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.

The AGACC "Keeping the Hobby Clean" Award

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The American Guild of Ancient Coin Collectors has instituted an annual award for the US collector of ancient coins who has done the most to help responsible dealers keep the hobby clean in the preceding calendar year. It is primarily intended as a recognition of the responsible behaviour and high moral character of collectors who report to the relevant trade and law enforcement authorities the surfacing on the US market of looted, smuggled or stolen items in such a way that it leads to charges being brought against those involved in dodgy dealings. The winner will receive a sizeable cash award (from funds donated by the US Responsible Antiquities Dealers' Association) and a wall-plaque which he is encouraged to display alongside any elements of his collection that he will be exhibiting at coin clubs and shows. The award also entitles the collector to wear the AGACC lapel badge with a red background (instead of the normal blue), so dealers can see immediately they walk into the shop who they are dealing with. Only collectors are eligible for the Award; the Guild already has a comparable recognition of 'Due Dilligence Excellence' awarded by the Guild's collector members to dealers excelling in supplying coins with properly documented collecting histories (this year the plaque was not awarded).

Guild spokesperson Jayne Moralsales stressed that this "Keeping the Hobby Clean" Award was a logical extension of the Guild's policies on legal and responsible collecting: "we encourage our members to exercise appropriate caution when buying ancient coins from any source", she said, "and to report any suspicious-looking activity so that it can be fully investigated". She stressed that the function of the Guild was to foster an environment in which the general public can acquire and hold any numismatic item of historical interest regardless of date or place of origin in confidence that the material can be shown to have arrived on the market in compliance with all applicable laws (domestic and at the point of origin) and standards of ethics and morals. 

Nominations for the 2013 "Keeping the Hobby Clean" award should be sent to Jayne Moralsales here. 

US Court Does not Buy Coin Collectors' Conspiracy Theory: Disallows Intrusive Snooping

Concerning a recent case, Lobboblogger Tompa informs his readers: "The Government's motion is available on-line for those with a "Pacer" account with the federal court system". Thanks to a tip-off, I can inform mine that if they follow this link they will find a much more interesting text by Marimer Matos:

'Feds Didn't Shortchange Coin Collectors on Info', courthouse News Service, Thursday, June 14, 2012 

The State Department did not illegally conceal coin-importation regulations from collectors, a federal judge ruled. In a 2007 complaint, three coin-collecting associations claimed that the U.S. State Department had blown off their eight requests for information on the restrictions surrounding ancient coin importation. The collectors said the government would not reveal limitations on importing ancient coins from Cyprus, Italy and China, and it also refused to explain how the regulations were created.

As my readers will know, to their eternal shame, the ACCG were after emails sent to the DoS  by the late Dr. Danielle Parks, an archaeology professor. The coin fondlers think intrusive snooping of this type acceptable, the US court does not: "This court finds, based on the evidence provided by State, that there was a demonstrated expectation of confidentiality between the parties and that the redacted portions of the e-mails have been appropriately withheld under exemption". The court ruled excessive and unreasonable the other demands of the Professional (sic) Numismatic Guild, the International Association of Professional (sic) Numismatists and the Ancient Coin Collectors' (sic) Guild.

UPDATE 16th June 2012: Despite the court not accepting the intimations of the PNG, AIPN and ACCG that there was some kind of a cover-up of a conspiracy going on, their Lobboblogger - instead of issuing an apology to the dead woman's family - still insists there was. Disgusting and disturbing.

The Sharp Eyes of Professor Gill

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Sharp eyed David Gill has spotted some interesting names in a list published as part of the ACCG case against import restrictions on Italian antiquities without documentation of lawful export. Apart from the IAPN and ACCG-related names there, he notes others:

The list is well worth a look as it includes a New York private collector who has returned material to Italy, a New York based antiquities dealer who has returned material to Italy, and two museum curators whose collections have returned material to Italy.

I also see on the list a ranty US coin dealer who lives in an area that on Google Earth looks like a dump, back in 1999 lived in an area that looks even more like a dump, even the surroundings of locatable UK metal detectorists living on council estates look more appealing from the satellite. Also back in 1999 the ratio White Hat Guys: Black Hat Guys submitting comments was more favourable, are there now fewer of us, or more of them? Or have White Hat Guys been going over to the Dark Side in the intervening period?

Thomas Albert for ACCG Director General

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Tom Albert certainly gets my vote as the new executive director of the ACCG, he has this conspiracy theory stuff sussed. Go, boy, go!

I have a different gubn'mint conspiracy theory, if coin collectors with their "free thought" pose such a threat to the New World Order and its plans to dominate the world through manipulation of History as Albert claims, we might ask what fresh dugup coins are soaked in before they come on the market? It's obviously a pretty potent mind-rot agent. By pretending to "restrict access" to fresh dugups (through import controls) the Illuminati are obviously fostering demand precisely in the dangerous non-conformist groups like coineys which they wish to target. Ancient coins impregnated with mind-control drugs that work through skin contact. Don't fondle the coins !

Vignette: Money never lies: the Illuminati dollar.

Comment From Thinking Collector

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A collector who has his own mind sent a comment to an earlier post (since I suspect that not everybody reads the comments here), I'd like to draw attention to two portions:

I let my membership in the ACCG expire. Their statements make little sense to me, nor do I think their strategy protects the long term interests of ancient coin collecting.

I totally agree, I suspect they are losing other members, hence the "David and Goliath" push recently trying to convince "World coin" (ie modern coin) collectors that maybe it is their turn next (it is not of course, the idea is patently ridiculous). Up to a point [the matter of 'protection' of the artefacts], I agree with much of the second bit too:

I believe that individuals should be allowed to be guardians of cultural objects. Dispersing them does protect them and make them available to everyone. But it is a role of stewardship and responsibility. The interests of all current stake holders and future generations must be taken into account. As others have noted. historical sites are a vanishing resource. What about the interests of children and grandchildren? And theirs?

From my own observations, I concur with this collector's view that there is little free and informed discussion of these issues among ACCG/Moneta-L coineys, their self-appointed leaders do their best to nip that in the bud wherever it breaks out.

Would You Like an ACCG Member Living Next-Door to You?

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One of the ACCG bloggers asserts:

Antiquities collectors in European nations should not imagine that because they live outside US jurisdiction, the efforts of the ACCG [...] in the USA are not also vitally important to them. These efforts, although focused on coins, are the only concerted action presently being taken in defense of antiquities collectors' rights. Legal precedents that result may have importance to cases involving collecting and trading in all types of antiquities.

