Sunday, February 22, 2015

Collectors Beware: Italian MOU Renewal Pending

The US State Department is now considering renewal of the Memorandum of Understanding with Italy, first promulgated in 2001 and subsequently renewed in 2006 and 2011, which restricts importation into the United States of a wide variety of antiquities, including many types of ancient coins struck in Italy.

The State Department's Cultural Heritage Center, under the leadership of archaeologist Maria Kouroupas, has become a willing and enthusiastic collaborator with the anticollecting ideological agenda of the Archaeological Institute of America. Since 2001 the State Department has been systematically working to extend import restrictions on a wide variety of collectible antiquities, which since 2006 has included ancient coins. Knowledgeable observers within the trade believe that the ultimate goal of the AIA is to close down the international antiquities trade, and perhaps even to make private ownership of antiquities illegal.

At present Roman Imperial coins, the most popularly collected ancient coins, have not yet been placed upon the Restricted List. It is widely predicted that unless very strong public opposition emerges, that may change in 2016.

If the relentless expansion of import restrictions is allowed to continue, it will eventually become very difficult (if not impossible) to import ancient coins into the United States. That will cause serious dislocations within the trade, and major problems for collectors of ancient coins in the United States. Since there will not be any restrictions on export of ancient coins from the United States, they will become scarcer and harder to find, and prices will inevitably rise as they leave the country never to return or be replaced.

It is time for US collectors to take a strong stand and summon up a firestorm of public opposition to this usurpation of power by a few radical anticollecting archaeologists and their unelected bureaucratic allies, who have unscrupulously flouted the legislative intent of the 1983 CCPIA implementing the 1970 UNESCO Convention in the United States.

To submit comments electronically, go to the Federal eRulemaking Portal (, enter the Docket No. DOS-2015-0010-0001, and follow the prompts to submit a comment. (for a direct link see!documentDetail;D=DOS-2015-001.) Please note comments may be posted only UNTIL MARCH 20, 2015 at 11:59 PM. Submit comments yourself and ask friends and family who reside at different addresses to also submit comments.


Peter Tompa, an attorney specializing in cultural property law, has provided very good reference material in his blog:

If you would like to "know your enemy" you can find a good starting point in archaeologist Paul Barford's anticollecting blog:

Mr. Barford's special theme is that while he does not altogether oppose antiquities collecting, he does oppose collecting of (and especially dealing in) unprovenanced antiquities. Mr. Barford snidely describes collectors of ancient coins as "coin fondlers." If you consider that insulting, it is nothing compared to the invective unleashed upon their suppliers: "dealer" in his vocabulary of invective is used with a haughty disdain that suggests such individuals are social outcasts. Perhaps in his far left-wing circle of acquaintances in Warsaw, that may indeed be the case.

If Mr. Barford were in control I am sure that it would become unlawful to collect unprovenanced ancient coins. Every collector should realize that this includes more than 95% of all coins available and that the cost of documenting provenance would be almost prohibitive. I have discussed this here:
The Logistics of Provenance

Please note that Mr. Barford has not accepted the approach discussed there, and no doubt would require something considerably more onerous and expensive.


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