Comment on DOS-2026-0628-0001

Dear Cultural Property Advisory Committee, I am writing to express my opposition to the proposed Memorandum of Understanding (MOU) with Romania and the renewal of the MOUs with Albania and Nigeria, specifically as they relate to ancient coins. I am the owner of Pugnus Maximus Numismatics, a California-based ancient coin business, as well as an active collector and student of Roman Republican, Roman Imperial, and Greek coinage. My interest in these objects is educational, historical, and cultural. Ancient coins provide a tangible connection to the civilizations that shaped the modern world, and they are among the most accessible artifacts available to students, collectors, and researchers. My primary concern is the continued expansion of designated coin lists within these agreements. Ancient Greek and Roman coins circulated widely throughout the ancient world, often far beyond the borders of modern nation-states. Coins commonly traveled hundreds or even thousands of miles through trade, military activity, migration, and commerce. As a result, the presence of a coin within the borders of a modern country does not establish that country as either the coin's origin or its findspot. The practical effect of these increasingly broad restrictions is to place a significant burden on lawful collectors, researchers, and dealers in the United States. Many ancient coins have been bought, sold, and collected throughout Europe for generations, often long before modern provenance standards existed. Documentation sufficient to satisfy current import requirements is frequently unavailable despite the coins having been traded legally for decades. This creates uncertainty for legitimate collectors while doing little to address illicit excavation or trafficking. I fully support efforts to protect archaeological sites and preserve cultural heritage. However, restrictions should be carefully targeted and based on evidence that they effectively reduce looting and illegal export. Broad restrictions on widely circulating coinage risk harming lawful educational and collecting activities without providing meaningful protection to archaeological resources. As someone who studies and preserves ancient coins, I respectfully urge the Committee to carefully reconsider these proposed restrictions and to avoid expanding import controls to categories of coins whose historical circulation extended far beyond the borders of modern Romania, Albania, or Nigeria. Thank you for your consideration. Respectfully, Mandy F. Woods Owner, Pugnus Maximus Numismatics San Diego, California