Merely a week after CPAC met to consider the proposed renewal of the MOU with the PRC, the news broke about an extensive PRC program to hack into US defense industry computer systems in an effort to steal US military secrets.
China is aggressively seeking an advantage against the US when it comes to defense preparedness. But so too is it with respect to the maintenance of a strong antiquities market. The difference is that the Defense Department is seeking to stymie Chinese ambitions, but our own State Department Bureau of Educational and Cultural Affairs and its Cultural Heritage Center seem all to willing to encourage a vibrant Chinese market at the expense of American interests-- all supposedly in the name of archaeology.
Showing posts with label Bureau of Educational and Cultural Affairs. Show all posts
Showing posts with label Bureau of Educational and Cultural Affairs. Show all posts
Far Away from the Archaeo-Blogosphere...
I enjoyed accompanying another collector who spoke to two classes of 7th and 8th Graders about ancient coins and what they can tell us about ancient societies. Teaching about ancient history is woefully inadequate in our nation's classrooms, so it was great to find a school where the classics are still king and where the kids were both knowledgeable and engaged in the subject matter.
All this raises another point that does directly touch on "cultural property" issues. The Bureau of Educational and Cultural Affairs (ECA) spends $500 million a year promoting "cultural understanding." But, I can't help but think that ancient coin collectors do the same thing every time they talk to a class, discuss ancient history and coins, or interact with foreign collectors and dealers, and all at no cost to the U.S. taxpayer.
One can only wonder if Assistant Secretary, ECA Ann Stock has any clue about the negative impact the actions of her Cultural Heritage Center have had on coin collectors and the good work they do promoting cultural understanding on a people to people basis. If it's really about protecting archaeological sites rather than encouraging jingoistic nationalism, why promote-- as ECA's Cultural Heritage Center has done-- import restrictions based on a coin's place of production rather than it's find spot?
All this raises another point that does directly touch on "cultural property" issues. The Bureau of Educational and Cultural Affairs (ECA) spends $500 million a year promoting "cultural understanding." But, I can't help but think that ancient coin collectors do the same thing every time they talk to a class, discuss ancient history and coins, or interact with foreign collectors and dealers, and all at no cost to the U.S. taxpayer.
One can only wonder if Assistant Secretary, ECA Ann Stock has any clue about the negative impact the actions of her Cultural Heritage Center have had on coin collectors and the good work they do promoting cultural understanding on a people to people basis. If it's really about protecting archaeological sites rather than encouraging jingoistic nationalism, why promote-- as ECA's Cultural Heritage Center has done-- import restrictions based on a coin's place of production rather than it's find spot?
Proposed Renewal of Chinese MOU
The Cultural Heritage Center website carries news about a proposed renewal of import restrictions on Chinese cultural goods. CPAC's public session will take place on May 14th.
The Federal Register notice formally announcing the renewal is to be released on April 1st.
Somehow that is fitting. I'm all for the Chinese populace collecting rather than destroying (remember the Cultural Revolution) artifacts like the bazillions of cash coins that are found all the time in China, but hope CPAC recognizes that current restrictions have done little but to provide Chinese auction houses and dealers with a leg up on their foreign (especially US) competition.
Is it about protecting the archaeological record or encouraging the continued movement of the trade in Chinese artifacts to China and other major market countries?
The Federal Register notice formally announcing the renewal is to be released on April 1st.
Somehow that is fitting. I'm all for the Chinese populace collecting rather than destroying (remember the Cultural Revolution) artifacts like the bazillions of cash coins that are found all the time in China, but hope CPAC recognizes that current restrictions have done little but to provide Chinese auction houses and dealers with a leg up on their foreign (especially US) competition.
Is it about protecting the archaeological record or encouraging the continued movement of the trade in Chinese artifacts to China and other major market countries?
More Double Standards at CPAC?
The New York Times has reported that the Cambodian Government asked for CPAC member Jane Levine, who is also employed by Sotheby's, to be recused from deliberating on the upcoming CPAC meeting relating to the renewal of the Cambodian MOU. Presumably, the Cambodians are claiming that Levine cannot fairly discharge her duties given the ongoing dispute involving a Khmer statue. The article indicates Levine was not going to attend the meeting anyway due to a conflict with a Sotheby's board meeting, but also suggests that the "scheduling conflict" may have provided Levine and Sotheby's with a graceful exit from the dispute.
But, if so, it's worth recalling that State failed to recuse an archaeologist who received an excavation permit from Cyprus despite the clear conflict of interest issues her participation in deliberations related to the renewal of the Cypriot MOU raised.
So, once again, is there one standard applied to collectors and the trade and another for archaeologists aligned with the State Department and source country bureaucracies?
But, if so, it's worth recalling that State failed to recuse an archaeologist who received an excavation permit from Cyprus despite the clear conflict of interest issues her participation in deliberations related to the renewal of the Cypriot MOU raised.
So, once again, is there one standard applied to collectors and the trade and another for archaeologists aligned with the State Department and source country bureaucracies?
Cultural Nationalism Now Bites American Archaeologists
A Kurdish source is reporting that the Iraqi Ministry of Tourism and Antiquities has stopped dealing with US archaeological teams in response to the refusal of US authorities to return Iraqi Jewish artifacts to the country.
If so, this is a rebuff not only to American archaeologists who have tirelessly promoted the interests of the Iraqi archaeological establishment (both during and after the fall of Saddam's Baathist regime) but also to the US State Department Bureau of Educational and Cultural Affairs and its Cultural Heritage Center, which have lavished millions of dollars on the Iraqi archaeological establishment-- all at a time US cultural institutions are finding themselves in an extremely harsh financial climate.
In punishing American archaeologists for a dispute over the repatriation of cultural artifacts, the Iraqis are apparently taking a page from the Turkish Government which has also recently punished German archaeologists for the perceived transgressions of German state museums.
Here, the Iraqis are apparently specifically miffed at US reconsideration of a controversial State Department "commitment" to return cultural artifacts confiscated from Iraqi Jews who were forced from their homeland in a callous act of "ethnic cleansing". Given their own "unclean hands," it's hard to see any "moral rights" Iraq may have to such artifacts.
And in an ironic twist, American archaeologists apparently have now themselves become the "victims" of the very same virulent cultural nationalism they have themselves done so much to foster. Perhaps it's finally time for the Archaeological Institute of America to rethink its unqualified support for the broadest claims of any nation state where American archaeologists excavate.
And it's certainly time to cut any further funding of Iraqi archaeology or the repatriation of any "Iraqi looking" cultural goods based on the slimmest suspicion they may have left that country after an international embargo was placed on the import of any Iraqi products.
If so, this is a rebuff not only to American archaeologists who have tirelessly promoted the interests of the Iraqi archaeological establishment (both during and after the fall of Saddam's Baathist regime) but also to the US State Department Bureau of Educational and Cultural Affairs and its Cultural Heritage Center, which have lavished millions of dollars on the Iraqi archaeological establishment-- all at a time US cultural institutions are finding themselves in an extremely harsh financial climate.
In punishing American archaeologists for a dispute over the repatriation of cultural artifacts, the Iraqis are apparently taking a page from the Turkish Government which has also recently punished German archaeologists for the perceived transgressions of German state museums.
Here, the Iraqis are apparently specifically miffed at US reconsideration of a controversial State Department "commitment" to return cultural artifacts confiscated from Iraqi Jews who were forced from their homeland in a callous act of "ethnic cleansing". Given their own "unclean hands," it's hard to see any "moral rights" Iraq may have to such artifacts.
And in an ironic twist, American archaeologists apparently have now themselves become the "victims" of the very same virulent cultural nationalism they have themselves done so much to foster. Perhaps it's finally time for the Archaeological Institute of America to rethink its unqualified support for the broadest claims of any nation state where American archaeologists excavate.
And it's certainly time to cut any further funding of Iraqi archaeology or the repatriation of any "Iraqi looking" cultural goods based on the slimmest suspicion they may have left that country after an international embargo was placed on the import of any Iraqi products.
