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New EU law on the horizon, affecting coin collectin


Tetradogma

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In the end, I don’t think it will make any more difference than it already has. “Anyone wishing to import cultural goods created outside the EU into the EU must follow the new rules.” If you think about coins, that statement is meaningless and unenforceable. Only high value coins will be affected, at the whim of whatever bureaucrat thinks they are doing a good deed, but that’s how it is now.

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Interesting article.  It appears the purported rationales for the new law, which are to combat terrorism and prevent money laundering, are baseless.  Two separate investigations failed to demonstrate the antiquities trade was being used as a cover for money laundering or for financing terrorism. 

For a law to be just, it must serve a legitimate purpose, that is the law must be for the common good.   Here a law is attempting to remedy a problem which does not exist, so far as we know.   

One could argue that antiquities have the potential to be used in schemes to nefariously transfer funds.  But in this, antiquities are not unique.  Pallets of iPhones, sacks of diamond rings, or bottles of rare cognac could serve the same purpose.  

The truth is that the EU bureaucrats do not believe hoi polloi should have the privilege (as they see it) to own and trade in antiquities, including coins.  For some reason, they find this offensive and intolerable.  They demonstrably are willing to lie to implement the regulations they desire.  

Lex iniusta non est lex.  

Sic semper tyrannis.  

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An unfortunate transatlantic ripple? In their auction this week, Roma stopped specifying which coins were from The Mare Nostrum hoard, one of the most important hoards ever from the period. 

I do respect however the American public feels about what coins should or should not be hosted by their country. I am worried about the possible loss of records about finds and damage to the knowledge of history.

Edited by Rand
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2 minutes ago, Rand said:

An unfortunate transatlantic ripple? In their auction this week, Roma stopped specifying which coins were from The Mare Nostrum hoard, one of the most important hoards ever from the period. 

I do respect however the American public feels about what coins should or should not be hosted by their country. I am worried about the possible loss of records about finds and damage to the knowledge of history.

It is very courteous of you to imply that we Americans still live in a democratic republic, and that the laws reflect the wishes of the people.  Would that it were true.  

It seems likely that governmental efforts to confiscate coins and artifacts, both in the US and the EU, which will be facilitated by the new operative legal principle that items without demonstrable provenance MUST be illegal and contraband, will only serve to drive the trade underground.  Loss of provenance information, though much to be lamented,  will be the least of our problems. 

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1 hour ago, Hrefn said:

Interesting article.  It appears the purported rationales for the new law, which are to combat terrorism and prevent money laundering, are baseless.  Two separate investigations failed to demonstrate the antiquities trade was being used as a cover for money laundering or for financing terrorism.  

I find the CulturalPropertyNews (CPN) article and the sources it relies upon a little biased in its reporting of this particular aspect.

Here's what CPN say:

Quote

As the Facts & Figures page on the ADA website demonstrates, both reports ordered by the European Commission to find such evidence turned up nothing of significance on the money laundering front and nothing at all relating to terrorism financing

The "Facts & Figures" page cited from the ADA website further says:

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Their ultimate objective? To prove that it is responsible for terrorism financing. The result? Nothing. Yet, even when their own studies can find no evidence to support their claims (See section on Deloitte[2]& Ecorys[3] reports below).

[2] Deloitte for the European Commission, June 2017: DG TAXUD [...] “As shown from the surveys to the Member States’ administrations, hard evidence on the existence of these effects is currently often lacking”. This statement annotates a bar chart showing zero evidence available of terrorism financing.

For starters, the objective of the study is to fight illicit trafficking in cultural goods, not necessarily just illicit trade that may be funding terrorists (see "Figure 32 - Objectives Tree"). As to the evidence, what does the actual report say? Well clearly the majority of respondents answered "No" for whether they had evidence for illicit trade financing terrorist activities, but they also answered no in the majority for other effects like corruption, organised crime, and destruction of cultural heritage/goods - all of which we hardly need evidence to believe are likely effects of illicit trade of cultural goods. Corruption is essentially part and parcel of illicit trade, as is organised crime, and we all know looters are not the best archaeologists out there.

image.png.a9020212d5eb658f091e703507bdec35.png

Separately, the study claims there is evidence that ISIS profits on the order of $150-$200 million USD in trafficking illicit cultural goods each year but unfortunately I did not see a citation for that figure.

