Thank you for listening today to Global Heritage Alliance’s
concerns about the MOU with Italy. I am
also happy to answer questions about the GHA’s and IAPN’s papers on both Italy
and Colombia, which I authored.
Current
events, including mobs tearing down historic statues and Erdogans’s conversion
of Hagia Sophia from a museum to a mosque, as well as the reaction of
archaeological advocacy groups and some of their prominent members, raise the
fair question whether lobbying on behalf of foreign governments directed at
suppressing market demand is really about conservation, or about exercises of
power and control.
That in turn
suggests that it is time for this Committee to consider a new paradigm, one
which focuses not on suppressing all trade of every conceivable artifact with
embargoes, but which instead facilitates lawful trade in objects, especially
those legally available for sale within the country seeking restrictions.
There is no
better place to start than this renewal. Legal trade in cultural goods of Italian types
has already been embargoed for 20 years.
During this period, Italy’s Carabinieri have mounted a successful
campaign against looters. However, largely
due to the sheer number of historic sites, lack of funding and corruption, the Italian
State has failed to preserve all the cultural heritage already in its care. As set forth in the IAPN’s study, this is
particularly true for small, commonplace items like coins.
What does
GHA request? First, we join hundreds of
coin collectors to ask that under no circumstances should the designated list
be expanded, particularly to late Roman Republican and Imperial coins. As set forth in IAPN’s papers, only 2.8% of
Roman Imperial coin hoards containing coins from Italian mints are found
within Italy itself making it impossible to fairly consider them Italian
cultural patrimony. We also believe that
the CPIA mandates that the current Italian designated list needs to be reformed
to ensure it only covers items only found in Italy. For coins, this means—using the Greek
designated list as a model—that at least larger denomination coins which
circulated in international trade should be delisted.
We also request
that any renewal be conditioned on Italy immediately facilitating the licit
export of any item legally available for sale within Italy itself. Despite solemn promises to do so under each
of the prior MOU’s, Italy has actually made it harder to export ancient coins
of the sort openly and legally sold within Italy itself.
Finally, this Committee should also facilitate lawful trade by requiring US Customs to accept legal exports from sister EU countries as legal imports of items on the Italian designated list into the United States. As set forth in our papers, such a modification of the MOU is not only consistent with the UNESCO Convention, but Italian law. Thank you.
Finally, this Committee should also facilitate lawful trade by requiring US Customs to accept legal exports from sister EU countries as legal imports of items on the Italian designated list into the United States. As set forth in our papers, such a modification of the MOU is not only consistent with the UNESCO Convention, but Italian law. Thank you.
Thanks for speaking on behalf of collectors.
ReplyDeleteShould I expect all comments to eventually be visible at https://www.regulations.gov/docket?D=DOS-2020-0022 ?
The right sidebar says 500 comments received. Yet “View more docket details” says 403 comments received. The 403 visible comments can be seen at https://www.regulations.gov/docketBrowser?rpp=50&so=DESC&sb=commentDueDate&po=0&dct=PS&D=DOS-2020-0022
I entered my comment on 7/4. It “posted” on 7/10.
None of the 403 comments were “posted” after 7/10, even though comments were allowed after that period, and several folks on CoinTalk claim to have successfully submitted comments on the last day, 7/14.