Showing posts with label ECA. Show all posts
Showing posts with label ECA. Show all posts
Cultural Heritage Center Website Updated
The Cultural Heritage Center's website has been spiffed up with pictures, including one of Hillary Clinton gazing at a Greek statute. Unfortunately, the Bureau of Educational and Cultural Affairs' tag line "promoting mutual understanding" rings hollow for ancient coin collectors at least. Indeed, ECA's controversial import restrictions on millions of ancient Greek, Roman and Chinese coins of the sort avidly collected world-wide has, if anything, greatly harmed people to people contacts between collectors in the US and foreign countries. Why not promote ancient coin collecting, and the cultural understanding it fosters (at no cost to the U.S. taxpayer), rather than seek to suppress it to the benefit of no one but a small number of academic archaeologists and their patrons in foreign cultural bureaucracies?
End Unilateral Trade Sanctions on Coin Collectors
The Huffington Post has published an editorial by Wayne Sayles attacking import restrictions on ancient coin collecting.
Coin collectors across the U.S. are tired of being singled out with unilateral sanctions. The State Department�s assault on our ability to collect coins is killing another American industry and leaving coin collectors in China and Europe to freely buy and sell. We�ve decided we aren�t going to take it anymore. Join us in ending the State Department�s assault on coin collecting.
Here is the first call to arms for coin collectors across the U.S.: http://www.huffingtonpost.com/wayne-sayles/trade-sanction-coin-collectors_b_1400563.html
Coin collectors across the U.S. are tired of being singled out with unilateral sanctions. The State Department�s assault on our ability to collect coins is killing another American industry and leaving coin collectors in China and Europe to freely buy and sell. We�ve decided we aren�t going to take it anymore. Join us in ending the State Department�s assault on coin collecting.
Here is the first call to arms for coin collectors across the U.S.: http://www.huffingtonpost.com/wayne-sayles/trade-sanction-coin-collectors_b_1400563.html
Seat Brent Benjamin on CPAC
A US District Court's decision to throw out the Government's claim against the Lady Ka-nefer-nefer Mask should also revive Brent Benjamin's appointment to CPAC to represent the interests of the Museum Community.
President Bush appointed Benjamin to the post, but the State Department never seated him, presumably because of Zahi Hawass' campaign to vilify Benjamin, a cause taken up by SAFE and other archaeological groups. See http://www.savingantiquities.org/brent-benjamin-to-join-cpac-an-outrageous-appointment/
Now that the Government's claim has been dismissed and Zahi Hawass has been disgraced, it's time for the State Department to follow the law and seat Mr. Benjamin, who after all was legally appointed by President Bush to the post.
President Bush appointed Benjamin to the post, but the State Department never seated him, presumably because of Zahi Hawass' campaign to vilify Benjamin, a cause taken up by SAFE and other archaeological groups. See http://www.savingantiquities.org/brent-benjamin-to-join-cpac-an-outrageous-appointment/
Now that the Government's claim has been dismissed and Zahi Hawass has been disgraced, it's time for the State Department to follow the law and seat Mr. Benjamin, who after all was legally appointed by President Bush to the post.
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.
Egypt in Crisis: Clamp Down on Pro-Democracy NGOs Derails Clamp Down on Collectors?
The Egyptian Military Dictatorship's decision to put Americans associated with pro-Democracy NGOs on trial may have derailed efforts to orchestrate emergency import restrictions on Egyptian cultural goods at least temporarily.
The roll-out of the new State Department funded Red List has occurred without the usual hoopla, except for this one post from a lawyer and former prosecutor who formally served as SAFE's Vice President:
http://culturalheritagelawyer.blogspot.com/2012/02/egyptian-red-list-now-available.html
And no wonder. While the State Department Bureau of Educational and Cultural Affairs has been funding efforts of the archaeological lobby to justify import restrictions on behalf of the Egyptian Military Dictatorship with a sole source contract to prepare this "Red List," the higher ups at State have threatened to suspend all aid to Egypt over the jailing and threatened trial of Americans associated with pro-Democracy NGOs. See
http://www.nytimes.com/2012/02/19/world/middleeast/trial-of-americans-in-egypt-shakes-nations-ties.html?_r=1&scp=3&sq=Egypt&st=cse
Cultural policy is a reflection of other government policies. In Greece, rational management of cultural resources has been hampered by over regulation, corruption and gross underfunding. Egypt's cultural policy suffers from the same ills along with an absolutely Pharaonic view of government control over the past. So why does the State Department Bureau of Educational and Cultural Affairs, its Cultural Heritage Center and the archaeological lobby continue to subsidize and cheer for such corrupt and unfair systems?
