2024 Q2
Tuesday, July 9, 2024
Section: 2024




Association News

Welcome New Members

(And thank you, referrers!)

The following joined NCBA between April 1 and June 30, 2024:

Copper
  • Mike Shields, Adamas (MD)
  • Ron Rodriguez, AltAsset (FL)
  • Eric Kibbey, Camelot Coins (IN)
  • Preston StPierre, Durango Bullion (CO)
  • Matthew Hall, Gibraltar Group (FL)
  • Brandon Thor, Thor Metals Group (CA)
  • Brett Charville, Toledo Coin Exchange (OH)
Basic
  • Art Boehning, Boehning LTD (CA)
  • Curt Bradbury, Bradbury Gold and Silver (MT)
  • Eddie Bruner, Glasgow Coin & Jewelry (KY); referred by Byrd Sailor III
  • Scott Hage, Private Bullion (FL)
  • Dustin Huff, The Sound Money Shop (TX)
  • Jenny Mousis, WPMRS (WI)
Concerned Collectors Coalition
  • David Blog (NJ)
  • Joel Cohen (NJ)
  • Shawn Davis (MN)
  • Ron Good (TX)
  • Felix Gostel (VA)
  • Daniel Lieuwen (NJ)
  • Linda Soileau (FL)
  • Charles Willette (PA)

Message from executive director David Crenshaw

Join the 2025 Initiative: Eliminate Sales Tax on Currency and Bullion in Key States
This summer marks a pivotal moment for our association and the broader numismatic and precious-metals communities. There are only a handful of states left who have not yet implemented a sales- and use-tax exemption on currency and precious metals in the United States, and we would like to close that gap. I am excited to announce the start of an ambitious initiative for 2025 aimed at eliminating sales and use tax on currency and precious-metals bullion in Hawaii, Maine, New Mexico, and Vermont. Additionally, we seek to clarify regulatory frameworks in Nevada.
 
Our success hinges on the collective efforts of our dedicated members, particularly in these key states. At NCBA, we recognize that navigating the political landscape can be daunting. Changing state legislation requires a committed coalition of like-minded individuals who are willing and able to invest their time and resources. This is where your leadership becomes indispensable. Without robust state coalitions led by passionate individuals like you, this crucial initiative cannot take off.
 
We understand the complexities involved in legislative advocacy and are prepared to support you every step of the way. NCBA has developed a comprehensive toolkit to help you that includes
  • Detailed explanations of the legislative process
  • Advice on hiring an effective lobbyist
  • Strategies for crafting compelling arguments
  • Guidance on communicating effectively with legislators
  • Model bill language to secure tax exemptions
  • Support for testifying at legislative committee hearings
  • A timeline for organizing a grassroots campaign
However, for our initiative to succeed, we need to partner with at least one local coin-business owner in each state to lead the coalition. This partnership ensures we have the necessary local leadership and commitment to drive this initiative forward.

Identifying local leaders prepared to take the helm is our immediate priority. We acknowledge the financial commitment involved and request that each coalition agree to cover any expenses incurred by NCBA during these campaigns.
 
This is your opportunity to make a lasting impact. By coming together, we can eliminate outdated taxes and promote equitable treatment of collectors and investors in coins, paper money, and precious metals. 
 
Your involvement is crucial. Let’s make history together.
 
If you have any questions or are ready to lead, please contact us at (678) 430-3252 or by email at ncba@ncbassoc.org. Thank you for your unwavering commitment to this cause.
 

Message from chair Patrick I. Perez

As we enter the third quarter of 2024, I can say that the first half of the year has been among the busiest and most productive months NCBA has had in some time. Thanks to our legislative advocates and partners, along with determined individuals in various states, we have accomplished much. For example, new exemptions in Wisconsin and Kentucky and significant progress made in New Jersey.

