By Richard Giedroyc
The future of importing and collecting ancient coins in the United States is once more in question as the U.S. State Department announced Feb. 26 that Italy has requested a renewal of an existing Memorandum of Understanding.
This MOU was authorized in 2001 and has since been renewed twice. The objective of the MOU was initially to authorize import restrictions on pre-Classical, Classical, and Imperial Roman period Italian cultural artifacts.
According to Washington, D.C., attorney and Ancient Coin Collectors Guild spokesman Peter Tompa, “Import restrictions were never meant to be permanent. Rather, they were aimed at cutting market demand to allow time for a source country to get its own house in order.”
The MOU has been expanded with each renewal. The 2011 renewal added import restrictions on coins of ancient Greece, early Republican Rome, and Roman Provincial coins from the early Imperial period.
Tompa speculated, “Now, it’s quite possible that the archaeological lobby, which actively opposes private collecting, will press for import restrictions on Roman Imperial Coins – the heart of ancient coin collecting – as well.”
Tompa urged collectors to contact The Cultural Property Advisory Committee to protest renewal of the MOU through the Federal eRulemaking portal, docket No. DOS-2015-0010-0001 to submit a comment. The deadline for such comments was March 20.
The Cultural Property Advisory Committee recommends to the State Department if import restrictions are appropriate and if restrictions should be placed on specific cultural goods. The mission of CPAC is to provide the State Department with useful advice. CPAC has in the past recommended against restricting the import of coins. Beginning in 2007 restrictions were placed on the import of coins defined as being ancient originating from Bulgaria, China, Cyprus, Greece, and Italy. Tompa said restrictions on some Egyptian coins may follow.
The State Department decisions on renewal of any MOU or restrictions on imports due to their being the cultural property of another country are all politically based. There are activist archaeologists who want to see all future private collecting of artifacts including coins become illegal, while there are organizations including the ACCG that lobby to protect the rights of private ownership for both collectors and museums within the United States.
Part of the problem is that any ruling by the US State Department restricting or banning the import or ownership of artifacts including coins only impacts the United States. There are no similar restrictions in any other of what could be called the art market consuming countries.
Restrictions on archaeological artifacts deemed to be of “cultural significance,” “first discovered within,” and “subject to the export control” of a specific UNESCO state party are governed under the Cultural Property Implementation Act. Among provisions in this act are that restrictions must be part of a “concerted international response” of other market nations, that restrictions can only be applied once “self-help” measures have proven to have failed, and restrictions must be consistent with the general interest of the international community as part of the interchange of cultural property among nations for scientific, cultural, and for educational purposes.
Tompa pointed out: “It’s typically impossible to assume a particular coin (especially Roman ones) was ‘first discovered within’ and ‘subject to the export control’ of Italy.”
According to Tompa, “In the past 15 years Italy has mounted aggressive police actions that have greatly diminished looting in the country. Yet, all this enforcement effort has done little to actually protect Italy’s cultural patrimony.”
Tompa added, “It’s time to scrap current import restrictions and instead promote real cultural cooperation rather than more confrontation. This is particularly true for common artifacts like ancient coins.”