legally exported, their import is wholly legal under both the conditions of the 1970 Convention and will be under the proposed regulation of the matter. What would not be legal is the ("minority", I am sure the trade would say) of coins arriving on American borders having been illegally exported.
Eric Karell, a coiney 'I know better than you' approach: ("This is the kind of regulation that sounds reasonable at face value but has aspects that only some people would appreciate" - but it is the writer himself who misses the point)
W.P. Lyon, does not seem to grasp what is involved at all: "I hereby state that I am completely against Bulgaria restricting any coins for import or export").
J. Conroy is "outraged that you have restricted some Roman coins from being imported from Italy". The CPAC is "destroy[ing] the hobby of coin collecting in the United States for the majority of ordinary collectors" and urges a reversal of the Italy MOU decision. Misses the point.
Bill Leubrie reckons himself a "scholar" ("This is ridiculous. No one needs to restrict the flow of ancient coins. They exist in their millions [...] Collectors of ancient coins are not criminals, but entirely a harmless, scholarly lot". He appears to think, but not be able to express properly, that the gubn'mint should "stay out of our hobby"). If coin collectors are not criminals, why do they support the opposition to this proposal to restrict US imports ONLY to legally exported coins? On whose side are they on, the responsible dealers who observe the applicable laws or those that deal with the antiquity SMUGGLERS? What is "harmless" in that? Misses the point.
Roy Iwata, ancient circulation, misses the point.
William Leitold,a longish, intelligently presented argument, worth reading for an insight into a mindset using the typical coiney pseudo justifications - see attachment for fuller text ("I hope that the US Government I voted for will not participate in this abuse of our rights"). Sadly it misses the section 303 point.
Wayne Hansen, ("Ancient coin collecting [...] is an important commercial enterprise. US access to coins is important to collectors worldwide").
Daniel Demeo, ("Not another mou with another country! [...] making it illegal to import ancient coins and artifacts from that area [...] We WILL REMEMBER in Novembers which administrations and which parties destroyed our enjoyment"). Forgetting of course that he is addressing his comments to the CPAC not the Democratic party. His point is keeping records of licit provenance is adding a responsibility and taking away the "pleasure" of collecting.
Steven Snyderman, "millions and millions", ancient circulation, "untenable", looks like cut and paste from Tompa.
Robert M. Harlick, believes there was an MOU with Turkey, "millions and millions", "ancient circulation", bloodline, "do they need all those coins"? Misses the point of the Convention, does not address section 303.
Daniel Owsen, pleads that coins not be included among the "protected" artefacts.
Constantinos Eliades, "This is to the State Department and CPAC". No it is not, it's to the CPAC. " because of the low price the vast majority of these coins will never have been through an auction and will have no verifiable provenance" - cut and paste from Tompa. Misses the point.
Robert Tromp, Conspiracy afoot: "Please look into the real issues involved, and you will find that there is a lot more right on the side of the collector than on the part of corrupt, cynical Balkan governments". Although this one too misses the point, it raises some questions I'd like to discuss tomorrow.
Jeffery Spier a "working numismatist" Fellow, American Numismatic Society (thanks to David Gill for reminding me this is a name connected with the Elmali hoard purchase). "Millions and millions", "ancient circulation", "Restrictions on collecting will certainly impoverish the long tradition of numismatic scholarship". Misses the point.
Col Dupont, C L Dupont Ancient Coin Jewelry, admonishes the Presidential advisory committee: "Come on; don't go there! It's just silly...".
Anthony Kurland, ("because of their low price the vast majority of these coins will never have been through an auction and will have no verifiable provenance" looks like cut and paste from Tompa). Misses the point.
Robert Crutchley, it is difficult to see what this guy thinks he is talking about ("The vast majority of coins found in grave robbing are of base metal and are not what the thieves are looking for because they have little value"), but it is certainly not section 303 of the CCPIA or what the CPAC is asked to give opinion upon.
Gregory Fairbanks, a mishmash of reasons not to observe the provisions (art. 3) of the 1970 UNESCO convention ("millions and millions", "ancient circulation" and they are not anyway "a part of a cultural heritage" - the latter failing to articulate with the reasons collectors give for collecting them)
Steve Benner, author, reckons restricting imports of illegally exported coins will harm numismatic scholarship.