The third quarter promises to be equally busy for NCBA, particularly at the American Numismatic Association’s World’s Fair of Money, which takes place in Rosemont, Illinois, just outside of Chicago this August. On Wednesday, August 7, we have our board meeting at 8:00 a.m., which is open to all members of the association. Shortly thereafter, at 10:00 a.m. we are offering an important seminar titled “Impacts of the 2024 Treasury Initiative on Precious Metals Dealers.” Finally, that evening at 6:30 p.m. we have our annual Membership Dinner and Update. 

These activities are among the most important events of our year. The board meeting is where we are able to set the overall goals for NCBA and make sure the board members, as stewards of the association, are making the best decisions for our future. Any and all feedback is welcome. 

With the tremendous surge in precious-metals prices, we have been fielding more inquiries than usual regarding regulations, and the seminars we put on for the benefit of our members, such as this one in August, are meant to respond to such inquiries. Lastly, the membership dinner is a chance to recognize those individuals who have gone above and beyond to help the association achieve its goals, and to relax and fellowship with other members. It is always a personal highlight of my ANA week, and I hope to see many of you there! The details of each of these events can be found in this newsletter. As always, thanks for reading, and thank you for your support of NCBA.
 

Upcoming Events

Seminar: Impacts of the 2024 Treasury Initiative on Precious Metals Dealers 

Date: Wednesday, August 7, 2024
Time: 10:00 a.m.
Location: ANA World’s Fair of Money, Donald E. Stephens Convention Center, Room 3

This presentation by Gary Knaus will cover the key components of the “2024 National Strategy for Combating Terrorism and Illicit Financing,” which will directly and indirectly impact dealers in precious metals over the next few years. (For more information see “Treasury Takes the Driver’s Seat on Anti-Money Laundering” below.)

Membership Dinner and Update
Get ready for a fantastic evening!

We are thrilled to invite you to our annual Membership Dinner and Update on Wednesday, August 7, 2024. It’s a wonderful opportunity to mingle with fellow members and guests, enjoy a delicious meal, celebrate award presentations, and get the latest updates on NCBA’s activities.

Date: Wednesday, August 7, 2024
Time: Hors d’oeuvres and cocktails at 6:30 p.m.; dinner at 7:00 p.m.
Location: Gibsons Steakhouse, 5464 North River Road, Rosemont, Illinois

Early bird special extended one week! Register by July 14, 2024, and save $25 per dinner ($100 now; $125 after July 14).

Complimentary admission for Gold and Platinum members and one guest.

Consider enhancing your involvement by becoming an event sponsor with a donation of any amount. Your support makes a significant difference!

Seating is limited, so be sure to register now and secure your spot! Simply click the button below to sign in and register. You’ll need your membership credentials. If you’ve forgotten them, there’s a link on the sign-in page to help you retrieve them.

CLICK HERE TO REGISTER NOW

We can’t wait to see you there!
 
NCBA Board of Directors Meeting
A board of directors meeting will commence at 8:00 a.m. on Wednesday, August 7, 2024, at the ANA World’s Fair of Money in the Donald E. Stephens Convention Center, Room 22.
 
General membership participation and engagement are invaluable to the growth and success of our association. Members are welcome and encouraged to attend.
 
Member Attendance Guidelines
  • Membership Status: Please ensure your membership is current and dues are up to date to attend.
  • RSVP: Kindly confirm your attendance by July 31 for logistical purposes.
  • Participation: Opportunities for member input will be provided during designated segments of the meeting.
  • Meeting Conduct: Respectful adherence to meeting protocols is appreciated.
Your involvement is crucial to shaping our association’s future. We eagerly anticipate your active participation and valuable contributions during the meeting.
 
For inquiries or to RSVP, please contact executive director David Crenshaw at ncba@ncbassoc.org.


Update Your Member Profile

Stay connected with NCBA through our website at ncbassoc.org. We ask that you take a moment to update your member profile via the Home page sign-in. If you do not know your username or password, from the Home page select “Forgot Your Password” to retrieve them.
 
Concerned Collectors Coalition members should add your state and federal legislators to your profile. CLICK HERE to find your legislators—remember, they may have changed following the last election. 
 