The roll-out of the new State Department funded Red List has occurred without the usual hoopla, except for this one post from a lawyer and former prosecutor who formally served as SAFE's Vice President:
http://culturalheritagelawyer.blogspot.com/2012/02/egyptian-red-list-now-available.html
And no wonder. While the State Department Bureau of Educational and Cultural Affairs has been funding efforts of the archaeological lobby to justify import restrictions on behalf of the Egyptian Military Dictatorship with a sole source contract to prepare this "Red List," the higher ups at State have threatened to suspend all aid to Egypt over the jailing and threatened trial of Americans associated with pro-Democracy NGOs. See
http://www.nytimes.com/2012/02/19/world/middleeast/trial-of-americans-in-egypt-shakes-nations-ties.html?_r=1&scp=3&sq=Egypt&st=cse
Cultural policy is a reflection of other government policies. In Greece, rational management of cultural resources has been hampered by over regulation, corruption and gross underfunding. Egypt's cultural policy suffers from the same ills along with an absolutely Pharaonic view of government control over the past. So why does the State Department Bureau of Educational and Cultural Affairs, its Cultural Heritage Center and the archaeological lobby continue to subsidize and cheer for such corrupt and unfair systems?
US State Department Helps Ship Auction House Jobs to China
The time was that Sotheby's and Christies did a lot of auction business involving ancient and modern Chinese art. These started as historic UK companies, but now they have large establishments in NY. Now, however, Chinese auction houses have begun to dominate the trade in part due to the monopoly afforded them in sales of Chinese artifacts by both the Chinese and US Governments. See http://www.bbc.co.uk/news/business-15933291
Isn't this more evidence that the State Department's MOU with China has done little but helped Chinese auction houses monopolize the trade in ancient art?
Isn't this more evidence that the State Department's MOU with China has done little but helped Chinese auction houses monopolize the trade in ancient art?
CPAC Meeting on Renewal of MOU with Cyprus
The United States Cultural Property Advisory Committee (CPAC) met on January 18, 2012, to discuss the Cypriot MOU. Once again, CPAC Chair Prof. Patty Gerstenblith (PG, DePaul, Public Representative) began by thanking all speakers or those who had provided comments to CPAC. PG was joined by the following CPAC members Katherine Reid (KR, Cleveland Museum (retired)-Museum); Nina Archabal (NA, Minn. Historical Society-Museum); Marta de la Torre (MT- Florida International University, Public); James Willis (JW, James Willis Tribal Art-Trade); Nancy Wilkie (NW-Carlton College, Archaeology); Barbara Bluhm Kaul (BK,Trustee, Art Institute of Chicago- Public); Jane Levine (JL, Sotheby�s Compliance Department (ex-prosecutor)- Trade); and Rosemary Joyce (RJ,U. Cal., Berkley-Anthropology). Two slots, one in archaeology and the other a trade representative, remain vacant. KR, NW and JW also served under the Bush Administration. The others are Obama Appointees though PG and MT also served the Clinton Administration. There was also staff present including CPAC Executive Director Maria Kouroupas, a Committee lawyer, and Committee archaeologists.
The following individuals spoke at the meeting in support of the MOU: Carmen Biucchi (Harvard); Brian Daniels (U. Pennsylvania Cultural Heritage Center); Nathan Elkins (Baylor); Jane Evans (Temple); Raymond Ewing (CAARI); Ellen Hersher (CAARI); Anne Marie Knobloch (Virginia Tech); Laetitia La Follette (U. Mass./ AIA); Andrew McCarthy (CAARI); Joanna Smith (Princeton); Chris Shaegel (U. Cyprus); Tom Kline (Andrews Kurth); Josh Knerly (AAMD).
The following individuals spoke against the MOU: Peter Tompa (IAPN/PNG); Wayne Sayles (ACCG); and Eloise Ullman (ICTA). In addition, 77% of the comments recorded on the regulations.gov website either opposed the MOU or their extension to coins.
Carmen Biucchi (Harvard) indicated that coins provide important documentation of early Cypriot history because there are few written sources. Even low value bronze coins are important because they frequently appear at archaeological sites. We need to all work together to preserve the past. Cypriot coins are relatively uncommon. In response to a question, Biucchi indicated that it is relatively easy to trace expensive coins due to their appearance at auction, but this is not the case for less expensive coins. She also indicated that metal detectors are the problem.
