Tuesday, July 8, 2008

The ACCG "Benefit Auction" and Intrinsic Interests

I have critiqued the goals, motives, and tactics of the Ancient Coin Collectors Guild (ACCG) several times before (those unfamiliar with the ACCG are urged to consult a list of some relevant web-postings at the end of this discussion). For those who do not know, the ACCG is a 501 (c) 4 organization to which financial contributions are not normally tax deductible since up to 100% of its funds can be used for the purposes of political lobbying. According to its website, the goal of of the ACCG is to maintain a "free-market" in all coins. It has lobbied against legislative measures designed to protect archaeological and historical sites from destruction. A possible financial motive for its activities may be apparent in the fact that its founder and most of its officers are ancient coin dealers, and the majority of its financial contributors (especially the larger contributors) are ancient coin and antiquities dealers and auction houses.

In November of last year, the ACCG announced it was suing the U.S. Department of State under the Freedom of Information Act (FOIA) for more transparency on the process under which it decided to impose import restrictions, at the request of Cyprus, on certain ancient coins of Cypriot type. Many who are familiar with the "blogstorm" last fall about these issues will recall that several vocal ACCG members and dealers were alleging various conspiracies between archaeologists and State Department officials (links here and here to relevant posts, some of which reference dealer accusations). A "benefit auction" for which the ACCG has been soliciting donations, which it will auction on August 17, 2008, has now sparked my interest.

In March 2008, it was announced that the ACCG would host a "benefit auction" in order "to raise funds for anticipated legal expenses in opposition to State Department imposed import restrictions on ancient coins" (for the notice on the ACCG website, dated in April after an update, click here). What I find most peculiar, and perhaps telling, about the ACCG's announcement is that it came only one month after a judge set the schedule for the pending lawsuit, in which it gave the State Department until May 9, 2008 to handover requested documents or request exemptions and the ACCG would have until June 2, 2008 to decide whether or not it would continue to pursue action. The State Department's deadline was still months away as the ACCG was soliciting donations for "anticipated legal expenses" to challenge the State Department further.

What does this mean? Is this about more than transparency? One can only speculate.

In any case, the auction itself is interesting in the context of other discussions I have had on the ACCG and its activities (again, see a list at the end of this post). As expected, the level of provenance reporting is very low; only 12 out of 265 ancient objects donated so far have any recorded history whatsoever and only six of those have a pre-1970 collection history or are recorded in the Portable Antiquities Scheme (PAS). See Figure 1 for the level of reporting (click on the figures to enlarge). This falls in line with many ancient coin auctions. In the SAFE Feature, "Why Coins Matter..." [similar version at FeRA], I demonstrated that CNG, a major auction house for ancient coins in the U.S., only reported the history of a coin in about 20% of its lots, with only 0.17% of these pre-dating 1973 in its Triton X sale (Jan. 2007). Further research has indicated that in all of its printed sales in 2007, which included 22,681 ancient coins, 77.28% had absolutely no recorded history and only 1.89% had a history before 1973. Another major ancient coin auction house in the U.S., Freeman & Sear, offered 3,384 ancient coins in its printed auctions and mail lists in 1973; less than 5% of the descriptions provided any previous history on the coins and only 1.15% (39 coins) had a history before 1973.

Typically, auction houses are the most diligent about recording provenances; when one considers the masses of coins that are sold on eBay, VCoins, and in other venues, we can imagine over 99% of ancient coins are sold without any recorded history. One coin dealer has vigorously asserted that very little in the way of fresh material enters the market and that much of what is sold has been bought and sold since the Renaissance and the provenance merely lost. Can he really expect us believe this, when we constantly hear of reports of antiquities smugglers and looters in sources countries being caught with large caches of ancient coins among other objects and when massive shipments are intercepted by Customs officials? (R. R. Dietrich, "Cultural Property on the Move - Legally, Illegally," International Journal of Cultural Property 11.2 (2002): 294-304, discusses a literal ton of ancient coins (c. 350,000 coins) that were smuggled out of Bulgaria into the U.S. by just one dealer in a short amount of time). Even on eBay tens of thousands of soil-encrusted coins are sold each week in bulk lots and online correspondence indicates these same "wholesalers" and "importers" also supply many individual dealers in private transactions. Certainly import restrictions are designed to counter the sort of wholesale destruction of cultural heritage and archaeological sites caused in the procurement of such masses of material.

