Comment on DOS-2026-0628-0001

Dear Cultural Property Advisory Committee, I am writing as a longtime collector of ancient coins and a student of ancient history to voice my strong opposition to the proposed new Memorandum of Understanding with Romania and the renewals of the existing MOUs with Albania and Nigeria. In their current form, these agreements are far too broad and fall well short of the objectives Congress established in the Cultural Property Implementation Act (CPIA). I respectfully urge the Committee to take no action until the drafts can be carefully reviewed and revised so they actually serve the CPIA’s goals while protecting the legitimate rights of American citizens, rights these proposals currently infringe upon. My greatest concern lies with the sweeping restrictions these MOUs would place on ancient coins, especially those listed for Albania and Romania. Both countries formed part of the ancient Greek world (Albania shares a border with modern Greece) and the Roman Empire. Coins from these periods circulated widely across the Mediterranean and Europe in antiquity and have been bought, sold, traded, and collected throughout the continent for centuries. The simple fact that a coin now resides within the modern borders of Albania or Romania tells us nothing reliable about where it was minted or where it was found. Under the proposed restrictions, American historians, researchers, collectors, and dealers would be required to meet an almost impossible standard of proof and documentation to import these coins legally. Because the coins have moved freely and legally across Europe—and especially within the European Union—for generations, obtaining the kind of detailed provenance now demanded is, in most cases, simply not feasible. These measures appear to conflict with long-standing EU internal market rules and with existing trade agreements between the European Union and the United States. With respect to Romania, I am also deeply troubled that the MOU could be used to extend Romanian government control over the cultural heritage of the Hungarian population of Transylvania, people whose ancestors have lived on that land for centuries. Rather than protecting cultural heritage as the CPIA requires, this would threaten the heritage of a displaced minority. Similar concerns apply to Nigeria’s MOU and its treatment of Biafran and other minority cultural patrimony. I strongly support the original purpose of the CPIA as Congress intended it. Unfortunately, each new or renewed MOU seems to drift further from those principles. During the original Congressional hearings on the legislation, the State Department made clear that coins would not be included in future MOUs. Yet that commitment has been steadily eroded. The result is a regime that does less and less to protect actual archaeological sites while placing ever greater burdens on legitimate collectors, scholars, and the American public. For these reasons, I urge the Committee in the strongest terms not to approve the current proposals. Respectfully, Andy Pierucci