Import Restrictions on Ancient Coins

A lobbyist who works on behalf of trade organizations has suggested that ancient coins currently protected by memoranda between the U.S. and certain foreign governments are not legally placed there since the basis of those restrictions is "place of production" rather than where they are found.  He alleges the CPIA is thus violated.  The exchange is in the comments section of a previous post here and his take is also presented on his website.

As I pointed out in that exchange, coins that are protected are types that are found in that country.  The memorandum with Italy, for example, protects early Roman coinage (aes signatum, aes grave, and the early republican struck coinage, as well as Roman colonial coinage) and the coinage of Greek cities in southern Italy.  Scholarly publications demonstrate that such coins had a primarily Italian circulation.  The memorandum with Italy even cites one of many sources that reference circulation and find patterns.  Widely circulating types where a find spot cannot be attributed (e.g. most Roman republican and imperial coins) are not protected by existing legislation.  As most republican and imperial coins were struck in Italy, a country with which the U.S. has an MOU, one is left to question Mr. Tompa's allegations.

The "scholarly evidence" submitted to CPAC by ACCG that Mr. Tompa refers to as an apparent indication that where such coins are found is not considered by CPAC is a simple list of hoard finds of types outside of the borders of countries that request MOUs.  It suggests a limited number of coins circulated out, but it totally ignores the fact that the vast majority of such types are found in the country of origin.  It is common knowledge among numismatic scholars that many coin types (e.g. some Greek coins and Roman provincial coins) had a very limited circulation and it is curious that the trade lobby does not acknowledge this in communications with CPAC; instead they argue more simply (and too simply) that coins can be found anywhere.  Would one really expect to see aes grave exavated in Israel or Jordan?

In considering whether Mr. Tompa's take on the situation is legitimate, one may recall that ACCG's lawsuit against the government, which has been handled by Mr. Tompa, has been dismissed on multiple occasions.  Legal authorities have not agreed with ACCG that there is any mishandling of import restrictions philosophically or legally. 

Rather than lawsuits and sniping over the interpretation of CPIA, would not a better approach be to recognize that indiscriminate attitudes in the sourcing of ancient coins promotes looting and destroys historical information?  And recognizing that, would it not be a better approach to engage in a productive dialogue about how ethical collecting can exist without maintaining a damaging status quo?

Summary of the Public Hearing on the Renewal of the MOU with Cyprus Now Online

In January, I summarized some of the discussion that took place on January 18, 2012 during the U.S. State Department's meeting of the Cultural Property Advisory Committee to hear public testimony on renewals of the Memoranda of Understanding with Cyprus and Peru ("Comments on the Extension of the MOU with Cyprus").

Most of those present spoke in support of these agreements. The Archaeological Institute of America has now posted a report on the January 18th meeting: "Report on CPAC Public Hearing, January 18, 2012."

Comments on the Extension of the MOU with Cyprus

On January 18, the Cultural Property Advisory Committee (CPAC) of the U.S. Department of State held a public hearing in Washington. The committee was receiving public comment on the requests for extensions of Memoranda of Understanding (MOUs) with Peru and Cyprus; these MOUs are a vehicle to protect the cultural patrimony and archaeological resources of these nations from looting, trafficking, and smuggling. Speakers were asked to address any of the four determinations, upon which the committee makes their recommendations, in their written and oral comments. I attended this meeting and spoke in support of an extension with Cyprus. Below is a summary of my comments.

After introducing myself, I stated that my comments would be related to the first and second determinations. I discussed a January 2010 raid by police in Cyprus. It is one of the biggest antiquities busts in Cyprus' history. Members of the smuggling ring were arrested and 11 million euro ($15.5 million) in looted antiquities were confiscated. Among those objects were a miniature gold coffin, terracotta urns, limestone figures, and bronze and silver coins. This important seizure bears on the first and second determinations as 1) it shows that the cultural patrimony and archaeological resources of Cyprus are in jeopardy through pillage and 2) shows that the Republic of Cyprus is taking proactive measures within its own borders to combat plunder.

My primary area of expertise and research is Roman coinage. And, as many individuals who follow MOU hearings are well aware, the inclusion of coins in the designated list of objects protected through an MOU is a hotly contested issue as there is a flourishing trade in ancient coins and a great demand for new material. Therefore, I took the opportunity to point out to the committee the need to protect coins alongside other objects on the designated list, such as sculpture, ceramics, metalwork, etc. The above-mentioned seizure illustrates the fact that looters and smugglers often procure ancient coins and antiquities from the same sources, i.e. tombs and archaeological sites of various sorts.