Small Businessman Pleads Guilty to False Statements; Government Ignores Allegations of Misrepresentations to Congress
Morris Khouli, a New York antiquities and coin dealer, has plead guilty to smuggling and false statements to federal law enforcement. See http://www.justice.gov/usao/nye/pr/2012/2012apr18c.html.
Hopefully, the Court will not sentence Mr. Khouli to anywhere near the 20 year maximum for the offenses. Any such penalty would be very harsh for the conduct alleged in the indictment.
One must also question a system where a small businessman can potentially be sentenced to 20 years for falsifying import documents, but which ignores credible allegations that State Department Bureau of Educational and Cultural Affairs Employees misled Congress in an official report about CPAC's true recommendations concerning the controversial 2007 decision to impose import restrictions on coins.
And even worse, it is likely that some of the same employees who pressed for the prosecution of Mr. Khouli, also had something to do with any false declarations to Congress.
Hopefully, the Court will not sentence Mr. Khouli to anywhere near the 20 year maximum for the offenses. Any such penalty would be very harsh for the conduct alleged in the indictment.
One must also question a system where a small businessman can potentially be sentenced to 20 years for falsifying import documents, but which ignores credible allegations that State Department Bureau of Educational and Cultural Affairs Employees misled Congress in an official report about CPAC's true recommendations concerning the controversial 2007 decision to impose import restrictions on coins.
And even worse, it is likely that some of the same employees who pressed for the prosecution of Mr. Khouli, also had something to do with any false declarations to Congress.
PLA Poly Seeks Consignments World-Wide
Poly Auction Co. Ltd. in Beijing�which is the largest art auction house in China, founded by officers of the People�s Liberation Army with strong support from the friends in the PRC government, is seeking consignments for its antiquity and coin auctions.
The front of the card shows several items recently sold at the Poly Auctions in Beijing, including:
A Silver One Dollar Coin (Commemorative) Portrait of Zhang Zuoling,
Early Republic Period, dated 1926
sold for RMB 2,300,000 (US $364,000)
Ancient Han Dynasty Bronze �Guobao jinkui zhiwan� Coin
Xin Mang Period (A.D. 9-23)
sold for RMB 1,150,000 (US $182,000)
Kunlun Bank 50 Liang Silver Ingot
Imperial Qing Dynasty Xuantong era (1908-1912)
sold for RMB 1,150,000 (US $182,000)
Ancient Chinese Bronze �Qing Yang� Mirror
Eastern Han Dynasty � Three Kingdoms Period, A.D. Late 2nd-3rd Century
sold for RMB 5,175,000 (US $819,000)
The purpose of this mailing, distributed throughout China, Asia and around the world, is to solicit property for sale in Poly Art Auctions in Beijing in Spring 2012.
Is the State Department�s MOU and import restrictions on wide ranges of Chinese cultural goods doing anything other than providing "connected" Chinese auction houses with a major competitive advantage over their US competitors?
The front of the card shows several items recently sold at the Poly Auctions in Beijing, including:
A Silver One Dollar Coin (Commemorative) Portrait of Zhang Zuoling,
Early Republic Period, dated 1926
sold for RMB 2,300,000 (US $364,000)
Ancient Han Dynasty Bronze �Guobao jinkui zhiwan� Coin
Xin Mang Period (A.D. 9-23)
sold for RMB 1,150,000 (US $182,000)
Kunlun Bank 50 Liang Silver Ingot
Imperial Qing Dynasty Xuantong era (1908-1912)
sold for RMB 1,150,000 (US $182,000)
Ancient Chinese Bronze �Qing Yang� Mirror
Eastern Han Dynasty � Three Kingdoms Period, A.D. Late 2nd-3rd Century
sold for RMB 5,175,000 (US $819,000)
The purpose of this mailing, distributed throughout China, Asia and around the world, is to solicit property for sale in Poly Art Auctions in Beijing in Spring 2012.
Is the State Department�s MOU and import restrictions on wide ranges of Chinese cultural goods doing anything other than providing "connected" Chinese auction houses with a major competitive advantage over their US competitors?
CPAC To Meet
The Federal Register reports that the Cultural Property Advisory Committee will meet to discuss renewals of current MOU's with Guatemala and Mali, and to conduct further discussion in secret about a request from Bulgaria. See http://www.ofr.gov/(S(mb4uyziobevezdhmm1qt4oyc))/OFRUpload/OFRData/2012-05909_PI.pdf
Archaeo-blogger Rick St. Hilaire's post about the upcoming meeting seeks to portray the secrecy and culture creep that has marked the Bureau of Educational and Cultural Affairs'administration of the CPIA as both necessary and consistent with the statutory mandate. See http://culturalheritagelawyer.blogspot.com/2012/03/mali-guatemala-and-bulgaria-up-for.html
However, others-- including several former CPAC members-- have questioned this, most recently during a public forum on Capitol Hill. See http://ordinarymag.blogspot.com/2011/03/cultural-property-implementation-act-is.html
Archaeo-blogger Rick St. Hilaire's post about the upcoming meeting seeks to portray the secrecy and culture creep that has marked the Bureau of Educational and Cultural Affairs'administration of the CPIA as both necessary and consistent with the statutory mandate. See http://culturalheritagelawyer.blogspot.com/2012/03/mali-guatemala-and-bulgaria-up-for.html
However, others-- including several former CPAC members-- have questioned this, most recently during a public forum on Capitol Hill. See http://ordinarymag.blogspot.com/2011/03/cultural-property-implementation-act-is.html
State Indirectly Funding War on Sotheby's?
During the Vietnam war era, the US Government funded a "secret war" in Cambodia. Now, is the State Department Bureau of Educational and Cultural Affairs and its Cultural Heritage Center indirectly funding a not so secret war against Sotheby's Auction House?
Heritage Watch, an archaeological advocacy group with a focus on Cambodia, has been at the forefront of a recent campaign against Sotheby�s. See http://art-crime.blogspot.com/2011/10/what-does-lack-of-provenance-indicate.html
And http://www.nytimes.com/2012/02/29/arts/design/sothebys-caught-in-dispute-over-prized-cambodian-statue.html?pagewanted=1
At the same time, Heritage Watch has received funding from the State Department�s Bureau of Educational and Cultural Affairs and its Cultural Heritage Center:
See http://ordinarymag.blogspot.com/2008/09/eca-ambassadors-fund-awards-22-million.html and http://ordinarymag.blogspot.com/2008/09/cambodian-import-restrictions-extended.html
Is State indirectly funding the archaeological lobby�s war on Sotheby�s? If so, it would be consistent with State's ongoing funding of the Cyprus American Archaeological Research Institute, which has been at the forefront of lobbying for a clamp down on collectors of ancient coins and other artifacts from Cyprus.
Heritage Watch, an archaeological advocacy group with a focus on Cambodia, has been at the forefront of a recent campaign against Sotheby�s. See http://art-crime.blogspot.com/2011/10/what-does-lack-of-provenance-indicate.html
And http://www.nytimes.com/2012/02/29/arts/design/sothebys-caught-in-dispute-over-prized-cambodian-statue.html?pagewanted=1
At the same time, Heritage Watch has received funding from the State Department�s Bureau of Educational and Cultural Affairs and its Cultural Heritage Center:
See http://ordinarymag.blogspot.com/2008/09/eca-ambassadors-fund-awards-22-million.html and http://ordinarymag.blogspot.com/2008/09/cambodian-import-restrictions-extended.html
Is State indirectly funding the archaeological lobby�s war on Sotheby�s? If so, it would be consistent with State's ongoing funding of the Cyprus American Archaeological Research Institute, which has been at the forefront of lobbying for a clamp down on collectors of ancient coins and other artifacts from Cyprus.
ICOM "Red List" to Pave the Way for New Restrictions on Egyptian Cultural Goods?
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.
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.
Hispanic Society Coins Put on the Auction Block
The Hispanic Society has put its collection of 38,000 historic Spanish coins up on the auction block in one lot with an estimated value of between $25-$38 million. See http://artsbeat.blogs.nytimes.com/2011/12/15/hispanic-society-enlists-sothebys-to-auction-rare-collection-of-coins/
Archer Huntington endowed both the Hispanic Society and the American Numismatic Society, where the coins were previously kept. See http://en.wikipedia.org/wiki/Archer_Milton_Huntington The fate of the group was the subject of litigation between the ANS and the Hispanic Society, which ended up with the Hispanic Society being awarded the coins they now want to sell.
