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The Ancient Coin Collectors Guild has become a driving force in the ongoing effort to protect coin collectors and museums in which coins are stored from being forced to give up these items to foreign governments under the premise the coins are the cultural patrimony of the claimant nation. — Richard Giedroyc, World Coin News April 26, 2010

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ACCG posts comment to CPAC on Italy hearing

ACCG Comment now online. Search ID 1jz-8hht-ujhi on the Regulations.gov web site.

March 02, 2015

The following was posted by ACCG to the Regulations.gov website in response to a Federal Register notice of public hearing on April 8, 2015 related to the requested extension of a Memorandum of Understanding (MOU) with Italy.  Search ID is 1jz-8hht-ujhi .   Online comment must be posted prior to March 20, 2015 and is open to the public. 

 

Dear Professor Gerstenblith and Committee members;

The Ancient Coin Collectors Guild (ACCG) supports the same goals that the Convention on Cultural Property Implementation Act (CCPIA) codifies in 19 USC 2601.   Those are: A) Protection of cultural patrimony against pillage; B) Measurable State Party actions to protect their own cultural heritage; C) A concerted international response and D) Each particular circumstance of import restriction shall be consistent with the general interests of the international community in the legitimate interchange of  cultural property.

The Executive Branch of the U.S. Government, including the Department of State, supported these goals during the lengthy and serious Congressional deliberation that led to enactment of CCPIA.  The Cultural Property Advisory Committee followed the specific provisions of this law with commendable fidelity for more than two decades.  Then, in 2007, the atmosphere of CCPIA governance changed—even though the law did not.  Arguments presented to CPAC on the basis of law and evidence have subsequently been ignored or trumped within the debate by ideological and philosophical arguments.  The five-year sunset provision of CCPIA has been totally ignored, with every request and renewal becoming in essence a foregone conclusion and a permanent action.  ACCG concern over this evolution has been shared by the public, the media, professors of law, institutions, associations and even by members of Congress.  Aside from the philosophical debate, there are very real and immediate impacts.

An argument is often made by supporters of import restrictions that any object lacking provenance, or proof of export from its country of origin prior to the effective date of those restrictions, must be considered illicit.  This attitude presupposes a condition, illegitimacy, that has no basis in fact nor in law—yet it is precisely the attitude that prevails within some elements of bureaucracy.  In fact, there have been several recent cases where Customs agents detained legally imported ancient coins for as much as a year or more without any explanation or due process and then released them without any justification whatever for the detention.  While records of ownership (provenance) may perchance exist for some objects of antiquity residing in famous collections, they do not exist for the vast majority of utilitarian objects like coins, household pottery, tools, etc.   Myriad objects of this nature, found and traded internationally over the past 600 or more years by private collectors, routinely change hands every day without any historical documentation aside from a current bill of sale.  It is irrational and a travesty to presuppose that all of these objects are illicit and it is equally irrational to demand proof of the negative when no such proof can possibly exist.  Are the retentionist views of a few ideologues, who publicly denounce and vilify private collecting, paramount to the very foundation of our legal system—the burden of proof?

The ACCG has repeatedly affirmed its support of CCPIA, petitioning CPAC and the Department of State to follow the law as it was written and enacted.  We are approaching a decade of deviation from that mandate.  Once again, we respectfully submit this petition to the Committee and to those who frame the ultimate response to Italy's request.   In your deliberations, you must consider the fact that ancient Roman and each of the other Italian coins on the current designated list are openly collected by the public within Italy and traded by an extensive network of Italian dealers both in the form of public auctions and "brick and mortar" stores.  These coins are legally exported to other EU countries, where they in turn are legally exportable either with or without export permits as local law dictates.   A concerted international response to the claimed threat does not exist.  There is considerable doubt that the "threat" has ever existed insofar as coins are concerned.  In any case, American coin collectors are bearing an unfair and unrealistic burden that coin collectors in virtually every other country on Earth do not share.  The MOU with Italy should be allowed to lapse or, at the very least, coins should be removed from the designated list of items subject to import restrictions.

 

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