That closes the contributions visible on the website at the close of the working day in the US on 19th October. Let us look at the comments which actually address section 303 of the CCPIA which is what the CPAC asked the public submissions to address. Unsurprisinly there are very few, as coineys apparently cannot themselves read the notices put out on behalf of the CPAC and the coin dealers'; lobbyists failed to inform them of what issues are open to public discussion. US Coineys allow themselves to be led by the nose at every turn, and a large proportion of them seem unable to enquire or think for themselves. the result is that just two even mention something which may vaguely relate to Section 303 of the CCPIA:

Brian Rowe a dealer from Canada- so outside the pernicious influence of the ACCG, says that Bulgaria and Belize should "police their borders" better.

Gregory Fairbanks might be trying to address section 303 issues writing: "Furthermore, the track record of countries protecting their so called cultural heritage is quite poor", but does not enlarge on the means it could institute to achieve the same aims as import restrictions on smuggled goods.

So basically the first thirty or so "informed contributions" to the public debate by US and Canadian coin collectors suggest so far a complete misunderstanding in those circles of what the 1970 UNESCO Convention is about. The reference to the "millions and millions" of these coins on the market betrays a lack of awareness (or concern) that this means millions and millions of HOLES in the archaeological record created so they can have their collectable geegaws to flash about (Wayne Melville). It is precisely the "minor antiquities" that are being recovered on an industrial scale that are the symptoms of the greatest damage being done to archaeological sites in Bulgaria. Furthermore the majority of these collectors write as though they are talking of a wholesale "ban on imports" rather than restrictions on coins not accompanied by paperwork verifying export from Bulgaria in accordance with the relevant laws. This not-so-subtle difference seems to be lost on the majority of collectors taking part in this campaign.

The arguments being trotted out are the same weak ones used against the other MOUs involving coins (Cyprus, China, Italy and probably Greece). Nothing new here.

Neither has anyone actually directly addressed section 303 as asked, so the first thirty six "informed" contributions to the debate on section 303 deserve to be binned. This proportion should be noted by all those that accuse the CPAC of ignoring public comments. They may or may not be ignoring them, but - as in the case of any public consultation on any issue - they will be entirely justified in doing so when the comments do not address the issue which the Committee specifically opens to public discussion.

Now, I know coineys read this blog. Why do you not go back to Mr Tompa and ask him why he is telling all of you this crap about "provenance", but failing to tell you what (Section 303) the CPAC have SPECIFICALLY asked for comment upon? Why not? Are the ACCG achieving anything useful for the hobby by NOT telling you this, when it is quite clear that the vast majority of US coin collectors have not the foggiest idea even of what the 1970 UNESCO Convention is about, or what the CCPIA actually says (even though both are a mouse-click away)? Why are you collectively following these pied pipers who are obviously and openly - and it now is very clear deliberately - misleading you about what is actually the subject of discussion? Can you be surprised that anyone observing this, and observing the scale of the resulting phenomenon, can only arrive at a certain conclusion about the intellectual abilities of virtually the entire dugup coin collecting milieu in the US? Why should any nominated member of a presidential advisory committee pay the slightest attention to flat-earthers who have not even bothered to find out what it is they are commenting upon?

CCPIA Section 303(a) (1)

.
Experience has shown that US coineys have an extraordinary capacity to misunderstand even written texts in their own language when they contain the regulations which govern their hobby. Nowhere is this more apparent than when something comes up before the CPAC for discussion. I am sure there will be lots to comment on when they start spamming the State depertment with their objections over the proposed Bulgaria MOU, so to make things easier, this is the chunk of text which sets out the ONLY topics the CPAC want to hear from members of the public (and that includes collectors and dealers) on.