If the collection could not stay intact, I'd rather it was broken up to allow American collectors and perhaps the ANS or ANA a chance at purchasing at least some of the coins. Given the estimated price, who will buy the group? The Smithsonian? Laughable. Cash strapped Spain? Doubtful. More likely the coins will go further East to the Persian Gulf or perhaps China.
Will the ANS be conducting a similar fire sale directed at foreign buyers sometime in the not too distant future? Let's hope not, but recognize such a possibility is becoming more likely given today's realities.
I've observed that both a prosperous numismatic trade and collector interest are essential to fund the ANS and the serious study of ancient numismatics in this country. See http://numismatics.org/wikiuploads/DigitalPublications/WitschonkeTompaFinal.pdf The fanatics at the AIA and the obdurate bureaucrats at the State Department's Bureau of Educational and Cultural Affairs might want to consider how their efforts to suppress ancient coin collecting will impact numismatic study in this country before its too late.
Archer Huntington endowed both the Hispanic Society and the American Numismatic Society, where the coins were previously kept. See http://en.wikipedia.org/wiki/Archer_Milton_Huntington The fate of the group was the subject of litigation between the ANS and the Hispanic Society, which ended up with the Hispanic Society being awarded the coins they now want to sell.
If the collection could not stay intact, I'd rather it was broken up to allow American collectors and perhaps the ANS or ANA a chance at purchasing at least some of the coins. Given the estimated price, who will buy the group? The Smithsonian? Laughable. Cash strapped Spain? Doubtful. More likely the coins will go further East to the Persian Gulf or perhaps China.
Will the ANS be conducting a similar fire sale directed at foreign buyers sometime in the not too distant future? Let's hope not, but recognize such a possibility is becoming more likely given today's realities.
I've observed that both a prosperous numismatic trade and collector interest are essential to fund the ANS and the serious study of ancient numismatics in this country. See http://numismatics.org/wikiuploads/DigitalPublications/WitschonkeTompaFinal.pdf The fanatics at the AIA and the obdurate bureaucrats at the State Department's Bureau of Educational and Cultural Affairs might want to consider how their efforts to suppress ancient coin collecting will impact numismatic study in this country before its too late.
Will the Obama State Department Uphold Import Restrictions Allegedly Founded on Cronyism?
How did the controverisal decision to impose import restriction on Cypriot coins come about? This is a significant issue because this "precedent" has formed the basis for far more extensive restrictions on Chinese, Italian and now Greek coins.
Well, here are some unrebutted allegations from ACCG's Amended Complaint in the Baltimore Test Case. They are largely based on information from FOIA releases:
48. In or about November 2005, Dr. Pavlos Florentzos, Director of the Cyprus Department of Antiquities, visited the United States at the invitation of CAARI and with the support of the U.S. Embassy in Cyprus. During this time, CAARI facilitated a meeting between Florentzos and employees of ECA�s Cultural Heritage Center, including its Executive Director, Maria Kourpoupas, and a staff archaeologist. See J. Green, Cyprus Director of Antiquities, Dr. Pavolos Flourtzos, Visits the U.S., 31 CAARI News 3 (Winter 2006).
49. Upon information and belief, CAARI has benefited from direct and/or indirect financial and/or material support from State, the Government of Cyprus and Cypriot entities, including the Bank of Cyprus Cultural Foundation.
50. Upon information and belief, the Bank of Cyprus Cultural Foundation was established to rescue the Island�s cultural heritage, which the Foundation maintains was pillaged and destroyed by Turkish forces when they occupied the Northern part of the Island. Upon further information and belief, the Bank of Cyprus Cultural Foundation maintains one of the largest collections of ancient coins of Cypriot type within Cyprus. Upon further information and belief, the Bank of Cyprus Cultural Foundation purchases unprovenanced coins on the open market for its collection of the sort now subject to U.S. import restrictions on coins of Cypriot type.
51. On January 19, 2006, State announced a five (5) year renewal of its Memorandum of Understanding (MOU) with Italy relating to cultural artifacts. Once again, Defendants exempted ancient coins struck in Italy from import restrictions.
52. On December 7, 2006, the Federal Register carried a notice indicating that CPAC would conduct a review of the MOU with Cyprus. That notice invited public comment to be submitted no later than January 11, 2007. The Federal Register notice contained no mention of an effort to extend new restrictions to coins. See 71 Fed. Reg. 71015-71016 (Dec. 7, 2006).
53. On December 8, 2006, Principal Deputy Assistant Secretary, ECA Miller Crouch indicated in a response to an e-mail inquiry that he �d[id] not anticipate� that new restrictions on coins would be addressed at CPAC�s hearing to consider the renewal of the MOU with Cyprus.
54. On December 14, 2006, two numismatic trade associations filed a request with State to recuse CPAC member Joan Connelly from voting on any last minute effort to impose import restrictions on ancient Cypriot coins. That recusal request noted that Dr. Connelly excavated in Cyprus and had publicly thanked �the Department of Antiquities of Cyprus, its Director, Dr. Demos Christou and the Ministry of Communication and Works, Republic of Cyprus, for granting us the license to excavate on Yeronisos Island.�
55. On January 12, 2007, State summarily denied the recusal request.
56. On January 17, 2007, according to a heavily redacted document released in response to a FOIA request, a State ECA Cultural Heritage Center staff archaeologist conferred with the late Dr. Danielle Parks, an archaeologist associated with the CAARI, about the inclusion of coins in the Cypriot request.
57. On January 19, 2007, according to a document released in response to a FOIA request, Cyprus requested State to amend the designated list of artifacts subject to import restriction to include coins of Cypriot type.
58. On January 25, 2007, CPAC conducted a public hearing on the renewal of the MOU with Cyprus. At that hearing, CPAC Chairman Jay Kislak announced that he had learned that Cyprus had requested that State amend the designated list of Cypriot artifacts subject to import restrictions to include coins of Cypriot type.
59. Upon information and belief, at that same hearing, neither Cypriot authorities nor members of the archaeological community could point to any material change of fact justifying a change in the exemption from import restrictions on Cypriot coins.
60. On January 26, 2007, in response to complaints about the lack of public notice for the inclusion of coins in the Cypriot request, State announced an additional ten (10) day comment period. State made this announcement on the Cultural Heritage Center website and not in the Federal Register. Nevertheless, during this extremely short time frame, numismatic groups generated over 1100 letters opposing the extension of import restrictions to coins.
61. Upon information and belief, comments provided by ACCG and others established: (a) that Cypriot coins were common, with many known examples of coin types struck on the Island; (b) that Cypriot coins travelled widely so that one could not assume that a coin struck in Cyprus was �first discovered� there; (c) that less drastic remedies like the imposition of a treasure trove law and/or the regulation of metal detectors should be tried before import restrictions were considered; (d) and that the CPIA�s �concerted international response� requirement could not be met.
62. Upon information and belief CAARI, the AIA, the Bank of Cyprus Cultural Foundation, and the late Dr. Danielle Parks submitted comments supporting import restrictions at the behest of Cyprus.
63. In a letter dated February 5, 2007, the AIA�s president claimed that it was proper to assume that coins of Cypriot type can be assumed to have Cypriot find spots, because �Coins minted on Cyprus were very rarely taken from the island in antiquity.�
64. On May 2, 2007, Assistant Secretary of State, ECA Dina Powell, the decision maker for the extension of the MOU with Cyprus announced her departure to become the Director for Global Corporate Engagement at Goldman Sachs. See http://en.wikipedia.org/wiki/Dina_Powell (last checked, 7/2/10).
65. Upon information and belief, Goldman Sachs is a bank holding company with worldwide business interests, likely including relationships with Cyprus or Cypriot entities like the Bank of Cyprus.
66. On or about May 7, 2007, according to a document released in response to a FOIA request, CPAC issued its report making its recommendations concerning the extension of the MOU with Cyprus.