By keeping your member profile up to date, you are guaranteed access to all the exclusive benefits and resources that an NCBA membership offers:
  • Member-only resources specifically for dealers, available online at ncbassoc.org
  • Federal and state legislative alerts and other important communications
  • Discounts on valuable cash- and broker-reporting information kits
  • Professional development educational seminars
  • Access to the online Member News quarterly newsletters
Should you need any assistance or have any questions or comments about your membership and/or benefits, please feel free to contact us at (678) 430-3252 or by email at ncba@ncbassoc.org.


Essential Resources for Your Business

NCBA provides essential information to help you with cash and broker reporting. Copper and above members get a 50% discount off the listed price.

Cash-Reporting Kit ($200): The information provided by NCBA is intended to assist dealers in understanding the regulations on cash reporting and money laundering. This information is designed to be used in conjunction with the advice of your professional tax advisor.

Consumer Information Kit ($50): This information has been produced in response to many questions from consumers regarding what products and circumstances require transactions be reported to the U.S. Department of the Treasury / Internal Revenue Service.

CLICK HERE to order information kits.

Broker Reporting (Form 1099-B): In response to the IRS clarification regarding reporting obligations for precious-metals dealers, the NCBA has released two new white papers. The first, titled “Understanding Reportable Items and Approved Brands for Precious Metals Contracts,” delves into the implications of the IRS clarification on reporting precious-metals sales. It offers insights into how specific items correlate with CFTC-approved contracts and provides information on approved brands that are acceptable for fulfilling precious-metals contracts.

The second white paper, “Navigating IRS Form 1099-B Reporting: Guidelines for Precious Metal Dealers,” is a comprehensive guide designed to show dealer-members how to navigate the reporting requirements outlined in IRS Form 1099-B. This document offers clear instructions on how to determine when reporting is necessary, particularly in light of potential regulatory changes. 

While these guidelines may stand alone, they are intended to complement the information provided in the “Understanding Reportable Items and Approved Brands for Precious Metals Contracts” white paper. Dealer-members may download these white papers from our website, ncbassoc.org, after signing in via the main menu: Resources > Knowledgebase > Anti-Money Laundering > Files. 


Member Benefits

Sales-Tax Status & Economic Nexus Requirements by State
This quick-reference guide, for dealer-members only, shows the sales-tax exemption status (complete, partial, or nonexistent exemption) of each state on in-state retail sales of coins, currency, and precious-metals bullion. This guide also shows each state’s post-Wayfair economic nexus requirements.

Dealer-members may download this resource from our website, ncbassoc.org, via the main menu (sign-in required): Resources > Knowledgebase > Sales and Use Taxes > Files.


Draw More Exposure for Your Company

Would you like members and visitors to our website to see your company’s message? Would you like to capture the attention of NCBA members in our newsletter, Member News?

Help your company stand out with an advertisement in the advertising carousel and/or Member News. The “Our Sponsors” carousel on our website displays each ad in rotation for approximately five seconds. A carousel advertisement is a free benefit for Bronze-level members and above. Advertising in Member News, which is sent to all NCBA members every quarter, is also a great way to get your message out.

CLICK HERE for more information.


States’ News

Presently, 43 states have complete or partial sales-tax exemptions on in-state retail sales of collector coins and precious-metals coins and bullion. Of those states, five (Alaska, Delaware, Montana, New Hampshire, and Oregon) have no state sales tax at all, while the other 38 have enacted legislation and adopted regulations to exempt such purchases. That leaves seven states (Hawaii, Kentucky (effective August 1, 2024), Nevada, New Jersey, New Mexico, Maine, Vermont, and the District of Columbia who do not exempt retail sales of coins, currency, and precious-metals bullion from sales tax. Any member who would like to start a sales-tax exemption initiative in one of these remaining states or the District of Columbia should email ncba@ncbassoc.org.

