Winners
1. The Greek Cultural Bureaucracy-- The Greek Government has mismanaged its economy so badly that it is relying on Germany and the rest of the EU to bail it out. Greece's cultural bureaucracy is as poorly managed and as corrupt as the rest of the Greek government. Yet, the MOU will no doubt be cited as some sort of U.S. "seal of approval" for the status quo.
2. The Obdurate State Department Cultural Bureaucracy- You've got to hand it to the entrenched bureaucrats at the State Department Bureau of Educational and Cultural Affairs and its Cultural Heritage Center. Important members of Congress have expressed severe misgivings about the implementation of their statutory authority. They have been sued in Court, and even though their decisions have been upheld to date as a matter of judicial deference, this is not the same as a ringing endorsement. Yet, culture creep has turned into a roll with these expansive regulations, by far the most wide ranging since the Chinese MOU in 2009.
3. The AIA and its Archaeological Fanatics- These fanatics hold that the only legitimate exchange of archaeological artifacts is a museum loan. They view import restrictions as a way to clamp down on a trade they do not believe should exist. So far their anti-collecting agenda has meshed well with the nationalism of countries like Greece and the predilection of the State Department to trade favors to the detriment of American collectors, dealers and museums.
4. Wealthy Greek Collectors- The fanatics criticise American collectors and museums, but don't seem to care that wealthy Greek collectors buy from the same sources as American collectors do. Now, Greek collectors will gain a competitive advantage over their American counterparts who can no longer import undocumented cultural goods. No wonder a representative from the Alpha Bank, which maintains Greece's best coin collection in private hands, was part of the Greek delegation that attended the public meeting of CPAC that discussed the MOU.
Losers
1. Greece's Cultural Patrimony-Even before Greece's recent financial meltdown, the country was highly dependent on EU funds to care for its major sites. Now, with money so tight, how can the country take care of its major sites, let alone the millions of minor objects in its stores? Yet, Greek cultural officials will no doubt hope that news about the MOU will will divert attention away from these hard financial realities and help stave off much needed reforms.
2. The CPIA and the Process Congress Contemplated- Import restrictions under the CPIA are supposed to be limited to culturally significant artifacts. Less onerous measures are supposed to be considered first. The restrictions are supposed to be part of a concerted international response. Here, these broad restrictions simply ignore these requirements. Moreover, the failure to give heed to the vast majority of public comments that opposed restrictions on coins again suggests that the whole process is little more than a farce.
3. The Small Businesses of the Antiquities and Numismatic trade- Import restrictions bar entry of cultural goods legitimately for sale abroad where documentation requirements for legal import cannot be met. This is particularly a problem for the small businesses of the numismatic trade. The documentation necessary for legal import is either typically unavailable for artifacts of limited value like most ancient coins or cost prohibitive to produce for such inexpensive items.
4. US Collectors- US collectors of cultural goods, including the thousands upon thousands of Greek coin collectors will face considerable problems securing material, particularly as time goes on.
5. US Museums- Loans are a poor substitute for purchases or donations for collecting museums. The archaeological fanatics may promote loans as a substitute, but they don't have to arrange such loans with the Greek bureaucracy or pay the considerable expense associated with such loans, which typically include expensive conservation costs.
6. US Customs- US Customs officers now have another broad set of import restrictions to administer. While they may make the "big bust" on occasion, I doubt that will make up for the frustration factor of trying to ascertain whether every ancient coin or minor antiquity that "looks Greek" is on the designated list or not.