Comment on DOS-2026-0628-0001

Dear Cultural Property Advisory Committee, I write to state my opposition to the new Memorandum of Understanding (MOU) with Romania and renewal of the MOUs with Albania and Nigeria. As written, they are extremely broad and highly ineffective at achieving the important aims of the Cultural Property Implementation Act (CPIA). No action should be taken until they can be carefully reviewed and revised to successfully meet the objectives of the CPIA, while also protecting the legitimate rights of American citizens, upon which they currently infringe considerably. I am specifically addressing the extremely broad listings of coins in these MOUs, particularly those for Albania and Romania. Both these nations were part of the ancient Greek realm (Albania, after all, is adjacent to modern-day Greece) and the Roman empire. Coins from both these eras circulated widely throughout the region in ancient times, and have been bought, sold, traded and collected throughout Europe for many centuries. The location of any one coin in a specific modern nation is no indication of its origin or where it may have been found. However, current statutes and procedures require American historians, researchers, collectors and dealers to meet an almost impossibly high level of proof and documentation in order to bring these coins into the United States. In addition, these coins are traded widely and legally throughout the European Union, further adding to the extreme difficulty of proving their provenance. Indeed, these MOUs are almost certainly in direct contradiction to internal EU trade laws and even trade agreements between the EU and the US. Regarding Romania specifically, it seems highly likely that the Romanian government will use this MOU to gain US approval for its control over the cultural heritage of its displaced Hungarian population from Transylvania. This does not support cultural heritage, as these agreements are required to do under the authorizing Cultural Property Implementation Act (CPIA) legislation, but instead actually threatens the cultural heritage of the Hungarian diaspora. The same applies to Nigeria and its treatment of Biafrans and other minority groups within that country. Lastly, the current political situation in both European nations is highly volatile, with serious corruption charges being leveled in Albania, along with violent repression of protestors, and serious political and financial instability in Romania. All other arguments against these MOUs aside, neither one should proceed until these nations’ governments are stabilized and truly democratic. As a collector of ancient coins and a student of ancient history, I strongly support the intent of the CPIA as it was originally adopted. Unfortunately, each new or renewed MOU seems to drift further and further away from those laudable objectives – in fact, the State Department made clear in the original Congressional hearings that coins were not going to be included in future MOUs – and each is proving less and less effective in achieving those objectives. In this light, I urge you in the strongest terms not to move forward with these latest MOU proposals. Respectfully, Peter D. Jones