For detailed breakdowns see Peter Tompa's blog:
Here are the highlights, and this observer's comments:
1) 94% of Public Comments Were Opposed to Renewal of Italian MOU and/or Restrictions on Coins
Only 15 comments supported MoU renewal without reservations (such as exclusion of coins). These 15 comments should not be discounted
because with the exception of David Knell (actor and anti-collecting activist), Paul Barford, and an anonymous contributor (who identified himself as a collector and academic), they came from academics and archaeologists with relevant knowledge and experience:
Leila A. Amineddoleh, Executive Director, Lawyers’ Committee for Cultural Heritage Preservation
Francesco de Angelis, Associate Professor, Roman Art and Archaeology, Columbia University
Fiona Rose-Greenland, Associate Research Director, The Past for Sale project, U. of Chicago
Nancy de Grummond, Professor of Classics, Florida State University
Elizabeth Colantoni, Assistant Professor of Classics, University of Rochester
Gordon Lobay, Senior Consultant, Perrett Laver (executive search firm)
Associate Scholar, Intellectual Property in Cultural Heritage Project
Jane Evans, Professor of Art History and Classics, Temple University
Kathleen Lynch. Associate Professor, Department of Classics, University of Cincinnati
Clemente Marconi, Professor of Greek Art and Archaeology, Institute of Fine Arts - NYU
Alex W. Barker, Director, Museum of Art and Archaeology, University of Missouri
Kris Lockyear, Faculty Member, Institute of Archaeology, University College London
David W. J. Gill, Professor and Director, Heritage Futures, University Campus Suffolk
In the past the Cultural Heritage Center bureaucracy, under the direction of anti-collecting archaeologist Maria Kouroupas, has given very little evidence of taking appropriate notice of the overwhelming number of public comments objecting to restrictions on ancient coins, and has even disregarded such recommendations from the CPAC. Hopefully on this occasion the views of interested academics and archaeologists (harmonious with those of the CHC bureaucracy) will not again prevail.
Interested collectors would do well to review these comments. The problem of looting of archaeological sites is real, and insights can be gained into what is happening at Italian sites and why archaeologists naturally want everything possible done to discourage looting. However, the one real investigative report (Fiona Rose-Greenland's comment) was rather tentative. Its author believes that the MoU has had an effect toward discouraging looting, however her primary observation was that it has become significantly more difficult for looters to sell their finds into the international antiquities market, and in many cases they are instead keeping them. She notes effective enforcement action by Italian police authorities, and the success of an educational campaign to develop public awareness of the importance of Italy's cultural heritage. These laudable successes may in themselves suffice to explain the observed decrease in looting, and certainly indicate that there is now less reason to believe that emergency measures such as import restrictions are required. Significantly, the author did not differentiate between types of objects sought by looters and did not mention coins.
2) The Association of Art Museum Directors (AAMD) comment presents a
sobering portrait of Italy's unwillingness or inability to live up to its end of the current MOU with the United States:
Italy's grossly underfunded, over-bureaucratic cultural establishment is not up to that task. Lack of effective and honest governance negatively impacts the preservation of Italy's cultural heritage. Given the dismal performance of Italy's public sector, Italy's antiquities and coin dealers should be allowed to sell not just to other Italians, but to the world. Each MOU has already called for Italy to ease the process for granting export permits for artifacts legally sold within Italy itself, something that has not happened (along with much else) because of Italy's choking bureaucracy.
AAMD advocates opening up the Italian auction market so it can not only be a source of legitimately acquired artifacts, but help bring much needed money to help fund Italy's underfunded cultural establishment.
The AAMD states that coins should be freed of foolish import restrictions:
Export restrictions on many ancient coins...are illogical because they are not specific to Italy in origin and there is a ready, legal market for them in Italy. Many dealers in Italy advertise ancient coins for sale. Either Italy must agree to issue export permits for coins sold legally in Italy or the designated list should be amended to allow such coins to be brought into the United States.
Collectors should realize that it is difficult and time-consuming to obtain export permits for any sort of artifact from the Italian government.
As a result, any unprovenanced coin included in the Designated List is effectively prohibited from entering the USA, even if it is sold at auction elsewhere in Europe and can legally be shipped almost anywhere else in the world.
