The ancient coin dealer lobby, primarily the Ancient Coin Collectors Guild (ACCG), consistently makes an effort to dissuade CPAC from the protection of coins each time a request for an MOU is made. Their arguments have been repeated recently since the Cultural Property Advisory Committee (CPAC) has asked for public comment on a potential MOU with Egypt that would place limits on imports of cultural and archaeological items into the U.S. that lack documentation prior to the date of enactment of that potential MOU. Namely, the lobby says coins are "common" and therefore do not warrant protection because they are not culturally or archaeologically significant, or they say it is impractical to protect coins since they circulated widely, and so one cannot say where a coin came from since dealers and suppliers do not record or track find spots. A few commentators have been so bold as to assert that there is no evidence that looted material from Egypt has made its way to American markets.
Those assertions are problematic.
1. The fact that coins were widely produced is precisely what makes them archaeologically and culturally significant. Coins communicated civic identities and/or political ideologies, whether "high art objects" or not, although the ancient understanding of "art" was very different from our modern understanding. And in Greek and Roman period excavations, coins are often one of the most common types of small finds, apart from pot sherds. Coins are vital chronological indicators and also speak to economic conditions at various sites. When one removes them from a site without record, what can be said about that site and the ancient people who lived or conducted activity there is greatly diminished. Imagine if there were a lobby attempting to exempt ancient ceramics from protection in MOUs; these are equally significant as coins, even though they are exponentially more "common" than coins. And their removal from sites is equally destructive to archaeology and the writing of history. Coins are both archaeologically and culturally significant objects; it is clandestine digging, looting, and smuggling of coins that neutralizes their potential archaeological value and diminishes their cultural value.
2. One of the most recent cases that demonstrated that Egyptian material is being smuggled into the United States is that of U.S. v. Khouli et al. In addition to Egyptian sarcophagi smuggled into the U.S., two of the involved defendants have also sold ancient coins in North America: Khouli and Alshadaifat. Alshadaifat operates a wholesale business and has supplied Egyptian and Middle Eastern coins to dealers and collectors in the United States.
In the public comments on the potential MOU with Egypt, it is remarkable that a number of coin dealers are asserting that coins ought not be protected because they circulated widely. This is, of course, a strained argument to make in view of the fact that ancient Egypt famously had a closed currency system in both the Ptolemaic and Roman periods. This does not mean that Egyptian coins are not found outside of Egypt - they are. But the vast majority of Egyptian coins are found in Egypt. One reason for Egypt's closed currency system may have been Egypt's need to retain silver since there were no silver resources in ancient Egypt; topography also isolated Egypt. In fact, Egypt's closed currency system is perhaps the best-known instance of locally or regionally circulating coinage in the ancient world and it is widely discussed in both collector and scholarly literature. A few examples include:
- E. Christiansen, Coinage in Roman Egypt: The Hoard Evidence. (Aarhus: Aarhus University Press, 2004, 40-46, 98, 133, 136-137, 140-141.
- E. Christiansen, The Roman Coins of Alexandria: Quantitative Studies. (Aarhus: Aarhus University Press, 1988), 11.
- J.W. Curtis, The Tetradrachms of Roman Egypt. (Chicago: Argonaut, 1969), ix-x.
- R.A. Hazzard, Ptolemaic Coins: An Introduction for Collectors. (Toronto: Kirk & Bentley, 1995), 71 et passim.
- J.G. Milne, Catalogue of Alexandrian Coins. (Oxford: Oxford University Press, 1933), xv-xvi.
- S. van Reden, Money in Ptolemaic Egypt. (Cambridge: Cambridge University Press, 2007), 33.
One popular book with ancient coin collectors, written in the 1990s , made note of Egypt's closed currency zone (W. Sayles, Ancient Coin Collecting IV: Roman Provincial Coins. (Iola, WI: Krause, 1998), page 87.). The author of that book is Wayne Sayles, the executive director of the Ancient Coin Collectors Guild (ACCG), although he made reference to Egypt's closed currency zone before he founded and took on the leadership of the lobby group in 2004. Interestingly, in his comments to CPAC concerning a potential MOU with Egypt, incongruous with what he wrote 16 years before, he proclaims: "Coins struck in Egypt during antiquity traveled widely then, and since then, as instruments of monetary exchange and of cultural interest." He refers also to Peter Tompa's letter, which addresses examples of coins of Egyptian type found outside of Egypt and characterizes Egyptian coins as circulating widely (Tompa is the ACCG's attorney and lobbyist). Both Sayles and Tompa overlook the fact that these foreign finds are exceptions, not the rule, and that the vast majority of Egyptian coins are found in Egypt, which had a closed currency system in the Hellenistic and Roman periods.
Fortunately, the distinguished members of CPAC take account of the substance of comments and evidence presented to them during the period of public comment.