All over the world tens (maybe even hundreds) of thousands of people collect antiquities. Most of them do so by adhering to the law. As pointed out there is just ONE group and in just ONE country where collectors of such material consider themselves to be 'above the law'. They object to being asked to abide by a law of their own country in some of their dealings and respect the laws of the source countries. This they regard as some kind of infringement of what they see as "collectors' rights". These "rights" include free access to the trade in ancient artefacts dug up in and removed from other countries, irrespective of whether the activities involved are lawful. They support the import into the US of items from countries whose archaeological sites are threatened by pillage, without documentation of lawful export. On this account they depict themselves as some kind of altruistic freedom fighters. They are in fact nothing but an isolated group of whining agitators, shielding the trade in illicit artefacts and are doing the image of responsible portable antiquity collectors a great deal of harm. Like Nighthawks in the United Kingdom.

Would you let your kids play with the children of an ACCG member? Why would any responsible collector join the ACCG?
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US Artefact Collectors and the Law

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Over in Krause Publications' "World Coin News" coin-dealer-investigative-journalist Richard Giedroyć is publicising some wild claims.

Countries including Bulgaria, China, Cyprus, Italy, Spain and Turkey have been making increasing demands not only to restrict the import of certain coins, but to repatriate coins now in private or museum collections they claim should be able to be returned regardless of how long these coins have been out of their country of origin or where the coins were discovered.

Do they? Where can he document such a statement, or does he want his readers to believe that the claims are part of secret backroom gubn'mint deals involving concessions to foreign governments in return for them buying Big Business's GM mutant popcorn? The mind boggles. The occasion for this latest literary production of the hapless numismo-journalist was a Jan. 7 meeting of the ACCG held during the New York International Numismatic Convention (you know, the one where 'the recent arrest' took place). The subject was '[US] Import Restrictions Declared 'Extra Legal', and the meeting was addressed by (of course, who else but) Peter Tompa and (who else but) Wayne Sayles. The name of the person they invited representing the Department of State's legal department was not given, probably because inviting such a speaker was not on their agenda. Tompa opened by saying:

two University of Miami law professors [...] examined laws regarding the import of certain coins and how these laws are being enforced, despite having no personal interest in coins or in coin collecting. Their conclusion, according to Tompa, was that those enforcing these laws have been going beyond the letter of the law, using the law term “extra legal” to describe these actions.

Now this is old "news", the article to which Tompa refers is obviously such old hat in coiney circles, everybody having read it, that no need is felt here to give details of the names of these professors (Stephen Urice and Andrew Adler) or the context of what they wrote. So basically the coineys are not coming up with anything new.

There is however a welcome new emphasis in the ACCG which now:

encourages those individuals and organizations with an interest in coins as collectibles to lobby to change or to discourage new laws that may restrict ownership rights regarding specific coins. [...] Sayles was careful to clarify what collectors and dealers should and should not do. “It is not in our best interests to find a way to get around the law. It is in our best interest to change the law,” he declared.

Of course one of the primary prerequisites of this is ensuring that they know the existing laws, which statements like the one started this text with do not help. In order to take active part in political life of their country the coineys will need to know how the system they want to change actually works, what it does and what it does not.

One word of sense from the WCN jurnlist:

Sayles told those at the ACCG meeting some coin dealers are now giving clients invoices on which photographs of their coins appear. Current statutes require an affidavit both from the dealer and from the buyer that some specific ancient coins are being imported legally. The provenance and the date of purchase of such coins is becoming increasingly important due to these restrictions.

Yes, and always has been, its just it has taken coin dealers and coin purchasers a long time to drag their hobby into the modern world. But its not just due to the restrictions, keeping proper records of holdings is a requisite of responsible and ethical collecting of such material.

On Urice and Adler:
'Miami Law: US Cultural Property Policies a Shambles'(17 August 2010)
'Talking Rot About "Rot at the Top" ' (20 August 2010)
'Well, it was inevitable was it not?' (23 August 2010)
'Urice and Adler Redraft' (31 March 2011)

Note though that the ACCG are very selective about informing their readers about Urice's writings on cultural property law: 'What the Dealers' lobbyists are Not telling Collectors' 5 December 2011 (and other posts here)

Coiney Total Nonsense

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ACCG ideologist John Hooker, addressing thinking numismatist Reid Goldsborough, attempts to explain archaeology to him based on his correspondence with some people on internet forums and gleanings from Wikipedia. Hooker attempts to show why archaeology and coin collecting are "different subjects with different emphases":

Contextual archaeology focuses on incidents of abandonment -- a site frozen in various times as determined from the strata (including cuts into that strata as is shown using the Harris Matrix). Numismatics deals more with incidents of creation -- blanks, and the creation and use of dies -- weight standards, alloys etc. Perhaps, if you read more qualified archaeologists than Paul Barford you would not make such silly mistakes.[...] many current "field archaeologists" confuse archaeology with the specific theory of contextual archaeology, as does Barford, but they are not very hot on theory. [...] I think [Barford] made it as far as assistant lecturer (the one who arranges the chairs and sets up the overheads? I don't know.)

Apparently in Canada, archaeology students are not expected to be able to find their own place to sit. In my classes they were able to work that out for themselves, the good ones sat at the front, the time-wasters at the back.

The reader can think what they want, but I personally find Hooker's attempt to explain that in reality Barford knows nothing about archaeology somewhat puzzling in the circumstances. Hooker apparently does not understand what Hodder and other post-processualists considered as "Contextual Archaeology"; he accuses others as "not very hot on theory" (unlike Hooker, I taught it at university) but he himself only cites Wikipedia.

As for site formation processes (the name should give a clue), archaeological stratification, like geological stratification (not caused by the "abandonment of the earth", after all), is created by a range of processes. Despite what Hooker affirms, these include deliberate creation (roads and streets, ramparts, graves, walls, postholes for example) not just "abandonment". Perhaps coin collectors like to think they are examining just "creation" (of beautiful tactile objects) but of course circulation (and for example the damage - wear - done to coins in the process) and deposition are studied by REAL numismatists. There is a whole body of numismatic theory about that which I've never seen an ACCG coiney refer to - and it is difficult to escape the conclusion that most of them apparently just heap loose coins on a table and look at the pictures on them and try to put them in some sort of order on that basis (Mr Hooker's book on the Gaulish coin hoards for example). I have asked the ACCG coineys many times to point us to the textbook of the methodology of heap-of-coins-on-a-table "numismatics", but have never met one who could impart even such basic information about this side of the coin-collecting 'discipline' as the title of even a single work in the genre.

