The US State Department’s Iraq Cultural Heritage Initiative

At the 10th anniversary of the looting of the Iraq Museum the US Department of State issued this press release about its efforts to “protect, preserve, and display the rich cultural heritage of Iraq.” It is reposted below.

Iraq-Museum-Islamic-Gallery-2011Commemorating a Decade of U.S.-Iraqi Collaboration in Renewing the Iraq Museum

Media Note

Office of the Spokesperson
Washington, DC
April 10, 2013

For ten years, the U.S. Department of State has been working closely with Iraqi counterparts and American academic and nonprofit institutions to protect, preserve, and display the rich cultural heritage of Iraq. Cultural heritage cooperation is a major pillar of the Iraq-U.S. Strategic Framework Agreement, reflecting the high value both nations place on this irreplaceable resource.

A major continuing effort has focused on the Iraq Museum in Baghdad, where looting in April 2003 left the facility physically damaged and an unsafe environment for both staff and the Museum’s collections. In summer 2003, State Department personnel were among the first responders to the museum’s needs, providing replacement photographic equipment, office furniture, and supplies. An assessment in autumn 2003 conducted by experts in museum security, environmental control, conservation, and information technology initiated a 2004 project of major improvements to the museum’s physical plant, IT capabilities, and security.

This assessment also laid the groundwork for the Iraq Cultural Heritage Project, a $12.9 million initiative developed and funded by the State Department, and implemented by the nonprofit International Relief and Development from 2008 to 2011. This project rehabilitated and furnished 11 of the museum’s public galleries, a 3-story collections storage facility, and the conservation labs, as well as providing a new roof and upgraded climate control systems.

Along with physical improvements to the building, the State Department sponsored and organized trainings for museum staff as part of its comprehensive approach to partnering with Iraqis in the preservation of their cultural heritage. In 2004, the Department funded a special five-week “Cultural Heritage Institute” through the Council of American Overseas Research Centers, to bring 22 Iraqi museum staff to the Smithsonian Institution for training in museum management, conservation, and curatorial practices. In 2009-2010, the Department’s Iraq Cultural Heritage Project also provided training for 20 museum professionals from throughout Iraq at the Field Museum of Natural History in Chicago, covering topics from exhibit design and museum education to archaeological site excavation and stabilization.

Iraq Museum Hatra Gallery 2011Funding for these projects was provided through the Bureau of Educational and Cultural Affairs’ Cultural Heritage Center and Office of Academic Exchanges, the U.S. Embassy Baghdad, and private foundations. Images and more information about other cultural heritage projects in Iraq can be found here.

Media contact: Susan Pittman,, (202) 632-6373.

US sets aside $79 Million for UNESCO

Four months after pulling funding from UNESCO, the US State Department has added $79 million to its proposed budget for the UN agency in order to obtain a Congressional legal waiver so that funding can be restored.

The US pulled its UNESCO funding, nearly 22% of the organizations overall funding, after the organization granted full membership to the Palestinian Authority in November 2011. The US was obligated to withdraw funding based on laws made in the 1990’s that order a mandatory funding freeze whenever there is full-membership offered to the Palestinian Authority in any UN Agency.

US Deputy Secretary of State For Management and Resources Thomas Nides remarked on the actions of the State Department, “UNESCO does a lot of enormously good work,” Nides declared, “and we’d like to make sure that we have a contribution commensurate with their work.” The programs most affected by the funding cuts include the Iraqi National Water Council and literacy and education initiatives in Iraq.

However, The Republican majority in Congress will no doubt have objections to the legal waiver, as those opposed to the move have fears of a further “Palestinian statehood push.”

It will be interesting to see where this attempt by the State Department goes—without US funding UNESCO has been struggling to close the gap on their 22% deficiency since November, despite Turkey’s contribution of 5 million to UNESCO’s emergency fund in February 2012.

Read the original article here.

More False Claims about Lobbying on Antiquities Issues

David Gill has recently addressed claims made by Peter Tompa that appear to have little basis in fact. Tompa is a lobbyist who represents commercial trade interests. He has alleged that the Cyprus American Archaeological Research Institute (CAARI) “was involved in behind-the-scenes lobbying on behalf of the Cypriot Department of Antiquities, the Cypriot government body that issues excavation permits that allow CAARI affiliated archaeologists to excavate on the Island.” The assertions are not substantiated further.

