They've Got it Backwards

Arturo Russo, a principal of Numismatica Ars Classica NAC AG, a numismatic firm and auctioneer with offices in Milan, Zurich and London, knows first hand about the frustrations of dealing with the Italian cultural bureaucracy.  As he states in his comments to CPAC:

As a quid pro quo for all prior MOUs, Italy promised to facilitate the issuance of export certificates for archaeological objects artifacts legitimately sold within Italy itself. 2001 MOU, Art. II, F; 2006 Extension, Art. II, F; 2011 Extension, Art. II, G.

This has not happened. In fact, since coins were added to the designated list for import restrictions in 2011, the Italian cultural bureaucracy has made it almost impossible for me to export coins from the country.

I used to be able to secure export licenses for collections of ancient coins so they could be sold at auction abroad. After restrictions were placed on Greek coins from Italy and Sicily, Etruscan coins from Italy, Early Roman Republican coins, and early Imperial Colonial and Provincial coins to 37 AD, I was told this would no longer be possible. When I enquired why, I was told that if such export licenses were granted, the Americans would not think that the Italian cultural bureaucracy was serious about protecting its cultural patrimony. It is important to state that these denials have been issued for coins with a legitimate provenance.

This is entirely backwards. The MOU purports to require Italy to make such objects legitimately sold within Italy available for legal export abroad, but instead the MOU is being used to justify precluding legal export of even common coins sold within Italy itself. Furthermore, Italian authorities deny export licenses even for very common coin types based on the argument that even a small variety is a good reason to decline an application. Please note that they also deny export licenses for coins of non-Italian origin with the premise that they would be difficult to acquire for Italian Institutions.

Another major problem is that most of the staff is not qualified to cast informed judgment on the rarity or importance of a coin, in fact they are archeologists and not numismatists. I must admit on several occasions I found myself informing them of the existence of the proper reference works required to establish the rarity of a coin type or even worse I had to draw their attention to the fact that several coins of that type were already in Italian Museums.

Unfortunately, since 2012 the attitude of the Italian officials towards export licenses for coins have changed dramatically. Italian collectors are still important buyers in auctions abroad, but in the eyes of Italian authorities every single coin of average rarity should remain on Italian soil. I find this position unfair and unreasonable especially considering that Italy has a gigantic numismatic heritage which is not published and more importantly very difficult to access for scholars and collectors.

In my experience, almost all European countries take a reasonable position by granting export licenses for most of the coins excluding only the exceedingly rare coin types.

More reason, if any were needed, to free the coins from foolish import restrictions or at least give them a "pass" and require US Customs to accept EU export permits or evidence no export permit is required for imports of "coins of Italian types" from the EU.  After all, Italy, as part of the EU, is also bound not only by the MOU, but EU law.