3) Arturo Russo of Numismatica Ars Classica NAC AG, a numismatic firm and auctioneer with offices in Milan, Zurich and London, comments regarding about the frustrations of dealing with the Italian cultural bureaucracy:
As a quid pro quo for all prior MOUs, Italy promised to facilitate the issuance of export certificates for archaeological objects artifacts legitimately sold within Italy itself. 2001 MOU, Art. II, F; 2006 Extension, Art. II, F; 2011 Extension, Art. II, G.
This has not happened. In fact, since coins were added to the designated list for import restrictions in 2011, the Italian cultural bureaucracy has made it almost impossible for me to export coins from the country.
I used to be able to secure export licenses for collections of ancient coins so they could be sold at auction abroad. After restrictions were placed on Greek coins from Italy and Sicily, Etruscan coins from Italy, Early Roman Republican coins, and early Imperial Colonial and Provincial coins to 37 AD, I was told this would no longer be possible. When I enquired why, I was told that if such export licenses were granted, the Americans would not think that the Italian cultural bureaucracy was serious about protecting its cultural patrimony. It is important to state that these denials have been issued for coins with a legitimate provenance.
This is entirely backwards. The MOU purports to require Italy to make such objects legitimately sold within Italy available for legal export abroad, but instead the MOU is being used to justify precluding legal export of even common coins sold within Italy itself. Furthermore, Italian authorities deny export licenses even for very common coin types based on the argument that even a small variety is a good reason to decline an application. Please note that they also deny export licenses for coins of non-Italian origin with the premise that they would be difficult to acquire for Italian Institutions.
Another major problem is that most of the staff is not qualified to cast informed judgment on the rarity or importance of a coin, in fact they are archeologists and not numismatists. I must admit on several occasions I found myself informing them of the existence of the proper reference works required to establish the rarity of a coin type or even worse I had to draw their attention to the fact that several coins of that type were already in Italian Museums.
Unfortunately, since 2012 the attitude of the Italian officials towards export licenses for coins have changed dramatically. Italian collectors are still important buyers in auctions abroad, but in the eyes of Italian authorities every single coin of average rarity should remain on Italian soil. I find this position unfair and unreasonable especially considering that Italy has a gigantic numismatic heritage which is not published and more importantly very difficult to access for scholars and collectors.
In my experience, almost all European countries take a reasonable position by granting export licenses for most of the coins excluding only the exceedingly rare coin types.
Collectors should realize that the cultural bureaucracy in nations receiving import restrictions awarded by MoU are not likely to understand their reciprocal obligations involving issuance of export licenses, and will instead "automatically" seek to deny almost every request pursuing a retentionist policy whose goal is to keep artifacts in state custody and prevent their export.
This is a bad policy when applied to artifacts in general, but in the specific case of ancient coins, it becomes a critical obstruction to the normal functioning of the international market for ancient coins. Italy is an extremely important source for Greek, Roman, Carthaginian and pre-Roman Italian coinage, and the USA is the most important market for these coins with an estimated half of the world's ancient coin collectors.
If reasonable policies for issuance of export licenses are not instituted, the intention of MoU restrictions is frustrated and these agreements become de facto barriers to international trade in certain classes of artifacts, in particular ancient coins.
In this observer's opinion, that result is not happenstance. It is instead exactly what could be expected when the requesting and issuance of import restrictions are being managed by bureaucrats with a strong anti-collecting bias, who (although they will not publicly admit this) would prefer to see the international trade in ancient artifacts suppressed, and private ownership of such artifacts declared to be unlawful.
Organizations commenting were opposed to renewal of the Italian MOU or import restrictions on coins
The International Association of Professional Numismatists, the Professional Numismatists Guild,
and the International Association of Dealers in Ancient Art
all opposed the MOU or import restrictions on the lawful trade in ancient coins.
Both the American Numismatic Association
and Ancient Coins for Education
expressed concerns about import restrictions on coins.
The Association of Art Museum Directors
took a nuanced approach to the MOU. While supporting the renewal, AAMD requested changes to encourage Italy to live up to its part of the bargain.
Two groups that advocate for the interests of dealers and collectors, the Association of Dealers and Collectors in Ancient and Ethnographic Art
and the Ancient Coin Collectors Guild
, also argued against renewing the MOU or extending restrictions on historical coins.
