In what has become a holiday “tradition,” the State Department has provided advance notice of an upcoming Cultural Property Advisory Committee meeting on Feb. 4-6, 2025.
https://eca.state.gov/highlight/cultural-property-advisory-committee-meeting-february-4-6-2025
Hopefully, the renewal of the MOU with Italy will not be used to expand the current designated list to additional coin issues, particularly those of the late Republic and Roman Empire. The current MOU with Italy does not include Roman Republican coins post 211 BC or or any Roman Imperial coins, but recently the State Department imposed restrictions on such coins on behalf of Afghanistan, Pakistan, and Ukraine, despite the lack of evidence many are found there.
The numbers of such coins found in Italy are also relatively small compared to those found elsewhere. Additionally, there is a huge legal internal market in Italy itself which undercuts any claim that import restrictions will lessen demand for "looted" material.
The real issue of course is that US Customs takes the position that the mere placement of coin types on the designated list is sufficient for Customs to "assume' they were illicitly exported from a particular country absent specific evidence to the contrary. Of course, such an assumption has no factual basis behind it, but to date courts have been unwilling to question State Department and Customs discretion in this area.
Moreover, coin collectors and the general art trade should be concerned about another recent trend, imposing restrictions on everything and anything identifiable as being produced or used by a given culture down to 1774 for “archaeological objects” and even more recently for “ethnological objects” which have included paintings, most recently for Ukraine. See https://www.federalregister.gov/documents/2024/09/10/2024-20385/emergency-import-restrictions-imposed-on-categories-of-archaeological-and-ethnological-material-of
Here are the relevant dates:
January 27, 2025- All written comments and requests to speak due.
February 4, 2025 @ 1 PM- Public meeting.