New restrictions on coins minted within Egypt include widely circulated Roman Egyptian pieces

New rules impact broad range of items, affect copper, silver, gold coinage
By , Coin World
Published : 12/09/16
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New import restrictions involv­ing a broad group of ancient Egyptian coins have the potential to impact collectors in the United States by restricting the movement of affected coins into the country.

The agreement — called a Memorandum of Understanding — was made between the United States and Egypt on Nov. 30 and includes a wide range of materials created across different periods and cultures dating from 5200 B.C. through 1517 A.D. Included are items from Egypt’s Predynastic, Pharaonic, Greco-Roman, Coptic, and Early Islamic through the Mamluk Dynasty eras.

The new import restrictions were published in the Dec. 6 Federal Register and represent the first cultural property protection agreement between the United States and a country in the Middle East and North Africa region. A Nov. 29 State Department press release stated, “Restrictions are intended to reduce the incentive for pillage and trafficking and are one of the many ways the United States is fighting the global market in illegal antiquities.” It explained, “The cultural property agreement, negotiated by the State Department under U.S. law implementing the [UNESCO] 1970 Convention on the Means of Prohibiting and Preventing the Illicit Import, Export and Transfer of Ownership of Cultural Property, underscores the United States’ commitment to our relationship with Egypt, as well as our global commitment to cultural heritage protection and preservation.”

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These MOUs are initiated by the country seeking protection and effectively shift the burden of proof. Prior to an MOU, Egypt needed to prove that an item was looted to enforce trade restrictions. With the MOU’s implementation, the burden shifts to the seller of an item included in the covered items to prove that it was legally imported or has been outside of Egypt since 1970. This type of documentation can be challenging for coins, which by their nature are small, often look similar to one another, and often lack provenance.

Upon signing the treaty Secretary of State John Kerry said, “I think it’s a good moment for Egypt, the United States, for the region, for us to make it clear that these antiquities are priceless treasures that do not belong to traffickers and crooks and should not be sold illegally and bought by wealthy people to hide away somewhere,” adding, “They are the antiquities that belong to the world, that have been protected and should be protected by an old civilization.”

Broad range of items

The restricted items are organ­ized in three broad categories. The first, stone, includes sculpture, vessels and containers, funerary objects and equipment such as sarcophagi and coffins, tools and weapons. The second, metal, contains largely the same but also includes jewelry, amulets, seals, armor and coins.

The coin category is broad and covers copper or bronze, silver and gold issues referenced in several books that are named in the guidelines published in the Federal Register. Among the books referenced for Hellenistic and Ptolemaic coins are: A Catalogue of Greek Coins in the British Museum: Alexandria and the Nomes and Ptolemaic Coins: An Introduction for Collectors by R.A. Hazzard. Examples of catalogs listing Roman coinage in Egypt are J.W. Curtis’ 1969 book The Tetradrachms of Roman and Roman Provincial Coinage I: From the Death of Caesar to the Death of Vitellius (44 BC–AD 69) and Roman Provincial Coinage II: From Vespasian to Domitian (AD 69–96).

The restrictions are more specific when addressing Hellenistic and Ptolemaic coins struck in gold, silver, and bronze at Alexandria and any other mints that operated within the borders of the modern Egyptian state. The restrictions include gold and silver coins struck in honor of Alexander the Great at the mints of Alexandria and Memphis.

The text of the restrictions tries to help those tasked with enforcing them to identify the subject coins by including some descriptions of the physical coins themselves.

For Ptolemaic coins it states, “Gold coins of the Ptolemies from Egypt will have jugate portraits on both obverse and reverse, a portrait of the king on the obverse and a cornucopia on the reverse, or a jugate portrait of the king and queen on the obverse and cornucopiae on the reverse. Silver coins of the Ptolemies coins [sic] from Egypt tend to depict a portrait of Alexander wearing an elephant skin on the obverse and Athena on the reverse or a portrait of the reigning king with an eagle on the reverse. Some silver coins have jugate portraits of the king and queen on the obverse.” It then explains, “Bronze coins of the Ptolemies commonly depict a head of Zeus (bearded) on the obverse and an eagle on the reverse,” before clarifying, “These iconographical descriptions are non-exclusive and describe only some of the more common examples. There are other types and variants.”

Finally, the import restrictions include Roman coins struck in silver or bronze at Alexandria along with any other mints that operated within the borders of the modern Egyptian state in the territory of the modern state of Egypt until the monetary reforms of Diocletian.

Other categories include objects made of ceramic, clay, wood, ivory, bone, shell, plaster, glass, textile, leather and other mediums.

Flawed restrictions?

Many in the numismatic com­munity believe that these import restrictions are flawed since ancient coins traveled far beyond their place of origin. For example, Roman Egyptian tetradrachms, which had the value of one Roman silver denarius, traveled far and have been found in hoards in Britain. The area considered today as Ptolemaic Egypt stretched far beyond Egypt’s present borders, encompassing modern-day Libya, Israel, Lebanon, Syria, Cyprus, and Turkey.

Those favoring the restrictions say that they are essential to helping protect archaeological sites and preserving the archaeological record.

Egypt’s government filed a cultural property request with the United States in April 2014 seeking import restrictions on archaeological and ethnological material from Egypt.

The Cultural Property Advisory Committee met June 2 to 4, 2014, in Washington, D.C., to consider whether to accept or deny the Egyptian request. Prior to the meeting 352 public comments were submitted to CPAC, with the majority of comments coming from those representing the coin hobby and trade. Most comments favored not including coins in the import restrictions.

In a Nov. 30 post to his blog Cultural Property Observer, attorney Peter Tompa wrote that in signing the MOU, “the Administration has ignored 91% of the public comment to CPAC which raised serious concerns with any MOU. Moreover, the decision once again raises the question whether there was any ‘done deal’ from the outset.”

The week before, Tompa com­mented on MOUs more broadly, writing, “Unfortunately, they have become little more than a special interest program for a small group of connected academic archaeologists and the cultural bureaucracies of countries where they excavate.” Tompa then wrote, “the interests of ordinary Americans who collect ancient coins and other cultural artifacts and our great museums have been damaged for years by hard to comply with import restrictions.”

To support the imposition of import restrictions, on Nov. 14, 2014, the assistant secretary for Educational and Cultural Affairs, Department of State, made the determinations for import restrictions, following guidelines established in 1983’s Convention on Cultural Property Implementation Act. First, it was determined that the cultural patrimony of Egypt is in jeopardy from the pillage of archaeological material from a broad swath of its history. Second, it found that the Egyptian government had taken measures to protect its cultural property and that import restrictions imposed by the United States would be of substantial help in deterring a serious situation of pillage and that less drastic remedies are not available.

Finally, the State Department determined that the import restrictions are consistent with the general interests of the international community in the interchange of cultural property among nations for scientific, cultural, and educational purposes.

The United States currently has bilateral agreements with 16 countries around the world, as well as emergency import restrictions on cultural property from two other countries, Iraq and Syria.

Evan Ryan, the U.S. assistant secretary of state for Educational and Cultural Affairs, said on the restrictions, “We want people to know that the United States will no longer be a market for these items.” She concluded, “We want Egypt to understand that we respect their history and their culture, just as much as we hope that people respect ours.”

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