The U.S. government and Bulgaria have agreed to a memorandum of
understanding that imposes import restrictions on certain
archaeological material from Bulgaria, among them a wide range of
coins that includes some produced as recently as 1750.
The restrictions were published in the Federal Register on Jan.
16, 2014, and became effective Jan. 15 for a five-year period. The
memorandum of understanding was signed by U.S. ambassador to Bulgaria
Marcie B. Ries and Bulgaria’s culture minister, Petar Stoyanovich, at
the National History Museum in Boyana Jan. 14.
With the signing of this MOU, Bulgaria joins Cyprus, Greece, China
and Italy in having import restrictions including coins. These
restrictions have the potential to affect coin collectors by limiting
the import of certain types of coins into the United States.
Designed to protect heritage
The import restrictions are designed to control illegal
trafficking of cultural property through international cooperation
designed to preserve cultural items that are of importance to the
nations where they originate and to contribute to greater
international understanding of history.
The agreement enables import restrictions on categories of
archaeological material representing Bulgaria’s cultural heritage
dating from the Neolithic period (7500 B.C.) through approximately
A.D. 1750 and ecclesiastical ethnological material representing
Bulgaria’s Middle Ages (A.D. 681) through approximately A.D. 1750.
The text accompanying the restrictions explains that a culture’s
archaeological items including coins, “often constitute the very
essence of a society and convey important information concerning a
people’s origin, history, and traditional setting.”
It added, “The importance and popularity of such items regrettably
makes them targets of theft, encourages clandestine looting of
archaeological sites, and results in their illegal export and import.”
Five coin categories included
The determinations of what would be included in the restrictions
were made on Nov. 20, 2012, by the U.S. State Department.
Five categories of coins are described that are inclusive of
nearly all coins produced in Bulgaria during antiquity except for
coins from Roman Imperial mints:
➤ Pre-monetary media of exchange including “arrow money,” bells,
and bracelets. Approximate date: 13th century B.C. through sixth
➤ Thracian and Hellenistic coins struck in gold, silver, and
bronze by city-states and kingdoms that operated in the territory of
the modern Bulgarian state. This designation includes official
coinages of Greek-using city-states and kingdoms, Scythian and Celtic
coinage, and local imitations of official issues. Also included are
Greek coins from nearby regions that are found in Bulgaria.
Approximate date: sixth century B.C. through the first century B.C.
➤ Roman provincial coins — Locally produced coins usually struck
in bronze or copper at mints in the territory of the modern state of
Bulgaria. May also be silver, silver plate, or gold. Approximate date:
first century B.C. through the fourth century A.D.
➤ Coinage of the First and Second Bulgarian Empires and Byzantine
Empire — Struck in gold, silver, and bronze by Bulgarian and Byzantine
emperors at mints within the modern state of Bulgaria. Approximate
date: fourth century A.D. through A.D. 1396.
➤ Ottoman coins — Struck at mints within the modern state of
Bulgaria. Approximate date: A.D. 1396 through A.D. 1750.
The Ancient Coin Collectors Guild has warned collectors about the
possibility of this request since 2011, and on Jan. 17, 2014, the
group filed Freedom of Information requests with the State Department
and U.S. Customs to learn why the decision to restrict importation was
made despite the fact that many of the coins included in the
restrictions circulated widely outside of Bulgaria and are collected
by Bulgarian collectors.
A public comment period on www.regulations.gov opened on Oct. 14,
2011. In total, 502 comments were posted before the comment period
closed on Nov. 2, 2011.
The ACCG summarized these as being 70 percent opposed to either
the MOU or the extension of restrictions to include coins.
Why were coins included?
During a Nov. 16, 2011, meeting of the Cultural Property Advisory
Committee — which advises the president on the appropriate U.S. action
in response to governments seeking assistance in protecting their
cultural heritage — several individuals spoke for and against the
inclusion of coins in the restrictions.
