Although the State Department seems to be on a long holiday and is not posting up any new comments on the Regulations.gov website, it seems that unless there was a huge spurt over the Christmas break that there will a rather shallow public response to this one, I guess a few hundred at the most. Sadly, most of them will be crazed coineys alarmed by something or other and all of them opposing the continued scrutiny of fresh coins coming to the US market from abroad. It is interesting to speculate on why the numbers of those roused by the ACCG campaigns is dropping quite sharply from several thousand a while back to mere hundreds recently. Is it because it is gradually dawning on collectors that they really have been led by the nose by alarmist projections and fantasies and conned into giving a knee-jerk reaction to an imagined threat? Is it because one by one they've actually been reaching for the actual wording of the CCPIA and having a moment of realisation what it actually regulates? Let's hope so, and that 2012 represents a change in the so-called Guild of collectors that is actually going to start giving collectors real facts about the CCPIA and not made-up ones and alarmist rabble-rousing projections (OK, that's a really slim hope, isn't it?).Anyway, I thought I'd add my voice alongside theirs, so as not to let the side down.
As somebody deeply concerned about the illicit international trade in antiquities and other cultural property and the role of US dealers and collectors in this, I support the renewal of the MOU with Cyprus to help curb the movement of illicit antiquities across US borders by increased scrutiny of imports as per Art. 3 of the 1970 UNESCO Convention and the CCPIA. It gives out a strong message of US commitment to equitable relations with the international community in such matters.There are still two days for you, gentle reader to put on the White Hat and stand up against cultural property philistinism. Cut and paste if you like, the coineys are convinced nobody at the State Department ever reads this stuff or passes it on to the CPAC.
The rich cultural heritage of Cyprus continues to be seriously threatened by looters who, in defiance of antiquity preservation laws, are systematically and clandestinely stripping sites of collectable items many of which are destined for sale on foreign markets. Cyprus applies the measures envisaged in the Convention to attempt to combat this looting but the financial temptations of the international no-questions asked market for smuggled goods (and the US market plays a potentially big role) encourage criminals to try and subvert these efforts.
I would ask the CPAC to urge the appropriate US authorities to pay especial attention to the US trade (both across the country’s borders as well as internally) in what the trade persists in calling “minor antiquities”, and in particular in dug-up coins. Coins like any other archaeological artefacts illegally taken out of the archaeological record and unlawfully exported cannot be exempt from scrutiny. Yet this is what the people who profit from trading this type of material would apparently like to see. It cannot fail to escape the notice of the CPAC that US coin dealers and their lobbyists are currently engaged in active opposition to the imposition of import controls on items without documentation of lawful export (19 U.S.C. 2606) which can only draw attention to the current form of the market for such items in the US. The comments in this docket include those of a few hundred collectors (among the 50 000 collectors of ancient coins the lobby group the Ancient Coin Collectors’ Guild claims). They, fired up by the alarmist rhetoric of the dealers’ lobbyists, oppose restricting imports onto the US market to only those with documentation of what the CCPIA considers to be lawful export. Their collective voice in favour of the reintroduction of an unrestricted flow onto the US market of freshly imported archaeological artefacts such as ancient coins without documentation of lawful export shows why it is so important that US vigilance is maintained.
The US needs to maintain their tough stance with anyone attempting to abuse the system and continue to seize illicitly-exported material of this type at the US borders (in accordance with the measures envisaged by the 1970 Convention), and in doing so help make international controls on the movement of illicit artefacts more effective.
Closer scrutiny of archaeological and ethnographic material of Cypriot origin crossing US borders is a non-drastic means of providing this help and respecting the obligations of the USA and other states parties under the 1970 UNESCO Convention.
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6 comments:
I presume the declining number of comments may have far more to do with the fact that the obdurate bureaucrats could care less what the public really thinks. Still, it hopefully won't escape notice in Congress that MOU's are little more than wasteful special interest programs for archaeologists that do little other than provide a prop for the corrupt status quo in countries like Cyprus.
Your suggestion that Cyprus is complying with its UNSECO obligations ignores information that most looted material goes to wealthy collectors within Cyprus itself with the full knowledge of Cypriot authorities.
In addition, you continue to misrepresent the impact of restrictions which as applied by US Customs bar import of any undocumented coin of Cypriot type rather than coins proven to be looted from Cyprus. This grossly overbroad formulation violates the plain meaning of the CPIA and forms the basis for most of the opposition to these restrictions from the numismatic community.
I don’t know, are you sniping deliberately to get me angry? Is that your aim, because you clearly are not coming here with the intent of talking his out properly.
"I presume the declining number of comments may have far more to do with the fact that the obdurate bureaucrats could care less what the public really thinks".
”could not care less” I suppose is what you meant. Why should they “care” when 90% of the people who write (ie most of the coiney rabble roused by your misleading alarmist announcements) cannot work out what 19 U.S.C. 2602 (a), A-D are all about. It’s like the Chalk Products Advisory Committee collecting comments on whether to import French chalk, and two hundred cheese manufacturers write in to say they don’t want imports of French cheese. They can hardly moan that the “bureaucrats don’t care” when there then is an MOU on French chalk imports can they?
