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Roman Coin Imports in Danger
IMPORTING ANCIENT ROMAN coins might become a thing of the past if a proposed update of a Memorandum of Understanding (MOU) between the United States and Italy is approved by the U.S. State Department.
The existing MOU originated in 2001 and has been augmented every five years since that time. The MOU defines restrictions on imports of specific artifacts from Italy to the United States. The artifacts unable to be imported are considered to be of cultural importance to Italy. There is no legal definition of this “cultural importance.”
The Italian MOU has become a political football, with the interests of museums and private coin collectors being sidelined in favor of politics and archaeological special interest groups. The memo is an indirect result of the UNESCO Convention on the Means of Prohibiting and Preventing the Illicit Import, Export, and Transfer of Ownership of Cultural Property.
Under the UNESCO convention, coins and other objects from antiquity must have already been outside the country from which they supposedly originated prior to 1970 to avoid being scrutinized regarding who has legal title to these objects. A major problem for coins is the lack of documentation available for most individual pieces. The U.S. 1983 Cultural Property Implementation Act creating the Cultural Property Advisory Committee followed. CPAC was meant to advise the president how the U.S. should proceed with other individual nations to safeguard each nation’s cultural heritage. A MOU is the official agreement between the U.S. and another country through which recommendations are implemented.
When the State Department addressed Congress in 1983, the department indicated MOUs would not impact coins except under “the most unusual circumstances.” Since that time, categories of ancient coins found within the borders of Italy that cannot be exported to the United States has been continuously expanding. Roman Imperial coins are proposed to be added to the growing list when the MOU is renewed in 2021.
Peter Tompa is a Washington, D.C.-based attorney and numismatic advocate who has been defending coin enthusiasts against CPAC for more than 10 years. He currently represents the International Association of Professional Numismatists. Tompa also has a blog: Cultural Property Observer.
According to Tompa, “There is a real question whether this MOU should be renewed for a fourth time, extending its limitations on the ability of American citizens and small businesses to import cultural goods of a sort widely collected in Italy itself to a total of 25 years. Any renewal should let current import restrictions on coins, particularly larger denomination trade coins, to lapse. No new restrictions should be countenanced on late Roman Republican or Roman Imperial coins or later coins which are not found exclusively in Italy, or which date from the Renaissance or later, which are not typically archaeological objects.”
Tompa continued, “If some historical coins remain subject to import restrictions, CPAC should also demand any renewed MOU requires Italy to facilitate issuance of export licenses for coins, and provides for the legal entry of coins of the sort lawfully available for sale in Italy itself that are accompanied either by an European Union export permit or other documentation evidencing legal export from another EU member state.”
The June 26 Report on Roman Republican and Roman Imperial Coins prepared by the IAPN for CPAC points out that “Roman Imperial coins from Italian mints can be found in large
