Back to Reality

Now that we've seen some of the misinformation and scare tactics used by coin collectors and dealers in regard to the Italian MOU, I thought it would be a good time to bring some reality back to the discussion.

First of all, as I said in my earlier post, nothing is being banned, as people would like you to believe. What would be required by the CPIA if this MOU is extended is EITHER an export permit OR proof that the item was exported from Italy prior to the date the restriction goes into effect. In the event that coins are added to the list of items, they would only have to be shown to be out of Italy before the date that restriction goes into effect, and that hasn't even happened yet.

So in the absence of an export permit, what would constitute proof that an item is out of Italy before the date of restriction? Not much really. Here are the requirements copied from this website: http://eca.state.gov/icpp/97-446.html

(c) DEFINITION OF SATISFACTORY EVIDENCE.-The term "satisfactory evidence" means-
(1) for purposes of subsection (b)(2)(A)-
(A) one or more declarations under oath by the importer, or the person for whose account the material is imported, stating that, to the best of his knowledge-
(i) the material was exported from the State Party not less than ten years before the date of entry into the United States, and
(ii) neither such importer or person (or any related person contracted for or acquired an interest, directly or indirectly, in such material more than one year before the date of entry of the material; and
(B) a statement provided by the consignor, or person who sold the material to the importer, which states the date, or, if not known, his belief, that the material was exported from the State Party notless than ten years before the date of entry into the United States,and the reasons on which the statement is based; and
(2) for purposes of subsection (b)(2)(B)-
(A) one or more declarations under oath by the importer or the person for whose account the material is to be imported, stating that, to the best of his knowledge, the material was exported from the State Party on or before the date such material was designated under section 305, and
(B) a statement by the consignor or person who sold the material to the importer which states the date, or if not known, his belief, that the material was exported from the State Party on or before the date such material was designated under section 305, and the reasons on which the statement is based.

So what it says is you need is a sworn statement by either the importer or the exporter that the coins were out of Italy prior to the date of restriction, and why they believe that to be true. Boy, sounds darn near impossible, right?

Foreign countries ask the US to enter into a cultural property MOU in an attempt to protect their cultural heritage from the damage done by illegal digging. This is without a doubt fueled by "don't ask-don't tell" collecting. It's not some sinister plot to keep coins out of American collectors' hands. When the US agrees to enter these MOUs we are simply saying "We will do our part to help you protect your cultural heritage by not allowing items that can't be shown to be legally acquired to enter our borders." I don't see anything wrong with that, and it certainly won't mean "the end of collecting if it gets through". There are many MOUs with other countries currently in effect, yet collecting still continues. That will still be the case if the Italian MOU is extended, even if it's amended to include ancient coins.