Brian Daniels (U. Penn. Cultural Center) argued for the extension of restrictions to post-Byzantine period ecclesiastical material. He also suggested that US law enforcement pursue better coordination with Cypriot law enforcement, and other countries with strong Greek cultural influence, including Greece itself and Bulgaria.
Nathan Elkins (Baylor) indicated that Cyprus� cultural property is in jeopardy as proven by a recent large seizure of artifacts, which included bronze and silver coins. There is a large market in the US as demonstrated by the fact that 200 Cypriot coins are currently listed on the V-coins website. Most Cypriot coins circulated locally. If you add together a list prepared by Wayne Sayles of coins found outside of Cyprus and a list Elkins compiled of coins from Cypriot contexts, that shows that Cypriot coinage is much more prevalent in Cyprus than outside of Cyprus.
Jane Evans (Temple) also indicated that it was important to continue restrictions on coins because it is important that their context not be lost.
Raymond Ewing is a former ambassador to Cyprus. He now serves a CAARI�s President. CAARI receives funding from the US Department of State, Bureau of Educational and Cultural Affairs and the National Endowment for the Humanities. Import restrictions should be as closely conformed to Cypriot law, that covers artifacts up to 1850, as possible.
Ellen Hersher is a scholar and archaeologist associated with CAARI. Cyprus has been a specialty for over 40 years. Looting is a historical problem in Cyprus. Looting still goes on until today. Looting only declined during the periods of WWI and WWII and during the 1950�s when British forces were involved in anti-insurgency operations. Wealthy Cypriots have collected Cypriot antiquities since the 19th Century. There is no shame in looting in Cyprus. Increasing efforts are being made to educate the populace. There is a great need for a new museum (the current one dates back to Victorian times) to encourage youth to respect their past. Metal detectors continue to be a serious problem; more legislation is needed. The major collections are grandfathered in. It is Ms. Hersher�s opinion that they are no longer adding much material, but most Cypriots don�t think that looting is wrong. We shouldn�t point fingers at Cyprus, but try to fix the problem.
Anne Marie Knobloch is a CAARI board member, who teaches at Virginia Tech. She is also an AIA member. Cyprus has important religious sanctuaries that need to be studied. Virginia Tech offers students the opportunity to excavate in Cyprus and would like to do more with Cypriot students.
Laetitia La Follette is the AIA�s VP for professional responsibility. She is associated with the University of Massachusetts. Looting remains a problem, including for coins. Because ancient coins are handmade, they are all different and may be traced. The AIA can help draft the designated list. The laws in the Greek Cypriot area need to be tightened. The laws in the North are actually stronger.
Andrew McCarthy is a CAARI trustee. Looting has increased since the 1960�s. There is a famous incident where a tomb was set aside as a dowry. The Department of Antiquities is doing its best to fight against looting. A site where McCarthy works has not suffered looting from 2007-2011. There was one incident where looters struck the site, presumably looking for coins. CAARI gives all documentation created from archaeological investigations to the Department of Antiquities. MOU�s can help educate Cypriots about the importance of their heritage.
Joanna Smith of Princeton is a past CAARI Trustee. Cyprus is an academic cross-roads. Cypriot children are being taught about their history and Cyprus sends exhibits abroad.
Chris Shaegel is from the University of Cyprus. He works closely with CAARI. Because there are few manuscripts that predate 1600, the preservation of Cypriot material culture is important. Coins should be protected and the restrictions should be extended further in time. Icons also need protection. There is no internal market in Cyprus.
Peter Tompa spoke for IAPN and PNG, two trade associations that represent the small business of the numismatic trade. Each Committee member must ask themselves whether they can do so in good conscious after considering these undisputed facts: (1) Coins were evidently placed on the designated list on the orders of former Undersecretary Nicholas Burns as a �thank you� to Cypriot advocacy groups which had given him an award; (2) Jay Kislak, CPAC�s former chair, has stated under oath that the State Department misled Congress and the Public about CPAC�s vote against import restrictions on coins: (3)In 2007, the AIA claimed that Cypriot coins �rarely circulated� to justify restrictions on �coins of Cypriot type.� However, a top Cypriot official has admitted that �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�� Moreover, this view has substantial scholarly support; (4) The CPIA requires less drastic remedies to be tried first before import restrictions are imposed, but Cyprus has no coherent regulatory scheme for metal detectors and even allows British tourists to bring them to the Island; and (5) Restrictions imposed on unprovenanced �coins of Cypriot type� only discriminate against American collectors and the small businesses of the numismatic trade; such coins may be shipped from abroad to anywhere but the USA, including Cyprus.