Now, there actually is no 19 U.S.C. 2602 (a), E “find out what the buyers of items imported without documentation of lawful export think” in addition to the other four criteria. If there was, the comments your knee-jerk coineys are sending in might be taken into account. When, however, so few of them address the issues reviewed by CPAC but write about something else entirely, it is not surprising that their comments are not central to CPAC deliberations. [And that, Mr Tompa, is directly YOUR fault.]
"MOU's are little more than wasteful special interest programs for archaeologists"
like the conventions and legislations on animal parts and exotic species are wasteful special interest programmes for ecologists you mean? Or do you think it is possible that there ARE other people in the United States who do not approve of smuggling (without documentation of lawful export) of various things? My bet is that its not just "archaeologists" who care.
Your suggestion that Cyprus is complying with its UNSECO obligations ignores information that most looted material goes to wealthy collectors within Cyprus itself with the full knowledge of Cypriot authorities.
Well, I am sorry you are just going to have to spell out for the rest of it which of the 26 articles of the 1970 UNESCO Convention on the Means of Prohibiting and Preventing the Illicit Import, Export and Transfer of Ownership of Cultural Property that actually contravenes.
Can you do that please?
Instead, the Convention has a specific scope and a specific purpose, and what you describe is not part of it. The “L” word is not there, either in the title, nor in the contents. Let me remind you that it is the United States that reads the “looting” into a Convention which is in effect about “smuggling”.
"In addition, you continue to misrepresent the impact of restrictions which as applied by US Customs bar import of any undocumented coin of Cypriot type rather than coins proven to be looted from Cyprus. This grossly overbroad formulation violates the plain meaning of the CPIA and forms the basis for most of the opposition to these restrictions from the numismatic community".
Bollocks and self-serving crap, no other words for it. US coineys clearly are upset about restrictions being placed on their ability to trade in smuggled coins.
I am not “misrepresenting” anything. In any case, it is not “any coin of Cypriot type” but the specific types mentioned on the designated list. No “documentation” is required for anything except the simple declarations as set out in 19 U.S.C. 2606 (a). These are ENTIRELY within the scope of the meaning of the CCPIA, since they are incorporated within it.
But we have been through all that before, you are just sniping and arguing round in circles citing the same trite mantras that you use to befuddle the coineys and adding nothing whatsoever to the discussion. I am getting fed up with this repetition, can’t 2012 be the year when you stop playing the dealers’ paid clown and actually make some real contribution to the debate?
Isn't sniping what your blog is about? I actually can't think of anything positive you have said about anything.
As to the State Department's dictates about comments, these are obviously meant to try to limit comments to those supportive of restrictions. However, if a collector simply opposes import restrictions, that in a broad sense goes to issues of cultural exchange. And I have to say overall many of the collector comments are far more sophisticated than some of the AIA inspired cookie cutter reponses of the few proponents of restrictions.
As to the effect of the restrictions, you are uniquely unqualified to comment. Have you ever tried to arrange for the legal import of an item on a restricted list? Our views on that our informed by actual experience with US Customs.
As for Cypriot corruption, your blog has covered that issue, though you claimed it was no different than PAS. If you forget, take a look at the Looting Matters blog. A Swiss academic did research which suggested that most looted material goes to Cypriot collectors with the full knowledge and approval of Cypriot authorities.
You are way off base in general. The only reason to comment on your blog is to provide some counterpoint to your effort to obfuscate the issues for the uninformed.
Then SHOW me to be "way off base" rather than just sniping and insinuating. Bring the discussion on base, rather than merely dodging the issues as you just did in your "answer".
1) There is of course a difference between criticism and mere sniping.
2) The four criteria that CPAC looks at are laid down not by the "State Department" but by the CCPIA.
3) Yes, the AIA is less than impressive in any of this. Needs more effort.
4) As for import of items on the restricted list, I remember you saying you had (several times I recall) to prompt the ICE to stop the Baltimore coins - is that not the case?
The effect of import restrictions is to try to keep fresh illicitly exported coins out of the US market.
How the ICE works is really a matter not for the State Department, but ACCG needs to take it up with ICE. I guess it works the same for importers of all sorts of things such as animals and foodstuffs.
So how many items on the restricted list have you personally imported Mr Tompa? What "experience" have you personally had? why are the ACCG not collecting these together from dealers and collectors and putting them up on a website (who was importing what, when, from where with what documentation) so we can all see the scale and nature of the problem?
5) You HAVE NOT ANSWERED THE QUESTION when I asked you (precise article of the 1970 Convention) where what you described going on IN Cyprus is AGAINST the 1970 Convention which is of specific scope and nature.
Cultural Property Observer said
"I actually can't think of anything positive you have said about anything."
I guess it depends if you are conservation minded. Personally I find this blog highly positive.
@ Cultural Property Observer:
As the increased visits on this blog prove there seems to be a well received view here "on various aspects of the private collecting and trade in archaeological artefacts today and their effect on the archaeological record." Since you get paid for your statements I recommend you take a step back and let the "uninformed" continue to learn more about the aspects addressed in this blog and let them decide how to best protect our world cultural heritage.
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