We have constantly been told that dealing in ancient coins is not a profitable venture and that it is merely the extension of an innocent hobby. Curiously, however, two of the ACCG's biggest financial backers (benefactors), are the aforementioned auction houses. In 2007, CNG reported $9.7 million in gross auction sales, excluding its 15% buyer's fees or any consignment fees. It also hosts bi-weekly internet auctions, which are not included this figure. Freeman & Sear offered $4.38 million in its printed auctions and fixed price lists in 2007; this again excludes any fees and its electronic auctions. Even the ACCG's founder and executive director (and also a benefactor) has a respectable inventory as co-owner of Sayles & Lavender. As of 14 April 2008, his online inventoried included ancient coins valuing approximately $258,583 in total.

Interestingly, the biggest financial backers of the ACCG and its efforts to combat such protective legislative measures and preserve a "free-market" in ancient coins are also dealers and auction houses. Figure 2 shows that 75% of donors to the ACCG "benefit auction" are ancient coin and antiquities dealers.

If we break down the data a bit more, it is clear that those investing the most into the ACCG's operations are those who would stand to lose the most if the trade in ancient coins and antiquities were to begin valuing documentation and the recent history of an object. At present it is very easy for an ancient coin, or any antiquity for that matter, to make it from the ground where it was removed by gangs of metal detectorists, tombaroli, or other looters, to a dealer's inventory.

To date, an estimated $26,875 worth of merchandise has been donated to the ACCG's "benefit auction" where 100% of the proceeds will go to these "anticipated legal expenses" in opposition to import restrictions. The material donated so far includes 263 ancient coins, 2 other antiquities (an Egyptian scarab and a Roman glass bracelet), a book, and five $100-gift cards for use to buy more coins or antiquities from VCoins. Over 40% of the estimated market value in this auction was donated by Freeman & Sear and CNG auction houses (see figure 3). Other dealers donated about 44% of the remaining worth and collectors and anonymous donations comprise the remaining 14%.

What about the history of the objects the ACCG is now auctioning to further their own interests? Where are they from? Under what circumstances have they entered the market? We only know for certain that 6 coins in the entire auction come from old collections or were recorded in the PAS (1 from a 1923 collection, 5 from the Braithwell hoard, recorded in the PAS). What is the ACCG trying to do with the money it raises from the sale of this material and what are the consequences of its actions? There is some irony here.

Suing the State Department must be a costly task indeed. But what about the fate of our past and the material and intellectual consequences of indiscriminate market activity and the apparent lack of concern that trade interest shows for it?

Background Information:

"Why Coins Matter..."
SAFE Feature; similar version at FeRA

Archaeologists Don't Care about Coins? (Nathan Elkins)

Can Cultural Property Legislation Kill an Academic Discipline? (Nathan Elkins)

Codes of Ethics vs. the Financial Interest (Nathan Elkins)

Coins, Ethics and Scheduled Monuments (David Gill)

Coins, Contexts and Collecting (Fleur Kemmers)

It's All the Same: The Looting of the High Arts vs. the Looting of the Minor Arts (Nathan Elkins)

"Dilettanti and Shopmen": Divergent Interests in Looting and Cultural Heritage Issues (Nathan Elkins)

Also checkout relevant posts with the keyword "coins" at David Gill's Looting Matters blog



That is an eye-opening analysis. The array of items on display simply raises once again the question of ‘where did this come from, and how did it reach the US’? I find it ironic that it is precisely this sort of undocumented archaeological material that is being sold off to support moves to fight legislation which has at its basis the notion of the documentation of legal export from the source country. Surely it would have more been in the ACCG’s interest to solicit donations of material with impeccable documentation from all those dealers. Indeed, would it not have been nice to see there a couple of ancient Cypriote coins which had verifiable records of legal export from Cyprus? I guess there were too many “practical” difficulties finding such material even in the ‘legitimate” trade….

Sadly I think these guys are barking up the wrong tree. Even if they win the court case, its not the “it’s legal innit?” argument of the unethical collector which will carry the most weight in the long run. I think the ACCG would do better spending the money on examining their own claims that “coins are not archaeological artefacts” (which is what is at the core of their Cyprus challenge) and that they allegedly “don’t come from real archaeological contexts” anyway. I’d say both of these claims are wrong-headed, and the arguments the ACCG have been advancing to support them are just laughable and ignorant demagogy not scholarship.