SECTION 2602. AGREEMENTS TO IMPLEMENT ARTICLE 9 OF THE CONVENTION
(a) Agreement authority

(1) In general
If the President determines, after request is made to the United States under article 9 of the Convention by any State Party--

(A) that the cultural patrimony of the State Party is in jeopardy from the pillage of archaeological or ethnological materials of the State Party;
(B) that the State Party has taken measures consistent with the Convention to protect its cultural patrimony;
(C) that--

(i) the application of the import restrictions set forth in section 2606 of this title with respect to archaeological or ethnological material of the State Party, if applied in concert with similar restrictions implemented, or to be implemented within a reasonable period of time, by those nations (whether or not State Parties) individually having a significant import trade in such material, would be of substantial benefit in deterring a serious situation of pillage, and
(ii) remedies less drastic than the application of the restrictions set forth in such section are not available; and

(D) that the application of the import restrictions set forth in section 2606 of this title in the particular circumstances is consistent with the general interest of the international community in the interchange of cultural property among nations for scientific, cultural, and educational purposes;

the President may, subject to the provisions of this chapter, take the actions described in paragraph (2).

Now of course the coiney lobby have all sorts of weasel-wordy objections to any restrictions whatsoever being placed on THEM on the basis of their own particular interpretation of this wording. I have discussed these narrow interpretations here more times than I care to remember. I have no doubt they will all be trotted out, by the weak-willed and weak-minded unable to come up with anything else, in the next month or so.

Let it be noted that the "drastic" measures proposed is that dealers and collectors only import into the USA material from Bulgaria which can be documented as having left the country in accordance with the measures set out in the CPIA (the option of two different kinds of pieces of paper). Importing cars, potatoes, poultry products, live tarantulas and a lot of other things into the USA (and other countries) needs certain paperwork to be filled in. The restrictions on the antiquities trade under the proposed MOU are no more "drastic" than what other traders have been doing without a grumble for some decades.

Vignette, Sofia church of Alexander Nevski.

Feeble-Minded Ramblings on "Cultural Justice"

.

Not everybody professing to be "interested in preserving the past" is happy about the Italians offering the benefit of their experience in museum design and management of the cultural resource to the Iraqis. Veteran antiquity dealer and moaner Wayne Sayles uses the announcement to ask "Where is Cultural Justice?". He chides that - in his opinion - the Italians are "unable to do the most basic forms of preservation in their own country — where it seems that everything is disintegrating". This seems an unjust criticism from somebody in a country where the Washington Monument in the centre of the capital is now closed because - like Pompeii - it has cracks in the walls. I think every country in the world (including my own) has problems finding the resources (financial and human) enough to conserve and protect everything that needs conserving and protecting - which applies equally to archaeological remains. To say that Italy, one of the world leaders in cultural property conservation is "unable" to conduct "basic conservation" is simply an unjust insult and expression of ignorance.

Conveniently forgetting that the agreement was for the Islamic gallery as well as the Assyrian one, Sayles postulates:

These efforts are reported as Italian assistance to Iraq's national heritage, ironically the present national government in Iraq has no cultural connection whatever with the Assyrian artifacts that are being preserved. Any heritage from that ancient civilization is diffused in the bloodlines of millions of people who inhabit virtually every corner of the earth today. If anything, the Assyrian heritage is global today, just as most cultural heritage is.

As indeed is the Islamic culture in the other gallery, an equal underpinning of the European renaissance as the 'Classical' civilization Sayles and his coiney mates adulate. "Bloodlines" Mr Sayles? One wonders what "Ahnenerbe" this writer understands by the notion "cultural connections". Have I as a fair-haired blue-eyed Brit no "cultural connections" with the Roman remains of my country or the legends of king Arthur because my "bloodline" (as the White supremacists of sites like "Stormfront" would have it) is most likely Teutonic? Am I from the wrong "bloodline" to feel Stonehenge is part of the landscape of the common past of my nation/people? What kind of talk is that? Where's "power of place", "heimat", "local homelands", "places of memory" in any of this antiquitist-fetish nonsense of the collectors?

Iraq has a duty to protect and exploit wisely the archaeological heritage that is buried or curated in and on its territory. Just the same as Mr Sayles' has towards the archaeological remains of the communities of Red Men (and women) that inhabited the land long before the White Man came and tried to exterminate them all. And the place for that is NOT natural history museums along with the stuffed birds, geological curiosities, pinned butterflies and shells. Its part of the world heritage, yes, but also part of the heritage of the land on which the modern state exists. One to be cherished and sustainably managed for common benefit and not squandered for extempore reasons or individual profit. That includes antiquity dealers like Mr Sayles.

