Here is what I said, more or less, at today's CPAC meeting to consider a renewal of the current MOU with Italy:
The MOU with Italy has been in place for 15 years. Another 5 will make that 20. It’s long past time to consider whether any benefits from associated import restrictions outweigh the costs to cultural exchange, collectors and the small businesses of the numismatic trade. Certainly, at a minimum CPAC should carefully consider the concerns of the 94% of the public comments either opposed to this renewal or import restrictions on coins.
The State Department spends over ½ billion in taxpayer dollars each year on cultural exchange. It should also be encouraging ancient coin collecting, which, as Italian-American collector Karen Antonelli has noted in her written statement, promotes understanding of ancient Italian cultures and fosters people to people contacts at zero cost to the US taxpayer.
Instead, State is harming our longstanding hobby with import restrictions that make it quite difficult to import coins legally from abroad. Make no mistake. The 2011 decision to impose import restrictions on “coins of Italian types” was not made with CPAC’s knowledge or consent, and, indeed, CPAC member Robert Korver resigned on account of it. In fact, coins were previously exempted from restrictions twice and there was no material change in the conditions on the ground in Italy to justify a change in this precedent.
CPAC should rethink current import restrictions and under no circumstances should restrictions be expanded to include late Roman Republican and Roman Imperial coins. These later coins circulated throughout Europe, the Middle East and Asia and have been actively collected world-wide since the Renaissance. They belong not to Italy, but to the World.
If anything, there is even less reason to continue import restrictions today. By most accounts, looting in Italy has diminished. At the same time, due to severe budget cuts, the Italian State can no longer properly care for major sites like Pompeii, let alone for the unknown number of coins stored in its museums. Given budgetary realities, private collectors, not the Italian State, are the best stewards for common artifacts like coins.
Certainly, coins identical to those already on the Italian designated list are openly and legally sold within Italy. They can travel freely back and forth between European collectors. And they can be legally exported from E.U. member states either with or without export certificates, depending on local law.
Prior MOUs sought to facilitate such lawful trade in ancient coins. In each, Italy pledged to consider ways to make it easier to secure export certificates for archaeological objects legitimately sold within Italy itself. Unfortunately, nothing has been done to keep this promise. Instead, according to IAPN member Arturo Russo, Italian cultural officials have actually cited the 2011 MOU back to him as a reason to withhold export permits. He was actually told if they were granted, “The Americans” would not think Italy was serious about protecting its own cultural patrimony! This, of course, is entirely contrary to the MOU’s expressed intent. Given this failure, CPAC should recommend that Article II the MOU be modified so that U.S. Customs accepts proof of lawful export from any E.U. member state to help facilitate the legal import of coins “of Italian types” also legitimately for sale within Italy. Such a recommendation honors the current MOUs’ intent to facilitate lawful trade and is consistent with E.U. law, which, of course, binds Italy as well. Thank you.
 2001 MOU, Art. II, F; 2006 Extension, Art. II, F; 2011 Extension, Art. II, G.