67. On or about May 14, 2007, according to a document released in response to a FOIA request, Pavolos Flouretzos, Director, Cypriot Department of Antiquities, admitted in a private communication to State, �It is true that Cypriot coins shared the same destiny as all other coins of the ancient world. As a standard media of exchange they circulated all over the ancient world due to their small size, which facilitated their easy transport� The continuous circulation of coins for many centuries amongst collectors and between collectors and museums make any attempt to locate their exact find spot extremely difficult.�
68. On or about May 16, 2007, Undersecretary of State Nicholas Burns, upon information and belief the third ranking official at State, accepted an award from Greek and Greek Cypriot advocacy groups as these groups lobbied the State policy makers. According to a press release, "Undersecretary of State Nicholas Burns was the first Philhellene to receive the Livanos Award. This award is given each year to, as its states on the award, 'that individual who, like George P. Livanos, has utilized ancient Hellenic values to realize extraordinary achievement in modern society while contributing to the improvement of our civilization.'" See http://news.pseka.net/uploads/img/documents/PSEKA-SAE_2007_Conference_EN_01_CEH_01.pdf (last checked, 7/2/10).
69. On or about May 16, 2007, State�s news service quoted Burns as stating on receipt of the Livanos award, "I wear this title of Philhellene rather proudly. You don�t spend four years in Greece, as my wife and three daughters and I did, and not come back feeling committed to Greek thought, to the Greek way of life, to Greece itself in my case....We�re personally committed to the country, to the relationship."
70. On May 17, 2007, according to a document released in response to a FOIA request, Kurt Volker, Acting Assistant Secretary of State, Bureau of European and Eurasian Affairs, wrote the Assistant Secretary, ECA Dina Powell, stating �[G]iven our general support for protection of antiquities and the importance of this MOU to our bilateral relations with Cyprus, EUR strongly recommends that ECA approve the renewal of the MOU and include the protection of coins.�
71. On May 29, 2007, according to a document released in redacted form in response to a FOIA request, Principal Deputy Assistant Secretary, ECA Miller Crouch wrote an �Action Memo� to the decision maker Assistant Secretary, ECA Dina Powell regarding the extension of the MOU with Cyprus. That Action Memo only provides the decision maker with the false choice of approving the import restrictions including coins in their entirety or disapproving them in their entirety. The Action Memo does not provide the decision maker the option of continuing the then current import restrictions without extending them to coins.
72. On May 30, 2007, according to that same document, Assistant Secretary of State Dina Powell signed off on that action memo that authorized import restrictions on ancient coins of Cypriot type.
73. On July 13, 2007, Defendants formally extended import restrictions to coins of Cypriot Types. See Extension of Import Restrictions Imposed on Pre-Classical and Classical Archaeological Objects and Byzantine Period Ecclesiastical and Ritual Ethnological Material from Cyprus, 19 CFR Part 12, reported at 72 Fed. Reg. 38470-74 (July 13, 2007).
74. On July 16, 2007, the MOU renewal with Cyprus was signed. That MOU fails to suggest that restrictions under the agreement satisfy the CPIA�s requirements, including the requirement �concerted international response� requirement or the requirement that less drastic remedies than import restrictions on coins are not available.
75. On July 19, 2007, Undersecretary Nicholas Burns conducted a signing ceremony for the MOU to coincide with Greek and Greek Cypriot lobbying efforts on Capitol Hill and at the State Department itself. Upon information and belief, representatives of CAARI were invited to this signing ceremony.
76. The official transcript of the Cyprus MOU signing ceremony omits several significant words. In the transcript, Ambassador Kakouris of Cyprus is reported as saying, "In fact, I was reminded just before we came in about something that I had said in January when we were before the Committee and responding to someone very much on the side of the coin collectors who -- talked about the hobby of collecting coins. And I said to him: �It may be your hobby, but it's our heritage!" and that is the way that we look at this issue.�"
77. In fact, what Kakouris actually said can be heard (at 10:09 of the audio). There, he states, "In fact, I was reminded by [Cultural Heritage Center ED] Maria Kouroupas just before we came in about something that I had said in January when we were before the Committee and dealing with the coin collectors and somebody who was very much on their side, when he talked about the hobby of collecting coins. And I said to him: �It may be your hobby, but it's our heritage!" and that is the way that we look at this issue.�" (Emphasis added.)
78. On July 20, 2007, State issued a press release about the MOU. That press release stated, �With the extension of this MOU, DHS amended the designated list of restricted categories to include ancient coins of Cypriot types produced from the end of the 6th century B.C. to 235 A.D. Coins, a significant and inseparable part of the archaeological record of the island, are especially valuable to understanding the history of Cyprus. This extension of the MOU is consistent with the recommendation of the Cultural Property Advisory Committee, which is administered by the Bureau for Educational and Cultural Affairs.� (Emphasis added.)
79. On August 29, 2007, State sent a report mandated under the CPIA to Congress. Under 19 U.S.C. � 2602 (g)(2), that report is required to: (a) describe the actions taken; (b) whether there were any differences between those actions and CPAC�s recommendations; and, (c) if so, the reasons for those differences. That report, however, contains no indication whether State rejected CPAC recommendation against import restrictions on coins, and, if so, why?
80. In addition, that report also indicates that Customs acted as the lead agency for imposing import restrictions on coins. In pertinent part, the report states, �The Federal Register notice for Cyprus was amended by the Department for Homeland Security, in consultation with the Department of State, to include coins of Cypriot types which are also vulnerable to archaeological looting.�
81. In or about July 17, 2007, ECA publicized the new restrictions on coins of Cypriot types on its website as follows: �The Government of the Republic of Cyprus requested and amendment to the designated list to include coins�. Q. What was the response? A. The Cultural Property Implementation Act places the authority for the Designated List with the Department of Homeland Security (DHS) in consultation with the Department of State. On July 13, 2007, DHS published a Federal Register notice concerning the extension of the agreement and amending the Designated List to include certain coins from Cyprus, effective July 16, 2007.�
82. In or about May-June 2008, the Cyprus News Service quoted CAARI�s president as stating, �CAARI has been in the forefront of the successful effort to renew the Memorandum of Understanding between Cyprus and the USA restricting the import of Cypriot antiquities into the United States�..� See http://www.caari.org/CAARIat30.htm (last checked, 7/2/10).
83. On January 16, 2009, the Federal Register announced import restrictions on Chinese cultural artifacts, including those on early media of exchange to Tang era cash coins. See 19 CFR Part 12, reported at 74 Fed. Reg. 2838-2844 (Jan. 16, 2009).
84. On April 20, 2009, past CPAC Chairman Jay Kislak signed a declaration in FOIA litigation that stated in pertinent part:
o I am told that Section 303 (g) of the CPIA requires the State Department to report to Congress any differences between CPAC�s recommendations and the State Department�s ultimate decision to impose import restrictions. In this regard, the release of the most recent CPAC report related to Cyprus and its discussion about coins could clarify misleading information contained in official State Department documents.
o I specifically recall the Cypriot request that then current import restrictions on other cultural artifacts be extended to coins was a matter of great public controversy. CPAC considered the question specifically and I recall a special vote being taken on this particular issue.
o With that in mind, I have reviewed both an official State Department Press Release and a State Department report made pursuant to CPIA Section 303 (g) about the MOU with Cyprus�I believe it is absolutely false to suggest in those materials that the State Department�s decision to extend import restrictions to ancient coins was consistent with CPAC�s recommendations. The full release of CPAC�s recommendations with regard to coins could be in the public interest because it should clarify misleading information contained in official State Department documents.
Will the Obama Administration and CPAC investigate these allegations before deciding to renew the Cypriot MOU? If true, don't they suggest that the MOU be terminated instead because it is founded on cronyism? If not, why not?
Well, here are some unrebutted allegations from ACCG's Amended Complaint in the Baltimore Test Case. They are largely based on information from FOIA releases:
48. In or about November 2005, Dr. Pavlos Florentzos, Director of the Cyprus Department of Antiquities, visited the United States at the invitation of CAARI and with the support of the U.S. Embassy in Cyprus. During this time, CAARI facilitated a meeting between Florentzos and employees of ECA�s Cultural Heritage Center, including its Executive Director, Maria Kourpoupas, and a staff archaeologist. See J. Green, Cyprus Director of Antiquities, Dr. Pavolos Flourtzos, Visits the U.S., 31 CAARI News 3 (Winter 2006).