Sayles reckons:

The UNESCO construct that led to its 1970 convention and resolution was already antiquated when it was adopted and becomes more and more irrational with each passing day and with each new birth in a world where cultures are homogenized. Yet, emerging governments try desperately to attach themselves, like parasites, to a distant and more stable past. This "nationalist" view is, of course, a feeble attempt to solidify their manifest destiny to rule and history is replete with failed examples.

Wow. the guy actually seems to think that "cultural homogenization' is a good thing. I suppose if you live in a country that presents itself as a cultural "melting pot", stubbornly ignoring the deep (and perhaps deepening) divisions which persist beneath the veneer within that society on racial and ethnic grounds (including between the native population and the immigrants with outside roots). Frankly from a European perspective the prospect is appalling. What creates a culture and national identity is the individual aspects of the past of the territory on which the state now exists as part of the cultural mosaic which is the heritage of humanity. That may be difficult for somebody to comprehend if they come from a society which sees its past as going back to some piece of paper signed by some rebellious gents in funny wigs in July 1776 defining it as not-a-colony.

The enshrined Holy Relic of a New Nation

It is against that background that I find laughable the phrasing about "emerging governments" who "try desperately to attach themselves, like parasites, to a distant and more stable past". Is that not precisely what US collectors of antiquities taken from the soil of the old world are trying to do? Is the attempt to claim the cultural heritage of foreign soil as their "own" by collectors of dugup Classical antiquities nothing more than a "feeble attempt to solidify" their identity as separate from the ancient heritage of the land which they now inhabit?

I'd be interested to know how many collectors of Greek, Roman and other ancient coins, Egyptian scarabs, Mesopotamian seals, chinese arrowheads and all the other stuff of the eBay antiquities market in the United States also collect arrowheads picked up on private land in the fields and creeks of the US itself?

Coming back to the theme of "cultural justice", it would seem from what he writes Missouri antiquities dealer Sayles thinks that it would be if the Italians would refrain from helping other nations look after antiquities in their museums or manage the archaeological resource better. It seems his idea of "cultural justice' would be to allow the stuff to come onto the open market where US collectors can claim the antiquities that take their fancy as bits of "their heritage" to be bought and sold no-questions-asked like potatoes.

The United States government will do everything within its power to make sure that the nationalist interests of both these countries are protected. The rights and interests of our own citizens are irrelevant. We will impose controls on the transfer of anything that might be imagined as "cultural property" under the ridiculous guidelines of UNESCO 1970 and we will disenfranchise natural descendants of a vanished cultural group just because they happen to live in the USA. This, we do in favor of the political ambitions and aspirations of an unrelated nationalist successor state. Where is the cultural justice in that?

Where is the cultural injustice in asking US dealers and collectors to respect the existence of laws governing the manner in which material like this circulates on the international market? Who is doing whom the injustice in the no-questions-asked, could-not-care-less global market in which US dealers and collectors all too willingly participate?

Dealer's View on What the PAS is For

.
Dugup ancient coin dealer Joe Blazick now complains on a coiney discussion list about a certain heritage blogger:

He is a disruptive force that causes nothing but trouble. I have been the target of this a few years ago when he attacked me on his blog and then had the nerve to have the head of PAS email over my legitimate purchase of less than 100 uncleaned English dugups.

Wow, what a nerve eh?

What I wrote about was a case where somebody was boasting in a commercial offer that they'd got a batch of dugups from an English detectorist which had not been through the PAS system, hardly an "attack" (have a look at the other references to subsequent events on this blog). The problem was the obvious (and symptomatic) feeling of entitlement this dealer exhibited in a documented case of handling objects that were obtained for sale "outside the system". What is the CAUSE of the trouble? Somebody hoping to get away with some dodgy dealing practice involving archaeological artefacts or somebody drawing attention to it in an effort to show this kind of thing needs to stop?

I think this is the real source of the problem coineys have with what I write elsewhere, that they are on the side of the dodgy dealer practices which they presumabbly see as the only way that new coins will come onto the market they are so interested in patronising. It is symptomatic that not a single Unidroit-er came back with a reflective "but Joe...".

Here's a question. The answer might be revealing:

What do US collectors think the actual function of the PAS is? To facilitate collecting, or to regulate the manner in which artefacts enter collections?