Alaska
In the last quarter, significant strides were made in advancing House Bill 3, An Act relating to specie as legal tender in Alaska, through the legislative process. The bill successfully passed the House on May 11, 2023, and was subsequently forwarded to the Senate, where it gained cross-sponsorship from Senator Bjorkman. Despite this progress, the Alaska Legislature adjourned sine die on May 16, 2024, without further action from the Senate Finance Committee, the bill is dead. Looking forward, we encourage everyone to join NCBA executive director David Crenshaw’s “2025 Initiative: Eliminate Sales Tax on Coins and Bullion in Key States” to continue this important work.

We extend our thanks to the Anchorage Coin Club board of directors for advocating for HB 3 by writing letters to the Senate and Governor Dunleavy.

Kentucky
Kentucky has become the 44th state to enact a full or partial sales-tax exemption on the sales of coins, paper money, and precious-metal bullion, effective August 1, 2024. Despite Governor Beshear’s line-item veto, citing the affordability of tax for gold owners and the need to treat bullion as tangible goods, the veto was invalidated on constitutional grounds. The legislature was able to send the bill instead to the Secretary of State for signature. Originating as Senate Bill 105 and later integrated into House Bill 8, the legislation defines “bullion” and “currency” for tax-exemption purposes, benefiting dealers and collectors. The bill’s passage followed years of advocacy by key stakeholders and reflects a collaborative effort to provide economic relief and foster a thriving numismatic market in Kentucky.

Minnesota
As previously reported, Representative Bjorn Olson introduced HF 106 in an effort to expand exemptions for precious-metal bullion and related currencies by modifying current sales-tax provisions. We were encouraged that HF 106 was referred to the House Taxes Committee, a significant step forward in the legislative process. Meanwhile, a companion bill in the Senate, SF 373 (championed by Senator Rich Draheim), which mirrors the objectives of HF 106, was introduced and directed to the Senate Taxes Committee, demonstrating bipartisan recognition of the importance of this issue.

Despite the challenges posed by the current political climate, we remained steadfast in our commitment to advancing this legislation. NCBA member Gary Adkins worked with the local coalition’s lobbyist to engage key stakeholders, including the bills’ sponsors. To bolster the bills’ prospects for a hearing, the lobbyist requested a meeting with legislators to emphasize the economic benefits of similar exemptions in other U.S. states. By presenting compelling case studies from states like nearby Michigan, where substantial growth in sales and employment followed the implementation of exemptions, we aimed to demonstrate the potential benefits for Minnesota’s economy.

Unfortunately, on May 20, the Minnesota Legislature adjourned sine die with no further action on either HF 106 or SF 373, resulting in the bills dying in committee. This outcome underscores the ongoing challenges in achieving legislative progress in this area. In light of this, we encourage you to heed the message of NCBA executive director David Crenshaw, “Join the 2025 Initiative: Eliminate Sales Tax on Coins and Bullion in Key States.” Your continued support and advocacy are crucial as we look ahead to future efforts to eliminate sales tax on currency and bullion.

New Jersey
NCBA is thrilled to announce progress in the ongoing push for Assembly Bill A5294, now reintroduced as S721, “Exempting sales of investment metal bullion and certain investment coins from sales and use tax.” On March 11, 2024, the bill underwent a pivotal amendment to remove the $1,000 threshold and unanimously cleared the Senate Budget and Appropriations Committee. The lobbyist spearheading the campaign diligently addressed concerns raised by the Office of Legislative Services (OLS) regarding the fiscal note, submitting NCBA testimony that effectively refuted its flawed assumptions. The bill passed out of the Senate on March 18, 2024, in a unanimous vote of 38–0 and was received by the Assembly, where it was referred to the Commerce, Economic Development, and Agriculture Committee. On June 3, the committee reported favorably on S721 and the bill was referred to the Assembly Appropriations Committee. After much negotiation and careful consideration, the bill was amended to reinstate the $1,000 threshold and was then reported favorably to the Assembly. The bill was substituted for the identical Assembly bill, A2812, and voted on, where it passed unanimously (71–0),  after which the bill was sent back to the Senate floor for concurrence. The Senate passed A2812 on June 28, 2024, and it will be sent to the governor’s office. Governor Philip Murphy has 45 days to act on the bill. 