If by "contextual archaeology" (of the "field archaeologists"), Hooker means stratigraphy, it is not a "theory" but a methodology.

Archaeology is a proper discipline and as such has an explicit methodology (or may even have several), so where is the methodology of heap-of-coins-on-a-table "numismatics" explicitly formulated and taught? What about a theory of the same brand of touchy-feely numismatics? There is no end to the number of books, even if we restrict the search to those written in English, on the methodology and theory or archaeology, written from a wide diversity of methodological, theoretical and ideological positions. There is therefore no excuse whatsoever for the enquiring coiney (or dugup antiquity collector) not to know what archaeology is about. Let them follow the lead and produce the textbooks allowing us to understand what we have been asking for years about just what it is they imagine they are doing with all those accumulations of dugup ancient coins.

So far, the sum total of the coiney 'critique' of archaeology looks no different than that of Erich Von Daniken (who also took a great interest in contextless archaeological artefacts, on the basis of which he wove his own story about the past).

Vignette: Pirates' idea of debate

Sowing the Dragons' Teeth: Keeping the Market Alive

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With reference to the notion that coin collecting might be losing its popularity among young Americans (a worrying prospect for all those wishing to profit from the sale of ancient dugups) Mark Lehman of "Ancient Coins for Education" (sic) soothes:

If, however, you're interested in finding out whether or not the introduction of coins into the curriculum is "raising a new crop" of numismatists, I could put you in touch with more than a few teachers whose students have gone on, beyond the teaching "unit" in which their classes worked with and studied coins, to become avid young collectors. For that matter, many teachers administering ACE programs have also become avid collectors in their own right [...], there most definitely are young people (interested in coin collecting) out there. We who work with ACE find that they crop up in nearly every class, once exposed to the concept. [...] wherever teachers and community members make an effort to engage students through this natural, hands-on approach to history and many other subjects, new collectors crop-up like dandelions from a single seed-head blown into the wind.

And the looting goes on to supply the demand. Remember ACE avoids discussions of the ethics of the manner of supply of the US antiquities trade both inside and outside the classroom "like the very plague". What kind of "education" is that? See Nathan Elkins' "Treasure Hunting 101 in American Classrooms" in a good library near you. Let's see it on the Internet for concerned parents to see.

(Responsible) teachers, and parents, take a good look at the ACE website, look for example at the answer to this question:

"Q: "Where did these coins come from?" A: The vast majority of uncleaned material on the market at the present time comes from Eastern Europe - the "countries formerly known as Yugoslavia" and Bulgaria in particular"

(you know, countries where digging this sort of stuff out of the ground and keeping it is illegal. This stuff comes from criminal activities and is going straight into US classrooms - "support a Balkan criminal today, join the ACE"? ). Who supports the ACE? Why all those jolly old ACCG and other dealers in dugup ancient coins who stand to make a profit by the expansion of their market, just as long as they can get their hands on enough of that stuff, no-questions-asked from gangs of looters and smugglers in "the 'countries formerly known as Yugoslavia' and Bulgaria in particular" - and now the strife-torn Near East and North Africa (maybe if enough questions were being asked about who supplies them how and why, "Blood antiquities" perhaps included among them).

US Dugup Dealer Shows True Colours and True Aims of their Anti CCPIA Movement

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The news of the armed robbery of the Olympia Museum was greeted with shock and dismay by the cultural community today, but among those involved in the trade in antiquities there was a totally different reaction. Dugup antiquity dealer Dave Welsh (Classical Coins) for example urges the immediate suspension of the implementation by the US of the 1970 UNESCO Convention on the Means of Prohibiting and Preventing the Illicit Import, Export and Transfer of Ownership of Cultural Property. He treats this theft by armed raiders as:

incontrovertible evidence that Greece, given her present difficulties, cannot at this time be considered a safe custodian for ancient artifacts. The USA should immediately suspend repatriation of artifacts to Greece and enforcement of import restrictions requested by Greece, until an impartial investigation determines whether the Greek government is capable of providing secure custody of the artifacts for which it is presently responsible.

What astounding nerve! First of all it is certainly not up to the United States of America to be the judge of whether another sovereign state should be a custodian of ITS OWN cultural property. This is sheer US imperialism raising its ugly head once again in dealers' dealings with the weaker nations of the world. Mr Welsh and his ACCG cronies would obviously willingly and without scruple take advantage of Greece's weakened position to keep in the USA any stolen Greek artefacts that may be found in that country. Disgusting.

Secondly, the UNESCO Convention (see Art. 7 for example) and the CCPIA which implements it (19 U.S.C. 2607 and 2610) is meant to deal precisely, and arguably even primarily, with just such circumstances as we have here. A museum has been robbed and states parties to the Convention are asked to keep an eye open for the loot and stop it being imported into and acquired in their own territories. It is precisely at such a moment that Mr Welsh wants to prevent the Convention being implemented in the case of Greece? This would not by any chance have any connection with Mr Welsh's own involvement in the trade in artefacts of (among others) Greek origin would it? Why would any dealer want to see a suspension of the Convention on the Means of Prohibiting and Preventing the Illicit Import, Export and Transfer of Ownership of Cultural Property as a result of a major museum theft in one of his "source countries"?

Thirdly, the only reason this raid was carried out was so the thieves (and we may speculate that they could be part of an armed - and even foreign - organized criminal group) could get their hands on valuable finds which they will try to monetise. Where? Pottery has minimal scrap value, so it seems they were taking items with a thought for their value on the no-questions-asked antiquities market. The very same international antiquities market that Dave Welsh and his organization the ACCG apparently support and wish to maintain. This raid would not have happened had there not been a market where stolen antiquities can safely be sold off, only to "surface" anonymously later. Collectors who buy stuff without requiring information where actually it came from are as much to blame for these sorts of thefts as those who see in the current state of the market a golden opportunity too good to miss.