Ellen Herscher, the vice president of CAARI and an independent scholar, responded to Tompa’s claims after they were posted to the Museum Security Network. She stated:

CAARI’s Director and several trustees publicly submitted statements in support of the agreement. This position is in accordance with CAARI’s Code of Ethics, which states that the organization “is dedicated to the protection and preservation of archaeological sites in Cyprus and the information they contain.” There was no “behind-the-scenes lobbying” involved.

Secondly, “CAARI-affiliation” has nothing to do with the granting of excavation permits in Cyprus. Permits are the sole responsibility of the Department of Antiquities of the Republic of Cyprus.

It is unfortunate that the ACCG continues to publish these erroneous statements, despite the fact that CAARI has responded and refuted them in the past.

Gill asks the question:

Are “false claims” being deliberately planted by some of the North American coin-collecting community as part of the background to the test case over the coins seized in Baltimore? (For some more discussion of the “test case”, see Gill’s “The Baltimore Coin Test Case“).

The question is a provocative one, especially in the context of other false claims recently made by one group Tompa is involved with, the Ancient Coin Collectors Guild (ACCG).

On November 13, 2009 The Cultural Property Advisory Committee (CPAC) convened for an interim review of the bilateral agreement with Italy and asked for public comment to be restricted to Article II. Among other things under Article II, which covers Italy’s obligations, Italy would allow long-term loans to American institutions, access to scholars, and prosecute antiquities traffickers within its own borders. Evidently, the CPAC asked that public comment be confined to Article II due to the concerns of many members of the Association of Art Museum Directors (AAMD) who felt that Italy was favoring institutions that had returned objects to Italy and that more longer term loans ought to be made. Indeed, there were several AAMD members at the interim review who gave presentations to the CPAC (their written comments have been posted online).

Immediately after the interim review, Tompa insinuated that archaeologists departed from Article II and raised the specter of coins and their potential inclusion in the upcoming renewal with Italy (see Tompa’s “Interim Review of the Italian MOU“). He later claimed, innacurately, that Stefano De Caro, who spoke on behalf of Italy’s Culture Ministry, argued that all coins made within the borders of what is now modern Italy should belong to Italy (see Tompa’s “Is the Italian Cultural Bureaucracy the Best Steward for Coins?“). However, after being challenged, he conceded that he may have misunderstood.

The ACCG’s founder, who was not even present at the interim review, then authored a press release alleging that archaeologists opportunistically raised the issue of coins; he also portrayed the AIA representative’s comments as radical (see Sayles’ “Archaeologists Plead for Import Restrictions on Common Coins“; for a more balanced view, see the AIA representative’s reflections on the interim review). While Sayles pretended as if there is not near universal agreement among the archaeological community that looting and indiscriminate sourcing for the antiquities trade is detrimental to archaeology, he failed to note that many collectors have themselves voiced concerns that the status quo, which the ACCG seeks to protect, requires some internal reforms in the trade. Some have even gone so far as to observe that the ACCG is oriented more towards the concerns of commercial dealers rather than to collectors or the interests of preservation.

Wetterstrom, president-elect of the ACCG and its representative at the interim review, then authored an editorial in the Celator (a collector magazine that he operates) claiming that archaeologists at the meeting received special treatment and were not limited in the length of their presentations. He also writes that he was cut off early while reading his written comments that the CPAC already had in front of them (Tompa has reproduced Wetterstrom’s text in his “Another Perspective on CPAC and the Interim Review of the Italian MOU“).

Sayles then solicited another online press release, prompted by Wetterstrom’s editorial (“Collectors Claim Bias Epitomizes State Department Committee Management“). Here, Sayles falsely reports that “Other speakers, who advocate import restrictions on coins, were reportedly allowed to exceed the published time limit with comments ranging up to 30 minutes.”

In spite of the repetition of the claims by ACCG leadership, they have no basis in fact.

