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<p>[QUOTE=&quot;Andrew McCabe, post: 4673432, member: 90666&quot;]Arturo Russo&#039;s testimony was excellent and deserves being reproduced here in full:</p><p><br /></p><p><b>Arturo Russo (International Association of Professional Numismatists</b>) speaks for the premier professional trade association for coin dealers.&nbsp; He starts his statement with a Latin maxim, “pacta sunt servanda” which roughly translates as “bargains are to be observed.”</p><p><br /></p><p>He notes that after the initial MOU with Italy in 2001, Italy did as promised make it easier to export Italian cultural goods, including coins.&nbsp; However, since import restrictions were first imposed on coins in 2011, it has become increasingly difficult to obtain export permits, and today it is almost impossible to get such permits for even low value and common ancient coins.</p><p><br /></p><p>Last year, Italian authorities published regulations that state that you cannot even apply for an export license unless you can prove that an archeological object is outside of the ground before 1909, the date of Italy’s first cultural patrimony law.&nbsp; Italy has over twenty different export offices and luckily some of them don’t enforce this regulation, as quite rightly, they do not consider coins in trade to be archeological items. On the other hand, other offices, like that in Milan, apply this regulation in a very stringent manner, and require proof of provenance before 1909.&nbsp; This makes it impossible to export ancient coins, because only few coins have a provenance stretching back that far.&nbsp; Just to be clear, ancient coins are freely bought and sold inside Italy, but they become “illegal” and important to Italian cultural patrimony only when one applies to take them outside of Italy, which is unacceptable. </p><p><br /></p><p>The situation is so egregious that there have been cases where coins that were legally purchased by Italian collectors in US auctions prior to 1980 where not only denied an export license, but were confiscated simply on the basis of lack of provenance prior to 1909. It is worth noting that coins have been collected since the Renaissance. There are studies from prominent Italian scholars, which Mr. Russo would be happy to share, which demonstrate that coins in the market should not be treated as archaeological objects because an immense number of coins were found before 1909. Nevertheless, most of the coins do not have a documented provenance because until the recently auctions were limited to coins from highly important collections. Mr. Russo notes that in 1994 the two most prominent numismatists in Italy, Silvana Balbi De Caro and Francesco Panvini Rosati, stated that only coins documented to be from an archaeological find are of archaeological interest. </p><p><br /></p><p>In 2012, Mr. Russo’s firm, Numismatica Ars Classica, represented a group of investors that purchased and dispersed the Archer Huntington collection of coins.&nbsp; This large collection was assembled between the end of 19th century and 1930. The collection was property of the Hispanic Society of America and on loan to the American Numismatic Society. The vast majority of the Ancient coins in the collection did not have a documented provenance prior to 1909 and theoretically if purchased by an Italian collector, would be subject to detention and seizure if they were subsequently exported from Italy. </p><p><br /></p><p>This behaviour is clearly unacceptable.&nbsp; So, Mr. Russo asks that CPAC freeze the renewal of import restrictions on coins until Italy complies with its obligation to facilitate the issuance of export licenses. The current situation clearly disadvantages American collectors and institutions as coins legally owned in the States can be freely sold to Italian buyers while the same coins cannot leave Italy and be freely sold to American collectors. </p><p><br /></p><p>What makes the whole situation even more inconceivable is the fact that Italy has probably one of the largest if not the largest numismatic patrimony in the world. There are over 200 institutions that have coins and the largest museums like Naples, Rome and Turin have collections which contain over a million specimens each. Unfortunately, most of these collections are not published nor accessible through the internet with the result that they are almost completely inaccessible to the public.</p><p><br /></p><p>Mr. Russo indicates that the Italian Carabinieri do an excellent job fighting looters and he knows as a matter of fact that they do not share the belief that everything without a provenance prior to 1909 has to be considered illegal. They are fully aware that a legal and healthy market exists and must be preserved. IAPN is not against a stronger cooperation between Italian authorities and US to fight illegally excavated coins coming onto the US market, but blanket restrictions are unfair to the trade. </p><p><br /></p><p>In concluding, Mr. Russo also indicates that any effort to extend restrictions to Roman Republican and Imperial coins is simply ridiculous as it uncontested that the vast majority of these coins are found outside the boundaries of Italy.&nbsp; In closing, he reiterates that current restrictions should be frozen until Italy makes it easier to procure export licenses.[/QUOTE]</p><p><br /></p>

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