Moreover, he stated that there is no good reason to renew the MOU for yet another 5 years. Cyprus has already had the benefit of restrictions since 1999 on ethnological artifacts and 2002 on archaeological artifacts. Yet, a Swiss scholar reports most looted material goes to wealthy Greek Cypriot collectors, and not as has been maintained to collectors abroad. In addition, all this appears to be done with the full knowledge and acquiescence of Greek Cypriot authorities. Thus, restrictions only discriminate against American collectors.
In response to a question from JW, Tompa indicated it was wrong to so burden the small businesses of the numismatic trade just so archaeologists might occasionally get some relevant information about dating sites from a coin. He also disputed the claim by JL that import restrictions are easy to comply with. He noted that US Customs will not allow entry of coins and other antiquities unless they are pictured in a catalogue that predates restrictions. Thus, even the difficult to obtain certifications are not enough for Customs.
Wayne Sayles indicated that the ACCG represents the interests of the approximately 50,000 serious ancient coin collectors in the United States. The ACCG is interested in fair and equitable application of US law. The CPIA was meant to protect significant artifacts, not everything under the sun. In response to a question from PG, Wayne Sayles indicated that it is unrealistic to ask the small businesses of the numismatic trade to provide provenance information for every coin they import.
Eloise Ullman indicated that most ICTA members have under 5 employees. She also noted that President Obama recently recognized that it is important not to overburden small businesses with paperwork when his administration signed onto an effort to end a burdensome requirement that coin dealers prepare 1099 forms for every purchase over $600.
Tom Kline disclosed that he previously represented Cyprus. He stated that Cyprus is a leader in protecting its own cultural property, but takes a reasonable approach in doing so. The Turkish Republic is an illegal regime so he disputes that DOS look to their laws on antiquities as models. We need higher ethical standards from collectors. The import restrictions on coins should be no big deal because the restrictions only date from 2007. Collectors only have themselves to blame if they do not keep adequate documentation.
Josh Knerly spoke on behalf of the AAMD which supports the MOU with Cyprus with some limited provisos. First, the AAMD would like to know more about a proposal to extend restrictions to new types of ecclesiastical objects. It appears members of the archaeological community know details of the request, but these have not been shared by the public at large. KR asked why no Museum Director was present. Knerly indicated he would determine if some curators with specialized knowledge would be able to testify in the future.
The following individuals spoke at the meeting in support of the MOU: Carmen Biucchi (Harvard); Brian Daniels (U. Pennsylvania Cultural Heritage Center); Nathan Elkins (Baylor); Jane Evans (Temple); Raymond Ewing (CAARI); Ellen Hersher (CAARI); Anne Marie Knobloch (Virginia Tech); Laetitia La Follette (U. Mass./ AIA); Andrew McCarthy (CAARI); Joanna Smith (Princeton); Chris Shaegel (U. Cyprus); Tom Kline (Andrews Kurth); Josh Knerly (AAMD).
The following individuals spoke against the MOU: Peter Tompa (IAPN/PNG); Wayne Sayles (ACCG); and Eloise Ullman (ICTA). In addition, 77% of the comments recorded on the regulations.gov website either opposed the MOU or their extension to coins.
Carmen Biucchi (Harvard) indicated that coins provide important documentation of early Cypriot history because there are few written sources. Even low value bronze coins are important because they frequently appear at archaeological sites. We need to all work together to preserve the past. Cypriot coins are relatively uncommon. In response to a question, Biucchi indicated that it is relatively easy to trace expensive coins due to their appearance at auction, but this is not the case for less expensive coins. She also indicated that metal detectors are the problem.
Brian Daniels (U. Penn. Cultural Center) argued for the extension of restrictions to post-Byzantine period ecclesiastical material. He also suggested that US law enforcement pursue better coordination with Cypriot law enforcement, and other countries with strong Greek cultural influence, including Greece itself and Bulgaria.
Nathan Elkins (Baylor) indicated that Cyprus� cultural property is in jeopardy as proven by a recent large seizure of artifacts, which included bronze and silver coins. There is a large market in the US as demonstrated by the fact that 200 Cypriot coins are currently listed on the V-coins website. Most Cypriot coins circulated locally. If you add together a list prepared by Wayne Sayles of coins found outside of Cyprus and a list Elkins compiled of coins from Cypriot contexts, that shows that Cypriot coinage is much more prevalent in Cyprus than outside of Cyprus.