But as you say, the real problem is that it’s the dealers that attempt to monopolise the debate and wish to steer opinions. It is their clients, the collectors, which suffer the consequences. I am sure no responsible and caring collector really wants to buy stuff where there is no guarantee that it was not acquired at the cost of a looted and trashed archaeological site. We need more of these Good Collectors, the sort of collector that would not touch with a bargepole undocumented portable antiquities which is all careless dealers can offer them.

Thirteen years ago McIntosh et al (1995) proposed a definition of the Good Collector “The Good Collector will actively demonstrate a willingness to join with like minded collectors to self-police the art market. As a necessary part of this action, they will wrest the dialogue about the ethics of collecting and about the relations of source and market nations from the trafficking syndicates and their apologists, where that dialogue about essential ethics is presently lodged”. The Good Collector “casts a jaded eye upon those dealers who insist that their reputation take the place of details of provenance”. Where are the Good Collectors of ancient coins, and will they buy anything in the ACCG “benefit auction” to support the combating of legislation necessary to curb the self-will of the looters, smugglers, dealers and their supporters?

In fact it’s worth noting for whose “benefit” this money is being raised, it’s clearly not the benefit of the cultural heritage of the source countries, nor the Good Collector, but solely for the benefit of the dealers and others who wish to participate in the unregulated and undocumented movement of archaeological artefacts from source countries to the States so they can make a quick buck (couple of hundred bucks) on their sale.

Paul Barford

Roderick J. McIntosh, Téréba Togola and Susan Keech McIntosh 1995, ‘The Good Collector and the Premise of Mutual Respect among Nations’, African Arts, Vol. 28, No. 4, pp. 60-73



A few points.

1. You should also note that ACCG membership (I think it is somewhere in the vicinity of 600) includes many collectors. Certainly, the affiliated coin clubs (some 20) are comprised mostly of collectors as well: See http://www.accg.us/affiliate

2. It’s not surprising that most of the coins in the auction don’t have a recorded provenance. As ACCG has long stated most coins don’t. Indeed, ACCG has pointed this out to government decision makers as a reason import restrictions (with their burden shifting on provenance) would be so hard for collectors and dealers to comply with.

3. ACCG was created as a 501 (c ) (4) out an of an excess of caution. Your organization, SAFE, is a 501 (c) (3). Sometimes one wonders whether it is acting as such or rather as lobbying shop that should have been created as a 501 (c) (4). Certainly, SAFE has taken advantage of its tax exempt status for purposes of securing donations.

4. It’s not surprising coin dealers donated most of the items for the auction. Most charity auctions get items from businesses and not individuals.

5. Our concerns about the State Department’s handling of our FOIA requests have been well documented and speak for themselves. http://www.accg.us/issues/news/limited-state-department-foia-releases-raise-more-questions-than-they-answer

6. If anything, it’s a sad statement about our State Department that the plaintiffs have had to hire a lawyer and sue the State Department in order to just get their FOIA requests (some of which had been languishing for some 3 years) processed. Senator Bond said it the best. See K. Bogardus, “Coin collectors, art dealers fear restrictions on Chinese imports, “ The Hill Newspaper (5/27/08) available at: (http://thehill.com/business--lobby/coin-collectors-art-dealers-fear-restrictions-on-chinese-imports-2008-05-27.html)( “I have longstanding concerns over the lack of transparency and openness in the State Department’s cultural property decision-making process and the operations of [CPAC],” Bond said in a statement from his office. “Federal agencies and advisory committees need to follow federal sunshine laws, and it would be disappointing if a lawsuit is required to make them do so,” Bond said.).

7. Your obvious co
ncern about undocumented coins does beg a question. Do you and SAFE also think the Bank of Cyprus Cultural Foundation (and other public and private museums in source countries) should purchase such coins? If not, fine. If so, please explain why the BOCCF and like entities should be able to purchase unprovenanced coins while American collectors should not be allowed to do so.


Peter K. Tompa



Thank you for your response.

