The ANA has shared the following letter with CPAC, seeking to ease unnecessary regulatory burdens for coin collectors —
Dear Mr. Passantino and Cultural Property Advisory Committee Members:
I am writing on behalf of the American Numismatic Association (“ANA”) concerning the Cultural Property Advisory Committee’s (“CPAC’s”) review of the renewal of the Memorandum of Understanding (“MOU”) with the Republic of Italy (“Italy”). This MOU has been in place for 20 years – the extension will make it 25. Enough is enough. Any benefit import restrictions have provided to deter looting are far outweighed by the damage they do to lawful collecting, and the people to people contacts and appreciation of Italian culture it fosters.
Protecting a nation’s cultural history is serious business and should be of major interest to all scholars of history and culture. However, with respect to Cultural Property, coins are unusual in that they are produced in massive amounts and are relatively durable, making the vast majority of coins quite common. They should not be treated in the same way as other historical artifacts which are much less durable and often quite rare or even unique. It is not practical or helpful to the understanding our past to sequester vast quantities of duplicate coins in museum vaults, especially when, by their availability in the market, they will engender more interest in history and, in the end help to keep museums open as the same educated public visits those museums to see truly rare and historically or culturally significant pieces. Please do not restrict Americans from access to these coins, which are part of our own cultural history as well! I present the following arguments in support of allowing Roman Republican and Roman Imperial coins of Italian origin to continue circulating into the United States without impractical and unnecessary import restrictions.
Numismatic objects are absolutely part of a nation’s or a civilization’s cultural and artistic history. However, unlike most other such objects, they were replicated in a process designed to create many thousands or even millions of nearly identical copies. These objects were then distributed through trade and conquest through a large area often well beyond the boundaries of the state or culture that issued them. The Roman Republic and the Roman Empire both extended well beyond the borders of Italy or any other of the modern states that were under Roman control and that were produced Roman Republican or Imperial coins in antiquity. Assuming that Roman coins, either of the Republican or Imperial eras, automatically originated in Italy is a mistake and requiring customs officials to differentiate between coins struck in Italy versus those struck in other parts of the Empire is not a reasonable expectation.
The problem is compounded for issues from Roman Imperial mints operating in Italy. These coins were never intended to circulate only within the confines of modern-day Italy. Research on coins hoards shows that the vast majority of the Roman coins struck at Italian mints are actually discovered outside of Italy. This makes any restrictions imposed upon them solely based on where they were made or found in complete contradiction to the CPIA’s statutory intent.
Roman culture is the foundation of our own and has left its physical remains throughout much of Europe, the Middle East and North Africa – and its intellectual, literary and artistic legacy is found throughout the western world and beyond. Thus, these import restrictions are an unjust and ill-founded restriction on the right of American citizens to access and experience their own cultural heritage first-hand.
The restriction of importation will result in a loss of interest in such items by collectors as the supply of Italian coins dries up. This will destroy the historically close relationship of advanced collectors and museums. Americans have been collecting Roman coins since the before the foundation of the United States. Institutions such as the American Numismatic Society, the Smithsonian Institution and the American Numismatic Association, which all have major collections of Roman coins mostly created from donations by private collectors, will have difficulty in obtaining additional collections.
Worse, these restrictions are likely to result in a drastic reduction in American numismatic scholarship – most of which, in the U.S. at least, has been the result of the fruitful interaction of advanced private collectors and museum curators. These collectors often subsequently donate their collections. Without access to the material, these collectors will never develop, leaving the numismatic community impoverished.
This will affect my museum's ability to obtain such coins for our collection and for educational programming, particularly through our exhibits and the various classes on ancient and medieval numismatic history that we offer. Not only will it restrict our educational mission, but it will also affect future donations to our museum as the American collector market is starved of these coins, depriving many Americans of any possibility of indulging in their interest in the material and artistic history of Italy. This could eventually lessen already pitifully low American knowledge of Italian and European history and culture.
In conclusion, CPAC should advocate dropping current restrictions on Greek, early
Republican and early Imperial era provincial coins struck in Italy which were imposed without CPAC’s knowledge or consent. At a minimum, all coins which circulated in quantity outside modern Italy should be de-listed. In addition, under no circumstances should this renewal be used as an excuse to impose new import restrictions on late Roman Republican and Roman Imperial coins. These coins were indisputably used throughout Europe, North Africa, the Middle East and beyond. They have been actively and legally collected since at least the Renaissance. They “belong” not to Italy, but to us all as the inheritors of their cultural legacy.
Sincerely,
Doug Mudd
Curator and Director, Money Museum
American Numismatic Association