For the second study from Ecorys, the quotes ADA cites in the footnotes are generally fair and representative (of the ones I looked them up) except for two cases from the same section. First, ADA quotes around the bit where the study says at least one criminal case linking illicit trade to terrorism has been brought to European court. The second, is where the study explicitly warns policy makers against focussing too strongly on the terrorism angle and instead emphasising illicit trade is first and foremost an organised crime issue

from Illicit trade in cultural goods in Europe, p.17 - https://op.europa.eu/en/publication-detail/-/publication/d79a105a-a6aa-11e9-9d01-01aa75ed71a1

image.png.66f1e196fbc6bee6d7d030f3dad0d0e3.png

Additionally, as far as I can see, ADA has ignored the section 3.5.3 Relation to terrorism and terrorism financing which does discuss several specific examples of known terrorist groups and/or armed factions being involved in the looting and trade of illicit goods. The study further mentions that it's difficult to say exactly what the involvement might be in general as it's hard to identify individuals acting as part of loosely-organised groups versus individuals acting independently and taking advantage of the situation. The study also cast doubt on the earlier $150-$200 million figure from the first report but says undeniably that ISIS has been making some money from illicit trade. 

Quote

p.114 - "Nevertheless, it is a fundamental reality of the trade that some of the money paid in Europe for objects excavated in or traded through territory controlled by terrorist organisations must ‘trickle down’ to the organisations involved."

p.114 - "There is no evidence to support claims that Daesh might have been making millions or even billions of Euros annually from the trade, or that the trade might have been a major source of revenue. Nevertheless, there is evidence that terrorist and other armed insurgency groups do profit from the trade."

p.114 - "Some research states that it is a ‘marginal source’ (CAT, 2015); other research explains that, while the money made of trafficking in cultural goods is not significant, it may be still important in relative terms or as diversification of the revenue portfolio for the budget of terrorist groups (Altaweel, 2016; Howard et al., 2016)."

p.114 - "Most existing research suggests that the involvement of terrorist organisations in trafficking cultural goods—and making money thereof—is limited to territory that they control (van Lit, 2016; FATF, 2015; Brodie 2018). There is no evidence that terrorist groups organise illicit trade activities outside their subject territories, where it is more likely that transnational organized criminal groups are involved—the so-called crime-terror nexus (Makarenko 2012)."

I could go on but will hold off for now. My reason for all of the above is to keep the conversation fair and honest. There are undoubtedly genuine flaws and shortcomings in the studies as well as the policy being implemented but we should make sure that we're not creating strawman arguments and misrepresenting the discussion by cherry-picking quotes or relying on sources that we can't trust to be honest and unbiased in their own reporting.

More importantly, defeating such policies by arguing that their statistics or evidence on links to terrorism are lacking won't help us in the long run. The studies seem to be in agreement that organised crime is by far the largest contributing factor to illicit trade and I don't doubt that the lawmakers will have any trouble passing similar regulation that focusses only on the issue of illicit goods traded via organised crime. In other words, we'll waste time and energy defeating a strawman argument. Though it may have some short-term benefit in the sense that the studies openly admit that linking illicit trade to terrorism helps with publicity, optics, and funding. However, I doubt in the long run that the loss of this "link" will stop these types of laws in their tracks.

Edited by Kaleun96
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One day same may happen to comic books and baseball cards. It may be time to implement their cultural protection status, introduce export restrictions and measures to prevent their use in illicit trade (I am sarcastic this time). 

I would not be surprised if their museum expositions attract more attention than those of ancient coins.

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@Kaleun96 I would like to thank you for your dispassionate tone and reasoned analysis.  I think we are in substantial agreement.  Pointing out the lack of money laundering or terrorism financing in the business of the antiquities trade will not derail the push for increased government regulation, nor does pointing out bad faith on the part of the regulators in advancing such claims avail much, either.  

My belief is that the prevailing sentiment amongst European and American government circles is contra to any private trade and ownership of antiquities.  The pretext for regulating the trade is unimportant.  If the above reasons prove ineffectual, then fighting organized crime or protecting cultural patrimony will be invoked.  

I hate to see archeological sites looted, but I place much of the blame on governments who arrogate all ownership rights, guaranteeing that the antiquities trade become a black market with the attendant secrecy, waste and destruction, loss of provenance, and despoliation consequent to a criminal enterprise.  Attempts to preserve “cultural patrimony” with confiscatory laws which prevent a private individual from profiting from discovery of a hoard or artifact have likely done vastly more harm than good, human nature being what it is.  And attempts to forbid the import of coins/artifacts without clear provenance will just drive the trade underground.  No one will benefit.   