What do the PAS tell US collectors their function is?
neither is it at all a "nerve" to expect the head of that organization to actually do what he and his organization are there, being paid (a lot of public money), to do.

It is not "disruptive" to point out that in the case of coins from the UK, this is not what should be happening when we have a PAS in position thirteen years which has cost the taxpayer thirteen million pounds to PREVENT this from happening and all dugup coin collectors and dealers say that it's wonderful. Obviously only as long as it stays out of THEIR business.

It's Another Conspiracy.

.
The news that a long-overdue ICOM Red List on Egyptian antiquities at risk was in production was met over in US collecting circles with another "Washington Conspiracy" theory ('State Department Commissions Egyptian "Red List:" More Evidence of A Done Deal?'). I bet that comes to a huge surprise to everybody. Apparently the US government is suspected by certain parties of being: "busily at work stage managing a shadow process for imposing import restrictions on cultural goods". The American CPRI "has already made a FOIA request related to whether there is any done deal on and MOU with Egypt "However, to date that FOIA request has not been acted upon by the State Department". They must be getting heartily fed-up with dugup coin collectors and their Anti-American activities. Anyway, says one of them, "can't Egypt come up with their own list"? I expect it can, but making Red Lists is what ICOM does and making a petulant fuss is what coin dealers and their supporters do.

Vignette: One for the DoS office wall, larger resolution available.

What is the matter with these people? (1) - the Coiney

.
Browsing Meg Lambert's blog I found this comment from somebody who signed themselves "Anonymous":

You might note that importing and collecting unprovenanced coins is not only tolerated, but encouraged in both Cyprus and China (as well as Italy and Greece). The only difference in Cyprus and Greece at least is that you need to be a registered collector to do so-- and who is registered? The connected few of course. If collecting provenanced material is such a great idea, why don't these countries require of their own citizens what they ask State to impose on US collectors?

What is the matter with these people? Where do they leave their brains when they start to write about coin collecting? This is what I answered:

"Anonymous" is afraid to put his or her real name under the post, and quite rightly so. "Anonymous" knows he or she is NOT telling the truth when he saying that "Cyprus, China, Italy and Greece" require the US to stop "collecting unprovenanced coins".

First of all the MOUs in question [for we are talking about the Convention of Cultural property Implementation (sic) Act] only regulate IMPORT, not internal circulation and consumption.

Secondly, the decisive factor is (of course as anybody fule wot can read would know) NOT whether a coin is "provenanced" but whether it is legally EXPORTED. In the same way as the UK has the PAS to record provenance, and an export licensing system to govern (duh) export. They are of course completely separate things to any straight-thinking person.

So I really do not know whether "Anonymous" is doing this deliberately or simply does not know what he or she is talking about, but the fact they did not want to use their real name here suggests that he or she is aware of one or the other. I bet they collect dug-up coins, yes?

The four countries mentioned are all states party to the 1970 UNESCO Convention, so do not in any way "encourage import" of illegally exported coins or any other antiquities. Article 3 of the convention defines such items as "illicit". The United States is one of the few countries which is a state party (one among 120) which does not honour this part of the Convention in its "implementing" legislation. Perhaps it is time it did.

I really do wonder what their problem is. The CCPIA is not an easy text to read as a piece of prose, but its not actually all that difficult, and there is not in fact all that much content to it (it is also a piece of junk as legislation). But time and time again we find that instead of reading it carefully for themselves they are relying on somebody to tell them what it says, and the "somebody" who does that are the dealers who apparently have a vested interest in believing it says and means something different from what it actually does say and mean. Even though the collectors eventually find out they were lied to (again) by the dealers, they believe the next lie, and the next one. Why? What is behind this extraordinary phenomenon?

"All Ancient Coins can be seized by US Customs from outside USA - Now!"

.
"All Ancient Coins can be seized by US Customs from outside USA - Now" proclaims "Bixbite: Ancient Coin House on Amazon" on a numismatic forum near you.

What he's done is reposted Patrick G. Lee's text from the Wall Street Journal as his own, apparently without really understanding what the CCPIA actually says (after all he's just a coiney - bulk seller by the looks of it). But he's not the only one getting hysterical. It seems artefact collecting is full of them. "The Government Uses Any Excuse To Seize Your Treasure! " write watery-stuff blog Mermanaut.