After briefly discussing the international market for Cypriot material and providing some numbers, I countered one of the arguments that is most often used by opponents of the protection of coins. Essentially the argument goes like this: "coins circulated in antiquity and thus it is impossible to know in what nation they might have been found once they enter the North American marketplace; as a consequence of this, coins cannot be protected according to the framework of the Cultural Property Implementation Act." In response to this claim, I made the point that it is in fact true that coins circulated in antiquity. But coin circulation is actually a much more complex issue than is often presented to the committee by those opposed to the protection of coins. Some coins circulated more or less than others. One example I gave is the imperial gold and silver coinage, struck at Rome and Lugdunum (Lyons); this coinage circulated widely across the Roman Empire. But in contrast to this, some Greek coinages and the locally produced Roman provincial coinage circulated regionally or locally. Such locally produced and circulating coins are already protected in the current MOU with Cyprus.

One tradesman, who had submitted a letter in opposition to the inclusion of coins in the designated list, provided a list of hoards from outside of Cyprus that included Cypriot coins. In the letter it is claimed that the list provides "uncontestable (sic) evidence that these coins circulated in antiquity and since." Yes, coins circulated. But the letter in question did not examine the evidence in a critical way. After all, the hoard evidence from Cyprus itself was wholly omitted. As I pointed out in my letter and in my oral commentary, the hoard evidence, which deals primarily with the Cypriot coinage of the Hellenistic period, shows a remarkably greater proportion of Cypriot coins in Cypriot hoards in comparison with the foreign hoards. I cited eight hoards from Cyprus recorded in IGCH. In aggregate, coins of Cypriot type comprised 45% of the total of all hoards found in Cyprus. On the other hand, coins of Cypriot type, in aggregate, composed 9% of the foreign hoards mentioned in the other letter. That letter had a list of 33 hoards containing a total 3,662 coins, of which 313 are Cypriot. The much smaller number of eight hoards from Cyprus totaled 2,878 coins, 1,303 of which are Cypriot. The evidence indicates that Greek Cypriot coins are much more prominent in Cyprus than outside of Cyprus.

Finally, I addressed the Roman provincial coinage in Cyprus. The authoritative study on this series is D. Parks, The Roman Coinage of Cyprus (Nicosia, 2005). One chapter, "Circulation of Cypriot and Imported Coinage in Cyprus" (pp. 137-162), examines Cypriot coins from a number of sources and provides ample evidence that Roman coins of Cypriot type circulated abundantly on the island and less frequently outside of it. The current designated list only includes coins until c. AD 235. As there are also Cypriot coins of Byzantine and Venetian type, it was suggested that these be added to any renewal.

Two other numismatists, distinguished in their areas of expertise, provided testimony in support of the extension of the MOU and the continued protection of coins.

I expect that a summary of the public hearing will soon be posted on the website of the Archaeological Institute of America by someone who attended the meeting. Summaries of the public hearings in November on Belize and Bulgaria can be found here.

"Why are ancient coins from Cyprus featured in a suit against the US Department of State?"

The systematic destruction of historical sites, and the knowledge that is lost with it, is a growing global problem that few would deny. In recent years there have been positive developments; for example, many museums have adopted more stringent acquisitions policies to diminish the role that their institutions play in this destructive process by purchasing recently surfaced antiquities. There are, however, a minority of vociferous naysayers - outside of the museum or archaeological community - who pretend looting is not a problem and assert that trade members (i.e. dealers or collectors) should not be held to or practice any due diligence standards. It goes without saying that this mentality maintains a detrimental status quo.

In 2007 in response to the bilateral agreement on import restrictions with Cyprus and the United States in which undocumented ancient coins of certain Cypriot type were included, the International Association of Professional Numismatists (IAPN), the Professional Numismatists Guild (PNG), and the Ancient Coin Collectors Guild (ACCG) sued the United States Department of State under the Freedom of Information Act, alleging a lack of transparency in the decision to include coins. The IAPN, which caters to an international constituency, and the PNG are both dealer groups. On the other hand, the ACCG claims to be a collector's advocacy group, although its biggest financial contributors appear to be dealerships and auction houses. Furthermore, all of the ACCG's leading officers listed on its website are also dealers or former dealers, save one lobbyist who has also received money from the IAPN and PNG to lobby on behalf of dealer interests. Recently, the ACCG staged the import and seizure of restricted coins (without documentation) in order to force a legal battle as part of a coordinated strategy to undermine and overthrow import restrictions, which negatively affect the interests of its constituencies.

