Ancient coin import restrictions may expand: Collectors invited to comment on proposed restrictions on Italian coins

People have until March 20 to submit comments on the proposed Memorandum of Understanding
By , Coin World
Published : 03/12/15
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The United States Cultural Property Advisory Committee will again be looking at possible import restrictions affecting various ancient coins that could impact collectors in the United States. 

Specifically, the committee will review the proposal to extend the “Memorandum of Understanding Between the Government of United States of America and the Government of the Republic of Italy Concerning the Imposition of Import Restrictions on Categories of Archaeological Material Representing the Pre-Classical, Classical, and Imperial Roman Periods of Italy.”

A MOU between the United States and Italy first authorized import restrictions on certain Italian cultural artifacts from the Pre-Classical, Classical and Imperial Roman periods in 2001. This MOU was extended in January 2006, and in 2011, the renewal was expanded to include import restrictions on certain Greek, early Republican and Provincial coins from the early Imperial period. Coins had been excluded from the 2001 MOU and its 2006 renewal. 

Attorney Peter Tompa, a board member of the Cultural Policy Research Institute and the Ancient Coin Collectors Guild, fears that the MOU may be expanded to include Roman Imperial coins, which he characterizes as the “heart of ancient coin collecting.” 

The effect of the import restrictions is that certain “coins of Italian types” may be imported into the United States only if accompanied by either an export permit issued by Italy or other documentation indicating that the coins left Italy prior to the effective date of the restriction.

The MOU will remain in force for a period of five years, when it be considered for renewal. Although the CPAC has no decision-making authority, and ultimately the State Department has the exclusive authority to make the final decisions, CPAC recommendations are typically followed by the government.

Tompa hopes that collectors speak up. He said, “We hope Roman Imperial will not be included, but last time around, an official Italian representative, egged on by American archaeologists, asked for them to be added. Without collector outcry, silence may be taken as acquiescence.”

Import restrictions limit the ability of American collectors and dealers to legally import certain types of coins that may be legally available in other countries.

Tompa notes that the import restrictions “have drastically limited Americans’ abilities to purchase historical coins from abroad and have negatively impacted the cultural understanding and people to people contacts collecting fosters.”

Those with an opinion are invited to make comments electronically, via the Federal eRulemaking Portal online at www.regulations.gov. To make a public comment, enter the Docket No. DOS-2015-10, and follow the prompts to submit a comment no later than 11:59 p.m. (EST) on March 20. 

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