Fortunately other bloggers, by far the majority were much less drama-queen about the case and had far more sensible titles showing a better ability to comprehend what is going on outside the cocoon of collectors' and dealers' hysteria: Court Rules U.S. Customs Rightfully Seized Ancient Coins.

Vignette: ACCG's representation of the coins affected, inadvertently indicating the damage coin zappers do to what they get their hands on.

Daily Mail Archaeology: the "Archaeological Crank" and the Rhinocerus

.
In his discussion of tabloid newspaper archaeology, Washington anti-archaeological preservation campaigner Tompa suggests that

"Archaeological cranks complain that the UK does not give them exclusive rights over the past".

One really wonders whether he misrepresents the issues being discussed accidentally (through simply not understanding) or whether he does it deliberately. I suppose which answer you choose hinges on whether you think the guy stupid or not.

Conserving rhinos, including preventing those who feel it would be nice to have their own pet rhino in their back yard to "look after and preserve" from illegally snatching them, is not a case of ecologists wanting to secure "exclusive rights to rhinos" but a matter of people wanting to preserve more than just isolated animals but rather communities of them in a habitat. What stands in the way of that, like archaeological sites, is the commercial value some unscrupulous people pay on the extraction of certain dismembered parts from that habitat. The no-questions-asked buyers of rhino horns and no-questions-asked buyers of freshly dugup coins have much in common and a shared responsibility for the destruction of something precious.

It cannot be stressed enough that coins end up on an illicit market only because collectors and dealers agree to buy them from criminals and trade in illicitly-obtained coins. No other reason.

ACCG Lawyer's "Double Standards"

.
Apparently coineys go wild for this lumpy piece of metal. It probably has less to do with how much it "tells" us about Athens in the fifth century BC than its rarity. "It's estimated that there are only about 30 authentic specimens known, nearly half of which are under wraps with the Turkish government and off the market" (Reid Goldsborough). As an auction catalogue explains:

"approximately 40 known today, with 18 in museum collections, 19 in private collections, and 3 whose locations are currently unknown. They rarely occur at public auction, with only seven coins appearing in the past 19 years: The Hunt Collection (Sotheby's, 19 June 1990), lot 66; Leu 77 (11 May 2000), lot 206; Goldberg (7 June 2000), lot 3125 = Numismatica Ars Classica 29 (11 May 2005), lot 183; Triton X (9 January 2007), lot 230; Gemini III (9 January 2007), lot 133; Barry Feirstein Collection (Numismatica Ars Classica 39, 16 May 2007), lot 41; and Baldwin’s 50 (24 April 2007), lot 21".

Here you can fondle one virtually, courtesy of the Athens Numismatic Museum. Whoopee, eh? This coin is the one sourgrapes Tompa moans about. Here he is getting up steam, and gathering speed, and here he is in full rant:

Double Standards: Unprovenanced Athenian Decadrachms in Greek National Coin Collection and Alpha Bank Collection [...] "why should the US Government preclude American citizens from importing unprovenanced Greek coins when both the Greek National Coin Collection and the private Alpha Bank collection recently accessioned valuable Athenian Decadrachms that also lack a provenance? [note the sly juxtaposition of two quite separate concepts there - PMB] Has anyone in the State Department Bureau of Educational and Cultural Affairs told Hillary Clinton that imposing import restrictions will place burdens on Americans that the Greeks themselves won't put on their own citizens and institutions? And it's not as if these coins likely came from Greek contexts. In fact, the scholarly literature puts the typical find spots of such coins further East in places like Turkey and Syria. Thus, the Greeks have little basis to claim they were merely buying back what had been "stolen" from them.

Image: Reverse of Unprovenanced Athenian Decadrachm from Greek National Coin Collection
Tompa does not give the source of the illustration he copied, but it is most likely:
http://www.eie.gr/archaeologia/En/chapter_more_7.aspx

Perhaps somebody more familiar with the literature can tell Mr Tompa and myself when and where it was bought, and what its prior collecting history was.

I'm a bit confused about this "Alpha bank coin" mentioned by Tompa, because Reid Goldsborough states it is currently in the Numismatic Museum too. Perhaps he is mistaken.
This one has an interesting "collecting history".