In light of the changing attitudes with regards to personal responsibility in looting issues, one naturally asks the question of why certain attitudes are not changing. Could it be that for certain people, their own commercial and self interests override a genuine concern for ethical practice, international law, and the incomprehensible loss of knowledge that takes place as a consequence of their own activities which actively encourage a market for loot?

Today the PR Newswire is carrying an article ("Why are ancient coins from Cyprus featured in a suit against the US Department of State?") by David Gill, an archaeologist and authority on looting issues, in which he considers the impetus for the ACCG's aggressive legal action. It reads:

Swansea, Wales, UK, June 25 2009 – David Gill, archaeologist, considers the recent Freedom of Information Act (FOIA) suit on the US Department of State.

The FOIA suit was served in November 2007 by three numismatic organizations; one of the three is based in Brussels, Belgium. The alliance objected to the US Cultural Property Advisory Committee (CPAC) restricting the import of ancient coins minted in Cyprus as part of a wider memorandum of understanding (MOU). CPAC was responding to concerns by the Government of Cyprus that the illicit searching for ancient objects (including coins) was destroying the archaeological heritage of the Mediterranean island. CPAC states, "The MOU offers the opportunity for the U.S. and Cyprus to cooperate in reducing the incentive for further pillage thereby protecting the context of intact sites for scientific study."

Coin collectors were also concerned about the 2009 MOU with China. This agreement also restricted the import of certain categories of coins.

As a result, one of the three numismatic organizations decided to test the resolve of the US Department of State in April 2009 by attempting to import a small number of coins from Cyprus and China in defiance of the newly established laws. These items were detained when their flight from London touched down in Baltimore.

Are these aggressive legal tactics really for the benefit of collectors, or are there other factors at work?

I strongly recommend reading David Gill's full discussion at Looting Matters: "Antiquities, ancient coins and changing attitudes in North America."

(Photo from Standartnews.com: A large shipment of freshly looted coins from Bulgaria destined for German market, an important transit country for the international market in looted antiquities)

Dealer Lawsuit Against the U.S. State Department to Continue

Yesterday, Peter Tompa, attorney, lobbyist and a former president of the Ancient Coin Collectors Guild (ACCG), gave an update on the status of the ACCG's lawsuit against the U.S. Department of State.

The American dealer lobby, which I term such because every leading officer is an active or former dealer (with the exception of Tompa, who acts as a lobbyist for organized ancient coin dealers) and most of its large financial backers are also dealerships and auction houses, is joined in its lawsuit by two other dealer organizations: the International Association of Professional Numismatists (IAPN) and the Professional Numismatists Guild (PNG). As many readers are aware, the ACCG and these other groups launched the suit in the fall of 2007, alleging a lack of transparency in the way that the State Department agreed to extend the Memorandum of Understanding (MOU) to coins of certain Cypriot type.

It was expected that the ACCG had every intention of pressing the lawsuit as far as they could since they hosted a "benefit auction" last year in order to raise funds "in opposition to State Department imposed import restrictions" (see discussion here, here, here, and here). Along with the progress report on the lawsuit, the ACCG has also announced the plan for another "benefit auction" in 2009 (note the heavy distortive and alarmist rhetoric used by Sayles that we have heard from him and the group before: see some discussions here, here, and here).

Two documents relevant to the ACCG's lawsuit are on its website: the progress report and a declaration from Jay Kislak, former chair of the Cultural Property Advisory Committee of the State Department. Curiously, Kislak's declaration all but explicitly states that CPAC did not recommend to extend the restrictions to coins. Therefore, it will be interesting to see what comes out in the end, although it remains unclear to me personally if the State Department must be bound by the recommendations of CPAC since it is an advisory committee and deliberations and decisions are no doubt often split considering archaeologists, museum specialists, and members of the trade serve simultaneously on the committee. On the other hand, CPAC members are meant to keep the activities of the committee confidential and so it appears that Mr. Kislak may have been sharing privleged information with the coin dealers the whole time - the same sorts of hidden activities the dealer lobby consistently accuses members of the State Department's Cultural Heritage Center of.

In any case, Mr. Tompa expects the court to rule on the release of further documents within the next six months. The ACCG has not shared the documents released thus far to outside parties, though its own interpretation of them has been relayed several times.