In the meantime, the lobbyist is making arrangements for us to meet with the governor’s assistant counsel to discuss the bill’s merits and solidify support for its enactment. The positive outcomes with the Senate and Assembly underscores the importance of proactive engagement and collaboration with key decision-makers. 

To contribute toward lobbyist fees and other campaign expenses, please make your check payable to Richard Cohen, and mail it to National Watch & Coin, 106 South 7th Street, Philadelphia, PA 19106. Write on the check “New Jersey Campaign.” For more information, please contact Cohen at (215) 418-2700 or via email at rlondon@guesswho.com.

Vermont
In the previous quarter’s update, efforts to support House Bill 295 in Vermont faced a significant obstacle as the bill failed to advance beyond the House Ways and Means Committee. Despite persistent attempts to engage Representative Peterson, the bill’s sponsor, there was no response regarding NCBA’s offers of support and suggestions. 

With only one NCBA dealer-member in Vermont and no members from the Concerned Collectors Coalition, it is imperative to rally local coin business owners and collectors to join the advocacy efforts. House Bill 295, introduced by multiple representatives, presented a crucial opportunity to advocate for a sales-tax exemption on precious metals sold for investment. However, with the bill’s demise in committee, the urgency to push for favorable legislation has become more pronounced. NCBA executive director David Crenshaw is emphasizing the importance of joining the 2025 initiative to eliminate sales tax on coins and bullion in key states, highlighting the need for continued advocacy and engagement to secure a favorable environment for coin-business owners and collectors in Vermont.

Wisconsin
The Wisconsin Legislature passed a sales- and use-tax exemption on the sales of precious-metal bullion, a move celebrated as a milestone in the state’s economic policy. Governor Tony Evers signed the legislation, Assembly Bill 29, on March 21, 2024, set to take effect the following day. This decision made Wisconsin the 43rd state to enact such an exemption, covering coins, bars, rounds, or sheets containing at least 35 percent gold, silver, copper, platinum, or palladium. The legal foundation for this exemption is outlined in Wisconsin Statute Section 77.54(71), with clear definitions and criteria for precious-metal bullion. The success of this legislation is attributed to the dedicated efforts of various legislators and stakeholders, including Representative Shae A. Sortwell, Senator Duey Stroebel, and industry advocates like NCBA Wisconsin dealer-members Andy Kimmel, Michelle Voecks-Griesbach, and Mark Ferguson, alongside Clifford Mishler and Patrick Heller. Their collaboration marks a significant victory for the precious-metals industry in Wisconsin.


National News

Treasury Takes the Driver’s Seat on Anti-Money Laundering: Impacts of the 2024 Treasury Initiative on Precious-Metals Dealers
 
How does the Department of the Treasury hope to combat money laundering? It’s a mystery. But this spring the Department of Treasury released its “National Strategy for Combating Terrorist and Other Illicit Financing,” a comprehensive and detailed document that lays the groundwork for how our nation addresses the legal and regulatory gaps existing within the current Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) system. Among the 55 pages in “National Strategy” are sections that apply specifically to dealers in precious metals, stones, and jewels. These topics will be the primary focus of the presentation I will be making in Rosemont, Illinois, at the ANA show on August 7. 
 
Our discussion will include the impact of new technologies and regulations on our industry:
  • Artificial Intelligence
  • Shifting Risk Factors
  • DeFi (Decentralized Finance—Blockchain and Cryptocurrency)
  • Government Supervision
  • Banks
  • Form 8300-B
  • And others
If time allows, there will be a Q&A session for attendings on Anti-Money Laundering.
 