1) Archaeologists (note the ACCG’s use of the plural) were not afforded any special treatment. All speakers were allowed only five minutes and were told to finish if they reached their time limit. Wetterstrom, like all other presenters, received a full five minutes and was cut off only after exhausting his time while reading his letter verbatim. All other speakers made “off-the-cuff” presentations. The only individual who made a longer presentation was Stefano De Caro who had traveled from Rome for the meeting, and who spoke approximately 20 minutes. Although it is implied he was improperly given excess time, the ACCG fails to note that foreign dignitaries are customarily not limited in the length of their presentation. This is proper since they represent the countries who have petitioned for an agreement with the U.S. government. As regular attendees of CPAC meetings, the ACCG is well aware of this fact.

2) Archaeologists did not raise the specter of coins. The order of presentation clearly demonstrates this since Tompa and Wetterstrom spoke before any archaeologist. Both individuals urged the committee not to consider coins any future renewal of the agreement and both made reference to the “test case.” Archaeologists and numismatists who addressed the issue of coins during their presentations were simply responding to arguments made by Tompa and Wetterstrom that coins were not worth protecting because they are “common” or “cheap” on the market. But if one requires further proof, compare the written comments of Kerry Wetterstrom and Wayne Sayles, submitted to the CPAC in advance of the interim review, with the letter submitted by Sebastian Heath, the AIA representative. It is clear from the letters that, contrary to the ACCG’s portrayal of events, the ACCG were focused on arguing that coins not be considered in the future. On the other hand, the AIA representative made no suggestion that coins be included in a renewal and instead had prepared to focus on Article II of the MOU as requested. It was only in oral comments that archaeologists and numismatists were forced to respond to issues beyond Article II that were raised by representatives of commercial interests.

Gill’s question about whether or not false claims are being deliberately fabricated is penetrating, especially in the context of the misrepresentation of events at CPAC’s interim review. Is it indeed hoped that the spin put on these events will construct a reality that is more conducive to their litigious activities? In this regard, it is worth noting that one of the points in the ACCG’s 37 page complaint about the seizure, which they staged, states that archaeologists argued that the agreement with Italy be extended to coins, while failing to note that they brought up the question of coins in the first place (pdf here, see point 80).

Gill considers the current legal action pending against the US Department of State regarding the import of antiquities

From “Why are ancient coins from Cyprus featured in a suit against the US Department of State?,” PR Newswire, 26 June 2009:


SWANSEA, Wales,June 26/PRNewswire/ –David Gill, archaeologist, considers the recent Freedom of Information Act (FOIA) suit on the US Department of State.

The FOIA suit was served in November 2007by three numismatic organizations; one of the three is based in Brussels, Belgium. The alliance objected to the US Cultural Property Advisory Committee (CPAC) restricting the import of ancient coins minted in Cyprus as part of a wider memorandum of understanding (MOU). CPAC was responding to concerns by the Government of Cyprus that the illicit searching for ancient objects (including coins) was destroying the archaeological heritage of the Mediterranean island. CPAC states, “The MOU offers the opportunity for the U.S. and Cyprus to cooperate in reducing the incentive for further pillage thereby protecting the context of intact sites for scientific study.”

Coin collectors were also concerned about the 2009 MOU with China. This agreement also restricted the import of certain categories of coins.

As a result, one of the three numismatic organizations decided to test the resolve of the US Department of State in April 2009by attempting to import a small number of coins from Cyprus and China in defiance of the newly established laws. These items were detained when their flight from London touched down in Baltimore.

Are these aggressive legal tactics really for the benefit of collectors, or are there other factors at work?

Read the full discussion:

Tons of Looted Afghan Antiquities Heading Back– Why Now?

National Geographic has an interesting story about England’s return of literally tons of Afghan antiquities seized at Heathrow over the past six years since the destruction of the Taliban regime. Although the story notes that

Poor villagers lacking other sources of income use shovels and wheelbarrows to cart off precious objects from historic spots around the country, while criminal gangs smuggle the loot to Pakistan and onwards.

The Kabul government remains too cash-strapped, and too caught up fighting the Taliban-led insurgency, to do anything about it. (Afghanistan’s own Ministry of Culture was the target of a suicide bomb attack last October.) And despite efforts to raise awareness among Pakistani customs and law enforcement officials, the situation is no better across the border.

