• INTERNATIONAL ASSOCIATION OF PROFESSIONAL NUMISMATISTS (IAPN)
• PROFESSIONAL NUMISMATISTS GUILD (PNG)
  

May 15, 2003

STATEMENT OF THE IAPN AND THE PNG ON
H.R. 2009 IRAQ CULTURAL HERITAGE PROTECTION ACT

The Iraq Cultural Heritage Protection Act (H.R. 2009) is legislation recently introduced in the United States House of Representatives addressing the illegal importation into the U.S. of artifacts stolen from the Iraqi National Museum (INM). Although this legislation addresses an important cultural property crisis, if passed in its current form, it will have unintended harmful consequences to those involved in the numismatic trade. This proposed legislation ignores not only the ample authority U.S. law enforcement already has to seize illegally imported items, but also the current administrative procedures in place to establish methods of policing importation of illicit materials with individual countries. Ancient coins have been exempted from previous cultural property import restrictions after a close review of the issue by the President's cultural property experts; however, this particular bill with its broad definitions of restricted materials will hinder the legitimate import of a vast amount of coins into the U.S.

As currently drafted, H.R. 2009 prohibits the import into the U.S of archeological or cultural materials of Iraq without either documentation that the materials were removed from Iraq prior to August 2, 1990 or official certification from the government of Iraq that the materials were not exported in violation of any Iraqi laws. H.R. 2009 defines archeological and cultural materials in extremely broad terms, altering accepted definitions and categories under current law. Additionally, H.R. 2009 contains stringent documentation requirements that are virtually impossible for a legitimate coin collector or dealer to meet due to the transitory nature of all historical coins. Since first being struck in the area, circa the 4th C.B.C., very few coins that may have originated in what is now described as Iraq necessarily have stayed in that region. It is the very nature of coins that they often became immediately transitory (e.g. Alexander the Great paid his mercenaries in coins stamped with images of his own choosing with the expectation that the message they convey would be widely dispersed as the mercenaries returned home). Thus, a coin that may have originated in the geographic region of Iraq but was immediately dispersed to other areas over 2,000 years ago, could still be confiscated from a dealer or a collector bringing the coin into the U.S. if that person does not have sufficient documentation to prove that it was ever legally exported from Iraq.

The IAPN and the PNG strongly condemn the looting and destruction of Iraqi cultural treasures at the INM and unequivocally support the return of these treasures to the Iraqi people. Current law already bans entry of such material into the U.S. Representative images of such material are available on the U.S. State Department's International Cultural Property Protection web site at http://exchanges.state.gov/culprop/. As numismatic dealers, our members will cooperate in every manner to ensure there is no trade in coins stolen from the INM collection including encouraging the repatriation of any INM coins discovered in the stream of commerce.

The focus of any new legislation should be to protect those unique and irreplaceable objects from early Mesopotamia c. 3000-1000 B.C; however, the bill is currently drafted so broadly that it could be interpreted to put restrictions on any coin struck as late as c. 1903 A.D. Thus, it is not the intention of the IAPN and the PNG to provide cover for those attempting to smuggle illicit Iraqi treasures into the U.S. However, the overly broad definitions and unrealistic documentation requirements of H.R. 2009 necessitate an amendment to exempt coinage from its scope so that legitimate numismatic trade may continue. To further this end, the IAPN and the PNG are requesting their members, coin collectors, and other concerned parties to alert their elected representatives in Congress to the important issues overlooked by this ad hoc legislation. Due to the speed with which this legislation is being considered, time is of the essence and all interested numismatists are requested to contact not only their Congressional members, but also the Chair of the House Ways and Means Committee, the Chair of the Trade Subcommittee of the Ways and Means Committee, the Chair of the Senate Finance Committee, the Chair of the Trade Subcommittee of the Finance Committee, and the State Department's Cultural Property Advisory Committee. The contact information is provided below, and a letter outlining the above concerns that may be sent to representatives can be found at following web sites: http://www.iapn.ch, http://www.pngdealers.com, http://harlanjberk.com, and http://www.goldcoinsoftheworld.com.

The IAPN is a nonprofit organization of the leading international numismatic firms founded in 1951. The objects of IAPN are the development of a healthy and prosperous numismatic trade conducted according to the highest standards of business ethics and commercial practice. The IAPN has 112 member firms in 23 countries, including 35 in the United States. The Association's Secretariat may be reached at 14, rue de la Bourse, 1000 Brussels, Belgium or P.O. Box 1057, Clifton, New Jersey 07014.

The PNG is a nonprofit organization founded in 1955. The PNG's motto, "Knowledge, Integrity, Responsibility" continues to reflect its aims, and is expressed in the strict requirements for election to membership to the PNG. The PNG has over 300 members across the United States and abroad. The PNG may be contacted at 3950 Concordia Lane, Fallbrook, California 92028.

Contact Information

Please fax and/or email your individual member of Congress. Contact information for members may be found at the following:

U.S. House of Representatives http://clerk.house.gov/members/index.php

U.S. Senate http://www.senate.gov/general/contact_information/senators_cfm.cfm

Additionally, please fax and/or email a copy of your letter to the following: