The US State Department has announced a proposed renewal of a cultural property Memorandum of Understanding (MOU) with the Republic of Italy.  There is a danger that this will provide an excuse for US import restrictions implementing that MOU to be expanded to include late Roman Republican and Roman Imperial Coins. 

Import restrictions could make it far more difficult to import such coins from legitimate markets in Europe like those in the United Kingdom, Germany and Switzerland.

Why?  Because  they would give US Customs the authority to assume that any late Roman Republican or Roman Imperial coins with a country of origin/manufacture of Italy (i.e., Rome and other late Imperial mints of Aquileia, Mediolanum, Ostia, Ravenna, and Ticinum) are the “cultural property” of the modern Republic of Italy.   

US Customs could then demand that the importer “prove” that such coins were out of Italy before the effective date of any governing regulations, which can be difficult to do for many coins, particularly low value ones like most Roman coins.

And if you can’t provide this information?  The coin(s) could be detained, seized and “repatriated” to the Italian government.

What can you do?  Go to https://www.regulations.gov/, search for dos-2024-0048, and then click the blue “comment now” button. Or try this direct link: https://www.regulations.gov/commenton/DOS-2024-0048-0001

What can you say?  Your own comments focusing on how import restrictions might make it more difficult to purchase coins to appreciate ancient history and culture are the best, but  here is a short model for you to use for your own comments:

Please reject any effort to expand current restrictions to include Roman coins. The Coin Hoards of the Roman Empire database lists over 6 million such coins. See https://chre.ashmus.ox.ac.uk/. Roman coins circulated from the UK to Sri Lanka so it is improper to assume any one individual coin is Italian Cultural Property.  Import restrictions would damage my ability to learn more about ancient history and negatively impact my own interactions with other collectors, especially those in Europe where collecting Roman coins is particularly popular.  

Want to learn more?  Visit the Cultural Property Observer Blog at: https://culturalpropertyobserver.blogspot.com/ Or contact IAPN’s Executive Director, Peter Tompa, at pkt@pktcounsel.com.

Comments Must Be Made on or Before January 27, 2025.

For more about the International Association of Professional Numismatists, see https://www.iapn-coins.org/

For a PDF of this Post which may be used as a handout, see NYINC Handout Italian MOU 010725.pdf