What is missing from the article is any indication of what, if anything, is being done by overstretched coalition forces to assist the Afghan government to protect some small fraction at least of its sites. Nor is there any indication whether the criminal gangs smuggling the loot to Pakistan might be linked to the Taliban, as Matthew Bogdanos has argued the antiquities smugglers in Iraq were also supplying insurgents there with weapons and even taxes on their revenues from antiquities sales.

Afghanistan offers an opportunity for all those who did far too little to protect Iraq’s sites — the military, the State Department, UNESCO, cultural heritage NGOs, collectors, dealers, and the museum community — to develop a coherent, focused, and cost-effective set of initiatives. Granted, the task in Afghanistan is more formidable than in Iraq, for a number of reasons: the sheer size of the country; its not having developed the kind of well established cultural heritage protection bureaucracy that Iraq had over many decades; the lack of pizzazz associated with fabled Biblical names like Babylon, to name just a few. But surely a task force given modest resources could come up with some measures that could make a real difference. Is anyone working on this problem?

State Department Admits No Mechanism Exists for Providing Ongoing Security for Sites or Museums, Defends Its Efforts

What has the State Department done to protect sites?

As readers of this blog already know, in October the State Department issued a fact sheet laying out its support of what was described as “numerous activities relating to the protection and preservation of Iraq’s cultural heritage”:

These include emergency response to the looting of the Iraq National Museum, training of Iraqi museum professionals, support for archaeological site protection, and instituting legal measures to mitigate illicit trafficking in Iraq’s looted cultural property. Since 2003, several million dollars have been applied to these needs resulting in professional and infrastructure improvements to the National Museum as well as other museums and institutions, and improved archaeological site security in Iraq.

As usual, the issue of site protection was lumped together with others, leaving it unclear how much money has been applied to supporting archaeological site protection, for what programs, protecting how many sites, with what results.

Addressing the problem? Not exactly.

In response to my request, Darlene Kirk, a spokesperson from the State Department’s Bureau of Cultural Affairs, has amplified on the fact sheet’s summary, and kindly permitted me to share this information with the public. Kirk admits that “the Department of State has no mechanisms at its disposal to provide ongoing security at archaeological sites and museums in Iraq,” but she goes on to argue that State “has taken steps to address the problem in a variety of ways…

• The Department of State is funding the newly announced Iraq Cultural Heritage Project (ICHP) and the development of a site management plan for Babylon. Together, these initiatives include programs that will focus on, inter alia, building Iraqi professional capacity for conservation, for preservation of sites including archaeological sites, and for museum governance and administration. It is expected that strengthening the ability of responsible entities within the Iraqi government and its citizens to serve as the responsible stewards of their rich heritage will have a positive impact on site and museum security on a sustainable basis.

• In April 2008, the Department of Homeland Security promulgated U.S. import restrictions on all Iraqi cultural property after a decision to do so was made by the Department of State acting under authority delegated by the President. This import restriction is in addition to the ongoing OFAC regulations banning importation of Iraqi cultural property since 1990.

• The Department of State supported two security assessments of the National Museum in Baghdad which resulted in $1 m. in contracts to implement security measures at the Museum.

• In 2004, in response to evidence of serious looting of archaeological sites in southern Iraq, the State Department used funds donated by the Packard Humanities Institute to purchase 20 trucks and communications equipment for site guards in Dhi, Qar, Diwanyah, and Babil provinces. It was determined that these guards needed such tools to monitor the sites and deter the pillage that was being carried out by very well equipped looters. These vehicles and equipment were given to the Iraq State Board of Antiquities and Heritage (SBAH) which in turn issued them to the provinces for use by the site guards. According to SBAH officials in the affected provinces, this resulted in a substantial diminution of the looting in those provinces.

• U.S. personnel responsible for the Ministry of Culture during the period of the Coalition Provisional Authority until July 2004 worked closely with the SBAH and with the Department of State to build and train a Facilities Protection Service (FPS) Archaeological Site Protection Force devoted to site protection under the administration of SBAH.

