The full text has finally been posted to the Federal Register: https://www.federalregister.gov/documents/2016/12/06/2016-29191/import-restrictions-certain-archaeological-material-from-egypt
The scope seems pretty ridiculous if I read that right. Essentially all coins minted in Egypt in antiquity are affected.
The logic however remains consistent with the MOUs on
Italy and
Greece. Coins minted only for local circulation are included under the MOUs because they can be presumed to be local finds. That covers all
Egyptian coins until the Diocletianic reform, and none afterwards. Likewise the
denarius coinage of the Roman republic is excluded from the
Italy MOU as it circulate everywhere, and similarly
Pegasi and Owls and other trade coins are excluded from the Greek MOU. Straightforward approach really, and the
ANS has tended to be heavily involved in the discussions leading to the MOUs. I think it's best we just bite the bullet on these MOUs as they are currently being drafted and focus on establishing provenances for what we already have and/or collecting non-local-circulation coinages. In each case these only apply on a going forward basis so anything you've already bought and have a purchase record for is
fine, anything bought now or in the future from a published or online dealer in the US is
fine (on the reasonable assumption that such dealers complied at their point of purchase) and anything purchased anywhere else where either the seller asserts pre-2017 out-of-Egypt or you find
provenance is
fine. Having worked under these MOUs for years now, probably 98% of my
collection remains MOU-clear for eventual US import under one or other category above and I'm actively working on the 2%, none of which includes pieces really essential to me (i.e. it's more likely that common worn bronzes haven't records). The system can be worked with. Don't panic and remember that a towel is about the most massively useful thing an interstellar hitchhiker (or ancient
numismatist) can have.