Here's the real McCoy, a dekadrachm weighing 42.13 grams currently residing in the Numismatic Museum of Athens. It was donated to it by Alpha Bank of Greece, who reportedly purchased it for $280,000 from Numismatica Ars Classica. Before that Freeman & Sear sold it for "more than" $150,000. This coin previously appeared on the cover of an Ira and Larry Goldberg catalog. I had a chance to handle and inspect this coin while it was in the possession of Freeman & Sear. Other Athenian dekadrachms occasionally appear on the market, with the most expensive reportedly changing hands privately for $1 million.

Nota bene, "the market" here being almost exclusively the AMERICAN market. Numismatica Ars Classica are a London firm with branches in Zurich and Milan, Freeman and Sear and Goldberg coins are however Californian dealers. This coin came to Greece through the US no-questions-asked market. In which case no export licence was required to import it legally into Greece, for the US does not issue export licences for antiquities (despite being a state party of the 1970 UNESCO Convention). So Tompa's point about "provenance" falls rather flat when the CCPIA is all about export licences, not "provenances".

Then we have the piece being sold earlier this year in the US by by Gemini Numismatics (a partnership between Harlan J. Berk [ACCG benefactor], Herb Kreindler and David Hendin [ACCG benefactor]) and Heritage Auction Galleries ([ACCG benefactor] remember Bob Korver on the CPAT assessing Greece's MOU request?), in conjunction with the Chicago International Coin Fair. It was withdrawn from sale, not because of problems with export licences, but where it had actually come from, it was a fake. Harlan J. Berk was a bit cagey on its collecting history:

Berk also would not reveal how and where he acquired the coin, other than to say he worked through an agent. “It’s like if you have a very good fishing hole: do you tell where it is to everyone?” he said. The chain of custody for ancient coins muddies the situation, Berk said. "Generally I know who I’m buying it from, but not where I’m buying it from.

But its generally a good fishing hole, and best not to ask too many searching questions eh? In any case, the buyer really is not all that interested in knowing. So how can heap of pretty geegaws on a table coin afficionados say that all ARE found outside Greece? What about the other seven that came onto the market, from the soil of which country were they clandestinely removed? How can coineys claim to be generating information by buying these things when the market they encourage obliterates even such fundamental pieces of information?

How can these people keep a straight face and accuse others of "double standards"?

If the United States of America was adhering to the 1970 UNESCO Convention, these coins (ie the dekas sold by US dealers, mostly to US collectors) would not be on open sale (Art 3: "The import, export or transfer of ownership of cultural property effected contrary to the provisions adopted under this Convention by the States Parties thereto, shall be illicit"). Also the fact that the items themselves have been shorn of any kind of provenance information by passing through the damaging no-questions-asked market that Tompa and the ACCG attempt to justify and support, the source country has no possibility of determining that their cultural patrimony has been robbed of these items, and no possibility therefore to demand/request them back from the Greek museum (see the 1970 UNESCO Convention Art 7(a)). The whole problem here is that the USA does NOT respect or abide by the Convention, but merely its own CCPIA. Certainly "no (US) law was broken" - that's how dealers in such stuff always justify themselves, isn't it? Greece has now asked for this loophole allowing such trade in illegally exported items to be closed - and the next importer of one of these coins is going to have to say where he got it from and show ICE that its export from that place was licit. Which is, after all, just what the legal and licit trade in archaeological artefacts is all about.

Illinois Archaeological Site Looted

.

Artefact hunters have damaged and looted an archaeological site of the Woodland and Mississippian cultures on farmland in southwestern Illinois. Large holes were dug with shovels into the excavated area in a hasty search for artefacts after the students had left the site after work on Friday. The thieves also broke into a locked equipment storage box and stole a $200 piece of surveying equipment. The damage was discovered on Monday morning, but heavy rain on Friday night erased any tracks the vandals may have left. The vandals caused so much damage that the team will have to begin the dig again.

Looter's hole in the middle of an excavation square

It is reported that the finds present on the site were of low monetary value, "there is nothing of commercial value here. You couldn't sell it," Gregory Vogel, an assistant professor with the archaeological field school at Southern Illinois University's Edwardsville campus, told the Belleville News-Democrat.