• Throughout the past several years the Department has acted to address the problem of looting in other ways such as promoting coordination within the international law enforcement community and funding the development, publication and distribution of the Red List for Iraqi Antiquities at Risk which is produced by the International Council of Museums in Arabic, English and French. Now in its third printing, this publication helps raise awareness about the problem among law enforcement entities and would be collectors. The US Embassy in Baghdad recently distributed new copies of the Red List throughout the country and in particular at border crossings.

• The State Department has funded satellite imagery acquisition for large areas of Iraq to allow archaeolgists at SUNY Stony Brook to assess site looting. The Department has also funded training programs in satellite imagery analysis for Iraqi archaeologists.

• The State Department has recently allocated funding for meetings of a proposed Iraq archaeological site protection working group, to be composed of SBAH senior officials from Baghdad, and senior archaeologists and FPS commanders from governorates most affected by looting. The possibility of convening an international law enforcement working group on Iraqi cultural property is also under consideration. (Kirk added in a followup message that “$93,000 has been allocated for the site protection working group meetings. The budget for the international law enforcement working group on Iraqi cultural property has not yet been determined, as this meeting is in the early planning stages.”)

• In July 2008, State Department and US Embassy Baghdad personnel arranged a helicopter overflight of 40+ sites in Qadissiya, Dhi Qar, and Wasit governorates to assess current looting. The results of this mission are being analyzed and will be shared with SBAH authorities for followup. (Kirk later added that “the July 2008 overflight of 40+ sites was conducted by a pair of US military helicopters at the request of the US Embassy in Baghdad. The expert participants were the Cultural Heritage Liaison Officer of the US Embassy and the State Department Special Coordinator for Iraqi Cultural Heritage. The sites were extensively photographed from the air by both experts. The data are being analyzed by the expert participants.”)

This list says volumes about the failure of American policy to deal with the problem of site looting. Import restrictions, Red Lists, site management programs, and security efforts at the Iraq Museum do not secure archaeological sites. The funding for trucks by the Packard Foundation in 2004 was never supplemented by any governmental assistance, nor was any effort made to solicit additional support from other foundations. The FPS force was never given the funding and logistical support it needed, and I believe it has now been disbanded. The funding for satellite imagery was not for large areas of Iraq, but only for southern Iraq, and was provided only in part by the State Department; given that the US military certainly has time-series satellite images available for all sites, it remains puzzling why the State Department did not arrange for those images to be provided to archaeologists, rather than paying for a private company to provide images for only a fraction of sites (and not in a coherent time series even for those sites).

A hopeful development

Only the last two of these bullet points deal directly with contemporary site-protection efforts. Most welcome is the news that a working group on site protection has finally been proposed and allocated funding for meetings. It would have been even more welcome if the working group included some experts on securing and protecting sites (not archaeological sites but all kinds of sites) from the military or State Department.

Where’s the Report?

The final bullet point raises interesting questions of its own. A similar helicopter tour of eight sites was conducted in June 2008, leaked almost immediately, and published in mid-July. Why is it taking so long to release the findings from the helicopter overflight in July? Could it be because they would contradict the message that both the US and the Iraqi governments want to present, that the looting is over? One hopes not, and it is always possible that the “expert participants” (presumably John Russell and Diane Siebrandt, neither of whom to my knowledge is an expert at analyzing imagery though both are highly competent, dedicated, and indeed heroic individuals putting their lives on the line in Iraq) simply are better at keeping things under wraps than the British Museum, but the delay certainly raises suspicions.

Harrison Ford and the AIA

Cross posted from Numsimatics and Archaeology: “Harrison Ford and the AIA” 13 June 2008.

Several weeks ago, I reported on the Archaeological Institute of America’s (AIA) appointment of Harrison Ford to its Board of Directors (Numismatics and Archaeology: “‘That Belongs in a Museum!’” 21 May 2008). Harrison Ford is popularly known for his role as the dashing, adventurous archaeologist, Henry “Indiana” Jones, Jr., in the Indiana Jones films. Since Harrison Ford’s appointment to the AIA Board of Directors, there has been some controversy over the appointment (there are some links to these discussion in the comments section of my previous post).