49. Upon information and belief, CAARI has benefited from direct and/or indirect financial and/or material support from State, the Government of Cyprus and Cypriot entities, including the Bank of Cyprus Cultural Foundation.
50. Upon information and belief, the Bank of Cyprus Cultural Foundation was established to rescue the Island�s cultural heritage, which the Foundation maintains was pillaged and destroyed by Turkish forces when they occupied the Northern part of the Island. Upon further information and belief, the Bank of Cyprus Cultural Foundation maintains one of the largest collections of ancient coins of Cypriot type within Cyprus. Upon further information and belief, the Bank of Cyprus Cultural Foundation purchases unprovenanced coins on the open market for its collection of the sort now subject to U.S. import restrictions on coins of Cypriot type.
51. On January 19, 2006, State announced a five (5) year renewal of its Memorandum of Understanding (MOU) with Italy relating to cultural artifacts. Once again, Defendants exempted ancient coins struck in Italy from import restrictions.
52. On December 7, 2006, the Federal Register carried a notice indicating that CPAC would conduct a review of the MOU with Cyprus. That notice invited public comment to be submitted no later than January 11, 2007. The Federal Register notice contained no mention of an effort to extend new restrictions to coins. See 71 Fed. Reg. 71015-71016 (Dec. 7, 2006).
53. On December 8, 2006, Principal Deputy Assistant Secretary, ECA Miller Crouch indicated in a response to an e-mail inquiry that he �d[id] not anticipate� that new restrictions on coins would be addressed at CPAC�s hearing to consider the renewal of the MOU with Cyprus.
54. On December 14, 2006, two numismatic trade associations filed a request with State to recuse CPAC member Joan Connelly from voting on any last minute effort to impose import restrictions on ancient Cypriot coins. That recusal request noted that Dr. Connelly excavated in Cyprus and had publicly thanked �the Department of Antiquities of Cyprus, its Director, Dr. Demos Christou and the Ministry of Communication and Works, Republic of Cyprus, for granting us the license to excavate on Yeronisos Island.�
55. On January 12, 2007, State summarily denied the recusal request.
56. On January 17, 2007, according to a heavily redacted document released in response to a FOIA request, a State ECA Cultural Heritage Center staff archaeologist conferred with the late Dr. Danielle Parks, an archaeologist associated with the CAARI, about the inclusion of coins in the Cypriot request.
57. On January 19, 2007, according to a document released in response to a FOIA request, Cyprus requested State to amend the designated list of artifacts subject to import restriction to include coins of Cypriot type.
58. On January 25, 2007, CPAC conducted a public hearing on the renewal of the MOU with Cyprus. At that hearing, CPAC Chairman Jay Kislak announced that he had learned that Cyprus had requested that State amend the designated list of Cypriot artifacts subject to import restrictions to include coins of Cypriot type.
59. Upon information and belief, at that same hearing, neither Cypriot authorities nor members of the archaeological community could point to any material change of fact justifying a change in the exemption from import restrictions on Cypriot coins.
60. On January 26, 2007, in response to complaints about the lack of public notice for the inclusion of coins in the Cypriot request, State announced an additional ten (10) day comment period. State made this announcement on the Cultural Heritage Center website and not in the Federal Register. Nevertheless, during this extremely short time frame, numismatic groups generated over 1100 letters opposing the extension of import restrictions to coins.
61. Upon information and belief, comments provided by ACCG and others established: (a) that Cypriot coins were common, with many known examples of coin types struck on the Island; (b) that Cypriot coins travelled widely so that one could not assume that a coin struck in Cyprus was �first discovered� there; (c) that less drastic remedies like the imposition of a treasure trove law and/or the regulation of metal detectors should be tried before import restrictions were considered; (d) and that the CPIA�s �concerted international response� requirement could not be met.
62. Upon information and belief CAARI, the AIA, the Bank of Cyprus Cultural Foundation, and the late Dr. Danielle Parks submitted comments supporting import restrictions at the behest of Cyprus.
63. In a letter dated February 5, 2007, the AIA�s president claimed that it was proper to assume that coins of Cypriot type can be assumed to have Cypriot find spots, because �Coins minted on Cyprus were very rarely taken from the island in antiquity.�
64. On May 2, 2007, Assistant Secretary of State, ECA Dina Powell, the decision maker for the extension of the MOU with Cyprus announced her departure to become the Director for Global Corporate Engagement at Goldman Sachs. See http://en.wikipedia.org/wiki/Dina_Powell (last checked, 7/2/10).
65. Upon information and belief, Goldman Sachs is a bank holding company with worldwide business interests, likely including relationships with Cyprus or Cypriot entities like the Bank of Cyprus.
66. On or about May 7, 2007, according to a document released in response to a FOIA request, CPAC issued its report making its recommendations concerning the extension of the MOU with Cyprus.
67. On or about May 14, 2007, according to a document released in response to a FOIA request, Pavolos Flouretzos, Director, Cypriot Department of Antiquities, admitted in a private communication to State, �It is true that Cypriot coins shared the same destiny as all other coins of the ancient world. As a standard media of exchange they circulated all over the ancient world due to their small size, which facilitated their easy transport� The continuous circulation of coins for many centuries amongst collectors and between collectors and museums make any attempt to locate their exact find spot extremely difficult.�
68. On or about May 16, 2007, Undersecretary of State Nicholas Burns, upon information and belief the third ranking official at State, accepted an award from Greek and Greek Cypriot advocacy groups as these groups lobbied the State policy makers. According to a press release, "Undersecretary of State Nicholas Burns was the first Philhellene to receive the Livanos Award. This award is given each year to, as its states on the award, 'that individual who, like George P. Livanos, has utilized ancient Hellenic values to realize extraordinary achievement in modern society while contributing to the improvement of our civilization.'" See http://news.pseka.net/uploads/img/documents/PSEKA-SAE_2007_Conference_EN_01_CEH_01.pdf (last checked, 7/2/10).
69. On or about May 16, 2007, State�s news service quoted Burns as stating on receipt of the Livanos award, "I wear this title of Philhellene rather proudly. You don�t spend four years in Greece, as my wife and three daughters and I did, and not come back feeling committed to Greek thought, to the Greek way of life, to Greece itself in my case....We�re personally committed to the country, to the relationship."
70. On May 17, 2007, according to a document released in response to a FOIA request, Kurt Volker, Acting Assistant Secretary of State, Bureau of European and Eurasian Affairs, wrote the Assistant Secretary, ECA Dina Powell, stating �[G]iven our general support for protection of antiquities and the importance of this MOU to our bilateral relations with Cyprus, EUR strongly recommends that ECA approve the renewal of the MOU and include the protection of coins.�
71. On May 29, 2007, according to a document released in redacted form in response to a FOIA request, Principal Deputy Assistant Secretary, ECA Miller Crouch wrote an �Action Memo� to the decision maker Assistant Secretary, ECA Dina Powell regarding the extension of the MOU with Cyprus. That Action Memo only provides the decision maker with the false choice of approving the import restrictions including coins in their entirety or disapproving them in their entirety. The Action Memo does not provide the decision maker the option of continuing the then current import restrictions without extending them to coins.
72. On May 30, 2007, according to that same document, Assistant Secretary of State Dina Powell signed off on that action memo that authorized import restrictions on ancient coins of Cypriot type.
73. On July 13, 2007, Defendants formally extended import restrictions to coins of Cypriot Types. See Extension of Import Restrictions Imposed on Pre-Classical and Classical Archaeological Objects and Byzantine Period Ecclesiastical and Ritual Ethnological Material from Cyprus, 19 CFR Part 12, reported at 72 Fed. Reg. 38470-74 (July 13, 2007).
74. On July 16, 2007, the MOU renewal with Cyprus was signed. That MOU fails to suggest that restrictions under the agreement satisfy the CPIA�s requirements, including the requirement �concerted international response� requirement or the requirement that less drastic remedies than import restrictions on coins are not available.