Only one advocacy group associated with the archaeological lobby, the Lawyers' Committee for Cultural Heritage Preservation,
supports the extension unequivocally.
In this observer's opinion there is a very clear divide between the opinions of those involved in ancient coin collecting and the numismatic trade, and the archaeology lobby.
Those involved in numismatics understand first-hand the immense damage import restrictions have done, and will continue to do, to the numismatic trade and to interests of ancient coin collectors worldwide and especially in the USA.
Those in the archaeology lobby do not understand numismatics or the numismatic trade, and perhaps do not even understand antiquities collecting. They instead view antiquities collecting and the international antiquities and art markets as "incentivizing looting of archaeological sites," and believe as an ideological tenet that the international trade in ancient artifacts should be suppressed, and private ownership of such artifacts declared to be unlawful.
They also do not understand that numismatics is a distributed science that is much older than archaeology, in fact an important ancestor of archaeology, and that ancient coin collectors are the primary source of numismatic research. Very little numismatic research is being carried out by archaeologists, although that which is being done is typically of very high quality and is enthusiastically welcomed by collectors and professional numismatists.
There simply are not enough archaeologists and academic professionals interested in this field to support its research requirements. To most archaeologists doing fieldwork, ancient coins are artifacts whose primary importance is utility in stratigraphic dating, and whose secondary importance is analysis of local economic and trade patterns. Once coins have been attributed, unless they are assessed as being suitable for museum display (a relatively rare event) they are placed in storage, usually without conservation or cataloging.
5) The Italian MoU has a harmful effect on the study and appreciation of Italian culture:
Karen Antonelli, a dual citizen of the US and Italy, expressed these concerns about the impact of the MOU on Italian Americans:
I am a dual citizen of the United States and of Italy living in San Francisco, California. I have a Ph.D. in Italian Literature from the University of California at Los Angeles as well as an M.B.A. from the University of Southern California. Although I lived most of my first twenty years in Italy (but born of American parents of Italian descent who were working for the U.S. government at the time), I have resided, full time, in the United States for more than forty years and treasure both my U.S. and my Italian heritage. I get tremendous satisfaction sharing my Italian heritage and culture with my fellow Americans and promote business relationships between Italy and the U.S. by teaching Italian language, literature and film classes as well as by performing professional translations for individuals and companies.
Unfortunately, the proposed extension (and perhaps expansion) of the present Memorandum of Understanding with Italy will do little to help, and a great deal to harm, the study and understanding of Italian heritage and culture, at the very least to the extent that it will restrict the import into the United States of abundant small objects like coins and other common artifacts. This is especially true as these objects were intended to, and did, travel great distances. These objects are useful not only in teaching the history of ancient Rome, its successor city-states and the modern Italian Republic, but in understanding so many aspects of its culture...societal relationships, religion, cultural tropes, trade and economics.
The proposed MOU only harms United States citizens...restricting the import of the coins and similar common artifacts here, while they continue to be bought and sold, and travel widely, throughout Europe and even in Asia.
As an Italian citizen, if I can purchase these objects in Italy as my heritage, why may I not bring them to the U.S. to share and teach?
Of course, I support the suppression of looting of archaeological sites (as I understand it, the purported reason for the ban on importation) but there are much better ways to do this than the extension of the MOU. Please do not renew it, or at least exempt from the extended MOU all common, abundant artifacts like coins. The goal of the Committee should be to preserve culture, not as an end in itself, but to promote the availability and awareness of culture to the citizens of the United States.
In this observer's opinion, "cultural heritage" is not something exclusively possessed by a modern nation such as Italy, but is something that nation shares with the rest of the world which is interested (for cultural reasons) in that nation's past.Their cultural heritage is just as important as that of the present day citizens of that nation.
The cultural heritage of US citizens interested in classical studies, classical numismatics, ancient history and Italian culture is being restricted and damaged by efforts to sequester common and redundant Greek, Roman and Etruscan artifacts in Italy without regard for their lack of importance to science and archaeology.
As Antonelli observes, "abundant small objects like coins and other common artifacts" are of little importance to science, but of great importance to cultural appreciation and understanding. They should be disseminated as widely as possible, to enrich the cultural heritage experience and appreciation of all mankind.