George Pawlaczyk, 'So much work, and it was gone': Vandals hit SIUE archaeology dig', Belleville News-Democrat, Jun. 14, 2011
Read more:

Chad Garrison, 'Dirty Rotten Scoundrels: Vandals Destroy Archaeological Dig at Southern Illinois - Edwardsville', Riverfront Times, Jun. 15 2011

Of course this digging is only visible (and being written about) because it took place on a site currently being investigated. The holes dug by artefact hunters, looking for exactly the same types of artefacts on exactly the same type of rural site, don't make it to the press, but are no less deep and wide, no less damaging to the archaeological record. And this is going on all the time, in the daytime, in evenings at weekends, but nobody bats an eyelid. It is the collector's "right" to collect the pro-collecting advocates say. They claim the right to create this kind of devastation of archaeological sites wherever and whenever they take a fancy, sometimes keeping within the law (only on private land with permission), sometimes breaking the law. It makes no difference to them, neither does it make much difference to the people who buy the artefacts coming from such diggings.

The Problems with Illegally Transporting Ancient Coins

.
I came across this 'Factoidz' article 'The Problems with Illegally Transporting Ancient Coins' by chance yesterday, while there is perhaps nothing much new here, and I would place the emphasis of some parts of it elsewhere, it is good to see the subject "out there" in the popular media. It is also nice to see colleague Nathan Elkins mentioned.

While many are happy to see displays and pictures of ancient coins, many people are bent on owning a collection of them. This leads to many looting from archeological sites and taking coins to sell on the black market. [...] By buying coins from black market sources, collectors are inadvertently hampering the study of the past according to most archeologists and de-valuing the coins as primary sources of history.

I would have mentioned that there is emerging evidence that it would also be supporting organized crime. Clicking on the source of the illustration brings the reader to Reid Goldsborough's well-known (or should be) text 'Looting, Smuggling, And Coins' which argues:

There should be a government-regulated free market of antiquities and coins in source countries around the Mediterranean, as there is in the United Kingdom.

Eh? What government regulation is there of the British antiquities market, surely some mistake! More misinformation about the PAS. has the existence of a government regulated free market of antiquities and coins put a stop to the looting of archaeological sites and illegal activity concerning artefacts in Israel?Goldsborough continues:

Governments would confiscate material shown to have been uncovered illegally at off-limits, bona fide archeological sites. The remainder of the material would enter the collector market, not secretly as happens today, with much knowledge of the past lost, but openly so the material could be fully studied. Governments of source countries would further benefit in the form of sales and export taxes just as with other goods sold or exported.

Well, isn't it the case that current laws confiscate confiscate material excavated illegally at off-limits archaeological sites? What is a "bone fide" archaeological site, who defines it and how (for the purposes of this market)? Also I fail to see how imposing a tax on antiquity exports is going to help cut down clandestine exportation. This can only work with some form of import control at the other end, as most collectors willingly buy antiquities on the open market without paying the slightest attention to the precise formalities of them leaving the source country.

So we come back to the same problem of the lack of responsibility of the collectors (the ubiquity of customers of the dodgy dealers) for providing the incentive for trading in licitly-obtained material. it is these collectors that are providing the motor for the looting and illegal export of material.

Goldsborough finishes with a flourish:

Saving Antiquities for Everyone is an advocacy organization that, despite its name, promotes the mainstream archeological position, which includes banning the private collecting of ancient coins and artifacts. Ancient Coin Collectors Guild is an advocacy organization that, despite its name, promotes the mainstream position of coin dealers, which includes the preservation of the right to sell and buy ancient coins. Neither organization is advocating the rationalization of laws in source countries and the furthering of knowledge this would lead to.

Firstly SAFE does not work for the "banning" of collecting, the mainstream position is that the market should be restricted to that which is licitly and sustainably obtained. Inasmuch as most of the antiquities market today seems to be quite the opposite (unsustainable and damaging) of the desired form, then it seems reasonable to oppose all elements within it which would tend to make that situation much worse as the market expands. But by all means let us work together to see a rationalisation of laws, we could start with the largest market country, the US rationalising its own laws not only as a receiver of antiquities, but a source of antiquities. Alongside legislative changes however we need to see a massive change in attitudes and a taking of responsibility by dealers and especially collectors to reduce the problems with illegally transporting illicitly obtained ancient coins.
.