75. On July 19, 2007, Undersecretary Nicholas Burns conducted a signing ceremony for the MOU to coincide with Greek and Greek Cypriot lobbying efforts on Capitol Hill and at the State Department itself. Upon information and belief, representatives of CAARI were invited to this signing ceremony.
76. The official transcript of the Cyprus MOU signing ceremony omits several significant words. In the transcript, Ambassador Kakouris of Cyprus is reported as saying, "In fact, I was reminded just before we came in about something that I had said in January when we were before the Committee and responding to someone very much on the side of the coin collectors who -- talked about the hobby of collecting coins. And I said to him: �It may be your hobby, but it's our heritage!" and that is the way that we look at this issue.�"
77. In fact, what Kakouris actually said can be heard (at 10:09 of the audio). There, he states, "In fact, I was reminded by [Cultural Heritage Center ED] Maria Kouroupas just before we came in about something that I had said in January when we were before the Committee and dealing with the coin collectors and somebody who was very much on their side, when he talked about the hobby of collecting coins. And I said to him: �It may be your hobby, but it's our heritage!" and that is the way that we look at this issue.�" (Emphasis added.)
78. On July 20, 2007, State issued a press release about the MOU. That press release stated, �With the extension of this MOU, DHS amended the designated list of restricted categories to include ancient coins of Cypriot types produced from the end of the 6th century B.C. to 235 A.D. Coins, a significant and inseparable part of the archaeological record of the island, are especially valuable to understanding the history of Cyprus. This extension of the MOU is consistent with the recommendation of the Cultural Property Advisory Committee, which is administered by the Bureau for Educational and Cultural Affairs.� (Emphasis added.)
79. On August 29, 2007, State sent a report mandated under the CPIA to Congress. Under 19 U.S.C. � 2602 (g)(2), that report is required to: (a) describe the actions taken; (b) whether there were any differences between those actions and CPAC�s recommendations; and, (c) if so, the reasons for those differences. That report, however, contains no indication whether State rejected CPAC recommendation against import restrictions on coins, and, if so, why?
80. In addition, that report also indicates that Customs acted as the lead agency for imposing import restrictions on coins. In pertinent part, the report states, �The Federal Register notice for Cyprus was amended by the Department for Homeland Security, in consultation with the Department of State, to include coins of Cypriot types which are also vulnerable to archaeological looting.�
81. In or about July 17, 2007, ECA publicized the new restrictions on coins of Cypriot types on its website as follows: �The Government of the Republic of Cyprus requested and amendment to the designated list to include coins�. Q. What was the response? A. The Cultural Property Implementation Act places the authority for the Designated List with the Department of Homeland Security (DHS) in consultation with the Department of State. On July 13, 2007, DHS published a Federal Register notice concerning the extension of the agreement and amending the Designated List to include certain coins from Cyprus, effective July 16, 2007.�
82. In or about May-June 2008, the Cyprus News Service quoted CAARI�s president as stating, �CAARI has been in the forefront of the successful effort to renew the Memorandum of Understanding between Cyprus and the USA restricting the import of Cypriot antiquities into the United States�..� See http://www.caari.org/CAARIat30.htm (last checked, 7/2/10).
83. On January 16, 2009, the Federal Register announced import restrictions on Chinese cultural artifacts, including those on early media of exchange to Tang era cash coins. See 19 CFR Part 12, reported at 74 Fed. Reg. 2838-2844 (Jan. 16, 2009).
84. On April 20, 2009, past CPAC Chairman Jay Kislak signed a declaration in FOIA litigation that stated in pertinent part:
o I am told that Section 303 (g) of the CPIA requires the State Department to report to Congress any differences between CPAC�s recommendations and the State Department�s ultimate decision to impose import restrictions. In this regard, the release of the most recent CPAC report related to Cyprus and its discussion about coins could clarify misleading information contained in official State Department documents.
o I specifically recall the Cypriot request that then current import restrictions on other cultural artifacts be extended to coins was a matter of great public controversy. CPAC considered the question specifically and I recall a special vote being taken on this particular issue.
o With that in mind, I have reviewed both an official State Department Press Release and a State Department report made pursuant to CPIA Section 303 (g) about the MOU with Cyprus�I believe it is absolutely false to suggest in those materials that the State Department�s decision to extend import restrictions to ancient coins was consistent with CPAC�s recommendations. The full release of CPAC�s recommendations with regard to coins could be in the public interest because it should clarify misleading information contained in official State Department documents.
Will the Obama Administration and CPAC investigate these allegations before deciding to renew the Cypriot MOU? If true, don't they suggest that the MOU be terminated instead because it is founded on cronyism? If not, why not?
Greek Import Restrictions: Winners and Losers
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.
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.
Obdurate Obama Bureaucracy Imposes Broad Import Restrictions on Greek Coins and Cultural Goods
The Obama State Department and US Customs have imposed broad import restrictions on most Greek coins and other cultural goods. See http://www.gpo.gov/fdsys/pkg/FR-2011-12-01/html/2011-30905.htm
The restrictions on coins are exceptionally broad, but seem to exclude large denomination trade coins:
Coins�Many of the mints of the
listed coins can be found in B.V. Head,
Historia Numorum: A Manual of Greek
Numismatics (London, 1911) and C.M.
Kraay, Archaic and Classical Greek
Coins (London, 1976). Many of the
Roman provincial mints in Greece are
listed in A. Burnett et al., Roman
Provincial Coinage I: From the Death of
Caesar to the Death of Vitellius (44 BC�
AD 69) (London, 1992) and id., Roman
Provincial Coinage II: From Vespasian
to Domitian (AD 69�96) (London, 1999).
a. Greek Bronze Coins�Struck by
city-states, leagues, and kingdoms that
operated in territory of the modern
Greek state (including the ancient
territories of the Peloponnese, Central
Greece, Thessaly, Epirus, Crete and
those parts of the territories of ancient
Macedonia, Thrace and the Aegean
islands that lay within the boundaries of
the modern Greek state). Approximate
date: 5th century B.C. to late 1st century
B.C.
b. Greek Silver Coins�This category
includes the small denomination coins
of the city-states of Aegina, Athens, and
Corinth, and the Kingdom of Macedonia
under Philip II and Alexander the Great.
Such coins weigh less than
approximately 10 grams and are known
as obols, diobols, triobols,
hemidrachms, and drachms. Also
included are all denominations of coins
struck by the other city-states, leagues,
and kingdoms that operated in the
territory of the modern Greek state
(including the ancient territories of the
Peloponnese, Central Greece, Thessaly,
Epirus, Crete, and those parts of the
territories of ancient Macedonia, Thrace
and the Aegean islands that lie within
the boundaries of the modern Greek
state). Approximate date: 6th century
B.C. to late 1st century B.C.
c. Roman Coins Struck in Greece�In
silver and bronze, struck at Roman and
Roman provincial mints that operated in
the territory of the modern Greek state
(including the ancient territories of the
Peloponnese, Central Greece, Thessaly,
Epirus, Crete, and those parts of the
territories of ancient Macedonia, Thrace
and the Aegean islands that lie within
the boundaries of the modern Greek
state). Approximate date: late 2nd
century B.C. to 3rd century A.D.
Obviously, the obdurate bureaucracy could care less that over 70% of the public comments received by CPAC opposed these restrictions and that the actual support for them is limited to archaeological fanatics who hold that the only legitimate cultural exchange is a museum loan.
It is also ironic that these restrictions provide for the repatriation of any coins seized by US Customs to the bankrupt Greek state, which has no money to care for major cultural sites, let alone for the thousands upon thousands of ancient Greek coins already within State collections.
Again, more proof that the Obama administration is anti-small business and pro-government regulation, despite all the claims to the contrary.
The restrictions on coins are exceptionally broad, but seem to exclude large denomination trade coins:
Coins�Many of the mints of the
listed coins can be found in B.V. Head,
Historia Numorum: A Manual of Greek
Numismatics (London, 1911) and C.M.