 

 

 

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It's amazing, how most humans will gladly give up their freedom, in order to have more safety. If this trend continues, then owning precious metals will become illegal, because precious metals are real money, and precious metals cannot be tracked by the government, and therefore precious metals could be used for illegal activity. As others have mentioned above, perhaps eventually all collectibles will become illegal to own, because they can't be tracked by the government, and therefore they could be used for illegal activity. In fact, one can imagine a dystopian future, in which everything real, which cannot be tracked by the government, will become illegal to own, all in the name of safety ("if it will save 1 life, then it's worth it"), all for the sake of decreasing illegal activity. Perhaps the world will eventually become a dystopian nightmare of safety, intellectual property, and "cultural property". But for some people, that would be a paradise.

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Nothing new here.  President Roosevelt confiscated gold coins and bullion from Americans in 1933, and forbade private ownership of gold coins beyond a limit of one hundred dollars worth, which would have been about 5 Troy ounces, or 5 $20 gold pieces.  It was only due to good fortune that FDR’s Treasury Secretary at the time, William Woodin, being a serious numismatist, that an exemption was made allowing collectors to retain gold coins of recognized collector value.  This executive order was only fully rescinded on December 31st, 1974.  

England and Australia both severely limited their subjects ability to own gold at various times during the twentieth century. 

Edited by Hrefn
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Some news from CoinsWeekly on the resistance from the US collector community/trade to the repatriation practice.

https://new.coinsweekly.com/news/customs-repatriation-to-greece-raises-questions/

I am still waiting for a celebratory update from the Greek or Turkish recipients of the Eid Mar aureus, with new high-quality photos, information about the find spot/provenance and public access to the coin. They have kept a low profile so far.

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On 7/8/2023 at 12:19 AM, Hrefn said:

England and Australia both severely limited their subjects ability to own gold at various times during the twentieth century

We have many burdens from the overlords of Westminster but this wasn't one of the worst, and was easily avoided. As Hansard shows, the government was fairly clueless (apologies  if this is definitionally obvious!) and wrapped itself  up on on what exactly gold was, what dates etc were allowed (1837 was a big  one!), what was coin of the realm etc. The short version  is you could  hold gold as much as you wanted, as they obsessed over specific coins. Gold in other forms was generally fine. I would far rather have my metal not worn though! A relative  swears to  me a friend turned his gold coins  into  a Celtic-style  torc at a Birmingham foundry but alas I have no proof.

https://api.parliament.uk/historic-hansard/commons/1966/jun/13/exchange-control-gold-coins

We still though  have to have any purchases over 10k reported to the government, supposedly for  money-laundering reasons.

More directly related to this thread , their endless willingness to  tinker and  interfere without  much thought for consequences beyond the most immediate does not  inspire any confidence.

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On 7/7/2023 at 2:08 PM, Kaleun96 said:

The studies seem to be in agreement that organised crime is by far the largest contributing factor to illicit trade

Thanks for this helpful post, @Kaleun96. I do wonder about this final point. There are two interpretations: 1) selling "looted" antiquities is a revenue stream for criminal organizations that engage in multiple criminal activities (e.g. illicit drugs, theft, racketeering, sex trafficking etc.), or 2) selling"looted" antiquities in any systematic way IS organized crime itself.

The ADA quote you give suggests it may be the second one: "However, looting and trafficking is an organised crime first and foremost." What?!

One of the objections we have (as expressed very nicely by @Hrefn) is that the export of coins from countries like Turkey where they have absolutely asinine antiquities laws is very definitely NOT (at least not always) "looting" or necessarily anything negative at all. It's people getting around unjust laws insofar as they can, so as to earn some money in a way they ought to have a right to.  It is not organized crime, at least not typically... although the ADA and others seem to be claiming it is organized crime by definition! This is not OK! We should not let them get away with it. 😠

The message we send should be: any country that has failed to adopt the UK system or something similar is failing to protect their cultural heritage. Draconian prohibitions on trade go even further, to the extent of being violations of human rights in some cases, and in all cases failing to be just.

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5 hours ago, Severus Alexander said:

Thanks for this helpful post, @Kaleun96. I do wonder about this final point. There are two interpretations: 1) selling "looted" antiquities is a revenue stream for criminal organizations that engage in multiple criminal activities (e.g. illicit drugs, theft, racketeering, sex trafficking etc.), or 2) selling"looted" antiquities in any systematic way IS organized crime itself.

