You can file despite being a non-US citizen. I submitted the following comment this evening:
Dear US Department of State officials,
Any regulations related to the importation of ancient coinage from
Turkey will raise serious challenges related to applicability, namely in relation to the determination of what is a Turkish coin. Such challenges call for careful expert study.
The most clear example of this challenges is related to coinage of the
Roman era.
During the "late
Roman" period of the
Roman Empire - generally taken as meaning the late third through to fifth centuries AD -
Roman coinage was struck at a series of approximately 15 mints scattered across the territory of the Empire. Five of these mints were on the territory of the modern state of
Turkey -
Heraclea,
Constantinople,
Nicomedia,
Cyzicus and
Antioch.
Coinage struck at these Imperial-controlled mints was then distributed throughout the
Roman Empire and beyond. This distribution began immediately after striking and continued, due to normal coin circulation, throughout the duration of the
Roman Empire.
As an example of this distribution, figures from the UK's PAS (
Portable Antiquities Scheme) website (finds.org.uk), which records only local finds made by the public in
England and Wales and voluntarily reported, registered (as of January 07, 2020) the following coins struck at these mints:
Heraclea: 105 examples
Constantinople: 1,054 examples
Nicomedia: 112 examples
Cyzicus: 181 examples
Antioch: 309 examples
Thus we have 1,761 coins struck on the territory of modern
Turkey, reported as found by
members of the UK public in recent years. We can assume that such finds almost entirely represent coins which appeared in the UK in ancient times - over a millennia and half before the creation of the modern state of
Turkey.
This distribution pattern of
Roman coinage can be found in countries across
north,
west, east and south Europe as well as the Middle east and
North Africa - in other words through the extent of the
Roman Empire.
How does one determine what coins fall under the
aegis of such an agreement? The argumentation that any coin struck in the territory of modern
Turkey is a Turkish coin is ridiculous. Can a coin struck by
Roman Imperial authorities in
Constantinople (modern Istanbul) in the 320s AD, but found by a detectorist in
England (where it
had lain in the ground for approximately 16 1/2 centuries) be considered a Turkish coin? Of course not. What then is the implication for such an MOU on the many thousands of such coins on the market today?
These same issues also apply to "Greek" coinage - much of which was struck in
Turkey, as well as
Byzantine and early
Islamic.
Based on the above facts, I would advise the responsible authorities to take the time to investigate this matter carefully and take the results of such an investigation into consideration when developing or implementing any policy decisions. Any professional
numismatist can provide an extensive list of sources that delve into these matters in much more detail.
Thank you for your consideration.
