ACCG comments on interim review of Italy MOU
An interim review of the Memorandum of Understanding with Italy was held on November 12-13 2009
November 13, 2009
A public comment session, as part of the interim Review of the MOU with Italy, was held on November 13, 2009 at State Department offices in Washington DC. ACCG Director Kerry K. Wetterstrom represented the guild with an oral presentation. Peter K. Tompa represented the International Association of Professional Numismatists and the Professional Numismatists Guild. A report on the hearing itself will follow. The ACCG also submitted a written comment for the MOU hearing. The oral statement of Mr. Wetterstrom follows:
Dear Ms. Reid and committee members,
I make this statement today as a member of the Board of Directors of the Ancient Coin Collectors Guild (ACCG), and also as the Editor of The Celator magazine, a monthly magazine devoted to the ancient coin hobby. The Celator is the only such magazine published in the U.S., but has a worldwide readership, including Italy.
I will be brief today as you have already received statements from Wayne G. Sayles, the Executive Director of ACCG, and from Peter K. Tompa, counsel for the International Association of Professional Numismatists (IAPN) and the Professional Numismatists Guild (PNG), which more thoroughly detail the concerns of the ancient coin collector living in the United States.
In respect to Article II, Section F of the current MOU with Italy, it is stated that the Government of the Republic of Italy will “improve the efficiency of the system to release certificates of exportation. The Government of the Republic of Italy will continue to examine new ways to facilitate the export of archaeological items legitimately sold within Italy.” To date, the Government of Italy has failed to address Section F of Article II of the MOU in any measurable way.
As an example of this failure, on November 7-8, 2006, an Italian coin dealer, Numismatica Varesi S.A.S., located in Pavia, just south of Milan, conducted a public auction that included ancient Roman coins. (It should be noted that Numismatica Varesi is a member of the IAPN, and has conducted regular numismatic auctions since 1984.) A colleague of mine, a Pennsylvania-based dealer of ancient Greek and Roman coins, attended this sale for his own account and also on the behalf of a New York-based collector. He was the successful bidder on numerous lots, but due to the current export system, had to return home without his purchases. Export licenses had to be obtained, first from officials in Milan and then in Rome, a bureaucratic duplication of time and resources, and finally the coins were approved for export, and shipped to my colleague, in early February of 2007.
This is hardly a paradigm for improving “the efficiency of the system to release certificates of exportation.” In the end, the cumbersome bureaucratic process unnecessarily delayed a legitimate transaction. An American citizen with a genuine interest in the culture and history of Italy experienced a process that had less to do with preservation than with administrative inefficiency, whether purposeful or inherent. As a result of this difficulty, participation by Americans in the legitimate Italian market is limited. Quite simply, the Italian market is prejudicial against Americans. The situation in Italy is not consistent with that in other EU countries where artifacts are found and sold daily in a legitimate market.
It is interesting to note that the market for ancient coins within Italy itself is robust, and there is a considerable trade in ancient coins flowing from the United States to Italy without the slightest interruption. There are many Italian auction houses, as well as brick and mortar stores, which sell ancient coins. The Italian periodical La Numismatica caters to collectors of ancient and medieval coins, as well as modern Italian coins, with ancient coins being advertised there by dealers throughout Italy. The Numismatici Italiani Professioniste, a numismatic trade organization within Italy, lists on its web site (www.numismatici-nip.it) more than 40 firms that advertise ancient and/or medieval coins for sale. Virtually every one of the 120+ dealers on the VCoins.com Internet site have customers in Italy who purchase ancient coins, legally, without any requirement for permits or provenance.
It seems inappropriate somehow, and ironic, that a bilateral agreement that is purported to preserve cultural heritage should in reality become trade protectionism in reverse. In the MOU that is under discussion today, we are favoring Italian consumers to the detriment of American consumers of the same product. The Italian MOU creates a “one way street” in terms of trade. While commerce in common ancient and medieval coins faces relatively few restrictions within Italy itself, Americans can participate in this market only with great difficulty and patience. It would be an even greater travesty if they were precluded legally from that market while Italian dealers and collectors continue to experience the rewards of independent scholarship and private collecting.
Of course, the major issue is not so much how difficult it is to export coins from Italy, but the unfair, unworkable burden import restrictions would place on unprovenanced coins of Italian type, of which there are millions already in the marketplace. By way of example, ACCG imported unprovenanced coins of Cypriot and Chinese type from the United Kingdom for purposes of a test case. The coins could have come from literally anywhere, but U.S. Customs has assumed they were exported from Cyprus and China contrary to the import ban. The coins were detained in April 2009, seized in August 2009, and Customs still has not brought an action in court to allow ACCG to contest the seizure. One can only imagine the chaos that would take place if the State Department reverses prior precedent and imposes import restrictions on coins of Italian type. ACCG, of course, plans to argue this point further when CPAC addresses Article I of the current MOU with Italy.
- wayne g. sayles
- kerry k. wetterstrom
- peter k. tompa