[MSN] Import Restrictions Imposed on Cypriot Coins

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Import Restrictions Imposed on Cypriot Coins
by Wayne G. Sayles — last modified 2007-07-19 17:07

On Friday July 13th the US State Department imposed restrictions on importation of ancient coins "of Cypriot types" issued prior to AD 330.

The ACCG deplores this unprecedented extension of UNESCO inspired import restrictions to include historical coins of possible Cypriot origin.  In this action, without stating any justification or disclosing reasons for this decision, the State Department departed from its prior decisions exempting coins from import restrictions - even though the solid factual basis for this exemption has not changed. 
 
Under the CPIA statute, import restrictions should only be imposed on artifacts “found in the ground” of a specific country. There is no statutory authority to impose import restrictions based on where an artifact was made.  In imposing these import restrictions, the State Department has evidently accepted the argument that coins from Cypriot mints are “only found in the ground”  of the modern nation state of Cyprus—despite very substantial factual evidence to the contrary.
 
This decision is also questionable on procedural grounds. The State Department accepted this request by Cyprus to amend current restrictions on Cypriot archaeological artifacts to include coins after the period allowed for public comment had closed. When that provoked a flood of complaints, the State Department then allowed the numismatic community only a brief ten day window in which to comment.  An immense volume of public comments objecting to inclusion of coins flowed in, despite the unreasonable brevity of the period allowed. This overwhelming evidence of public concern and outrage apparently meant little to the State Department.

These and other procedural concerns regarding “due process” were raised in the attached correspondence to the State Department’s Inspector General’s office along with exhibits.  Regrettably, the IG declined jurisdiction, referring the issue back to the Bureau of Educational and Cultural Affairs, the very same State Department organization overseeing imposition of import restrictions, whose eventual reply is also attached.  That perfunctory, meaningless response shows a complete lack of respect or consideration for valid concerns of the numismatic community, and others interested in legitimate international exchange of cultural artifacts.
 
Import restrictions on coins of possible Cypriot origin give US Customs officers broad discretion to detain any coin that “looks Cypriot.”  The burden will then shift to the importer to prove that the coin was outside of Cyprus before July 13, 2007 (the date of the restrictions).  Coins lacking such documentation are subject to seizure.  Due to the absence of such documentation or provenance for most coins, there is a real danger that many coins which have not been in Cyprus since ancient times will be subject to seizure.  There is also a significant concern about the ability of Customs inspectors to distinguish coins struck at Cypriot mints from other coins in shipments that may include thousands of coins.  Overly broad application of import restrictions may destroy the traditional freedom Americans have always enjoyed in being able to import and collect historical coins, damaging the study and appreciation of these fascinating coins. Once again the State Department has
 put narrow interests of the archaeological community and certain foreign states above those of small businesses and ordinary American citizens who believe that collecting helps preserve the past and encourages the appreciation of other cultures.

http://accg.us/