Comment on DOS-2026-0628-0001

Dear Cultural Property Advisory Committee, The Hungarian Human Rights Foundation is a 501 (C) (3) not-for-profit organization incorporated in New York State. The Foundation monitors the human and minority rights situation of ethnic Hungarian minorities who live in the countries of East Central Europe. Namely, for the past 50 years our focus has been on Romania where the largest national minority of. 1.1 million is the Hungarian community. Under communism, the community was subject to a systematic campaign of forced assimilation which included destruction and expropriation of its cultural patrimony that extends back 1,000 years in the region named Transylvania which since 1920 has been part of the Romanian state. Unfortunately, in the 36 years since the fall of communism, justice has not been served for all the rightful owners of culturally significant properties and assets that were confiscated from ethnic and religious minorities by the state between 1945 and 1989. The Foundation has monitored and advocated to end this gross injustice for the past 36 years. Our up-to-date report can be found here: https://hhrf.org/on-our-radar/property-restitution-in-romania/ These issues were reported in the Department of State’s International Religious Freedom Report for 2016 and 2017, among others. In light of Romania’s new request for a cultural property agreement, we are especially concerned about the Batthyaneum Library and Astronomical Observatory and its priceless collection of rare manuscripts. The Romanian state – ignoring domestic laws and European Union decisions - has refused to return the building and the Library’s contents to its legitimate owner, the Alba Iulia Catholic Archdiocese, compelling the church to engage in legal battles for the better part of the last quarter century. The Library’s collection of 65,000 volumes holds 1,650 incunabula (printed books before 1501) counting for three quarters of all such books in the country. The most valuable piece in the collection is the Codex Aureus a hand-written Bible from the Charlemagne period considered priceless. These belong to the Hungarian cultural patrimony. We call on the Cultural Property Advisory Committee to recommend that the State Department condition any Cultural Property Agreement with Romania on an assurance that Romania will return objects belonging to the Batthyaneum Library and other significant cultural institutions that were unlawfully expropriated from the autochthonous Hungarian national minority to representatives of that community within Romania. See 19 USC Section 2605 (f) (4) (a) (indicating that the Committee’s report may include terms and conditions for any CPA). We note this request would help enforce the 1992 Agreement for the Protection and Preservation of Certain Cultural Properties made between the Governments of the United States and Romania as well as a 2012 European Court of Human Rights Decision (ECHR Decision 33003/03) ordering the return of the Library and Observatory. Second, we find that the scope of the Romania’s request is too broad as written and should therefore be rejected by the Committee. Firstly, such restrictions could be applied to heirlooms brought into the US by Hungarian refugees, which we oppose. Secondly, depending on if the restrictions are written to apply specifically to Transylvanian or Hungarian items, the CPA would de facto recognize the rights of the Romanian government/state to ownership and control of Hungarian diaspora property, similarly unacceptable. Thank you for your attention. Sincerely, Emese Latkoczy, Executive Director