The ADA quote you give suggests it may be the second one: "However, looting and trafficking is an organised crime first and foremost." What?!

I did wonder that myself but I don't think the sentence you quoted indicates one way or the other whether it's only associated with organised crime because the looting is criminal or because the people looting are linked to organised crime. What you quoted only suggests that looting and trafficking is an organised crime itself but not if it's in isolation of other crimes. The same applies to the corruption issue too - if looting wasn't illegal, then would the issues of corruption disappear? Probably not entirely but to a large degree you would imagine.

The second study does touch on all of this, of course:

https://op.europa.eu/en/publication-detail/-/publication/d79a105a-a6aa-11e9-9d01-01aa75ed71a1

Quote

In some instances, the police and prosecutors come across this illegal activity while investigating other forms of crime, for example. In general, it appears that the conditions in which the art market currently operates may facilitate criminal behaviour in the case of unscrupulous traders. It is believed that the illicit trade in cultural goods sometimes operates as a mafia-style hierarchical organised criminal network, but other times as flexible networks of individuals and groups acting together opportunistically [...] As mentioned in section 3.1, the opinions of stakeholders on the extent to which the illicit trade is organised differ significantly.

Quote

Most of the interviewees also indicate that the organised crime groups that are involved in the transporting of cultural goods are also active in the narcotics and/or arms trade.

Quote

During the 1990s52, the area of Sarmizegetusa Regi, Romania, the ancient capital of the Dacian Kingdom, was looted by organised criminal group with international connections (Oberländer-Târnoveanu, n.d.).

There's a few more quotes but I think it's clear that the authors of the study consider both of the following to be true: trafficking in looted antiquities often requires organised criminals and is thus itself an organised crime, and trafficking in looted antiquities tends to attract the interest of existing organised crime networks.

-------------------------------

OK back to quoting you (not sure how to make a second quote that references the person who said it):

Quote

One of the objections we have (as expressed very nicely by @Hrefn) is that the export of coins from countries like Turkey where they have absolutely asinine antiquities laws is very definitely NOT (at least not always) "looting" or necessarily anything negative at all. It's people getting around unjust laws insofar as they can, so as to earn some money in a way they ought to have a right to.  It is not organized crime, at least not typically... although the ADA and others seem to be claiming it is organized crime by definition! This is not OK! We should not let them get away with it. 😠

The message we send should be: any country that has failed to adopt the UK system or something similar is failing to protect their cultural heritage. Draconian prohibitions on trade go even further, to the extent of being violations of human rights in some cases, and in all cases failing to be just.

Couple of things here where I disagree. Starting with "looting", I think this depends on your definition of "archaeological site". If you only use that to refer to places of habitation, then a lot of coins leaving Turkey illegally may not be technically "looted". However, if you use "archaeological site" to refer to any site that contains evidence of past human activity, even if it is just a single grave or deposit, then it is most definitely looting. However, either way, it is still theft. Whether you call it looting or not doesn't change that.

In regards to "unjust laws" and "they have a right to", this tends to be more of an American-centric viewpoint in my experience. Laws differ between countries, it's something more people here need to get used to. Laws in the legal sense aren't laws of universe (even American laws!) and there's not necessarily a right or a wrong - they are going to differ between countries. The fact of the matter is that many countries prohibit the excavation and selling of artefacts recovered from the ground as they are not the property of the individual. It may be different in the US but it's like that in many other places around the world. This means illegally exporting coins from their country of origin is theft or the participation in such. You can claim all you like that it's your human right to do so but you'll still end up in prison with a criminal record at the end of the day.

These types of arguments remind me of Americans that I've seen argue that a certain Amendment applies globally and thus countries that have laws infringing its rights are similarly unjust and are in violation of basic human rights. I'm afraid it doesn't work that way and it's better not to waste time on these types of arguments as you're likely going to have a difficult time convincing a court that everyone has a right to whatever they find in the ground. The best way forward is what you mention later, something along the lines of the current laws "failing to protect their cultural heritage" and it's better for everyone if a UK-style law is implemented.

As for whether it's OK for the ADA (N.B. the ADA doesn't take this view as far as I know, they take the view of many on this forum) and others to claim trafficking in antiquities is organised crime by definition, I don't see the problem with this, at least where they use it correctly. As the second study notes, not all trafficking is organised crime, but it does tend to require organisation of criminal elements. So where that burden on "organisation" is met, it seems reasonable to then call it organised crime. Of course if it were legal, it wouldn't be a crime, but you could say the same thing about narcotics and I don't think we should not use the term "organised crime" for that just because one day trafficking narcotics may be legal.