Jane Evans (Temple) also indicated that it was important to continue restrictions on coins because it is important that their context not be lost.
Raymond Ewing is a former ambassador to Cyprus. He now serves a CAARI�s President. CAARI receives funding from the US Department of State, Bureau of Educational and Cultural Affairs and the National Endowment for the Humanities. Import restrictions should be as closely conformed to Cypriot law, that covers artifacts up to 1850, as possible.
Ellen Hersher is a scholar and archaeologist associated with CAARI. Cyprus has been a specialty for over 40 years. Looting is a historical problem in Cyprus. Looting still goes on until today. Looting only declined during the periods of WWI and WWII and during the 1950�s when British forces were involved in anti-insurgency operations. Wealthy Cypriots have collected Cypriot antiquities since the 19th Century. There is no shame in looting in Cyprus. Increasing efforts are being made to educate the populace. There is a great need for a new museum (the current one dates back to Victorian times) to encourage youth to respect their past. Metal detectors continue to be a serious problem; more legislation is needed. The major collections are grandfathered in. It is Ms. Hersher�s opinion that they are no longer adding much material, but most Cypriots don�t think that looting is wrong. We shouldn�t point fingers at Cyprus, but try to fix the problem.
Anne Marie Knobloch is a CAARI board member, who teaches at Virginia Tech. She is also an AIA member. Cyprus has important religious sanctuaries that need to be studied. Virginia Tech offers students the opportunity to excavate in Cyprus and would like to do more with Cypriot students.
Laetitia La Follette is the AIA�s VP for professional responsibility. She is associated with the University of Massachusetts. Looting remains a problem, including for coins. Because ancient coins are handmade, they are all different and may be traced. The AIA can help draft the designated list. The laws in the Greek Cypriot area need to be tightened. The laws in the North are actually stronger.
Andrew McCarthy is a CAARI trustee. Looting has increased since the 1960�s. There is a famous incident where a tomb was set aside as a dowry. The Department of Antiquities is doing its best to fight against looting. A site where McCarthy works has not suffered looting from 2007-2011. There was one incident where looters struck the site, presumably looking for coins. CAARI gives all documentation created from archaeological investigations to the Department of Antiquities. MOU�s can help educate Cypriots about the importance of their heritage.
Joanna Smith of Princeton is a past CAARI Trustee. Cyprus is an academic cross-roads. Cypriot children are being taught about their history and Cyprus sends exhibits abroad.
Chris Shaegel is from the University of Cyprus. He works closely with CAARI. Because there are few manuscripts that predate 1600, the preservation of Cypriot material culture is important. Coins should be protected and the restrictions should be extended further in time. Icons also need protection. There is no internal market in Cyprus.
Peter Tompa spoke for IAPN and PNG, two trade associations that represent the small business of the numismatic trade. Each Committee member must ask themselves whether they can do so in good conscious after considering these undisputed facts: (1) Coins were evidently placed on the designated list on the orders of former Undersecretary Nicholas Burns as a �thank you� to Cypriot advocacy groups which had given him an award; (2) Jay Kislak, CPAC�s former chair, has stated under oath that the State Department misled Congress and the Public about CPAC�s vote against import restrictions on coins: (3)In 2007, the AIA claimed that Cypriot coins �rarely circulated� to justify restrictions on �coins of Cypriot type.� However, a top Cypriot official has admitted that �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�� Moreover, this view has substantial scholarly support; (4) The CPIA requires less drastic remedies to be tried first before import restrictions are imposed, but Cyprus has no coherent regulatory scheme for metal detectors and even allows British tourists to bring them to the Island; and (5) Restrictions imposed on unprovenanced �coins of Cypriot type� only discriminate against American collectors and the small businesses of the numismatic trade; such coins may be shipped from abroad to anywhere but the USA, including Cyprus.
Moreover, he stated that there is no good reason to renew the MOU for yet another 5 years. Cyprus has already had the benefit of restrictions since 1999 on ethnological artifacts and 2002 on archaeological artifacts. Yet, a Swiss scholar reports most looted material goes to wealthy Greek Cypriot collectors, and not as has been maintained to collectors abroad. In addition, all this appears to be done with the full knowledge and acquiescence of Greek Cypriot authorities. Thus, restrictions only discriminate against American collectors.
In response to a question from JW, Tompa indicated it was wrong to so burden the small businesses of the numismatic trade just so archaeologists might occasionally get some relevant information about dating sites from a coin. He also disputed the claim by JL that import restrictions are easy to comply with. He noted that US Customs will not allow entry of coins and other antiquities unless they are pictured in a catalogue that predates restrictions. Thus, even the difficult to obtain certifications are not enough for Customs.
