By Richard Giedroyc
The U.S. State Department recently decided against expanding import restrictions to include Roman Imperial coins. The department did extend the existing Memo of Understanding with Italy that restricts the import of coins of ancient Greece, Etruscan, and early Roman Republic as well as city coinages known to have originated in Italy.
Peter Tompa is a Washington attorney who represents the Ancient Coin Collectors Guild. According to Tompa, “The Italian restrictions are particularly ridiculous given the fact that ancient coins of the sort already on the designated list are sold quite openly in Italy itself.”
Tompa continued, “There was a concern that there might be a move to expand the list given the breadth of the designated list for Bulgaria, but it seems common sense (helped along by the overwhelming number of public comments) prevailed.”
The MOU with Italy was extended for another five-year period. The memo has already been in existence for 15 years. Tompa questions why the memo has been renewed, claiming the memo lacks public support.
According to Tompa, “Restrictions put unreasonable burdens on American citizens importing Italian cultural goods. Many objects cannot be imported at all because they lack the necessary paperwork. Yet, Italy has an open, legal market in certain of the objects-- notably ancient coins--which raises an obvious question: What’s the point?”
Initially the MOU was agreed to as Italy began enforcing antiquities laws that were meant to limit looting in such problem areas such as Sicily. Mismanagement and a lack of funding to protect cultural resources are continuing problems in Italy.
According to the Bureau of Educational and Cultural Affairs web site, “On January 19, 2001 the government of the United States of America and the government of the Italian republic entered into a bilateral agreement or Memorandum of Understanding imposing import restrictions on pre-Classical, Classical, and Imperial Roman archaeological material in stone, metal, ceramic, glass, and painting from Italy.”
The website continues, “The MOU is in response to a request from the government of the Italian republic made under Article 9 of the 1970 UNESCO Convention on the Means of Prohibiting and Preventing the illicit import, export, and transfer of ownership of cultural property. Import restrictions are intended to reduce the incentive for pillage and illicit trafficking of cultural objects.”
“Objects from categories described in the designated list may enter the US if they have an export permit issued by Italy, or verifiable documentation indicating that they left Italy prior to the effective date of the restriction: January 23, 2001. As of January 19, 2011, coins of Italian types constitute a sub-category of archaeological metal objects subject to import restriction.”
Italy is only one of several countries that has been attempting to limit the import of antiquities, including ancient coins, to the United States. Some of the other countries attempting to restrict the export of antiquities and coins found within their borders determined by their legal definition to be ancient include Bulgaria, China, Cyprus, Greece, Iraq, Israel, Spain, and Turkey. China has suggested any Chinese coin made prior to 1911 is ancient.
In early 2014 US Customs and Border Protection announced new import restrictions on all Byzantine, Bulgarian, Celtic, Greek, Ottoman, and Roman Provincial coins made in Bulgaria from 1750 and earlier. The restrictions include unidentified “Greek coins from nearby regions that are found in Bulgaria.”
In the second issue for 2015 of the Journal of Field Archaeology Nathan T. Elkins wrote, “The Ancient Coin Collectors Guild (ACCG) has launched multiple legal challenges aimed at undermining import restrictions on ancient coins into the United States in bilateral agreements with foreign countries. One key component of the ACCG’s argument is that the State Department has inappropriately restricted certain types of coins according to where they were made rather than where they are found, as mandated by the 1983 Convention on Cultural Property Implementation Act.”
According to the ACCG website, “There are millions of coins on the market that could never be restricted under present law because of the length of time that they have been removed from their source country. Some of them were removed more than 2,000 years ago.
“It is irrational and erroneous to presume that any ancient coin imported today is necessarily ‘stolen property’ from a foreign nation. Yet, that is precisely what some archaeologists, and other academics, believe and that is indeed where the current legislation will lead us.”
This article was originally printed in World Coin News.
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