The slippery slope may be on the verge of becoming a complete landslide: the renewal of the MOU with Italy threatens to include a ban on importing Roman Republican and Imperial Coins.
Under the original Cultural Property Implementation Act, ancient coins were never contemplated to be included in import restrictions. A little over a decade ago, that line began to get blurred; but even as recently as 2021, no new restrictions were placed on Roman coins.
Yet the last two years have seen multiple MOUs, from countries such as Afghanistan and Ukraine, include a ban on importing Roman coins. Now State appears to want to extend this ban to Italy. And if Roman coins are prohibited from coming into the U.S. from Italy, how much longer will it be before all potential sources of these coins are shut down?
Public comments on the MOU can be made through January 27, and we urge every one of you to weigh in on this. Currently, only 42 comments have been received, and some of those are from the opposition. A mere five years ago, 450 comments opposing Roman coin import restrictions were submitted. We simply must flood CPAC with our comments, or we risk losing one of the most important sources for our hobby.
Below are key points you can make if you can create your own comments, as well as information on how to submit them. A sample comment template is also provided, but we must stress that individual comments are more impactful.
The key arguments against the Italy MOU are:
- Roman Republican and Imperial coins were minted in vast numbers, and have been found everywhere from Denmark to India. As such, they do not fall under any of the guidelines of the Cultural Property Implementation Act (CPIA). Indeed, when the CPIA was first adopted, the State Department stated clearly that there was no expectation that any coins would ever be subject to import restrictions under the aegis of the Act.
- The wide distribution of these coins makes it impossible to discern whether any specific coin was “first discovered within” and “subject to the export control” of Italy, as the CPIA mandates. In fact, by far most Roman Imperial coins are found not in modern-day Italy, but in other parts of the Roman empire’s vast territory.
- The sale, trade and private ownership of these coins is completely legal in Italy, and in most European countries. Preventing their importation to the United States is unfair to American citizens, while contributing nothing to the CPIA’s goals of protecting cultural heritage.
- Strict enforcement actions taken by the Italian government in recent years have virtually eliminated the looting and damaging of cultural and historical sites in the country. Given that this is the fundamental objective of the CPIA, no expansion of the MOU is necessary. In fact, given this success, the MOU should be allowed to lapse completely, as it is no longer relevant to the purposes of the CPIA.
- The current MOU with Italy does not expire until 2026. Considering a renewal and possible expansion of this MOU at this time, especially with a new administration taking office, is completely unwarranted.
Regarding the MOUs with Chile, Morocco and Vietnam, the key points are that again, coins from these countries were never intended to be addressed by the original CPIA; and again, that their wide distribution makes it impossible to ascertain whether any individual coin is the “cultural property” of a particular country.
In order to submit your own comments, please click on this link, and follow the fairly simple instructions. For reference, the docket number is DOS-2024-0048 . Please do remember that your comments are part of the public record; and again, that the deadline for comments is January 27.
Template for Comments
If you prefer to submit something already written, here is some sample text. To the degree that you can at least customize it slightly, please do; but the most important thing is simply to make sure that all of our voices are heard by CPAC.
Dear Cultural Property Advisory Committee:
I am writing in strong opposition to renewal of the MOU with Italy, as well as those with Morocco and Chile, and also the proposed new MOU with Vietnam.
The current MOU with Italy, which has been in effect since 2001, should be allowed to lapse completely. It is no longer necessary because Italy’s own aggressive enforcement efforts have greatly diminished any looting of cultural and historic sites. Moreover, the MOU negatively impacts legitimate collecting coin collecting, a hobby which expands the appreciation of Italian history and the cultural interaction of individuals in both countries. At a minimum, please free all ancient coins from restriction. Such coins are openly and legally available for sale and private ownership within Italy itself, as well as throughout most of Europe. It makes no sense to continue to restrict American citizens’ access to what Italians themselves have enjoyed since the Renaissance.
Finally, please do not recommend new restrictions on Roman Imperial Coins. As the products of a great empire, as well as being instruments of commerce, these coins circulated throughout Europe, the Middle East and beyond. It is thus virtually impossible to determine where any specific coins was actually first discovered, a key requirement of the CPIA. Ancient Roman, and for that matter, ancient Greek, coins are items of world heritage, not that of any present-day nation, and thus truly belong to us all.
As for current and potential restrictions on coins from Vietnam, Chile and Morocco, I also oppose such restrictions. Again, as a general rule coins circulated outside their modern borders in considerable quantities, and one cannot assume that they are the “cultural property’ of a given country.
Underlying all of this, it needs to be stated once again that the original CPIA was never intended to include coins, as State Department testimony by Deputy Legal Adviser Mark Feldman given to Congress at that time made abundantly clear.
Sincerely,
[add your name]
For a more detailed commentary on these items, read this blog by ACCG Board Member Peter Tompa. This can help if you have time yourself to submit more expansive comments to CPAC. More detailed comments can be helpful, but what is most important is that CPAC receives as many comments from our side as possible.
For those of you interested in the CPAC hearing, it will take place on Tuesday, February 4, at 1:00 PM Eastern Time. We will circulate the link to observe the meeting once it is available.