Here are a few more points keyed to the paragraph numbers in your latest post:

2. As I have explained on more than one occasion, restrictions under the CPIA require importers to present affidavits about a coins whereabouts before the date import restrictions are imposed. This is difficult enough on day 1, particularly for coins of limited value. Imagine its "do ability" 5 or 10 years from now.

3. On point 3, the SAFE Charter (http://www.savingantiquities.org/aboutuscharter.php) includes the following goal: "Supporting legislation that will limit the traffic in looted or stolen antiquities."

I am a bit unclear what you mean by "political lobbying." The SAFE Charter does suggest that SAFE contemplates "lobbying" by any common meaning of the term. My understanding of the term lobbying is that it includes monies expended in grass roots efforts.

5. No one has a problem with archaeologists making their views known to the State Department. The problem is that the State Department has an obligation under its own ethics rules (and the principles of good government) to ensure that everyone is treated fairly. My concern (and that of the ACCG, IAPN and PNG etc.) is that it is quite clear that the State Department was conferring with a private archaeological group about import restrictions on coins even before Cyprus asked for restrictions on such coins, and after a high ranking State Department official had indicated to me in an email that no new restrictions on coins were contemplated. I also suspect that CPAC recommended against import restrictions on coins, but this was later overturned. If so, that suggests that State was treating CARRI as a shadow CPAC. That would be fundamentally unfair and wrong. We would like to test this hypothesis by reviewing State Department documents, but State has produced little of value in unredacted form. I would be happy to hear privately with you on this further.

6. In our opinion, State has not made a meaningful production. Therefore, we feel a need to go forward.

7. Thanks for clarifying your views on no. 7.


Peter Tompa


Dear Peter,

Thank you for your comments. I add some clarifications following the order of your points.

1. I understand there is a strong collector contingent to the ACCG’s general membership; I was highlighting that most of the members in the ‘contributor’ class (friends, patrons, benefactors), which is based on level of financial support, are dealers, and that some of the more profitable dealerships retain the highest class of membership.

2. I understand that provenance reporting on ancient coins has traditionally been low, especially after the fall of the Iron Curtain and the flood of fresh material from the Balkan region. However, as I understand it, the new import restrictions from Cyprus – which only affect a few coins of Cypriot type – only require that the material in question be shown to have existed in some collection before the date of implementation, i.e. before June 2007. Is this a great burden? Certainly collectors and dealers do not want to be party to the encouragement of looting by purchasing recently looted material, which the import restrictions are designed to curb.

3. It is not my place to discuss the reason that SAFE is a 501 (c) 3; however, I know for certain that SAFE does not spend any funds on political lobbying. SAFE’s mission is not to engage in political lobbying in Washington, but rather to educate the public and raise public awareness. In fact the SAFE website clearly states:

“SAFE is a nonprofit 501(c)(3) organization, and contributions are tax deductible under section 170 of the Internal Revenue Code. Upon request, a copy of the last financial report filed by SAFE may be obtained by writing SAFE at 123 Town Square Place, #151, Jersey City, NJ 07310 or the NY State Attorney General at The Capitol, Albany, NY 12224-0341”

By stark contrast, the dealers who founded the ACCG seem to have had political lobbying and litigious measures in mind from the outset. For example, the "objectives" page reads:

• "To lobby effectively against the imposition of import restrictions on coins of any age or place."
• "To seek, in the event of adverse legislative action, favorable administrative or court interpretations affirming the right of individuals to collect objects from the past."
• "To fight for the continued existence of a free market for all collector coins."

And so on...

4. Well enough.

5. The link you cite here has several errors and incongruous statements (which I would be happy to discuss with you privately). Why must an archaeologist’s discussion with the Educational and Cultural Affairs branch of the State Department be interpreted as collusion and conspiracy? Would not a wildlife commission naturally consult with zoologists or the CDC consult with doctors and biological scientists? To allege such conspiracies, in my humble opinion, seems to spin the circumstances of the evidence and to smack of desperation. In response to the link you cite, it is well worth reviewing Sebastian Heath’s discussion and the following comments. Personally, I find the implications made against the late Dr. Parks highly distasteful. I can't say I was surprised by them though. One of the tactics used by some ACCG bloggers over the past year has been to personally attack certain individuals and archaeologists, who disagree with the ACCG agenda.

6. Peter, I completely understand your frustration with government transparency. I know for a fact that many archaeologists are also irritated with the State Department for various reasons. Personally, I wish our government were more transparent on a number of issues, especially since the Bush administration has taken power.

