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
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.
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
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.”