So it's absolutely illegal to import ancient Roman coins into USA?

Hi everyone,

I see that back in March 2015, there was a thread discussing the possible renewal of a memorandum of understanding between the USA and Italy. I don't see if it ever was.

The other day I made an on line purchase of some uncleaned ancient Roman coins. They are in Europe. After reading that 2015 CT thread and the attorney blog link in that thread, I came here to ask whether it is legal or not to import Roman ancient coins into the USA.

If it is not, I want to cancel the transaction as soon as possible so he can relist. I don't want to hold him up if he can make a legal sale to someone else.

Thanks for any feedback you can give.

 

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It might say so on paper, but it is not enforced. I have imported hundreds of ancient Chinese coins, and they got past Customs despite import restrictions.

 

Clearly, it's not illegal to import ancient Roman coins into the U.S. Many collectors on this site (including me) have bought coins from dealers or at auctions outside the U.S. and received those coins within the last two years.

There may be restrictions applying to specific countries, or certain types of coins, etc., that make it difficult to import coins into the U.S. The seller/exporter should know about such restrictions, and I would start by contacting the seller and asking him/her to clarify any shipping issues you may encounter.

 

I'm not sure. But the outlet (UK) I was using for uncleaned coins recently shuttered, their website saying "Due to EU restrictions, we no longer will be able to sell coins ethically, and since we won't do business unethically, we will no longer be in the trade".

I googled some terms related to EU restrictions on ancient coin sales and found nothing definitive, so I am as confused as you are.

 

it's not illegal.

 

Thank you.
Gee whiz.
I will go ahead with the transaction and if anything interesting happens with US Customs, i'll let you know and we will learn something.
Thank you for your prompt responses!

 

It's not 'absolutely illegal to import ancient coins'. But as I understand, US customs has a LOT of latitude to seize more or less anything without a very clear provenance. My lay reading is that if they say it could have come from Cyprus or Bulgaria, which are specifically restricted, then it becomes YOUR responsibility to prove it's from elsewhere. I don't think they're out to get you, and it seems actual siezures are rare, but there is a theoretical risk. That's from my very lay reading of the situation - I'd be interested if anyone has better information.

 

@LaCointessa , the Memorandum of Understanding was renewed and was not expanded from previous MoUs. The MoU imposes import restrictions on coins of Italy minted before the introduction of the denarius (ca. 211BC). You can still import these early Roman Coins, but you risk seizure by ICE unless you have either a provenance that the coin was outside Italy before January 2011 (the date of the MoU) or evidence that the coin has been outside Italy for at least 10 years. The MoU only impacts Roman Republican Coins before 211BC. Roman Imperial coins are not impacted. However, there are other MoUs that impact Roman Provincial Coins of the Imperial era (notably Greece and Bulgaria). I hope that helps.

 

I came across this and will be reading on it.
http://www.forumancientcoins.com/Certification For Legal Importation.pdf

 

Thank you everyone. Yes, that helps. And it's ANOTHER interesting topic for study.

 

time to join or send a donation to ACCG. i don't think you'd have anything to worry about on those right now. it's my understanding that the USA requires ok'd paperwork on some stuff from certain countries regarding national treasures sold after a certain date. and i've had a friend in Turkey that was out digging up all kinds of Roman and Byzantine coins and showing us, but could not sell or send them out of the country. he even asked me to come to where he was to purchase them, but if he couldn't mail them out, i figured i didn't want to end up in a Turkish prison

 

The MOU with Italy covers pre-denarius Roman Republic coins(early cast issues, Romano-Campanian, etc.) as well as certain types from Magna Graecia and early Italian colonial issues up to a certain point. You can read the full list online, but that largely covers the types that are restricted.

So what do these restrictions entail, you might ask? Borrowing from CNG's page on import restrictions "The above restricted coins of Italian types can only be imported into the United States with an export certificate issued by the Republic of Italy or “satisfactory evidence” demonstrating that the coins were exported from or were outside of Italy at least 10 years prior to importation into the US or that the Coins were exported from or were outside of Italy before January 19, 2011. What constitutes “satisfactory evidence” is ultimately left to the discretion of Customs, but usually takes the form of a declaration by the importer and a statement by the consigner."

There are similar agreements with Greece and others, so this doesn't just affect Italian coins, but all the agreements are fairly similar. My recommendation, if you're worried about import restrictions, is to read the information on the page linked above, decide if the coin(s) you're interested in fall under the restrictions and then contact the seller and ask about getting a declaration meeting the criteria above written up. If the seller cannot provide one and you believe that the coins fall under the restrictions, then keep in mind that they are subject to seizure at the border. I don't know what the process is for contesting that seizure as I've never had it happen, though I've only imported a handful of coins that fall under these MOUs and in those cases I always had supporting evidence available but as far as I know it was never actually included in the coin package itself.

If you're worried about this or feel like any of it is unclear, I recommend speaking to a lawyer(which I am not). What I've posted above is my interpretation and understanding of these somewhat ambiguous laws and may or may not be correct.

 

@red_spork -- I was going to post that CNG link in this thread but couldn't find it on their site. Did you have the page bookmarked? I guess the page is still there but is unlisted (no visible link), or else I somehow overlooked it???

Maybe they removed it from the list because the page hasn't been updated in three years and may no longer be accurate?

 

..send us a postcard..

 

Yes, I noticed Chinese customs is pretty shill. I accidentally imported illegal Chinese coins into the US without any issues. Next time though I'll make sure it is a HK dealers and not someone on the mainland.

 

Ancient Chinese coins are easy to import because they were made last week. The MOS only covers actual coins.

 

I couldn't find it on their site either but I searched "site:cngcoins.com import restrictions" on Google and it came up. I think you may be right, as it isn't completely up to date(i.e. no mention of the Egypt MOU).

 

Many of us have accidentally bought Chinese items illegally, though not with any awareness. A couple times I bought from two people who said they were in Hong Kong (where it is legal to ship) but the post mark was from Shanghai. Both times they breezed through customs, primarily because I think nobody cares.

Back when the Three Rivers Dam project was ramping up there was a huge amount of essentially state ignored looting. Everyone knew millions of artifacts would be flooded and made inaccessible to humanity, so everyone turned a blind eye to what was going on as the government had no ability to preserve much of anything. To my knowledge most of it was funneled through Hong Kong, so in essence it was 'made legal'. Kind of like how Irsraeli dealers use their paperwork to keep selling essentially all they want, with a legal paper trail (though my understanding is that this or last year they closed the loopholes).

 

@gregarious is right, "time to join or send a donation to ACCG". The guild supports ancient coin collectors. You can read more about them here -
http://www.accg.us/home.aspx

 

From the item description, item and seller location, representation that he found the items and owns them, types of items, I think that they probably fall outside the importation restrictions on Italian ancient coins. The only thing about which I could not be assured because the coins are crusty is that the coins are younger than 211BC. Also, how can one be sure that the coins were outside Italy for more than 10 years? Seller invites me to contact him if there are any customs issues.

(I am now a supporter of ACCG)

Thanks everyone.