Wayne Sayles indicated that the ACCG represents the interests of the approximately 50,000 serious ancient coin collectors in the United States. The ACCG is interested in fair and equitable application of US law. The CPIA was meant to protect significant artifacts, not everything under the sun. In response to a question from PG, Wayne Sayles indicated that it is unrealistic to ask the small businesses of the numismatic trade to provide provenance information for every coin they import.
Eloise Ullman indicated that most ICTA members have under 5 employees. She also noted that President Obama recently recognized that it is important not to overburden small businesses with paperwork when his administration signed onto an effort to end a burdensome requirement that coin dealers prepare 1099 forms for every purchase over $600.
Tom Kline disclosed that he previously represented Cyprus. He stated that Cyprus is a leader in protecting its own cultural property, but takes a reasonable approach in doing so. The Turkish Republic is an illegal regime so he disputes that DOS look to their laws on antiquities as models. We need higher ethical standards from collectors. The import restrictions on coins should be no big deal because the restrictions only date from 2007. Collectors only have themselves to blame if they do not keep adequate documentation.
Josh Knerly spoke on behalf of the AAMD which supports the MOU with Cyprus with some limited provisos. First, the AAMD would like to know more about a proposal to extend restrictions to new types of ecclesiastical objects. It appears members of the archaeological community know details of the request, but these have not been shared by the public at large. KR asked why no Museum Director was present. Knerly indicated he would determine if some curators with specialized knowledge would be able to testify in the future.
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.
77% of Posted Comments Against Renewal of Cypriot MOU
John Hooker has performed the following analysis of the 338 comments posted on the regulations.gov website in response to the State Department's invitation to comment on the proposed renewal of the MOU with Cyprus:
The following results are rounded to 1% and are accurate to within 0.5%
Against the renewal of the MoU: 77%
For the renewal: 20%
This breaks down over the coin issue thus:
Those against the renewal that mentioned coins: 71%
Those against the renewal that did not mention coins: 6%
Those for the renewal that mentioned coins: 8%
Those for the renewal that did not mention coins: 12%
Inappropriate responses (6 people thought they were responding to a Peru MoU, one to the Bulgarian MoU): 3%
The following results are rounded to 1% and are accurate to within 0.5%
Against the renewal of the MoU: 77%
For the renewal: 20%
This breaks down over the coin issue thus:
Those against the renewal that mentioned coins: 71%
Those against the renewal that did not mention coins: 6%
Those for the renewal that mentioned coins: 8%
Those for the renewal that did not mention coins: 12%
Inappropriate responses (6 people thought they were responding to a Peru MoU, one to the Bulgarian MoU): 3%
Putting a Happy Face on ECA's Work-- But No Mention of Its Import Restrictions Regime
The Bureau of Educational and Cultural Affairs has posted this year in review on the State Department's Blog: http://blogs.state.gov/index.php/site/entry/year_in_review_educational_and_cultural_affairs
Oddly, there is no mention at all about the Bureau's deeply unpopular effort to clamp down on American coin collectors. Instead, there is only a short reference to an agreement to help "protect" Greece's cultural heritage. Wonder why?
Oddly, there is no mention at all about the Bureau's deeply unpopular effort to clamp down on American coin collectors. Instead, there is only a short reference to an agreement to help "protect" Greece's cultural heritage. Wonder why?
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?
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?
Can't Egypt Come Up With Its Own List?
Archaeologists have criticised the idea of suggesting programs akin to PAS to foreign states.
Yet, they seem supportive of the State Department's paternalistic effort to announce to Egypt and the rest of the world what Egyptian antiquities are supposedly "at risk." See
http://ordinarymag.blogspot.com/2011/09/state-department-commissions-egyptian.html
The Federal Budget is facing large cuts that will impact health care, defense and foreign aid. Under the circumstances, is money for the sole source contract to create this "red list" really money well spent?
Why can't Egyptian authorities prepare their own list if one is truly necessary?
Yet, they seem supportive of the State Department's paternalistic effort to announce to Egypt and the rest of the world what Egyptian antiquities are supposedly "at risk." See
http://ordinarymag.blogspot.com/2011/09/state-department-commissions-egyptian.html
The Federal Budget is facing large cuts that will impact health care, defense and foreign aid. Under the circumstances, is money for the sole source contract to create this "red list" really money well spent?
Why can't Egyptian authorities prepare their own list if one is truly necessary?