The point I was raising here was not about whether or not the lawsuit was warranted. On that, I have no opinion. Instead, what interests me is the deicision to solicit large amounts of funds via a “benefit auction” well before the State Department’s deadline to provide documents or request exemptions. Could you perhaps clarify? Otherwise, one could interpret this circumstance as meaning that the decision had already been mean that action against the State Department would continue in spite of whatever documents might be handed over.

7. I do not think my concern about market activities and the source of material begs any particular question about any particular institution. I have no firsthand knowledge of the institution you bring up and cannot respond to any allegations made against it, nor would it be my responsibility to do so. However, I think I have always made my personal views quite clear. Speaking in my own capacity, it is my own opinion that anyone – dealer, collector, or museum – who purchases ancient coins or other antiquities without any concern as to the recent history of the object (provenance, pedigree, etc.), and who does not apply a rigorous due diligence process, only encourages looting and the destruction of archaeological sites by making it profitable.



Dear Peter,

I do not wish to belabor discussion much more, but I would like to know if you could address the point and question I raised in no. 6.

For our readers, I should point out that the third and fourth comments should be switched in order. These are now out of order because I fixed a typographical error in my comment and apparently Blogger does not let one fix the arrangement of comments.



Nathan- Thanks for your note. The ACCG auction is meant to raise funds for further efforts. I don't believe it is specifically keyed to the FOIA litigation, though monies from the auction will help pay for our lawyer. We would discontinue that litigation if we were satisfied by the production, but we are not. A prior report on the ACCG website indicates the numbers of documents initially produced. Much of it was material either already on the State Department website or publicly available from other sources. As further detailed in that prior report, the most significant things that were produced was the cover page of an action memo regarding the Cyprus decision and an email chain between ECA staff and Dr. Parks. The attachements to the cover memo were very heavily redacted as was the email chain with Dr. Parks. The latest production was a few letters made in the public comment period (including one from Dr. Parks), some redacted communications with Customs and some previously produced documents with some additional information related to names. We have shown our good faith to the State Department by granting them multiple extensions of time to respond (in the hopes they would do so fully). They have not so we plan to excecise our rights to press forward with the litigation. If State produced what was requested, there would no longer be a "live dispute" and the case would have to be dismissed.


Peter Tompa


I share your goal of archaeological and historical sites free from destruction but I'm also a member of the ACCG. I'm a collector and I've bought five ancient coins this year. None have provenances (which irritates me.)

I don't know why coin dealers don't give provenances. I often buy unprovenanced coins and find them in earlier catalogs. (I buy catalogs for the purpose of looking for earlier appearances of coins in my collection.) Because I've found them I know that some coins with no provenance listed go back at least a decade. Why is it not given? One theory is that the provenances are lost because folks don't keep receipts and dealer tickets. A more cynical theory is that if dealers tried really hard to print the provenances it would be obvious which coins were "new."

I respect and honor your moral ferver. I think your heart is in the right place. I'm a member of the ACCG because I think a regulated market would have incentives to stop looting and lead to less looting than approaches based on making commerce difficult. Let me explain.

1. Before collectors, gold and silver ancient coins were melted for scrap.

2. Laws giving ownership to nations mean there is no incentive for folks finding coins to report finds. I feel giving land-owners a share of found coins would cause them to be viligant about criminals digging on their land instead of trying to avoid trouble.

3. I feel licensed dealers, in competition, would report smuggling among their competitors if smuggling meant dirty merchants lost their license.

4. I encourage source countries to offer bounties for informing on smugglers and tomb robbers.

5. A registry of known legal coins would help everyone. I have some ideas for doing this cheaply in high-tech ways but many claim it is impossible.

A lot of collectors really do love preservation of sites and knowledge I wish there was a way that we could brainstorm on tactics and unintended consequences and come up with efficient strategies.


Dear Ed,

Thank you for your sharing your thoughts. I understand several of your points, but I disagree that the ACCG supports any sort of regulation since it has actively opposed import restrictions and has also stated on it's website that it seeks to maintain a "free-market in all collector coins." I interpret this as an unregulated market.