Other commentators on these developments include:

D.W.J. Gill, "Cyprus and the Coin Collectors: Yet Another Round," Looting Matters (27 April 2009)

P. Barford, "Leaky Old CPAC - Mystery Solved?," Portable Antiquity Collecting and Heritage Issues (27 April 2009).

P. Barford, "'ACCG Presses Claims to Hidden Information'," Portable Antiquity Collecting and Heritage Issues (27 April 2009).

P. Barford, "Per Lucem ad Veritatem, sed nemo surdior est quam is qui no audiet" ("Through light to the truth, but no one is more deaf than one who shall not listen"), Portable Antiquity Collecting and Heritage Issues (28 April 2009).

Internet Discussions on Looting, Legislation, and Lobbyists

The ACCG "benefit auction" on which I have commented earlier (here, here, and here) has now closed and appears to have been a success for the group having raised over $45,000. The "benefit auction" was meant to raise funds "in opposition to State Department imposed import restrictions." The ACCG has sued the U.S. State Department through the Freedom of Information Act (FOIA) to learn more about the process under which the decision was made to accept Cyprus's request for import restriction on ancient coins of Cypriot type. Elsewhere, several of the ACCG's members have alleged various sorts of conspiracies between archaeologists and State Department officials (see, for example, Ellen Herscher's concise response the latest allegations made against CAARI by Peter Tompa, president of the ACCG, on the Museum Security Network List).



As I have mentioned before, the ACCG is a 501(c)4 organization to which contributions are not normally tax deductible since up to 100% of contributions can be used for the purposes of political lobbying. Indeed, it is well-known that the ACCG actively lobbies senators and congressmen to oppose any sort of legislation which might hinder a "free market" in ancient coins and grants them "Friends of Numismatics Awards" for their support (see here, here, here, and here). Legislative measures are almost universally endorsed by archaeologists and ancient world scholars as a way to diminish looting and the irrecoverable loss of information that results from the unscientific procurement of ancient objects to supply market demand. Looting can be both a casual "hobby" activity for some or can be much more organized and systematic, as is presently the case in Balkan countries, which are major sources for the ancient coin and antiquities trade (for example, see the report on "Organized Crime in Bulgaria: Markets and Trends," which is briefly discussed and to which a link is provided here).


In the past, we have heard much from several members and leaders of the ACCG. For example, some collectors and antiquities dealers belonging to that group have labeled archaeologists who are concerned about looting as "radicals," "extremists," "zealots," "jihadists," and "fascists," and these are just a few of the pejorative terms out there. Several ACCG leaders have tried to assert that the ancient coin trade is independent of the antiquities trade as a whole, that fresh material does not enter the market to a significant degree, and that market demand does not play any role in looting that occurs in source countries. They have also attempted to argue that looting in Iraq after the U.S.-led invasion is either fiction or greatly exaggerated (e.g. see David Gill's response to Peter Tompa's discussion of old news on Iraq looting).



Although the ACCG itself is a 501(c)4 organization that uses its contributions for political lobbying, it consistently accuses and criticizes archaeological professional groups such as the AIA, American research centers abroad such as CAARI, and advocacy groups such as SAFE for what it calls political lobbying and manipulation. Of course the irony in this is that all of these are 501(c)3 organizations, which could not pay for political lobbying with the same freedom that the ACCG can.

During the course of the "benefit auction," there has been an increased amount of noise coming from certain ACCG leaders making new allegations. On these David Gill has been making some very useful observations (Looting Matters: "Lobbying and Archaeological Material", "Collecting Coins: 'A Fundamental Aspect of Citizenship'", and "Burns: 'I Wear this Title of Philhellene Rather Proudly'"). Peter Tompa, has criticized the use of foreign "lobbyists" on the decision to impose import restrictions from Cyprus. In response, David Gill has pointed out some of the irony in this since Mr. Tompa is himself the paid lobbyist for two major international coin trade (i.e. dealer) organizations, the Professional Numismatists Guild (PNG) and the International Association of Professional Numismatists (IAPN). The IAPN is based in Brussels, Belgium. One might also wonder whether or not he is the official paid lobbyist for the ACCG or if this work is pro bono. In regards to Iraq, it is noteworthy that Mr. Tompa is currently lobbying Washington lawmakers to exempt ancient coins from the emergency import restrictions on antiquities from Iraq that were imposed to curb the flow of plundered material into the U.S. As we all know, the U.S. is an important market country for ancient objects. Why does the ACCG have an interest in importing ancient coins from Iraq?