Those who attended the “Navigating the New Anti-Money Laundering Act of 2020 Regulations, Part 1” seminar at the August 2023 ANA World’s Fair of Money in Pittsburgh (or watched the video afterwards) may recall that the Financial Crimes Enforcement Network (FinCEN) was going to release the new AML/CFT Notice of Proposed Rule Making, which directly relates to our industry, in December 2023. 
 
And they didn’t. 
 
Those who attended the “Navigating the New Anti-Money Laundering Act of 2020 Regulations, Part 2” at the January 2024 FUN Convention learned that FinCEN had rescheduled publication to March 2024. Again, that month came and went. 
 
Nada. Nil. Nothing. 
 
I wrote FinCEN to let them know that their repeated failure to deliver was disappointing and to request that they provide a more definite timeline. Their response basically stated that they couldn’t give us one. 
 
It turns out I must be far from alone in expressing my dissatisfaction. In May I came across a publication of FinCEN Director Andrea Gacki’s remarks at a major conference. At the bottom of the second page, I noticed the following:
 
“The issuance of an updated AML program rule is a foundational part of this effort, and we intend to issue a proposed rule this year that includes regulatory amendments that would ensure that AML/CFT programs incorporate the National AML/CFT Priorities, and are effective, risk-based, and reasonably designed.

“When we issued the Priorities in June 2021, we encouraged financial institutions to assess their risk exposure to those Priorities while we work on implementing regulations. We recognize that financial institutions have been anxiously waiting for a proposed rule to see how they will be required or expected to incorporate the Priorities into their AML/CFT programs.

“We view revising the AML/CFT program rule consistently with the AML Act to be a substantial step in a multi-year and multi-step effort to transition to a more effective and risk-based AML/CFT framework.” (Emphasis mine. Prepared Remarks of FinCEN Director Andrea Gacki During the SIFMA AML Conference.)
 
If I were to guess, the delays were due to the Treasury Department working on the National Strategy discussed above. They wanted FinCEN to hold off because they realized there was more work to be done before the AML/CFT regulations could be finalized.
 
Mystery solved. Maybe.

Are you going to the ANA World’s Fair of Money? If so, we hope you can attend our seminar, “Impacts of the 2024 Treasury Initiative on Precious Metals Dealers,” at 10:00 a.m. on Wednesday, August 7, 2024, in Room 3 of the Donald E. Stephens Convention Center. This presentation will cover key components of the “2024 National Strategy for Combating Terrorism and Illicit Financing,” which will directly and indirectly impact dealers in precious metals over the next few years.

Gary Knaus, NCBA member and owner of Knaus & Associates, Inc., has provided AML compliance services to bullion, coin, and jewelry dealers since 2012. Contact him at 630-963-6350 or gknaus@aml4u.com.

NICAC Raises Concerns Over Flawed Legislation for 2026 World Cup Commemorative Coins
The Numismatic Industry Coinage Advisory Committee (NICAC), a special committee of the National Coin & Bullion Association, released a report, “NICAC’s Concerns Regarding Pending Legislation for a 2026 World Cup Commemorative Coin,” expressing concerns with legislation authorizing the minting of coins commemorating the 2026 FIFA World Cup.

“Eighteen months ago, NICAC urged Congress to adopt a coin program observing our nation's role as one of three host nations for the 2026 World Cup,” said Philip Diehl, NICAC's chairman. “Unfortunately, FIFA has chosen to proceed with its own ideas, and the result is deeply flawed.”

Profits from sales of the coins would be paid to FWC2026 US, Inc., a wholly owned subsidiary of FIFA, the Zurich-based organizer of the World Cup. FWC2026 US, Inc., could receive well in excess of $12 million from the program, 10 times its revenue from 2022 (the latest year available), which totaled $1.1 million.

