U.S. Considers Restrictive MoUs with Turkey and Tunisia Affecting Coin Collecting
by Mark Fox

To be fair, the anticipated Turkish Memorandum of Understanding (MoU) with the US, received by the government on October 2 of last year, did not specifically state itsdesire to see US import restrictions applied to coins, but it is all but assured, given Turkey's lengthy list of general wants. The public summary of the request can be read here:
https://eca.state.gov/files/bureau/turkey_cpa_request_public_summary.pdf

For the Tunisian request, received on November 26, coins are plainly mentioned:
https://eca.state.gov/files/bureau/tunisia_request_public_summary.pdf

What is particularly problematic this time around are the scopes of the requests, which encompass archaeological material from prehistorical times to a large slice of the 1700sA.D., and the countries making them, which collectively comprise an enormous chunk of coin-issuing history. We are talking about billions of coins of Punic, Persian, Greek, Romanprovincial and imperial, Byzantine, and Ottoman type, not to mention doubtless other types such as perhaps Vandal.

If the requests are accepted in their entirety, including what is not explicitly stated, then we may start feeling the negative effects of these and previous bilateralagreements on a more personal level. The logic behind this is that U.S. Customs may feel they need less numismatic knowledge to sort through restricted and non-restricted cointypes, leading possibly to a less careful-and more regular-policy of detainment and confiscation. Most Greek-inscribed ancient coins, the majority of Byzantine coinage (who wouldhave thought we could get to an extreme like that?), and a large portion of Constantinian and other late Roman bronzes (LRBs), would all suddenly be vulnerable import itemswithout proper export permits and/or documentation (giving evidence of their presence outside the source country before the implementation date of a given MoU).

Of course, the bitter icing on the whole cake is the now regular move to also restrict modern coins. In the current cases, Ottoman types will be the most likely targets,although due to the fact that few Westerners can read Arabic, many other kinds of similarly-inscribed coins will likely attract misplaced suspicion.

This is the strange world we are now living in, where a previously criminalized drug has been effectively decriminalized, and a popular, educational, and formative pastime isbeing slowly criminalized without any external helps to adapt it which are not punitive in nature.

With a hope and eye toward challenging the current grave situation affecting our hobby and scientific research, scholars, numismatics, and collectors not only in the US,but everywhere on the globe, are seriously urged to contribute a simple electronic public comment to help change the otherwise certain outcomes later this year. Interested partiescan do so by entering the docket DOS-2019-0043 at http://www.regulations.gov and clicking on the "Comment Now!" button.

More info on the current MoUs and instructions on what points should be addressed in electronic comments can be found at:
http://culturalpropertyobserver.blogspot.com/2019/11/please-comment-on-proposed-mous-with.html

Please don't brood over the possible futility of such an exercise. Please instead send a respectful comment by 11:59 P.M. (EST) on January 7, the time and date of theswiftly-approaching deadline. Even if you are of the opinion that import restrictions on coins would be beneficial in the long run, still say something! As of this writing(January 3), only a mere eleven electronic comments were publicly noted as received by the U.S. Department of State (DOS). This may be our last easy chance to effect meaningfulchange to the current, numismatically-harsh climate.

Above are a few relevant photos of coins in my collection.

1. Mysia, Gambrium (Gambrion). 4th Century B.C. Æ 17mm, 2.74 g.
2. Pontus, Comana. Septimius Severus (A.D. 193-211). Æ 29mm, 12.37 g., 12h.
3. Troas, Alexandria Troas. Trebonianus Gallus (A.D. 251-253). Æ 22.33mm, 6.32 g, 12h.

For a more complete picture of the coins that Turkey and Tunisia would undoubtedly like to see mostly barred from entering the US, I have selected a few example types from theCNG archives.

TUNISIA

TURKEY