Edited by Kaleun96
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42 minutes ago, Kaleun96 said:

I did wonder that myself but I don't think the sentence you quoted indicates one way or the other whether it's only associated with organised crime because the looting is criminal or because the people looting are linked to organised crime.

I suspect most coins people try to smuggle from Turkey and Greece are incidental finds, often on their own land.

What options do people have? 
- To give the coins to authorities. I have heard this may put people into trouble as they may be suspected of not returning all coins and investigated.
- To keep them. From Greek friends, I have heard that many families keep ancient coins they found (which could be a long time ago).
- To try selling the coins, feeling it is unfair for the governments to take away from them what they found on their own land, especially if they struggle financially, and they approach grey dealers.

These people may not see it as looting and organised crime, but governments may.

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1 minute ago, Rand said:

I suspect most coins people try to smuggle from Turkey and Greece are incidental finds, often on their own land.

What options do people have? 
- To give the coins to authorities. I have heard this may put people into trouble as they may be suspected of not returning all coins and investigated.
- To keep them. From Greek friends, I have heard that many families keep ancient coins they found (which could be a long time ago).
- To try selling the coins, feeling it is unfair for the governments to take away from them what they found on their own land, especially if they struggle financially, and they approach grey dealers.

These people may not see it as looting and organised crime, but governments may.

Even if the person who digs up the coins is not part of an organised criminal group, it doesn't mean that organised crime doesn't facilitate the rest of the trafficking. These farmers are likely not reaching out to auction houses and exporting the coins out of country themselves. I might also question the assumption that *most* coins coming to market are incidental finds given how methodical some looters are and even in countries like Greece there is evidence of large looting groups. In that case, it's even supposedly farmers and hunters performing most of the searching/digging but it's anything but incidental

Anyhow, whether that person sees their actions are looting or not is really not important. How does that help us as collectors? I could likewise say a drug dealer may not see their actions as trafficking and organised crime, but governments may.

I feel myself taking on the role of Devil's Advocate in this thread because there's so far been little discussion that would convince anybody of a different opinion. For the most part, much of what has been written above can be changed so it's from the perspective of a narcotics trafficker and the argument would hold equally well, which is to say not very.

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18 minutes ago, Kaleun96 said:

I feel myself taking on the role of Devil's Advocate

Not at all! A very interesting discussion.


I may sound like a Looter's Advocate, which I am not at all - I do agree with your reasoning! It just helps to consider the perspectives of different parties involved.

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There are two issues:

1) Collecting coins that have been legally exported.
2) The laws in a country that makes their exportation legal or not.

Firstly, we should all be doing everything we can to comply with (1). I agree with the various authorities that looting is a problem and anyone doing it should be prosecuted, even if that law isn't to our liking. The reason is that if you ignore the law in one place because it's draconian and unjust, you have difficulty drawing the line as to where you 'should' comply with the law. Someone could just as easily say it's unfair that the UK authorities take your find off you and pay what the British Museum thinks is a fair price for it, rather than letting you keep it or sell it to whoever you want.

This is the same problem with speeding. I might say, well, I was only 5mph over the limit, so what? My car can do that speed on that road no problem. Throw the book at those doing 30mph over, but 5mph is ok. Then I'm surprised when the authorities reduce the speed limit on that road because everyone's doing 5mph over, in the hope of making them drive nearer to the original limit, and now we all have to drive even slower.

Secondly, we should be doing all we can to improve (2). One way is to comply with (1). If collectors don't buy looted coins, the authorities wouldn't have a reason to clamp down on the trade. There will always be countries where the laws are draconian and unreasonable, but most countries will go for something in the middle.

There have to be reasons why more countries don't adopt the UK model (which I think is also the system in the Netherlands and other places). I imagine the UK model was created to try to avoid having to police every little find, as despite some of these repatriations being worth a lot of money, it has surely cost more policing, investigating and prosecuting them. It also has the benefit that people are happy to report finds, so in the UK we have a record of our cultural heritage.

One reason they don't could be corruption, but it could be a genuine fear of a country's culture being smuggled out from under their noses. At a top-line level, that makes sense and a law restricting it makes sense. It's only when you get into the detail of certain items - like coins - that you realise it doesn't make sense. But the fear of having all their heritage stolen will always ensure they go for the 'safest' law. We should be demonstrating that actually, your cultural heritage will be enhanced by having less draconian laws, that you could benefit from a database of finds your academics can use, and your museums will have more, better artefacts because they get first refusal on everything.