NICAC's report identifies several concerns with the proposed legislation:
  • While the bills suggest profits from coin sales would go to programs for “inner-city youth,” in fact the money could be used for any U.S.–based soccer program, including the construction of a new headquarters and/or national training center for the U.S. Soccer Federation, developing elite national teams, and increasing the pool of referees.
  • The bills are unclear whether profits would be shared with Canada Soccer and the Mexican Football Federation. Regardless, the bills do not require reciprocity in profit-sharing from commemorative coin programs of the other two host nations.
  • FIFA has a longstanding, revenue-sharing partnership with an international numismatic business. The bills would enable this European firm to make discounted bulk purchases of coins and sell them to World Cup fans and coin collectors abroad, leaving the U.S. market shortchanged.
  • According to the bill, mintages set by law could be raised by the Treasury secretary at any time based on market research FIFA would conduct. Collectors value scarcity and consider changes in mintages set by law a form of bait-and-switch marketing.
NICAC urges Congress to work with FIFA and this committee to address these concerns.

CLICK HERE for the full report.

Jimmy Hayes is NCBA’s general counsel, a numismatist and former member of Congress. He has also served as Commissioner of Financial Institutions and Commissioner of Securities in Louisiana. Jimmy Hayes and Anthony J. Correro (Securities professor at LSU Law School) wrote the current Louisiana Securities Code.

Philip N. Diehl, a member of the NCBA board of directors, is celebrated for his transformative leadership as U.S. Mint director. He launched the 50 States Quarter program and the first U.S. government-issued platinum coin, boosting the Mint's annual profits from $450 million to $2.5 billion. Diehl's deep expertise in fiscal and monetary policy now guides his work in the precious metals industry.

Congress HR 7865: Facilitating the Lawful Trade of Ancient Coins
The International Association of Professional Numismatists urges NCBA members to contact their federal representatives and request their co-sponsorship of HR 7865: To amend the Convention on Cultural Property Implementation Act to make certain technical corrections to facilitate the lawful trade and collecting of numismatic materials. This bill aims to streamline the lawful trade in ancient, medieval, and early modern coins with our European colleagues.

Introduced by Representative Beth Van Duyne, HR 7865 would permit the import of certain designated coin types—provided there is evidence of lawful acquisition, known type identification, and an absence of direct association with illicit excavations within a country after the effective date of any import restrictions on coins.

If enacted, this legislation would ease the lawful exchange of collectors’ coins with our European trading partners while supporting the objectives of the Cultural Property Implementation Act (CPIA) to prevent recently looted material from entering the market. The necessity for this legislation arises from overly broad import restrictions, which currently embargo common coins that circulate regionally and internationally. These restrictions are enforced not only on items smuggled from UNESCO state parties after implementing regulations against looting but on all coins of designated types.

During initial discussions about the CPIA, Mark Feldman, a senior State Department lawyer, indicated to Congress that restricting coins would be challenging. Current certification language was not drafted with coins in mind. As a result, customs authorities currently detain or even seize coins simply because they match increasingly expansive designated lists, unless the importer can prove their lawful acquisition from a particular country prior to its implementing regulations. Existing import restrictions have significantly limited Americans’ ability to purchase and import historical coins from legitimate markets abroad. Millions of American citizens engage in collecting historical coins, and millions of such coins are lawfully available for sale worldwide.

This legislation would align the requirements for legally importing collectible coins with what buyers in legitimate markets abroad should be able to reasonably certify—lawful acquisition, known type identification, and no association with illicit excavations.

The bill enjoys support from the American Numismatic Association and the Ancient Coin Collectors Guild. But it is vital that we encourage support among legislators. You can find your congressperson using the link: Find Your Representative | house.gov. Upon contacting your representative, please let me know by email at pkt@becounsel.com so I can provide specifics to their staff.

For additional context, please see the article discussing HR 7865 published in CoinWeek, “Bill Introduced to Facilitate Lawful Trade of Ancient Coins.”

Peter K. Tompa currently serves as the executive director of the International Association of Professional Numismatists (IAPN). Previously, he held the position of outside legal counsel for the IAPN, where he advocated for fair treatment of micro and small businesses within the numismatic trade when dealing with government regulators. Throughout a career starting in the 1990s, Tompa has specialized in cultural property law and has contributed significantly to the field through his extensive writing and lecturing engagements.