Hearings, Meetings, Proceedings, etc.: Cultural Property Advisory Committee; Proposals to Extend Bilateral Cultural Property Agreements with Albania and Nigeria; Receipt of a Request from Romania under the Convention on Cultural Property Implementation Act

The commenter, representing Boardwalk Numismatics, opposes the renewal of import restrictions on coins from Albania and the consideration of new restrictions for Romania. They argue that these restrictions harm the international trade of coins and the rights of American collectors, requesting that any restrictions clearly exempt coins from legal markets.

The Ancient Coin Collectors Guild, a nonprofit organization representing coin collectors, opposes the proposed cultural property agreements with Romania and Albania. They argue that the proposed restrictions are overly broad, lack specific cultural significance, and harm the legitimate trade and education of American collectors and small businesses.

Mandy F. Woods, owner of Pugnus Maximus Numismatics, opposes the proposed and renewed MOUs with Romania, Albania, and Nigeria regarding ancient coins. She argues that broad restrictions on widely circulated coins create unnecessary burdens for lawful collectors and dealers without effectively addressing illicit trafficking.

The commenter opposes the broad scope of the new Memorandum of Understanding, specifically arguing against importation restrictions on common items like coins. They contend that coins are commercial products of multiple influences and that the burden of proof for illicit acquisition should rest on the state rather than the collector.

The International Association of Professional Numismatists (IAPN) supports the review of the Cultural Property Agreement with Romania but requests specific limitations on the scope of import restrictions. They argue that restrictions should only apply to coins of cultural significance found exclusively in Romania and advocate for "less drastic measures" such as requiring Romania to implement a finders' database and recognizing legal exports from sister EU countries.

The commenter argues that placing restrictions on the movement of materials through MOUs is ineffective and creates unnecessary confusion. They suggest that instead of trying to "plug holes" in the illegal market through these restrictions, the government should work with and recognize the legitimate market to address illegal activity.