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News on the Memorandum of Understanding (MOU)

September 16th, 2010 – The Republic of Greece has requested that the United States impose import restrictions on Greek cultural artifacts from the Neolithic period until the mid-18th Century. The precise contents of the request remain secret, but the State Department has published a “Public Summary” that suggests coins may be included. The State Department is only allowing for a short public comment period that ends on September 22, 2010. Comments made during the Italian renewal process WILL NOT be reviewed for purposes of the Greek request.

To date, import restrictions have been put on Cypriot and Chinese coins. Last May, almost two thousand collectors wrote the State Department to express disapproval of any effort to extend import restrictions to Greek and Roman coins from Italy. That decision remains pending. Now, however, collectors must act quickly again to head off equally devastating import restrictions on Greek coins struck as late as the 18th c. (This includes Greek, Greek Imperial, Byzantine, Venetian, Crusader and Turkish issues.).

The effect could be significant. Restrictions allow US Customs to seize coins on a “designated list” without regard to their place of discovery unless they are accompanied by extensive documentation proving they were out of the country for which restrictions were granted before the date the restrictions were imposed. If restrictions are put in place on coins from Italy and Greece, it will become much more difficult to import such coins legally into the United States. Prices will rise and it may even become financially impossible for dealers to import many of the common coins most people collect.

You can read all about the Greek request at http://exchanges.state.gov/heritage/whatsnew.html (note that Greece's formal name "The Hellenic Republic" is used).

Comment procedures have also changed. You can no longer fax your comments. Regular mail goes through security clearing and can take weeks to reach the State Department. Instead, the State Department will accept comments online through the website http://regulations.gov.
For a direct link to the comments page, click here.

If that does not work, try the following. Go to http://regulations.gov Enter the docket number "DOS-2010-0339" into the "Enter Keyworld or ID" field and click "Search." In the search results select the check box for "Notices" – this will filter the results so that only the official notice is showing. Finally, click on "submit a comment" under actions.  Fill in the box and submit it. After a day or so, your comments will then appear with those of other collectors (as well as those in favor of restrictions).

It’s always best to say what you feel in your own words, but these points can certainly be made:

* The governing statute requires that restrictions only be applied on artifacts "first discovered in Greece." But hoard evidence demonstrates that Greek coins circulated extensively outside the confines of the modern Greek nation state.

* The governing statute requires restrictions only be placed on artifacts of "cultural significance." But coins – which exist in many multiples – do not meet that particular statutory criteria, which is a “term of art.”

* The governing statute requires that less drastic remedies be tried before import restrictions. But Greece has not tried systems akin the UK Treasure Act and Portable Antiquities Scheme before seeking restrictions.

* The governing statute requires that restrictions be consistent with the interests of the international community in cultural exchanges. But restrictions will diminish the ability of American collectors to appreciate Greek culture and could greatly limit people to people contacts with other collectors in Europe.

* Restrictions are unfair and discriminatory to Americans. Collectors in the EU – including Greece – have no similar limitations on their ability to import ancient coins.

What you say is important. But it’s most important that you let the State Department Cultural Property Advisory Committee know of your concern about the potential impact of import restrictions on legitimate collecting.

Thanks in advance for your comments on this important issue for collectors.

Peter Tompa

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