Bulgarian coins next target?

ACCG warns of import restrictions
Published : 11/13/11
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The Ancient Coin Collectors Guild in late October alerted collectors to the possibility of import restrictions on Bulgarian coins, and prepared and filed an appeal in its legal case challenging the legality of import restrictions on certain ancient coins from Cyprus and China.

The organization continues to address both existing and proposed U.S. State Department import restrictions affecting ancient coins.

On Aug. 8, Maryland U.S. District Court Judge Catherine Blake issued a 52-page opinion stating that the court did not have review authority over a decision of the U.S. State Department and Customs and Border Protection regulations. The ACCG’s Board of Directors decided to appeal her ruling on Aug. 23.

ACCG files appeal

On Sept. 20, the ACCG filed a notice to the federal Court of Appeals that it intended to appeal, which was filed Oct. 31 in the U.S. Court of Appeals for the Fourth Circuit. The organization requests that the appellate court reverse Judge Blake’s decision and remand the case for further proceedings.

The ACCG is represented in the case by attorneys Peter Tompa and Jason Ehrenberg. In an Oct. 31 email, Tompa stated, “A number of interested parties will also be filing supportive amicus briefs.” Amicus or “friend of the court” briefs typically are submitted by nonprofit organizations, corporations, governments or other affected parties to add information not presented by the parties at trial. They are often public policy statements that show the impact of the court’s ruling on an industry or group.

ACCG tests policy

The ACCG launched the case in April 2009 when it imported a group of 23 low-value ancient coins from Cyprus and China specifically to challenge existing import restrictions on Greek and Chinese coins. Although import restrictions potentially protect archaeological sites, they pose challenges to U.S. coin collectors and dealers because as a practical matter, they prevent the legal entry of the vast majority of common ancient coins that are readily available abroad.

Import restrictions expand

In the past several years, an increasing number of countries including Greece, China, Cyprus and Italy have requested import restrictions, although the requests don’t always include coins. Bulgaria recently requested U.S. import restrictions on cultural property.

While the State Department did not indicate whether coins were part of Bulgaria’s request, the ACCG wrote in an Oct. 20 press release, “based on recent history, it is probable that import restrictions on coins will be proposed. As a practical matter, this means the State Department may be considering restrictions on tribal coinages from Thrace, coins of Greek city states like Apollonia Pontica and Messembria, Roman provincial coins struck at Bulgarian mints, and even some Roman Imperial coins.”

The ACCG press release also noted that coins from Bulgarian mints are typically common and often inexpensive, “and because of the low price the vast majority of these coins will never have been through an auction and will have no verifiable provenance.”

The public summary of the import restriction notes that Bulgaria’s request includes restrictions on objects from 7500 B.C. to the 19th century A.D.

Public comment closed

The window for members of the public to submit comments to the U.S. State Department’s Cultural Property Advisory Committee online closed Nov. 2.

The ACCG has been successful in getting large numbers of coin collectors to submit public comments. Recently when a memorandum of understanding with Greece was opened to public comments, 70 percent of the comments that CPAC received were from concerned coin collectors.

Bulgaria’s request will be reviewed during a Nov. 15 to 17 meeting of the Cultural Property Advisory Committee ■

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