Fourthly, it took kalashnikovs to loot this museum and the violent treatment of a museum guard. The ANS money Museum in the USA was robbed much more easily, through a fault in the internal auditing system which allowed a thief to take a million dollars worth of objects probably over a period of time, and earlier another theft of the same type to take place. As I said earlier, there has not been a peep about this on the coiney anti-preservationist blogs, let alone a call from US coineys for a deep investigation of museum security in the US. And these are the people whingeing about "discrimination"...

Finally, it is misleading to present the fight against the trade in illicit antiquities merely as a drive for "repatriation". Its not about what to do with the proceeds of crime, but preventing the crime. Let us not ignore the crime, let us call a spade a spade - even if no-questions-asked traders and collectors cannot bring themselves to.

Vignette: Dodger and Fagin discussing a "newly surfaced" coin. Some dealers in such "collectables" apparently hanker for a return to the golden period of culture-theft before the UNESCO Convention, they apparently would feel better working in a more nineteenth-century mode.

"Legal because cheap"?

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Minnesota dugup coin collector Jorg Lueke in a post called "Most Ancient Coins are Legal and Undocumented" writes about this dreadful "Paul Barford, an extreme archaeoloist living in Poland" who according to him "has almost arrived at the crux of the matter regarding import restrictions". Wow, all those years looking at the antiquities trade and now I achieve coiney acclaim (what is an "extreme archaeologist"?). The "crux of the matter", according to Lueke, is the fact that "most coins being traded today by volume [in the USA] are not covered MOUs”, coupled with the fact that these bulk lots are not above a certain threshold level for the National Stolen Property Act makes them legally "not stolen". Well, I guess Mr Lueke would know more about what is considered stolen and what is not considered stealing in the US than me; I personally reckon half-inching a packet of fags from a newspaper stand is stealing, regardless of the value of the item. Obviously this is something that collectors with convictions of their own may not endorse.

Lueke goes on to express the view that:

US Customs law is only going to deal with those items specified in MOUs [...] this is a minority of all the ancient coins on the market.

Mr Lueke has clearly not been paying attention to recent events in the collecting word. As I mentioned on this blog, the self-appointed "leaders" of the dealer-lobbyist ilk are making sure that discussion of recent events is minimalised. Mr Lueke is under-informed. Another way in which collectors keep themselves under-informed is by not actually reading the relevant documents. Lueke says:

The UNESCO Convention deals with illicit trade so, for Mr. Barford's assertion to be true, he must believe that the majority of coins on the market right now are illicit. I believe the majority of coins being traded are in fact licit. (punctuation corrected -PMB)

Well, article 3 of the 1970 UNESCO Convention defines illicit trade, Mr Lueke may prefer to "believe" what he likes, the wording of the Convention is quite clear how the licit origins of cultural property on the market will be expressed, and its not by mere assumption.

Coiney Academic Rigour: Adding it up at the CPAC

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There is a telling comment in Peter Tompa's account of the 18th Jan meeting with the CPAC. The Ancient coin Collectors' Guild had sent them a 'public comment' intending to demonstrate that Cypriot coins would not all be "first discovered" in the territory of Cyprus. They provided a list of hoards to show that such coins were sometimes buried in antiquity outside Cyprus. There was not much academic rigour in their presentation of the 'evidence' to support (rather than in the spirit of academic enquiry examine) their case, as they omitted the hoards found ON Cyprus. In his presentation at the public CPAC meeting, Prof. Nathan Elkins pointed out the sleight-of-hand. Look how Tompa justifies it to the slack-jawed masses:

If you add together a list prepared by Wayne Sayles of coins found outside of Cyprus and a list Elkins compiled of coins from Cypriot contexts, that shows that Cypriot coinage is much more prevalent in Cyprus than outside of Cyprus.

Why, in order to arrive at a conclusion about "where" certain things happened in the past would one have to "add" fresh information to what the coiney dealers had already supplied to the CPAC - except if the coiney dealers (this so-called "Ancient Coin Collectors Guild" run by people calling themselves "professional numismatists") had supplied the public enquiry with one-sided, FALSE and MISLEADING information? What other explanation is there?

More Imaginary Bogeymen for the Coineys

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In an apparent effort to show his "Cultural Property Observer" blog to be wholly irrelevant to the current situation on the US no-questions-asked antiquities market, the dealers' paid lobbyist breaks his silence to write about (in connection, his tag proclaims, with: "the Greek MOU") the fact that the Greeks might rent out the Athens Acropolis for commercial use (Tuesday, January 17, 2012, "Acropolis for Rent ). Wholly moronic is his opening line:

In a move that will no doubt leave archaeological purists aghast, [...]

Who are these mythological "archaeological purists"? Do they really exist, or are they another of those coiney made-up bogeymen with which the coiney lobbyists aim to scare childlike and uncritical collectors? Are these US "archaeological purists" or "Yuropeen" ones?

I would have thought the current situation threatening the whole US dugup coin market would be an ample reason for dealers' paid mouthpieces to stop talking of made-up problems, but addressing the real ones with which the US collector of dugup artefacts on his hands is likely to be faced in the coming year. It is not the "MOU" which is US dugup and undocumented coin collecting's greatest problem any more, when are the ACCG and its camp-followers going to admit that? Or do they believe that in this too, that an ignored problem will simply go away? Like toothache?

UPDATE 19.01.12
All right, I'll have to say this before Tompa does. It seems I was wrong; Tom Flyn says it is "sacrilege". Does that make him an "archaeological purist"? He is entitled to his opinion of course, but I really think he is over-reacting. We have many examples of films for examples involving real ancient monuments as settings. I have in mind for example "Death on the Nile" which (surely bits of it were) filmed at Karnak, and if I've got that wrong, then there is the classic "Night of the Counting of the years" (deserves to be better known) . I seem to recall a Doctor Who episode which was filmed at one of the megalithic monuments, many a BBC costume drama is filmed against a backdrop of some stately pile or another - which is cheaper than plasterboard and paint. A number of churches feature in films ("Four Weddings and a Funeral" for one, using a church near where I had the misfortune to live for a while). I really cannot see anything wrong with that if the incumbent and congregation do not. Then there was the comedy-drama series "Chasing mummies" ...

Anyway, as reported just now on Museum Security Network,

Greek Minister of Culture and Tourism, P. Yeroulanos, has stated that any claims by the press that the Acropolis will be rented out are false. (This was tweeted by the Minister himself, Pavlos Yeroulanos @P_Yeroulanos)

- which I suppose raises the question, why on earth not if its done properly?