State Department Commissions Egyptian "Red List:" More Evidence of A Done Deal?
The US State Department has given a sole source contract to pro-import restrictions ICOM to create a "red list of Egyptian antiquities at risk." See https://www.fbo.gov/index?s=opportunity&mode=form&id=fa0c2fe21fd3cf5028a500f1fc4b97e4&tab=core&tabmode=list
Even as any "cultural property emergency" (if there ever really was one) fades, it again appears that the State Department Bureau of Educational and Cultural Affairs Cultural Heritage Center may be busily at work stage managing a shadow process for imposing import restrictions on cultural goods.
What should happen under the CPIA is clear. A request from Egypt itself is contemplated. And the request should be processed through CPAC.
Here, however, former Egyptian antiquities head, Zahi Hawass, has himself been assured by American archaeologists that import restrictions are a done deal, making any request from Egypt or CPAC hearings to consider it a mere formality. See http://ordinarymag.blogspot.com/2011/05/hawass-says-emergency-import.html
And now it would seem that CPAC will have no real input on the content of any designated list either-- that presumably will be derived from whatever "red list" ICOM creates.
The CPRI has already made a FOIA request related to whether there is any done deal on and MOU with Egypt. See
http://ordinarymag.blogspot.com/2011/06/cpri-files-foia-request-on-purported.html However, to date that FOIA request has not been acted upon by the State Department.
In running for election, President Obama promised transparent government and attention to procedure. Yet, the Obama State Department Bureau of Educational and Cultural Affairs appears committed to neither.
Even as any "cultural property emergency" (if there ever really was one) fades, it again appears that the State Department Bureau of Educational and Cultural Affairs Cultural Heritage Center may be busily at work stage managing a shadow process for imposing import restrictions on cultural goods.
What should happen under the CPIA is clear. A request from Egypt itself is contemplated. And the request should be processed through CPAC.
Here, however, former Egyptian antiquities head, Zahi Hawass, has himself been assured by American archaeologists that import restrictions are a done deal, making any request from Egypt or CPAC hearings to consider it a mere formality. See http://ordinarymag.blogspot.com/2011/05/hawass-says-emergency-import.html
And now it would seem that CPAC will have no real input on the content of any designated list either-- that presumably will be derived from whatever "red list" ICOM creates.
The CPRI has already made a FOIA request related to whether there is any done deal on and MOU with Egypt. See
http://ordinarymag.blogspot.com/2011/06/cpri-files-foia-request-on-purported.html However, to date that FOIA request has not been acted upon by the State Department.
In running for election, President Obama promised transparent government and attention to procedure. Yet, the Obama State Department Bureau of Educational and Cultural Affairs appears committed to neither.
Double Standards: Unprovenanced Athenian Decadrachms in Greek National Coin Collection and Alpha Bank Collection
As set forth below, Greek cultural bureaucrats and their allies in the archaeological community have lobbied for the inclusion of coins in the newly announced MOU with Greece.
Yet, why should the US Government preclude American citizens from importing unprovenanced Greek coins when both the Greek National Coin Collection and the private Alpha Bank collection recently accessioned valuable Athenian Decadrachms that also lack a provenance?
Has anyone in the State Department Bureau of Educational and Cultural Affairs told Hillary Clinton that imposing import restrictions will place burdens on Americans that the Greeks themselves won't put on their own citizens and institutions?
And it's not as if these coins likely came from Greek contexts. In fact, the scholarly literature puts the typical find spots of such coins further East in places like Turkey and Syria.
Thus, the Greeks have little basis to claim they were merely buying back what had been "stolen" from them.
Of course, all this was discussed during the CPAC hearing on the Greek MOU. But, did it sink in?
Image: Reverse of Unprovenanced Athenian Decadrachm from Greek National Coin Collection
Secretary Clinton Misinformed?
The text of Hillary Clinton's signing statement for the Greek MOU can be found here:
http://rose4hillary.blogspot.com/2011/07/slideshow-hillary-clinton-at-acropolis.html.
In addition to the predictable pandering to the bankrupt Greeks, Secretary Clinton makes the following statement:
This agreement that we are signing today will protect Greece�s culturally significant objects even further from looting and sale on the international market. It will be illegal to import protected items from Greece into the United States unless they have been certified by the Greek authorities. And that will help reduce the incentive to illegally remove such objects in the first place.