SAFECORNER recently posted a reaction by Oscar Muscarella, a well-known scholar and advocate against the illicit trade in antiquities and an active AIA member (“‘Indiana Jones is a Plunderer.’ What do you Think?” 5 June 2008). SAFECORNER has asked for public comment on the controversy and has received a dozen comments so far.

In the AIA article announcing Ford’s appointment to the Board, the AIA President, Brian Rose, stated: “Harrison Ford has played a significant role in stimulating the public’s interest in archaeological exploration.” Surely, this is an accurate statement and the films have cult status among many young archaeologists. As an undergraduate studying archaeology and classical studies, I was a member of my university’s “Archaeology Club,” which organized trips to local archaeological sites, “pot parties” (not what you are thinking – these consisted of purchasing cheap Wal-Mart ceramics, smashing them and then gluing them back together again), and other social gatherings. One of the most popular events were the regular Indiana Jones movie marathons. I recall several students in archaeology that I went to college with said that the Indiana Jones films were partly responsible for their desire to study archaeology. As archaeologists, we are fully aware of the differences in archaeological practice and ethics used by the fictional Indiana Jones and archaeologists working in the real world. But what about the general public?

The controversy does not seem to be so much a question of whether or not the Indiana Jones films will inspire someone to loot an archaeological site, but what message the AIA is sending by putting the actor behind Jones’ character on its Board of Directors. The AIA has adopted a bold stance on archaeological ethics and has supported research on and legislative measures against the illicit trade in antiquities. Does the appointment of “Indiana Jones” to the AIA Board then exacerbate public perception that artifacts are there for the taking by anyone who comes across them? This seems to be the question at the heart of the controversy and is a question well worth asking. For example, when I tell people I am an archaeologist, I am always asked at least one of two questions, “So you’re into dinosaurs?” or “Do you get to keep what you find?” Muscarella’s concerns are justified.

I wonder, however, if it may be too early to assess the capacity in which Ford will work with the AIA. Indeed, the first line of the AIA article reads: “‘Indiana Jones” shows his commitment to real archaeology.'” Ford himself stated, “Knowledge is power, and understanding the past can only help us in dealing with the present and the future.” It has been reported that Harrison Ford has lent his star-power to advocacy against wildlife trafficking in conjunction with the U.S. Department of State and WildAid. Will Mr. Ford also use his celebrity status and his Indiana Jones stardom to help raise public awareness on the problem of plunder and the illicit antiquities trade in his new role at the AIA? I hope so.

Already, some from the collecting and trade community seem concerned about Harrison Ford’s new role at the AIA. Two prominent members of the Ancient Coin Collectors Guild (ACCG), a lobby of ancient coin dealers and collectors that I and others have discussed elsewhere (relevant posts at SAFECORNER and Looting Matters), have expressed fear that Ford will help raise public awareness on looting and the trade in antiquities. Jim McGarigle, an ancient coin dealer who lobbied Republican Congressmen in Wisconsin, on behalf of the ACCG, to put “collectors rights” on the state’s Republican party platform, apparently with no concern regarding the source or nature of collected material, recently stated on the Unidroit List:

“I predicted something like this would occur over a year ago [Ford’s appointment]. Be ready for the AIA to pull out the big guns on collecting with an easy celebrity reference where they can put on the ‘White Fedora’ and try to place the black one atop the heads of ancient and world coin collectors.

Maybe it’s time to start writing scripts about a heroic ancient numismatist [dealer/collector] who beats up the bad guys, saves the world and gets the girl or an antiquity collector who solves a murder every week.”

Peter Tompa, the ACCG’s current president, recently blogged about Ford’s support of the State Department and WildAid against wildlife trafficking and expressed concern that he would also help the AIA in its efforts to raise awareness on antiquities trafficking:

“I also have to wonder if Harrison Ford and the State Department are also working on PSAs that will expose the evils of collecting ‘illicit cultural property’ now that Ford has joined the AIA board.”

Like many people, I am sure Harrison Ford has an interest in archaeology and ancient history and I am delighted he is so enthusiastic about it that he decided to become an active part of the leading professional organization for archaeologists. I am anxious to see in what capacity Mr. Ford will be working with the AIA and wish him the best in his exciting new position.