Kraay, Archaic and Classical Greek
Coins (London, 1976). Many of the
Roman provincial mints in Greece are
listed in A. Burnett et al., Roman
Provincial Coinage I: From the Death of
Caesar to the Death of Vitellius (44 BC�
AD 69) (London, 1992) and id., Roman
Provincial Coinage II: From Vespasian
to Domitian (AD 69�96) (London, 1999).
a. Greek Bronze Coins�Struck by
city-states, leagues, and kingdoms that
operated in territory of the modern
Greek state (including the ancient
territories of the Peloponnese, Central
Greece, Thessaly, Epirus, Crete and
those parts of the territories of ancient
Macedonia, Thrace and the Aegean
islands that lay within the boundaries of
the modern Greek state). Approximate
date: 5th century B.C. to late 1st century
B.C.
b. Greek Silver Coins�This category
includes the small denomination coins
of the city-states of Aegina, Athens, and
Corinth, and the Kingdom of Macedonia
under Philip II and Alexander the Great.
Such coins weigh less than
approximately 10 grams and are known
as obols, diobols, triobols,
hemidrachms, and drachms. Also
included are all denominations of coins
struck by the other city-states, leagues,
and kingdoms that operated in the
territory of the modern Greek state
(including the ancient territories of the
Peloponnese, Central Greece, Thessaly,
Epirus, Crete, and those parts of the
territories of ancient Macedonia, Thrace
and the Aegean islands that lie within
the boundaries of the modern Greek
state). Approximate date: 6th century
B.C. to late 1st century B.C.
c. Roman Coins Struck in Greece�In
silver and bronze, struck at Roman and
Roman provincial mints that operated in
the territory of the modern Greek state
(including the ancient territories of the
Peloponnese, Central Greece, Thessaly,
Epirus, Crete, and those parts of the
territories of ancient Macedonia, Thrace
and the Aegean islands that lie within
the boundaries of the modern Greek
state). Approximate date: late 2nd
century B.C. to 3rd century A.D.
Obviously, the obdurate bureaucracy could care less that over 70% of the public comments received by CPAC opposed these restrictions and that the actual support for them is limited to archaeological fanatics who hold that the only legitimate cultural exchange is a museum loan.
It is also ironic that these restrictions provide for the repatriation of any coins seized by US Customs to the bankrupt Greek state, which has no money to care for major cultural sites, let alone for the thousands upon thousands of ancient Greek coins already within State collections.
Again, more proof that the Obama administration is anti-small business and pro-government regulation, despite all the claims to the contrary.
Small Business Saturday Promotion Needs to Be Extended to Obama CPAC
American Express is running advertisements in the United States promoting "Small Business Saturday." The campaign underscores the importance of small business to the American economy, something that one also often hears from politicians of both political parties as well.
Such a promotion also needs to be run for the Obama CPAC, the State Department's Bureau of Educational and Cultural Affairs and its Cultural Heritage Center. President Obama may claim that he sympathizes with small business, but no such sympathy was on display at CPAC's recent meeting on a proposed MOU with Bulgaria.
Instead, Jane Levine, a former prosecutor for the FBI's Art Crime team who now runs Sotheby's compliance department and who is an Obama CPAC pick for a trade slot on CPAC, seemed to suggest that it should be "easy" for the small businesses of the numismatic trade to comply with the certification requirements for legal import of items on the designated list under the CPIA.
Really? As I explained to Ms. Levine, the small businesses of the numismatic trade (most of which are sole proprietorships) really don't have the resources of a Sotheby's to cope with all the red tape involved (even assuming that European sources would be willing to provide the required certifications for EACH restricted coin that is imported). And as I also noted, Customs has been known to go well beyond the documentation requirements of the CPIA and only allow restricted items entry if they are pictured in a catalogue predating any import restrictions. This of course forecloses the import of virtually every ancient coin type on the designated list, as perhaps only one in every 10,000 or so coins actually is significant enough to be catalogued in this manner.
Although one hopes there is enough common sense left somewhere in the State Department or Customs to realize that the CPIA's restrictions were never meant to apply to such numerous and inexpensive artifacts like most ancient coins, one suspects that this really won't matter to a group of AIA members or supporters that hold that that the only legitimate exchange of cultural artifacts is a long term loan from a source country museum to a like institution in the United States.
Hopefully, someone in the Obama White House political operation will realize there is a problem at CPAC and the State Department that is threatening to turn ancient coin collectors (most of whom are likely Democrats) against President Obama's reelection bid. Can the President's appointees really afford to alienate at least 50,000 serious ancient coin collectors and the hundreds of small businesses of the numismatic trade, particularly when the number of public comments recorded in support of MOU's is so infinitesimal?
Such a promotion also needs to be run for the Obama CPAC, the State Department's Bureau of Educational and Cultural Affairs and its Cultural Heritage Center. President Obama may claim that he sympathizes with small business, but no such sympathy was on display at CPAC's recent meeting on a proposed MOU with Bulgaria.
Instead, Jane Levine, a former prosecutor for the FBI's Art Crime team who now runs Sotheby's compliance department and who is an Obama CPAC pick for a trade slot on CPAC, seemed to suggest that it should be "easy" for the small businesses of the numismatic trade to comply with the certification requirements for legal import of items on the designated list under the CPIA.
Really? As I explained to Ms. Levine, the small businesses of the numismatic trade (most of which are sole proprietorships) really don't have the resources of a Sotheby's to cope with all the red tape involved (even assuming that European sources would be willing to provide the required certifications for EACH restricted coin that is imported). And as I also noted, Customs has been known to go well beyond the documentation requirements of the CPIA and only allow restricted items entry if they are pictured in a catalogue predating any import restrictions. This of course forecloses the import of virtually every ancient coin type on the designated list, as perhaps only one in every 10,000 or so coins actually is significant enough to be catalogued in this manner.
Although one hopes there is enough common sense left somewhere in the State Department or Customs to realize that the CPIA's restrictions were never meant to apply to such numerous and inexpensive artifacts like most ancient coins, one suspects that this really won't matter to a group of AIA members or supporters that hold that that the only legitimate exchange of cultural artifacts is a long term loan from a source country museum to a like institution in the United States.
Hopefully, someone in the Obama White House political operation will realize there is a problem at CPAC and the State Department that is threatening to turn ancient coin collectors (most of whom are likely Democrats) against President Obama's reelection bid. Can the President's appointees really afford to alienate at least 50,000 serious ancient coin collectors and the hundreds of small businesses of the numismatic trade, particularly when the number of public comments recorded in support of MOU's is so infinitesimal?
Chinese Auction Houses to US State Department and AIA: Suckers!
The Art Newspaper has reported that China Guardian, a well respected Chinese auction house that sells Chinese antiquities and ancient coins, is to open a New York Office.
For now, China Guardian plans to use its office to drum up consignments for its auctions in China, but it is not foreclosing the possibility that its longer term plans may include establishing a presence in the US Market.
Of course, China Guardian will no doubt be able to use its excellent contacts with the Chinese Government to ensure that it secures export permits for any artifacts it might choose to sell abroad.
While China Guardian will no doubt execute its plans quite successfully, one must consider that any success it may achieve will likely be largely based on the competitive advantage it will have over Sotheby's and other US Auction Houses, all courtesy of the US State Department Bureau of Educational and Cultural Affairs and its moronic import restrictions on Chinese archaeological artifacts.
One must also wonder whether the AIA and all those self-righteous archaeologists that strongly supported a MOU with China now realize all they have done is to help allow the Chinese themselves to corner the market in Chinese artifacts.
For now, China Guardian plans to use its office to drum up consignments for its auctions in China, but it is not foreclosing the possibility that its longer term plans may include establishing a presence in the US Market.
Of course, China Guardian will no doubt be able to use its excellent contacts with the Chinese Government to ensure that it secures export permits for any artifacts it might choose to sell abroad.
While China Guardian will no doubt execute its plans quite successfully, one must consider that any success it may achieve will likely be largely based on the competitive advantage it will have over Sotheby's and other US Auction Houses, all courtesy of the US State Department Bureau of Educational and Cultural Affairs and its moronic import restrictions on Chinese archaeological artifacts.