1. I understand that before the Renaissance ancient coins (gold and silver) were often melted for scrap, but so too were bronze statues. Marble statues were crushed up for lime. Very few collectors, outside of the museum world, collect antiquities like large bronze or marble statues any more, but I don't think finders would start melting them down or crushing them up for lime just because they couldn't find a buyer. In any case, some of what you discuss below might discourage that activity.

2. I have told Peter and others before that I agree that schemes such as the PAS, which reward finders for reporting their material, are beneficial and worthwhile. Where we disagree is on the overall effectiveness. Many in the ACCG have painted such schemes as a "cure all" scheme for looting, but even in Britain nighthawks who are motivated by profit operate widely. I support the PAS and similar schemes - even in countries which don't yet have them - but I think coupling such schemes with other such legislation (e.g. import restrictions) would help to control the entrance of recently looted material into the marketplace. There will always be people who will not report finds if they can find a market that does not value an object's recent history.

3. Quite possible.

4. This would also be worthwhile; I think I have heard some countries do this, but I'm not sure which ones.

5. I also agree this would be a useful enterprise and if used properly, and if universally endorsed by the trade community, such a registry could cut off the flow of fresh material into the marketplace. Certainly there would be logistical problems, but the technology and manpower should be there. I would be completely happy if a scheme such as this were introduced and adhered to. My goal is not repatriate every coin or stop collecting altogether, instead I am concerned about the material and intellectual consequences caused by indiscriminate market demand. As such, I'd like to see the market take proactive steps to ensure that recently looted material is not entering the marketplace.

Thank you again for your comments. I enjoy your blog, by the way.



Nathan, the ACCG supports the Portable Antiquities Scheme. The ACCG has sponsored lectures by Roger Bland and the page http://www.accg.us/issues/news/roger-bland-to-speak-at-field-museum?searchterm=scheme says "The Ancient Coin Collectors Guild ... is a strong supporter of the PAS." (I think *moral* support is what is meant).

The ACCG's wishes for an "unknown implies legal" policy (for the reasons Sayles gives in his essays) and you support "unknown implies illegal" (for the reasons you give). I am sure you and the ACCG will never resolve that difference--and that's a big problem because most coins' provenances have been lost. My wish is that while you fight the ACCG on that issue that you understand that many of us agree with you on the need to fight organized looting and wish for ways to "provenance" coins besides printing catalogs (commercial and academic).


I suppose where we are now disagreeing is on semantics. I understand the ACCG supports the PAS, as do I. However, many dealers seem happy enough to import coins from source countries that do have restrictive laws. In my opinion, it's one thing to endorse schemes like the PAS with one hand and then to encourage the breaking of other laws with another. Many wholesalers (who supply other dealers), for example, import en masse from Balkan countries, and someone's laws are being broken in the process (maybe not U.S. laws, but the laws of source countries and transit countries). I recall one dealer, who is a member of the ACCG, once wrote it was of little concern to break "an Albanian law or two" on an online discussion list.

I understand many collectors are against looting, but I do not see what the ACCG is doing to actively combat it. In fact, I find their actions only facilitating it. Dealers should respect the laws of foreign countries - whether or not they disagree with them - and should employ greater due diligence processes. I think if the existing cultural property laws of certain nations were being respected, those who are touting the PAS would have a higher moral ground.

I am sure there are many coins on the marketplace that have "lost their provenance," since some collectors or dealers may not keep up with the history of them for whatever reason. However, it is clear that freshly looted coins are entering the market at an astonishing rate - this is what needs to be stopped.



Hi Hathan-

As to what the ACCG stands for I direct your attention to the following. You are probably not completely happy with it, but I think there would be a willingness to discuss this further as part of a larger discourse.

The Board of Directors of ACCG has agreed on a uniform Code of Ethics for Collectors and Sellers of ancient coins.

At a formal meeting of the Board of Directors at New York, NY on January 15, 2005 the ACCG officially adopted a Code of Ethics for “Collectors” and “Sellers” of ancient coins. The private collecting community has long been in need of a national organization and of a stated code of ethics by which members of the fraternity ought to abide. The code, as adopted, includes the following points:

1. Coin Collectors and Sellers will not knowingly purchase coins illegally removed from scheduled archaeological sites or stolen from museum or personal collections, and will comply with all cultural property laws of their own country.

