I just received my wins from the recent Gorny auction, and the attached import papers caught my eye. Maybe nothing new, since I don't always pay much attention to the papers. The coins I bought were LRBs, and the import papers said that Gorny certifies they are: 1) Eiither not "Italian or Greek Coins" (in scare quotes) as defined under 19 U.S.C. 2606, OR 2) Exported from Italy before Jan 2011 if they are "Italian or Greek coins" and therefore in either case exempt from the import restrictions of 19 U.S.C. 2606, and may be freely imported into the USA. I'm curious if anyone knows anything more about this: 1) What exactly is the definition of "Italian or Greek coins" 2) Is there a blanket ban on USA import of "Italian or Greek" coins exported from Italy after 2011, or just some more stringent limitations that apply ?
The designated list of what is deemed to be "Coins of Italian Types" can be found here:- https://eca.state.gov/files/bureau/it2011dlfrn.pdf This is the latest version of the designate list on the Bureau of Educational and Cultural Affairs website. This list relates to the MOU between the USA and Italy wrt cultural export restrictions. It is this list that is then called up by "import restrictions of 19 U.S.C. 2606". That's my understanding....
Thanks, guys. So if I'm understanding this correctly it only covers Roman imperial coins issued from Italian territories, and issued not later than 37 AD.
It looks to me like 19 USC 2606 covers the full range of memoranda of understanding and emergency restrictions that are in place under the 1970 UNESCO Convention. I'm not a lawyer but I get the feeling that the disclaimer is largely mumbo-jumbo. Perhaps someone among us who actually practices law will chime in.
Let's not be pejorative here! It's not mumbo-jumbo; it's just a shorthand description of the trail of definitions one has to follow in order to find out what it means. Thus, "Italian or Greek coins" doesn't mean all Italian or Greek coins; it means Italian or Greek coins as defined by the applicable regulations. In all seriousness, Nomos did a much better job of explaining the meaning in the "Certificate of Antique Declaration" accompanying the coins I bought in the Nomos Obolos Auction 22 last month. Thus, the Certificate states that because one of my coins was made in present-day Lebanon and the other in present-day Italy in 161-180 AD, they didn't fall within the applicable regulations defining coins of Greek, Italian, or Turkish origins covered by import restrictions, and, therefore, are excluded from those restrictions. (See the second and third columns on page 2 at the link provided by @maridvnvm). The final three paragraphs of the Certificate summarize the relevant restrictions on "Greek," "Italian," and "Turkish" coins much more succinctly than the regulations themselves: Thus, for Roman coins, as long as they were outside of Italy before Jan 19, 2011 OR were struck after 211 BC, it's OK to import them. I would assume that your coins from Gorny must be excluded from the import restrictions for similar reasons. Gorny simply failed to provide an explanation.
Thanks. That certificate from nomos is definitely clearer in referring to the actual regulation, which is indeed the one @maridvnvm linked. Here's the relevant excerpt. The two, 211 BC and 37 AD dates refer to different categories of coinage.
Pardon my neophyte question, but does this mean that I, living in the United states, cannot purchase a Roman coin directly from an Italian merchant in the present time?
Well, IANAL, but I assume it's OK as long as the coin meets the appropriate cutoff issue date, but you could potentially have problems if the seller didn't include shipping papers certifying that the coins did meet this criteria. For earlier coins, I don't know ... what if a coin not meeting the issue date criteria had been previously exported from Italy prior to 2011, but was now back in Italy ... ?
The way I read the regulation, such a coin (even if it were, hypothetically, a pre-211 BC Roman coin) was quite literally "outside of Italy" prior to 2011, so it shouldn't really matter whether it's back in Italy now or when it was struck. How U.S. Customs would act in the situation, I have no idea. And, of course, people should keep in mind that if they are buying from an Italian dealer, then long before the coin reaches the point of U.S. Customs and U.S. law is considered, the coin has to get an export permit from Italy, applying Italian law and regulations -- which are, apparently, notoriously difficult to satisfy as a practical matter, regardless of whether the letter of the Italian law might support the granting of an export permit. Which is why I've never even attempted to buy an ancient coin from a dealer in Italy.
I've never purchased an ancient coin from a dealer based in Italy. I have purchased more "modern" coins from the 17'th century and maybe a lion daalder or two, as well as some cobs, but those coins are outside the jurisdiction of the statute covering ancients. I remember, at the flea market in Rome, 1969, we purchased a couple of Roman Republic cast coins that were clearly not genuine, even to a 16-year-old. I remember my dad asking the seller if they were original, in kind of fake Italian accent. I was so embarrassed! In 2017 I notice that there's coin shop near the bus station in Rome. I was interested in visiting it, but other factors got in the way - brutally hot temperatures (El Diablo that year, scorched much of Europe), I was getting sick (the Roman cold I took back to the US), and there just wasn't enough time (rushing around with this family seeing as many sites as possible in one day - exhausting!).