UPDATE 19.01.12:
As Tom Flynn now reports:

The source of the almost instantly viral rumour that the Greeks were considering renting out the Acropolis and other archaeological sites to help pay off the country's sovereign debt seems to have been a Conservative former Greek Minister — Gerasimos Giakoumatos. ‎"It's better to rent the Acropolis to private companies than to cut wages and pensions," Giakoumatos told the press. "Rent the Parthenon, the Delphi, the Temple of Apollo, Knossos and let the money flow into the public funds.” That recommendation, which had cultural heritage experts choking into their cornflakes, was endorsed by another Greek MP, Nea Dimokratia.

"Collectors" Guild Keeps US Collectors in the Dark

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The US organization run by some dugup artefact dealers which claims to be a "Guild" of and for "Collectors" of such items seems to be going about looking after US collectors' interests in a very strange way. It is becoming clear from events over the past few weeks that there are currently a number of ongoing changes in the context in which the no-questions-asked collecting of ancient artefacts has so far operated. These must be confusing and difficult times for that collecting milieu. Collectors wanting to know where they stand, and what the future will hold for them and their collections surely should have somewhere to turn for information and advice.

There are as we know a number of US-based coiney blogs and discussion lists, many of them propagating the ACCG point of view. Are collectors finding the information they need to understand the rapidly changing situation on places like Peter Tompa's "Cultural Property Obbserver" blog? Or the "News" section of the ACCG website? or on the Moneta-L discussion list?

Certainly collectors are being enlisted through these and other resources to join the ACCG-led fight against the CCPIA (implementing the 1970 UNESCO Convention) which places import controls on unlawfully exported artefacts and has provisions for the return of stolen artefacts. They have even brought these people into conflict with their own government over this matter, thus exposing them to the danger of being added to a watch-list in future.

But to what extent is the ACCG making the effort to acquaint collectors with the other problems the collector may face if not very careful about the legality of the purchases they make according to US law? I will set out below a few things that collectors will NOT find being discussed on the coiney blogs. The pattern is such that it is very tempting to see this as a deliberate suppression of information. Are collectors being wilfully misled?

A few weeks back I noted that the journalists who run the Chasing Aphrodite blog had drawn attention (Looted Antiquities at American Museums: An On-Going Crime, law professor argues) to an article of Stephen Urice about cultural property and US law which noted a serious problem for the owners of cultural property of less than clean origins: "Between Rocks and hard Places: Unprovenanced Antiquities and the national Stolen Property Act". This was not picked up by coiney bloggers, as I predicted at the time that it would not be, since it undermined the coiney premise that "provenance does not matter". It seems collectors have lost the chance to read the original article which was originally open access and is now subscription-only.

Then there have been developments in the SLAM mummy mask case which suggests some creative use of US legislation by the government (the first to pick this up was 'White Hat' cultural property lawyer Rick St Hilaire, it received very little attention in collecting circles). There have however since been three cases involving interpretations of US law on imports quite separate from the CCPIA which potentially have, I would say, far reaching consequences for those collecting ancient objects brought into America from other countries by less-than-legal means. There were some paintings going to auction, a painting loaned from a museum, and a whole historic warplane that somebody had managed to sneak through not-so-vigilant US Customs. Again, the possible implications of these cases, or rather the interpretation of law on which they are based, have been totally ignored on the coiney blogs. Why?

Dealers try to convince US collectors that current US law (but again, just the CCPIA) "discriminate" against American collectors because allegedly over here in Europe we can fill our homes with looted artefacts and art taken from neighbouring countries. It seems however that the stereotype of collectors over there of the meaning of a Europe without frontiers is maintained only by a refusal on coiney websites to inform collectors of cases which show that this is not the case. Such as the long-running saga in Switzerland about a coin sold there two years ago at auction which was looted from northern Greece. The collector who bought it without proof of legal origins has just lost it, a fact that coiney blogs are not sharing with their audience of collectors who buy stuff from US dealers without proof of legal origins.

Another myth they like to perpetuate is that non-white "Wiley Oriental Gentlemen" are not capable of looking after the cultural heritage of their countries, they are all corrupt and their museums are badly-run and full of thieves. The inference they draw from that is that the laws intended to get freshly-surfaced items into national collections are "bad" laws, and the stuff is "better off" being exported to teh US where private collectors there can look after the artefacts. In order to uphold this viewpoint, each and every case of damage occurring to objects in the museums of the "Wiley Orientals" and especially insider thefts. These are the staples of blogs like Peter Tompa's or Dave Welsh's "Unidroit-L' discussion list. The same "resources" however are totally silent about analogous events when they take place in the museums, archives and public collections of the USA. This is even more noticeable when they affect numismatic collections, such as the recent court case over thefts from the American Numismatic Association Money Museum. The total silence on the coiney blogs is all the more puzzling because there is an appeal for help (and from whom if not the international numismatic community?) to find the missing coins.

Then we have some more missing information on coins, it seems the American Numismatic Society (where our old friend Rick Witschonke is Curatorial Associate) is for some reason at this moment busily censoring the online records of donations from a certain individual, removing the information about where these particular coins came from. It seems to me that coin collectors thinking of donating research material to a US public collection ought to be aware of the fate that may await their own gifts of generosity if they choose the ANS, and this is something that collectors should have to go somewhere else to find out rather than Paul Barford's blog (and look how popular that post is, there seems to be quite a lot of interest in these behind-the-scenes-doings by the ANS). As readers will know, I make the point about the hypocrisy of dealers invoking the "presumption of innocence" in the case of transactions involving freshly-surfaced artefacts, but they do not apply it themselves to acquisitions from certain collectors the moment a grey cloud appears anywhere near their name. We saw this in the case of the ACCG's own treatment of two affiliated dealers (and benefit auction donors) the moment they seemed to be in trouble with the law (the case has not yet come to trial).

