In the US, Congress has established the following process for imposing import restrictions: (1) a State Party to the 1970 UNESCO Convention requests US assistance; (2) the request is vetted by the US Cultural Property Advisory Committee (CPAC) as to whether it meets the statutory requirements generally and for what artifacts specifically; (3) the President's Designee in the State Department considers CPAC's recommendations in making her own findings whether the statutory criteria are met: (4) if the statutory criteria are met, US Customs restricts entry of certain artifacts that meet the statutory criteria.
Unfortunately, a new extra-legal model has emerged that appears to have been perfected under the Obama Administration either through inattention by political appointees or by design: (1) Archaeologists intone that looting (real or imagined) justifies a clamp down on another collecting area; (2) their allies in the State Department Cultural Heritage Center issue a sole source contract to a NGO associated with the extreme archaeological view to prepare a list of artifacts that supposedly can be assumed to be "stolen" unless proven otherwise; (3) Archaeologists lobby the modern foreign government that sits on the land where these artifacts can be found to ask the US to impose import restrictions; (4) CPAC (which is now populated almost exclusively by those sympathetic to the extreme archaeological view) and the President's Designee in the State Department go through the motions of considering a request, but ignore all the statutory criteria in order to "get there"; and (5) artifacts are restricted based on the "Red List" prepared by the NGO associated with the extreme archaeological view.
It is quite possible that the process has already begun for imposing new restrictions on Egyptian cultural artifacts.
1. During unrest during the Egyptian revolution, there apparently was some looting, though the extent does not seem to be very extensive.
2. Archaeologists have argued this justifies a clamp down on collectors of Egyptian artifacts.
3. The State Department issued a sole source contract (See https://www.fbo.gov/index?s=opportunity&mode=form&id=fa0c2fe21fd3cf5028a500f1fc4b97e4&tab=core&tabmode=list) to ICOM for the creation of a "Red List." See also, http://exchanges.state.gov/heritage/special.html (noting that the Cultural Heritage Center funds Red Lists as a "special project.")
4. ICOM has now completed its work. See http://icom.museum/press-releases/press-release/article/icom-publishes-a-new-emergency-red-list-the-emergency-red-list-of-egyptian-cultural-objects-at-risk.html Note, according to ICOM: " Any cultural object that could have originated in Egypt should be subjected to detailed scrutiny and precautionary measures."
5. Although the State Department has indicated that former Egyptian Cultural Heritage Pharaoh Zahi Hawass' claim that a MOU was in the offing actually related to an agreement with US Customs, that does not foreclose the possibility that the process for imposing new import restrictions on Egyptian cultural goods has already commenced with the production of this "Red List." See http://ordinarymag.blogspot.com/2011/10/state-department-clarifies-egyptian-mou.html
Only time will tell.