2. Coin Collectors and Sellers will protect, preserve and share knowledge about coins in their collections.

3. Coin Sellers will not knowingly sell modern forgeries of ancient coins, and all ancient counterfeits or Renaissance type copies will be clearly identified as such.

4. Coin Sellers will disclose all known defects, including tooling, re-engraving or reconstruction of coins they sell.

5. Coin Sellers will not misrepresent the value of coins they buy or sell.


The ACCG Board of Directors also agreed that the standards of conduct of museum professionals and archaeologists ought to include certain issues like conservation, publishing responsibilites, respect for private ownership and public access. These concerns will be communicated to the appropriate organizations or associations in the form of an ACCG petition for consideration.

I guess off hand, I respectfully disagree with you that US Collectors (or the US Government) should give "full faith and credit" to foreign law in all circumstances.

I won't repeat the legal/philisophocal reasons here, but I think went over them in one of my postings on the "Torah Controversy" on the IraqCrisis list.

As to practical matter, you should also keep in mind that in a lot of countries there is a great difference between what the law might say and what practice is. (That actually is the case here too for some laws that are considered antiquated.)

Also, in places like China or Bulgaria for that matter, there may be laws on the books that prohibit sales of archaeological material, but at the same time, there also is quite an open internal market. It's hard for me to fault dealers and collectors or tourists for that matter buying coins in such places and bringing them here in such circumstances.

In other countries, like Cyprus, there is a two-tiered system. If you are "connected" like the Bank of Cyprus there is no problem collecting what you want. If you are not, watch out.

Anyway, I do hope this will be a topic for further discussion some day at a place like the ANS. Overall, I think dealers should provide what provenance information is reasonably available. I do not think it is reasonable or do able to ask importers and consigners to prepare detailed certifications about a coin's whereabouts to satisfiy the import restrictions under the CPIA. I think the practicality considerations is the major reason ACCG is opposed to import restrictions. Certainly, if you look at the statutory history, it should become readily apparent that the CPIA was not meant to apply to artifacts made in mass quantities.

Finally as an aside, I should add one reason dealers don't always provide provenance information for coins is that are afraid that such information will allow the buyer to figure out the "mark up" on a coin.

Best wishes,

Peter Tompa


Agreed semantics is a problem for future ACCG and archaeologist meetings.

A good introduction to how the market defines words and market morality can be found in chapters 5-6 of S.R.M. Mackenzie's _Going Going Gone: Regulating the Trade in Illicit Antiquities_. It isn't kind to dealers!

Alcohol prohibition failed -- although usage initial dropped it rose throughout the 1920s and was nearly back to pre-prohibition levels. Drug prohibition seems close to failing -- it's easier for a 20-year-old to buy marijuana than alcohol. Gun prohibitions and animal trafficking prohibitions are not working. Essays against unprovenanced coins are antiquities treaties may be adding commercial value to provenanced objects, but that just makes the unprovenanced coins cheaper thus stimulating demand for them.

I encourage schemes where landowners get a share of the commercial value of antiquities because this incents the landowner to come out with a shotgun to discourage night diggers. Today many rural folks would rather have smugglers spending money in the local economy than having "their" antiquities taken without recompense to a museum in the capital city. I think PAS-type systems bring official archaeologists into the picture but give some control to local stakeholders. I think something like a "Fair Trade" logo system, like for coffee, or like the conflict-free diamond thing would incent dealers to keep provenance records.

If you can convince me that essays and lawsuits will work for coins better than they are for drugs, guns and animals I'll leave the ACCG.

What S.R.M. Mackenzie recommends is registration of antiquities. I believe I know how to do this cheaply. A collector or dealer could upload a picture of a coin to a web site run by a national or international body. The web site would sign the image digitally using public key cryptography and today's date. The signed image would absolutely prove the coin was out of the ground at that time. The picture doesn't even need to be that good -- place a small hoard of coins on a flatbed scanner and digitally sign the whole thing.

This nearly-free registration system has some flaws, for example it doesn't prove where the coins are, just that they are not in the ground. A requirement to bring the coins to a registrar and put them on a conveyor belt could deal with that. I don't know if this is a good system but I think it would do more to getting criminals out of the coin business than essays and unobtainable export permits.


Thanks for the continuing discussion. I hope that someday we will be able to make headway on one of these registries that have been discussed here and elsewhere. I think that would be a good start.