Then there is the raid on the New York International Numismatic Convention on 3rd January and the further developments in this case. There seems every reason to believe - including what appear to be a number of 'strategic leaks' - that this is going to be a watershed case. Yet the coiney blogs are silent, forum moderators are keeping discussions under a tight rein and deleting posts before other members see them. It seems to me that for far too long both US dealers and US collectors felt not only that they were above the law, entitled to do what they wanted in the name of their hobby, even to the extent of suing the US government and spreading all sorts of false information about government officials (and others who they saw as their opponents). Obviously if a group is going to accuse the government of illegal acts (which is what the coin dealers have been saying over the application of the CCPIA for years), they had better be 100% sure that they themselves are 100% inside the law. Otherwise they are opening themselves up to precisely the kind of investigation which it seems to me that coin and antiquity collecting are about to face in the USA over the next few months. The fact that it seems to have caught them all by surprise seems to be due to the fact that they as a milieu have been kept woefully poorly-appraised by their (self-appointed) leaders not only of the law itself, but also recent developments that should have been sending out signals that the status quo was not going to last for ever.

Meanwhile, as if to show the irrelevance of the ACCG, despite all that has been going on in and around the coineysphere, the last post on Tompa's blog is an old one about a guy who will not ship Sicilian coins to the USA (see here) and on Dealer Dave's how restrictions on importation of unlawfully exported coins is "destroying the coin market". Both so CCPIA and so old hat...

Vignette: Byron Reed, an early US coin collector (1870s-1890s), time for a change.

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

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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.

Two US Lawyers, Two Approaches to CPAC Comments

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It is quite instructive to look at the approach of two US cultural property lawyers to the public commenting on the Cyprus MOU renewal. It seems that there were a total of 338 comments electronically submitted regarding Cyprus’ request but only 23 comments regarding Peru’s request. Rick St Hilaire gives a sampling of the range of arguments offered for and against the Cyprus renewal (I note he could not avoid having to use "(sic)" in the two coiney examples he selects) - Comments Submitted to CPAC in Cyprus and Peru MoU Extension Requests.

The lawyer who is a paid lobbyist of the coin trade associations however totally ignores Peru and concentrates on the percentages of the comments "for" and "against" the renewal of a bilateral agreement with Cyprus and how many mention coins - 77% of Posted Comments Against Renewal of Cypriot MOU. He makes no mention of how many of the coiney replies actually refer to the criteria mandated as the theme of CPAC deliberations. According to the figures on this blog, 20% of respondents were supportive of the idea of the US continuing to monitor imports of artefacts from Cyprus for documentation of lawful export, but 77% were against it (3% were comments wholly off-topic):

This breaks down over the coin issue thus:
Those against the renewal that mentioned coins: 71%
Those against the renewal that did not mention coins: 6%
Those for the renewal that mentioned coins: 8%
Those for the renewal that did not mention coins: 12%

These percentages of course do not add up. Turning them into numbers and calculating the percentages properly reveals the following:

Those against the renewal that mentioned coins: 92%
Those against the renewal that did not mention coins: 8%

Ninety two percent of the Philistine comments were written by coin collectors and dealers. None of their names appears on the list of those commenting on the Peruvian request.

Clowns Need to Check the Law

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Dealer Dave has excelled himself, with one of the longest deranged comments on the doings of the preservationists in a long time, cross posted in several places. Mind you, most of it is, as is usual, cut and pasted from my blog with a bit of the traditional lowbrow vindictive coiney sniping and anti-gubn'mint rabble rousing (this time with a nautical theme) thrown in. I must have touched a nerve with the post about the first of the coiney comments on the Cyprus MOU renewal. As a result of the usual misdirection introduced by this particular blogging "Professional Numismatist", a number of matters of fact need to be straightened out:

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I) Dealer Dave, counting on the fact that they are too lazy to check for themselves, tries to convince his coiney readers that Paul Barford:

does not understand the 1983 CCPIA, which essentially anticipated that nearly all MOUs would NOT be renewed and would instead be allowed to lapse unless very convincing evidence could be shown, to the effect that the proposed continuation of what was presumed to be a temporary emergency justifying extraordinary measures would be justified. Congress did not ever intend that MOUs should automatically be renewed unless some extraordinary situation intervened.

[There is no question here of "automatic" renewal of course, this whole discussion is taking place because the process of the renewal of the Cyprus MOU is being referred to the CPAC].

But did the US Congress never intend renewals as Welsh asserts? The one-click approach to finding out the ACTUAL WORDING of the Act (as Public Law 97-446; or as 19 U.S.C. 2601 et seq. I'll use the latter, but the wording of the other is the same, note that Welsh cites no such references) pretty quickly reveals :

2606 (e) Extension of agreements
The President may extend any agreement that enters into force with respect to the United States for additional periods of not more than five years each if the President determines that --
(1) the factors referred to in subsection (a)(1) of this section which justified the entering into of the agreement still pertain, and
(2) no cause for suspension under subsection (d) of this section exists.

That's actually completely the opposite of what Welsh asserts. How is it possible that a coin dealer in the US apparently gets so muddled about the wording of the main law which has any effect on what he does?

Most other nations when they became state party to the Convention did so with the intent of applying its measures permanently (or until they denounce the Convention as per its Articles 23 and 24). As far as I am aware [and I am sure Peter Tompa can provide the other examples if they exist] only the USA considers that it is something they can chose to abide by only when THEY please, and most of which they can choose to ignore except for temporary occasions when they might (perhaps), if you ask them nicely, and convince them that they really should, consider applying a few of the principles to their international trade in artefacts for a while before they stop.

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II) Dealer Dave reckons that I am unaware that:

the title of the 1970 UNESCO Convention does not really describe what it is about,

yes, I would indeed be surprised about that, because the title and the contents are quite clearly by the same hand(s) and the title describe the contents of the Convention. According to Dealer Dave the "actual" purpose of the 1970 UNESCO Convention on the Means of Prohibiting and Preventing the Illicit Import, Export and Transfer of Ownership of Cultural Property:

"is very clearly to control "looting" in all its forms, from stripping a nation of ethnological and historical artifacts that have never been buried, to smuggling antiquities that might once have been buried.

No it is not. Just look at it, read it. It is about the Means of Prohibiting and Preventing the Illicit Import, Export and Transfer of Ownership of Cultural Property, in other words, smuggling. The reference to "looting" (actually "pillage") comes from the US legislation supposedly "implementing" it which refers to the single article (9 of 26) which mentions archaeological looting as PART of the problem of illicit trade. Again we see an attempt by the US to impose its own values on the rest of the world.

It is Mr Welsh who does not understand, the Convention covers movement of cultural property across international borders which a state party to the Convention wishes to regulate the passage of, and not just that which is looted and pillaged. It is the legitimacy of that movement (and not merely the origins of the objects themselves) which is the subject of that Convention (see Art. 2, 3, 5, 6, 7, 8, 10-15, 17). "As any fule can see".

