Comment on DOS-2026-0628-0001

Dear Cultural Property Advisory Committee, I am writing to oppose the new Memorandum of Understanding (MOU) with Romania and the renewal of the MOU with Albania. As written, they are far too broad and will prove ineffective to achieve the intended aims of the Cultural Property Implementation Act (CPIA). No action should be taken until they can be carefully reviewed and revised to meet the objectives of the CPIA, while also protecting the legitimate and legal rights of American citizens, upon which they infringe. I am specifically concerned about the extremely broad listings of coins in the MOUs for Albania and Romania. Both of these nations were part of the ancient Greek and the Roman worlds. Coins from both of these cultures circulated widely throughout the region in antiquity, and have been bought, sold, traded and collected throughout Europe for many centuries – as they are to this day.. Current statutes and procedures require American citizens, whether they be curators, historians, researchers, collectors or dealers to meet impossibly high levels of documentation in order to bring these coins into the United States. These coins are traded widely and legally throughout the European Union, further adding to the extreme difficulty of proving their provenance. These MOUs are in direct contradiction to internal EU trade laws and trade agreements between the EU and the US. American citizens bear the burden as a result. As a (now retired) curator of Greek, Etruscan, and Roman art and material culture, I have always strongly supported the intent of the CPIA as it was originally adopted and intended. It is one of the original MOU’s (our MOU with Italy) that made sure that the exhibition “Magna Graecia: Greek Art from South Italy and Sicily” was loaned to the United States in 2002. I co-organized that exhibition. Without our MOU with Italy, and the intercession of Ambassador Mel Sembler and Mrs. Betty Sembler, that exhibition would not have been loaned to us. Unfortunately, each new or renewed MOU drifts farther and farther away from laudable objectives. The State Department made it clear in the original Congressional hearings that coins were not going to be included in future MOU’s. I urge you not to move forward with these latest MOU proposals as they are written. Thank you. Respectfully, Aaron J. Paul