Among those supporting a position that limited the inclusion of
coins in the MOU was Kerry Wetterstrom, editor of The Celator, a
journal on ancient coins, who was representing the ACCG. Wetterstrom
indicated that huge amounts of coins came out of Bulgaria in the 1990s
with the fall of communism and that some issues, including Roman
provincial coins that were struck in Bulgaria, remain a glut on the
market. He suggested that Bulgaria adopt a law similar to the United
Kingdom’s Treasure Act and Portable Antiquities Scheme, which promotes
finders sharing details about their finds with scholars.
Basis for decision
The group’s executive director, Wayne Sayles, stated in a press
release, “The ACCG is particularly interested in learning the basis
for the State Department’s apparent conclusion that all coins produced
in Bulgaria from ancient times to 1750 must be considered local issues
that only circulated within the confines of the modern Bulgarian
Sayles characterized the category of “Greek coins from nearby
regions that are found in Bulgaria” as bizarre and commented: “It will
be interesting to see how the Department of Homeland Security decides
whether such a coin arriving at a U.S. port falls under the MOU with
Greece or under the MOU with Bulgaria. If seized, which country should
the coin be returned to? Following the above statement’s logic, all
ancient coins found outside their source country should be governed by
the laws of the country where they are found.”
Peter Tompa, a Washington, D.C., attorney who has written
extensively on the issue and is a board member of the ACCG, said,
“State and U.S. Customs only have authority to restrict coins first
discovered within and subject to Bulgarian export control, but they
have placed restrictions on all coins struck in Bulgaria over a 2,000
year period, even ones of gold and silver that circulate very broadly
He is concerned that the restrictions will place particular
hardships on U.S. collectors. “It’s not just a problem for ancient
coin collectors — these restrictions go up to 1750,” he said. “And,
all these coins are widely available for sale within Bulgaria and the
rest of the European Union. Only American collectors are impacted.
Bulgaria has a corrupt cultural establishment which is the root cause
of its problems. Import restrictions on Americans won’t help. Change
must take place in Bulgaria itself.”
Tompa warns that the MOU with Italy is up for renewal in 2015, and
he believes archaeologists will likely again seek restrictions on
Roman Imperial coins, which he predicts “would be a debacle for the
trade and collectors.”
A protective perspective
Nathan T. Elkins, an assistant professor of art history with a
specialization in Greek and Roman art and Roman coins at Baylor
University, says that the MOU represents the first time that
post-Classical coins, including some Byzantine, medieval and Ottoman
coins that were made and circulated in Bulgaria, are covered.
He adds, “As for the ancient Greek and Roman coinages, what is
protected in the new restrictions is analogous to what is protected in
other MoUs: types that circulated primarily in the countries with
which there is an agreement.”
Elkins said that he’s deeply interested in numismatics and that
“one does not have to be a collector or supportive of an insensitive
market to be a student of ancient money.”
Elkins characterized the MOU as focusing on types of coins that
circulated locally in Bulgaria, such as Greek coins of Bulgarian
cities and Roman provincial cities in Bulgaria that are primarily
found locally. He notes that the MOU excludes many broadly circulating
types, stating: “Look at what is not covered, although these are
commonly found in Bulgaria: Roman Republican and Imperial silver
denarii and aureii, as well as the late Roman imperial bronze coinage.
These coins, while commonly found in Bulgaria, circulated widely
across the Mediterranean.”
Elkins characterized the MOU as protective of archaeological sites
and historical information. “This, by no means, outlaws a trade in
coins of Bulgarian type”. He concluded: “This ought to be no problem
for scrupulous dealers and conscientious collectors. We all value the
past and we should not want to see historical information damaged for
In a statement made concurrent to the signing of the MOU,
Ambassador Ries said: “Of course this agreement will not eliminate the
problem overnight. We recognise that and we also recognise that we
must continue to work creatively together to preserve what we all
recognise to be an invaluable cultural heritage. This agreement is of
importance for its substance but also because it means more
cooperation on a daily basis in the area of culture which is of
importance to both Bulgarians and Americans.” ■