Of course, if that was all the agreement did it would be far less objectionable than it is: But restrictions also bar import of items on the designated list from other legitimate markets abroad unless accompanied by documentation proving they were out of Greece as of the date of restrictions. The problem is that such documentation typically does not exist for common artifacts like ancient coins. Certainly, as far as I know no other country (including Greece) requires such documentation before importing ancient coins into the country.
Is Secretary Clinton misinformed about the impact of import restrictions? And if so, who at the Bureau of Educational and Cultural Affairs is responsible?
http://rose4hillary.blogspot.com/2011/07/slideshow-hillary-clinton-at-acropolis.html.
In addition to the predictable pandering to the bankrupt Greeks, Secretary Clinton makes the following statement:
This agreement that we are signing today will protect Greece�s culturally significant objects even further from looting and sale on the international market. It will be illegal to import protected items from Greece into the United States unless they have been certified by the Greek authorities. And that will help reduce the incentive to illegally remove such objects in the first place.
Of course, if that was all the agreement did it would be far less objectionable than it is: But restrictions also bar import of items on the designated list from other legitimate markets abroad unless accompanied by documentation proving they were out of Greece as of the date of restrictions. The problem is that such documentation typically does not exist for common artifacts like ancient coins. Certainly, as far as I know no other country (including Greece) requires such documentation before importing ancient coins into the country.
Is Secretary Clinton misinformed about the impact of import restrictions? And if so, who at the Bureau of Educational and Cultural Affairs is responsible?
Hypocrisy and Cronyism on Display at US Embassy in Cyprus
The Director the Cyprus American Archaeological Research Institute (CAARI) and the US Ambassador to Cyprus have dedicated a display of unprovenanced antiquities at the US Embassy. http://news.caorc.org/2011/06/caari-director-and-us-ambassador.html
The artifacts were apparently registered with the Cypriot authorities before they were displayed, but are said to be gifts from Cypriot citizens. There certainly is no suggestion that they are the products of scientific archaeological investigation.
Of course, CAARI has bragged that it was instrumental in lobbying the State Department for import restrictions on behalf of the Cypriot Department of Antiquities and the Assistant Secretary of State, Bureau of Educational and Cultural Affairs, approved the ban on US collectors obtaining such material from abroad.
Yes, hypocrisy and cronyism are indeed on display at the US Embassy in Cyprus along with those cases of unprovenanced Cypriot antiquities.
The artifacts were apparently registered with the Cypriot authorities before they were displayed, but are said to be gifts from Cypriot citizens. There certainly is no suggestion that they are the products of scientific archaeological investigation.
Of course, CAARI has bragged that it was instrumental in lobbying the State Department for import restrictions on behalf of the Cypriot Department of Antiquities and the Assistant Secretary of State, Bureau of Educational and Cultural Affairs, approved the ban on US collectors obtaining such material from abroad.
Yes, hypocrisy and cronyism are indeed on display at the US Embassy in Cyprus along with those cases of unprovenanced Cypriot antiquities.
"Any chance of using any influence you might have to get all the Medici photos published?"
So asks the only collector congratulating Archaeo-blogger David Gill on his award from the AIA. See http://lootingmatters.blogspot.com/2011/06/archaeological-institute-of-america.html
But why should Gill accede to such a request? He's gained much of his notoriety by ambushing unsuspecting collectors and auction houses with pictures from the Medici archives that he evidently has special access to. During the CPAC hearing on a renewal of the Italian MOU, lawyer Bill Pearlstein asked CPAC to condition any renewal on making these pictures public so that this looted material could be identified by the market. We don't know if CPAC adopted that suggestion in its recommendations to ECA Assistant Secretary Ann Stock, but we do know that the State Department did not incorporate that reasonable request in the revised MOU with Italy.
So, David Gill should also give thanks to the Bureau of Educational and Cultural Affairs Cultural Heritage Center for allowing him to continue his game of "gotcha" and the notoriety embarrassing others gives him.
But why should Gill accede to such a request? He's gained much of his notoriety by ambushing unsuspecting collectors and auction houses with pictures from the Medici archives that he evidently has special access to. During the CPAC hearing on a renewal of the Italian MOU, lawyer Bill Pearlstein asked CPAC to condition any renewal on making these pictures public so that this looted material could be identified by the market. We don't know if CPAC adopted that suggestion in its recommendations to ECA Assistant Secretary Ann Stock, but we do know that the State Department did not incorporate that reasonable request in the revised MOU with Italy.
So, David Gill should also give thanks to the Bureau of Educational and Cultural Affairs Cultural Heritage Center for allowing him to continue his game of "gotcha" and the notoriety embarrassing others gives him.
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