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III) Dealer Dave asserts that the CPAC is "entitled to recommend to the US Government that the requests of the Cypriot government are not in the best interests of the USA". Is it? Is that its actual mandate? I thought that was what the CCPIA leaves up to the President to decide and the task of the CPAC is something else, that's what the CCPIA says.

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IV) Dealer Dave apparently thinks its awfully important to regulate metal detector use to prevent archaeological artefact looting (here we are agreed). In answer to what I wrote, he asks whether I can "establish that Cyprus is doing anything effective to actually regulate use of metal detectors on that island?" Well, despite the fact that it has nothing to do with the smuggling of antiquities, I suppose we could ask metal detectorists what they know about that. Here, for example, is a thread on a European metal detecting forum talking about beach detecting (not archaeological sites, shallow beach detecting is not - I would say - in general archaeologically destructive): "the local police [...] told her that anyone detecting on the beach or land would be scooped right away" (interesting to note another detectorist saying something quite significant in the circumstances: "Try the Turkish sector" since it is the looting following the Turkish invasion which is behind the whole fuss over Cyprus).

Dealer Dave is confused (and showing his woeful ignorance on the matter) when he says that metal detectors must be regulated because:

"metal detectors can only be used to search for buried metal artifacts"

Metal detectors are used in airports, schools, government offices and museums to check people entering the building, in food processing plants, sawmills, they are used by contractors to search for pipes and cables before using a mechanical excavator (or under plaster), they are used to search for lost change on beaches and fairgrounds (there are lots of You Tube videos of US detectorists getting excited by finding 1930s wheaties), they are used by meteorite hunters, gold prospectors. They can be used in token hunts on rallies, and childrens' games at English fairs, US exhibitions, and on the PAS website. All of which are archaeologically harmless (well, except - I would say - the PAS website one). This is one reason why I think the term "metal detectorist" is ambiguous and why when I am trying to be more lucid, I tend to speak of the problem I am concerned about as "artefact hunting".

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V) Neo-colonialist Dave says "

nations such as the Republic of Cyprus must solve their own problems, and that it is unfair and unreasonable to create difficulties for US collectors because foreign governments are unable to control the behavior of their own citizens. A government that cannot do that, ipso facto stands indicted as being incompetent to be the steward and guardian of cultural property of any sort.

Let's leave aside that obvious fact that (just as the looting of Iraqi sites when the country was under US/UK-led occupation), the problem of looting on Cyprus is not actually always a problem of the Cypriot government "not controlling" its OWN citizens; Mr Welsh apparently needs reminding that part of the island is under foreign occupation. Also I'd be interested to learn of a nation that has no criminals or ofenders - equally when it comes to making money out of ancient collectables.

Taking the sort of isolationist attitude expressed by Welsh above to its logical conclusion, Welsh would presumably then have the US withdraw from all international conventions involving international co-operation to achieve a common aim. For the rest of us, the illicit trade by culture criminals in items which form the world heritage is not the problem of any one government, but one of those problems that all thinking people should be concerned about and decent people should be joining in to do something about. That antiquity dealers and collectors see themselves as somehow above all that and even actively oppose it is a shame. I personally think they should indeed be shamed and ashamed of themselves for this and the way they go about it.

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I leave it up to the reader to decide the degree of intellectual honesty revealed by this polemicist. The original coiney commentator had in a brief text written at the behest of the dealers quite clearly got it wrong in several places. ACCG spokesman Welsh could have agreed and written something addressed to coineys to avoid a situation where they are all repeating the same nonsenses, wasting their own time and that of everyone else. Instead of doing that, Welsh sets out to convince his readers (among other things) that both the US law (CCPIA) as well as the Convention say something other than what they mean, though he provides not a smidgen of evidence (still less any kind of a link to the original text) to substantiate his claims.

Vignette: Dealer Dave thought it necessary to explain to his US readers what an ovicaprid is, for their information, this is not an ovicaprid, just looks a bit like one.

ACCG "Sell the Antiquities to US to pay off Eurodebt"

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Economic doom and gloom in Yurope has the coineys over in the US rubbing their hands with glee. They have been banging on for the last couple of months about how Greece and Italy could resolve their 'eurozone' financial problems by the simple expedient of emptying their museum storerooms onto the market and letting private collectors buy the formerly state property (assets) and use the cash raised to pay off their collective debts. According to the BBC, Greece's debt is 340 billion (UK billion 000 000 000) euros. If the US has a population of 312 700 000, that means that to allow this model to function, EACH and every US citizen would have to buy antiquities or work of art to the value of 1091 euros (1453 dollars).

Also according to the BBC, Italy needs 400bn next year to "refinance maturing debt, finance the deficit and pay interest". To pay for that for this year alone, EACH US citizen would have to fork out another 1710 on antiquities and works of art from their museum storerooms.

Of course they'd have to pay more, because the cost of selecting and deaccessioning the works to be sold off would have to be paid for, then packing it, cataloguing it, putting it on sale, the costs of safe transport to the dealer who will market it, insurance during transit. Then the dealer's overheads. And of course we cannot imagine ANY dealer selling a single one of these items without supplying proper paperwork detailing its legitimate origin and transport out of the country, and we all know how much dealers say THAT will cost them to produce. For every thousand dollars earned by Italy and Greece by this means, it seems the end buyer will have to contribute a considerably greater sum.

Now I am sure the dealers in such things would be very happy if suddenly (for the problems of Greece and Italy are urgent) 700 billion euros worth of antiquities and works of art suddenly appeared on the market for them to profit from. Those collectors who already have such items in their collections (maybe bought as a nest egg investment) might not be so happy, as their value would plummet as the market is flooded with quality goods.

But then how BIG is the art market? There is quite a nice Art Market Monitor article on that topic by Marion Maneker from October 1, 2009 which suggests that the short answer is "that the best guess at the size of the art market in 2008 would be $40 billion". Since then of course there has been expansion of the market maybe, but then a recession. The longer answer to the question “what’s a healthy level for the art market, especially in these difficult times?”– is "probably around $15 billion worldwide" (which as somebody pointed out is "puts it roughly on par with the pet food industry").