One must also wonder whether the AIA and all those self-righteous archaeologists that strongly supported a MOU with China now realize all they have done is to help allow the Chinese themselves to corner the market in Chinese artifacts.
CPACked?
The State Department Cultural Heritage Center Website has announced that Marta de la Torre has taken over a public CPAC slot and that Jane Levine has assumed a trade slot.
See http://exchanges.state.gov/heritage/culprop/committee.html
President Obama's Administration earlier announced their appointment here: http://m.whitehouse.gov/the-press-office/2011/10/07/president-obama-announces-more-key-administration-posts
While both are certainly knowledgeable about the legal issues before CPAC, one can legitimately question whether they really reflect the interests of the stakeholders they were supposedly appointed to represent.
Ms. de la Torre's association with ICOM is more in line with an appointment to represent the museum or archaeological communities rather than the general public. Moreover, though Ms. Levine currently works for Sotheby's (she previously was a prosecutor associated with the FBI's art crime team), the CPIA's legislative history makes clear that the "trade slot" was actually meant for a dealer that has "hands on experience" in the types of artifacts that are subject to possible restriction.
This is just more evidence that the Obama State Department has ensured CPAC is "packed" with members much less likely to "rock the boat" and question the "archaeology over all" status quo than the likes of Jay Kislak, Bob Korver or Robert O'Brien.
But doesn't this just do more to confirm the widespread view that President Obama is pro-regulation and anti-business? And is the Administration really served if CPAC does not offer a real balance of opinion to the Executive on the often difficult issues before it?
Consensus is only meaningful if it is built from a diversity of views representing all the stakeholders in the process.
See http://exchanges.state.gov/heritage/culprop/committee.html
President Obama's Administration earlier announced their appointment here: http://m.whitehouse.gov/the-press-office/2011/10/07/president-obama-announces-more-key-administration-posts
While both are certainly knowledgeable about the legal issues before CPAC, one can legitimately question whether they really reflect the interests of the stakeholders they were supposedly appointed to represent.
Ms. de la Torre's association with ICOM is more in line with an appointment to represent the museum or archaeological communities rather than the general public. Moreover, though Ms. Levine currently works for Sotheby's (she previously was a prosecutor associated with the FBI's art crime team), the CPIA's legislative history makes clear that the "trade slot" was actually meant for a dealer that has "hands on experience" in the types of artifacts that are subject to possible restriction.
This is just more evidence that the Obama State Department has ensured CPAC is "packed" with members much less likely to "rock the boat" and question the "archaeology over all" status quo than the likes of Jay Kislak, Bob Korver or Robert O'Brien.
But doesn't this just do more to confirm the widespread view that President Obama is pro-regulation and anti-business? And is the Administration really served if CPAC does not offer a real balance of opinion to the Executive on the often difficult issues before it?
Consensus is only meaningful if it is built from a diversity of views representing all the stakeholders in the process.
Libya: What Emergency?
There they go again. Only months after apparently receiving assurances from their buddies at the State Department about "emergency import restrictions" on Egyptian cultural artifacts, archaeological trade groups are again taking advantage of another supposed emergency to call for yet another round of emergency import restrictions, which of course, are just the first step towards a permanent ban. See http://www.archaeological.org/news/aianews/6415
Yet, the facts seem to conspire against them. See http://www.guardian.co.uk/culture/2011/sep/11/tripoli-museum-antiquity-shattered-gaddafi-image (noting that there was no looting of archaeological artifacts at the Libyan national museum).
If I were a member of the Libyan provisional government, I might be a bit peeved that foreign academics are implying that the Libyans themselves are incapable of caring for their own cultural patrimony (despite considerable evidence to the contrary) and view this call for import restrictions as nothing more than a paternalistic violation of Libyan sovereignty.
One also has to wonder what, if any contacts, members of these groups had with the deposed regime. If past history in places like Egypt and Iraq are any guide, these relations could have been considerable. And certainly, this should be considered by Libyan officials as well in determining whether the help of these groups is necessary or desirable.
But do the facts on the ground and the desires of the Libyans really matter when the cronies of these groups run the State Department's Cultural Heritage Center? Or, will Libyan cultural officials be convinced to go along whatever the true facts and what the need for emergency restrictions says about Libya's own competence to care for its own cultural patrimony?
Yet, the facts seem to conspire against them. See http://www.guardian.co.uk/culture/2011/sep/11/tripoli-museum-antiquity-shattered-gaddafi-image (noting that there was no looting of archaeological artifacts at the Libyan national museum).
If I were a member of the Libyan provisional government, I might be a bit peeved that foreign academics are implying that the Libyans themselves are incapable of caring for their own cultural patrimony (despite considerable evidence to the contrary) and view this call for import restrictions as nothing more than a paternalistic violation of Libyan sovereignty.
One also has to wonder what, if any contacts, members of these groups had with the deposed regime. If past history in places like Egypt and Iraq are any guide, these relations could have been considerable. And certainly, this should be considered by Libyan officials as well in determining whether the help of these groups is necessary or desirable.
But do the facts on the ground and the desires of the Libyans really matter when the cronies of these groups run the State Department's Cultural Heritage Center? Or, will Libyan cultural officials be convinced to go along whatever the true facts and what the need for emergency restrictions says about Libya's own competence to care for its own cultural patrimony?
Ancient Coins and Cultural Property Debate at ANS
My own article is the second in a series being published in the ANS Magazine about ancient coins and the cultural property debate. Not surprisingly, while Sebastian Heath's article came from an archaeological perspective, my own article comes from that of a collector. An extended version can be found here:
http://numismatics.org/wikiuploads/DigitalPublications/WitschonkeTompaFinal.pdf
After explaining that bureaucrats in the State Department Bureau of Educational and Cultural Affairs Cultural Heritage Center and their allies in the archaeological establishment have perverted the statutory process for imposing import restrictions on cultural goods to ensure that undocumented coins are treated as "stolen," and that such regulatory overkill can only damage numismatics in this country, I urge the following:
I'm grateful for the ANS to allow me to express my views, and hope others will also make workable suggestions on how to preserve both collecting that is essential to numismatics and context that is so important to archaeologists.
Not for Me to Decide....
That's the message that comes across loud and clear from Judge Blake's admittedly well written opinion dismissing the ACCG test case. See
http://www.accg.us/News/Item/Decision_released_in_Baltimore_litigation.aspx
But if it's not a matter for the courts, who then will address legitimate concerns about how the State Department and US Customs impose and apply import restrictions on widely collected cultural goods like ancient coins?
The State Department or US Customs? Fat chance.
The Obama White House, under its transparency and regulatory reform initiatives? Doubtful.
Congress? Well, members of the House and Senate from both political parties have indeed made their concerns known about how import restrictions are imposed to the State Department, only to be stonewalled in return. But wrestling with the State Department's entrenched bureaucracy is not a high priority, particularly given the other problems facing our country.
All this, of course, helps explain why regular citizens increasingly hold our government in such low regard. Indeed, this issue in many ways encapsulates what is wrong with Washington: Faceless bureaucrats making decisions in secret at the behest of connected, narrow special interest groups with little more than lip service being given to the protections built into the law for small businesses and individuals.
All shameful, but legal, at least according to one US District Court.
http://www.accg.us/News/Item/Decision_released_in_Baltimore_litigation.aspx
But if it's not a matter for the courts, who then will address legitimate concerns about how the State Department and US Customs impose and apply import restrictions on widely collected cultural goods like ancient coins?
The State Department or US Customs? Fat chance.
The Obama White House, under its transparency and regulatory reform initiatives? Doubtful.
Congress? Well, members of the House and Senate from both political parties have indeed made their concerns known about how import restrictions are imposed to the State Department, only to be stonewalled in return. But wrestling with the State Department's entrenched bureaucracy is not a high priority, particularly given the other problems facing our country.
All this, of course, helps explain why regular citizens increasingly hold our government in such low regard. Indeed, this issue in many ways encapsulates what is wrong with Washington: Faceless bureaucrats making decisions in secret at the behest of connected, narrow special interest groups with little more than lip service being given to the protections built into the law for small businesses and individuals.
All shameful, but legal, at least according to one US District Court.
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