“All the news that’s fit to print”?

A few important omissions in Jeremy Kahn’s “Coin Dealers Sue State Dept. for Details on Import Bans” in the New York Times, on November 17, 2007 should be pointed out:

In the article, Mr. Kahn claimed, “It was the first time the government had barred trade in a broad category of ancient coins…” But this is not true. While the US/Cyprus bilateral agreement does represent the first time that ancient coins have been subject to temporary import restrictions under the Cultural Property Implementation Act, coins have been subject to government-mandated import restrictions for many years in other contexts. For example, Executive Order 12722, which prohibits the importation of ancient coins from Iraq, went into effect on August 2, 1990. This order has been renewed several times, e.g., see section 4 of the renewal dated July 29, 2004. This prohibition remains in effect. In addition, antiquities, coins and other artifacts of Iranian origin have also been subject to trade restrictions for a number of years; importing such items to the U.S. is currently prohibited, and the US Customs and/or the Department of Justice does confiscate such items. In addition, according to the US Customs and Border Protection’s website, “gold coins … originating in or brought from Cuba, Iran, Iraq, Libya, Serbia, and Sudan are prohibited entry” under regulations administered by the Office of Foreign Assets Control.

Mr. Kahn wrongly characterizes import restrictions on Cypriot coins as a sweeping ban. For example, the photo caption in the article reads: “Importing Cypriot coins like this one is now banned.” But according to the U.S. Federal Register, the coins restricted from entering the US under the bilateral agreement are quite specific and listed as:

Coins of Cypriot types made of gold, silver, and bronze including but not limited to:

1. Issues of the ancient kingdoms of Amathus, Kition, Kourion, Idalion, Lapethos, Marion, Paphos, Soli, and Salamis dating from the end of the 6th century B.C. to 332 B.C.

2. Issues of the Hellenistic period, such as those of Paphos, Salamis, and Kition from 332 B.C. to c. 30 B.C.

3. Provincial and local issues of the Roman period from c. 30 B.C. to 235 A.D. Often these have a bust or head on one side and the image of a temple (the Temple of Aphrodite at Palaipaphos) or statue (statue of Zeus Salaminios) on the other.

Coins minted in Cyprus outside of the categories specified are not affected. In addition, no import ban exists for these types of coins, or any coin of Cypriot type, if the coin is accompanied by a valid export permit from the Government of Cyprus. Any bona fide museum, university or organization with a need to access and study Cypriot coins, can apply to the Cyprus government for a long-term loan, as described in Section 27 (subsections 1 and 2) of the Cyprus Antiquities Law.

The State Department operates under the provisions of the Cultural Property Implementation Act, the enabling legislation passed on January 12, 1983 and amended December 22, 1987, which implements into US law the 1970 UNESCO Convention on the Means of Prohibiting and Preventing the Illicit Import, Export and Transfer of Ownership of Cultural Property (UNESCO 1970). As parties to the Convention, Cyprus and the US, as well as more than 100 countries, have agreed to abide by Article 1(e), which includes under the definition of Cultural Property subject to protection, “antiquities more than one hundred years old, such as inscriptions, coins and engraved seals”. Parties to the Convention have also agreed to abide by Article 9: “Any State Party to this Convention whose cultural patrimony is in jeopardy from pillage of archaeological or ethnological materials may call upon other States Parties … to participate in a concerted international effort to determine and to carry out the necessary concrete measures, including the control of exports and imports and international commerce in the specific materials concerned. Pending agreement each State concerned shall take provisional measures to the extent feasible to prevent irremediable injury to the cultural heritage of the requesting State.”

In other words, the US-Cyprus bilateral agreement is fully in keeping with an international legal mechanism that has been in place for decades.

To describe the import restrictions of ancient Cypriot coins without including the proper background information and circumstances does not serve the purpose of pursuing “greater disclosure”, reportedly the basis for bringing the lawsuit. Context does matter. We believe the public deserves better from The New York Times.

As for the lawsuit itself, the 15-page complaint speaks for itself. But consider this fact: it costs as little as $100/month to hire an archaeological site guard; an FOIA attorney in Washington, D.C. typically receives $400 per hour, or more, to sue the federal government.