So, if these estimates (and there are others) give something like a realistic assessment of the size of the market, in order to raise money through the sales of art works "liberated" from state collections to pay off the debts of these two Eurozone countries, the market would have to expand between twenty (generous estimate) and 46 times to accommodate them - not only that, in order for the buyers to not lose money, it would have to be maintained at that higher level indefinitely. It seems to me that before such a move is even contemplated it would be useful to see the ACCG's thoughts on a business plan whereby the size of the art market as a whole can be increased 46 times in the sort time needed to achieve the effects they propose.

Of course this has been done before, for example the Bolsheviks sold off items from the state collections to finance their repressive regime, many of them ending up in US public collections where they remain to this day (Anne Odom, Wendy R. Salmond (Eds) 2009, 'Treasure into Tractors: The Selling of Russia's Cultural Heritage, 1918-1938, University of Washington Press). It seems some antiquity dealers would like to see the return of the days of the Robber Barons.

US Import Restrictions Only Apply to Illicitly Exported Items

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The accusation that many coineys with educations gained in US schools have fluff for brains seems to be increasingly confirmed not only by the ease with which their self-appointed leaders manage to convince them with false admonitions of "what the new MOU will mean for YOU" which they never check, but also by the flow of whingeing pseudo-justifications which has recently been emerging from the milieu. Peter Tompa now asks: Do Import Restrictions Only Apply to "Illicitly Exported" Items?

Do MOU's only apply to "illicitly exported" artifacts as archaeo-blogger Paul Barford has claimed? No. In fact, import restrictions as applied by US Customs bar entry of coins openly and legitimately sold in markets abroad merely because they are of a type on a designated list.

Whoah, whoah. What is the CONNECTION between "openly and legitimately sold" within a country and "openly and legitimately exported"? None. As these clowns well know. The coiney lobbyist whinges on:

First, for coins coming directly from the country for which import restrictions are granted, there is an exception if they are accompanied with an export permit.

"OK, your starter for ten, fingers on the buzzers: "what do we call a coin exported from a country which has export restrictions which is accompanied by an export licence?"..." [buzzzz]
"Yes, Oxford Magdalene, "licitly exported". That is the correct answer".

"Fingers on the buzzers, now what do we call a coin exported from a country which has export restrictions which has been taken out of the country without getting an export licence?" [buzzz] "No, I am sorry Wisconsin Numismatic Academy, the correct answer is "illicitly exported", bad luck".

"Fingers on the buzzers again, what is the correct legal term for a coin removed from a country which does not issue export licences for archaeological artefacts and therefore has none? Anyone?" " [buzzz] "Yes, Wisconsin... No... no. No, the correct answer is that we call such a coin 'illicitly exported', or simply smuggled, bad luck again..."
[inaudible]

"No, Wisconsin, if it left the source country illegally, it makes no difference whether it passed through another country - since it arrived there illicitly; can we pass on t..."

[inaudible] "No, Wisconsin, the ten year "get out clause" as you put it is just a local convenience, which does not negate the principles established by the international agreement, so if we could... and there is no need for that sort of language, ...".
[raises eyebrow, discretely makes note to producer never to ask these rowdy peabrains back to University Challenge].

Three days later, the TV production company got an indignant letter from the principal numismatist of the Wisconsin Coin Academy, protesting:

The import restrictions discussed on the programme are both illogical and themselves definitely illicit, according to the 1983 CCPIA implementing US accession to the 1970 UNESCO Convention. That [is a] very clear contravention of the terms of the CCPIA...

They ignored the letter as the writings of a madman of course.

Basically, if you have an antiquity of a type which is on the designated lists (which certainly contain many, many more categories than just a few scrappy coins) and you want to import it into the US either get the seller to obtain an export licence, or failing that as the CCPIA (19 U.S.C. 2601 et seq.) SECTION 2606, Import Restrictions, (a) Documentation of lawful exportation (note that title, Peter Tompa in particular) states: "unless the State Party issues a certification or other documentation which certifies that such exportation was not in violation of the laws of the State Party". Note this has nothing to do with "open and legitimate sale within the country". Neither has it anything in the least connected with its 'provenance' or collecting history. This is purely and simply about lawful export (note that title everybody, Peter Tompa and coin dealers in particular).

All is not lost even if you've not got one of those, the actual text of the CCPIA contains a useful get-out clause [2606(c)(1)(B)] "a statement provided by the consignor, or person who sold the material to the importer, which states the date, or, if not known, his belief, that the material was exported from the State Party not less than ten years before the date of entry into the United States, and the reasons on which the statement is based". Not even on oath, not even asking for any supporting material to be supplied. Basically scribbling down some (could be made-up) story of innocence.

Now the reason the silly whingers are complaining about even this is that they reckon a fellow dealer scribbling such a note on a company letterhead would - they assert - cost "more than the coin itself". So who else, except dumber-than-my-cat coineys, would do business with a seller that would charge you an arm and a leg for putting down a few words on paper why the circumstances of the sale of these particular coins are not breaking the law? How much were Spink's charging to scribble a note about the coins seized in Baltimore on their way to the ACCG? Did they not know the US law on the imports of such items and ignored it? Not very professional, is it?

Remember what article 3 of the 1970 UNESCO Convention, implemented in the US by the CCPIA, says.

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UPDATE 28.11.11: Dealer Dave attempts to defend the logic of Peter Tompa by incomplete sentences (at the beginning of his "commentary" to a lengthy cut-and-paste) and tekkie language (at the end of his insulting "commentary" to a lengthy cut-and-paste). Between them however is nothing which refutes the notion that commerce in objects removed from a country in disregard of its export licensing procedures is anything except illicit. Perhaps instead of insulting and merely ridiculing those whose views differ (from those of which he wants to convince coineys and others), it might be more useful to actually indicate, citing chapter and verse, where I am wrong here instead of merely sniping without providing justification [except his wholly irrelevant assertion that Peter Tompa probably earns "ten times as much" as me for lobbying on behalf of the coin sellers. He probably does, that does not make doing what he does right].

UPDATE 28.11.11 (bis)
"Any reader interested in finding out the omitted details will have little difficulty doing that". Yes, I suppose not quoting (this time) beyond the first sentence and not giving a link saves the coiney readers of the coin dealer's blog from having to bother their confused brains about what it says here about what an "illicit export" is. Any readers he has who have not got fluff for brains will take note of his manipulation and whether the Dealer Dave "Ancient Coins" blog or this PACHI blog is a better source of information for responsible collectors on what the law actually says.