Dave Welsh, an ancient coin dealer and Chair of the ACCG's International Affairs Committee, has publicized Tompa's comments about foreign "lobbyists" on the Internet with an interesting spin; on the British Archaeology list, he posted it with the headline: "Lobbyists paid by foreign government to join assault on collecting." What Mr. Welsh fails to mention, of course, is that his own lobby, the ACCG, has accepted donations, financial contributions, and memberships from foreign collectors and dealers who may well have interests in U.S. legislation on ancient objects and market regulations. Mr. Welsh also advertised the ACCG's news article on the success of its "benefit auction" to several online discussion lists with the subject heading "ACCG Raises $45,000 to fund the Struggle Against Radical Archaeologists" (I thought it was to fight "State Department imposed import restrictions"!). Last year, he urged collectors to donate and join the ACCG using what may be best referred to as "fear-mongering" tactics, asking them to envisage this unrealistic world:

"If the AIA sent a squad of radical archaeologists to your house to seize your collection, in the process verbally abusing you as a moral cripple responsible for everything bad that is happening to archaeological sites, wouldn't you be mad as Hades? Wouldn't you be ready to fight? Well get ready to fight, because that is more or less what they intend to do, and actually are doing, one small step at a time."

In the context of Welsh's behavior and actions, and even his use of insensitive language and slurs such as "cripple," it is interesting to note that they are apparently endorsed by the ACCG leadership since he was recently awarded with the "exceptionally meritorious service award." The online notice about this states:

"As founder and moderator of the Unidroit-L discussion list, Dave has dedicated countless hours to providing a balanced forum for discussion online of cultural property issues. He also represents the collector fraternity very effectively on numismatic discussion groups that reach a broad range of interested parties."

As the moderator and owner of the Unidroit-L discussion list, one might wonder how "balanced" the forum is when he posts headlines like the ones above and moderates the postings of opinions contrary to his own, but allows like-minded individuals to publish various diatribes, and even ad hominem attacks, freely on the list. Although it claims to give a voice to collectors, the behavior, tactics, and views of some ACCG leaders have been questioned by other collectors and metal detectorists before (see here and here, for example).


Instead of adopting more stringent due diligence practices in their business transactions or engaging equitably in a dialogue with the historical scientists who encounter, study, analyze, and publish ancient material on a daily basis and as part of their professional career, ancient coin and antiquities dealers have locked themselves in a public relations battle with archaeologists and other scholars and the medium for this battle is, by-in-large, the Internet. For example, one may recall the ACCG's widely circulated and self-promotional press release (via the PR Newswire) of its benefit auction, which misrepresented archaeology and the issues surrounding looting. This press release appears to have been authored by Wayne Sayles, a coin dealer and founder and executive director of the ACCG (click here and here for discussions of the press release).



The Internet is a double-edged sword in the sense of the information it provides. With it, we can share and access information unlike ever before, but at the same time anyone can use it is a platform to "publish" anything they wish, thus making it difficult for casual browsers to discern between the quality of information available. Andrew Keen, author of The Cult of the Amateur: How Today's Internet is Killing our Culture (New York, 2007), explores these issues in detail and comments more specifically on how the Internet is being used by some individuals and groups to grind political axes. For example, he discusses the junk science that is disseminated through the internet and backed by certain energy companies that claim that climate change is fiction. Without more thorough investigations, casual readers are not usually aware of the sources of information they read or the political agendas that may guide them or the spins that are put on available data.


Several informed commentators and scholars have discussed the looting issue as one similar to climate change, the ivory trade, and the hunting of endangered species. Indeed, these are all issues which seem to pit the profiteer against the scientist, the commercial and self interest against that of knowledge and preservation.

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

Differing Viewpoints on the Value of Import Restrictions

The Hill has reported on the discussion surrounding China's request for U.S. import restrictions on Chinese antiquities, including ancient Chinese coins (K. Bogardus, "Coin Collectors, Art Dealers Fear Restrictions on Chinese Imports," 27 May 2008). The article addresses the controversy raised by collectors and dealers, alleged diplomatic concerns intertwined with proposed legislation, and the endorsement of import restrictions as useful protective measures by archaeological professional groups and SAFE, a public advocacy group.

Image: Chinese Coin of the Western Han dynasty, 73-47 BC, in the collection of the British Museum.