Below is a transcript of the oral comments presented by Wayne G. Sayles, representing the Ancient Coin Collectors Guild, at the 2015 hearing of the Cultural Property Advisory Committee on April 8 at Washington, DC. The hearing included public comment on a proposed extension of the current Memorandum of Understanding with Italy. Formal written comments were submitted earlier and may be seen here.
Madam Chair and distinguished committee members,
The Ancient Coin Collectors Guild was founded as a non-profit organization in 2004. Since then, I’ve appeared eight times before this committee to comment on potential import restrictions. The guild and its 22 Affiliate Member clubs represent the interests of doctors, lawyers, educators, clergy, politicians and members of countless trades and walks of life. Even some archaeologists. U.S. import restrictions on ancient coins that are legally traded elsewhere around the globe negatively impact many thousands of American citizens and hundreds of businesses. The private collecting of ancient coins is a venerable activity with an associated trade dating back more than 600 years and enabling a remarkable tradition of independent scholarship. It remains, today, a legitimate and honorable pursuit that serves society well and is therefore protected under law. For tactile learners at all levels, there is no stronger connection to the past than the holding in one’s hand of an authentic ancient coin—common though it might be. Even in Italy, ancient coin collectors and dealers abound—collecting and trading in coins that are on the MOU designated list here. Italy has no import restrictions on ancient coins.
Ironically, yellow journalism has portrayed private collecting in a totally different light. Spurious articles characterizing collectors as “the real looters” are classic illustrations of the Big Lie. In a recent NY Times article, archaeologist and Getty Museum director Timothy Potts acknowledged that “It has become an article of faith that any form of trade in cultural items is bad.” He was of course describing an institutional ideology, not a public condemnation nor tenet of law. We are a nation governed by law. Subjective articles of faith and ethics are not precepts of law and therefore are not relevant to the deliberations of this committee. We petition this committee to honor the wishes of the People and use law, rather than emotion, as a guide to your deliberations.
We’re all here, despite our differences, because of one cultural property law. It’s a fair, well-thought-out law and we in the Ancient Coin Collectors Guild stand by it. In addition to protecting significant cultural objects and heritage, the Convention on Cultural Property Implementation Act very clearly recognizes and protects the trade in utilitarian artifacts like coins. It protects what we call orphaned artifacts that have circulated in international trade, often for centuries, without any requirement or need for recorded provenance. The law only allows import restrictions on objects that were “first discovered within” and “subject to export control” of a State Party with whom an MOU might be negotiated. Another of the protections under this law is the formation of this very committee to represent the interests of all affected parties and to advise on issues that are germane to the law’s purpose and implementation.
We all deplore and condemn illicit trade and must cooperate with just and concerted international enforcement to combat that scourge. The Cultural Property law was written for all of us and we all need to follow it. We will and I hope you will—by following that law and exempting common coins from any renewal of this MOU