Edited by John Conduitt
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@Kaleun96

On reflection, I retract my 'I suspect most coins people try to smuggle from Turkey and Greece are incidental finds, often on their own land.'.

There was a clear spike in coin finds since metal detecting became widespread in the UK and elsewhere, and finds by metal detecting are deliberate rather than incidental. Even if metal detecting is less common (or prohibited) in Greece and Turkey, illegal searchers use it.

Still, if Google's translation from Greek is any good, the linked articles are not convincing that large-scale looting is a major problem in Greece. One article repeats the known Eid Mar aureus story; the other refers to a trial that has yet to be completed (if understood correctly).

The trial case refers to 2,024 coins confiscated by authorities and 600 coins repatriated from Munich during the investigation started in 2015. It would be interesting to know how many coins reached the Archeological Museum in Athens over the same period for comparison.

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1 hour ago, Rand said:

@Kaleun96

On reflection, I retract my 'I suspect most coins people try to smuggle from Turkey and Greece are incidental finds, often on their own land.'.

There was a clear spike in coin finds since metal detecting became widespread in the UK and elsewhere, and finds by metal detecting are deliberate rather than incidental. Even if metal detecting is less common (or prohibited) in Greece and Turkey, illegal searchers use it.

Still, if Google's translation from Greek is any good, the linked articles are not convincing that large-scale looting is a major problem in Greece. One article repeats the known Eid Mar aureus story; the other refers to a trial that has yet to be completed (if understood correctly).

The trial case refers to 2,024 coins confiscated by authorities and 600 coins repatriated from Munich during the investigation started in 2015. It would be interesting to know how many coins reached the Archeological Museum in Athens over the same period for comparison.

Just want to add that I didn't link the article to prove that large-scale looting is a major problem in Greece, rather it was just an example of such. Personally I think we all underestimate how prevalent organised looting is and perhaps there's also some confirmation bias on our part where we find it more palatable to collect coins if we think they're coming from landowners trying to make a buck off of their land when they can.

My experience with less-organised looting comes from the Balearic islands, where the looters are local and are seemingly not part of some grand trafficking ring, yet they still have zero respect for the graves they loot and the objects (or skeletons) and archaeological context they destroy in the process. Maybe they sell to a market vendor on the mainland, some shady antiquities dealer (of which Barcelona has a reputation), or perhaps some criminally-connected middleman, but either way it would be a mistake to consider their "finds" incidental or some how to be justifiable just because they're locals who live in the area and aren't making much money. So even in the case where it may be a few individuals acting independently, I don't think that necessarily makes the picture any rosier than if it were a sophisticated criminal enterprise.

I should probably also clarify that when I think of coins coming to market, I think of those going to auction houses and dealers, not the $3 coins popping up in troves on eBay. I wouldn't be surprised if in some countries, e.g. the Balkans, these lower value coins do make up the majority of trafficked coins simply due to their prevalence.

 

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11 hours ago, John Conduitt said:

 If collectors don't buy looted coins, the authorities wouldn't have a reason to clamp down on the trade.

The assumption that government authorities can be expected to act on reasonable grounds is one I would hesitate to make. That they have the power is reason enough for many of them, and the fact that they are clamping down on something doesn't automatically mean they have a good reason for doing so.

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3 minutes ago, CPK said:

The assumption that government authorities can be expected to act on reasonable grounds is one I would hesitate to make. That they have the power is reason enough for many of them, and the fact that they are clamping down on something doesn't automatically mean they have a good reason for doing so.

People in power rarely go around looking for random things to regulate. It's too much effort. They usually get involved when someone makes a lot of noise about something. Then they can be the saviour and put their heroics on their resume or campaign leaflet.

I know of many dreadful regulations where the authorities were responding to a perceived need but got it very wrong - environmental assessments, housing standards, tax law... all with apparently altruistic intentions that on the face of it should be reasonable. But they don't ask the right questions, argue amongst themselves, run out of time so they miss the detail, fudge the difficult bits and end up with something worse than useless. (Governments are not alone in this).

For collectors, the people making the noise are the academics who think everything should be left in the ground waiting for them to get to it. They need to be given less to complain about and more reasons to work with collectors and metal detectorists, such as by gaining a stream of finds and information.

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