By Mark Fox
Italy recently asked the United States to once again extend for another five years the Memorandum of Understanding (MoU) that restricts the U.S. importation of a wide range of archaeological material, including some ancient “coins of Italian types.” Only such coins that can be demonstrated to have left Italy before the last MoU extension was implemented (Jan. 19, 2011) can be legally imported.
Roman coin collectors and researchers are very concerned that Roman imperial coins (31 B.C.E.-491 C.E.) may be added this time to the designated list of restricted objects, which are unequivocally the heart of ancient coin collecting. Particularly vulnerable as well are Roman Republican coins. Those minted before 210 B.C.E. in gold, silver and bronze are already restricted. For the details of what other archaeological material is currently restricted by the Italian MoU, see the designated list at http://eca.state.gov/files/bureau/it2011dlfrn.pdf.
“The MoU with Italy has the potential to be a watershed (or said another way, the straw that broke the camel’s back),” writes Wayne G. Sayles, founder and current executive director of the Ancient Coin Collectors Guild (ACCG). “Strong united comment in opposition is essential to those in Washington who only seem to measure response by the pound and tend to ignore truth and justice. If the history of coin restrictions under MoU is any guide, we can expect that there will be an effort within the Cultural Heritage Center to expand the designated list for coins from Italy to include Roman Imperial issues. That would affect tens of thousands of collectors in the U.S. alone and the one-way flow of these coins in years to come would eventually destroy private collecting as an avocation of any but the wealthy and privileged – setting ancient numismatic research and preservation back 300 years.”
The American Numismatic Association (ANA) is equally opposed to any expansion or extension of the Italian MoU, “because,” explains ANA Gov. Scott Rottinghaus, “it not only restricts collecting of ancient coins, but it also hinders cultural understanding and person-to-person contacts that are promoted by the international exchange of historical coins.”
With so many different MoUs in force now, many restricting particular groups of coins that only experienced numismatists are equipped to recognize easily, some fear that any more import restrictions will cause U.S. Customs to begin detaining ancient coins indiscriminately.
The Cultural Property Advisory Committee (CPAC) will meet from April 8-10, 2015, to discuss Italy’s request and receive oral public comments during the open session on April 8. However, the public has only until March 20 to make their written concerns known in the decision-making process. Comments are currently being accepted through the eRulemaking Portal at the following link: http://www.regulations.gov/#!documentDetail;D=DOS-2015-0010-0001
Only comments the writer believes “to be privileged or confidential” may be mailed to the following address: Cultural Heritage Center (ECA/P/C), SA-5, Floor C2, U.S. Department of State, Washington, DC 20522-05C2.
Regarding whether or not the public needs to address all four determinations, as laid out by the Convention on Cultural Property Implementation Act (CPIA), under 19 U.S.C. 2602 (http://www.gpo.gov/fdsys/pkg/USCODE-2013-title19/html/USCODE-2013-title19-chap14-sec2602.htm), lawyer and coin collector Peter Tompa has these words to say: “The fact is that most collectors can only comment on what they know. They know the impact of restrictions on their hobby. That’s an entirely appropriate basis for comment, and I would note the Federal Register notice does not suggest otherwise.”
As of March 6, only 63 online comments were posted. Such a number is unlikely to help sway decisions in either direction. If not renewed, the current MoU with Italy will expire on Jan. 19, 2016.
