The Cultural Property Advisory Committee meets in July. You have a chance to submit comments to the Committee via regulations.gov. The deadline for comments is July 8. Further information about the July 22, 2020 Cultural Property Advisory Committee (CPAC) meeting and how to comment before the July 8, 2020 deadline can be found here: https://www.federalregister.gov/doc...property-advisory-committee-notice-of-meeting The Federal Register notice also has a green "submit a formal comment button" which should allow you to comment directly. The cumulative impact of import restrictions has been very problematical for collectors since outside of some valuable Greek coins, most coins simply lack the document trail necessary for legal import under the “safe harbor” provisions of 19 U.S.C. § 2606. The CPIA only authorizes the government to impose import restrictions on coins and other artifacts first discovered within and subject to the export control of Italy. (19 U.S.C. § 2601). Furthermore, seizure is only appropriate for items on the designated list exported from the State Party after the effective date of regulations. (19 U.S.C. § 2606). Unfortunately, the State Department and Customs view this authority far more broadly. In particular, designated lists have been prepared based on where coins are made and sometimes found, not where they are actually found and hence are subject to export control. Furthermore, restrictions are not applied prospectively solely to illegal exports made after the effective date of regulations, but rather are enforced against any import into the U.S. made after the effective date of regulations, i.e., an embargo, not targeted, prospective import restrictions. While it is true enforcement has been spotty, CPO knows of situations where coins have been detained, seized and repatriated where the importer cannot produce information to prove his or her coins were outside of a country for which import restrictions were granted before the date of restrictions. B. What You Can Do Admittedly, CPAC seems to be little more than a rubber stamp. Still, to remain silent is to give the cultural bureaucrats and archaeologists with an ax to grind against collectors exactly what they want-- the claim that any restrictions will not be controversial. For comments, either comment through the Federal Register notice above or use http://www.regulations.gov, enter the docket [DOS-2020-0022] and follow the prompts to submit your comments. Alternatively, click this link and click on the Blue “Comment Now” Button which should pull up a screen that allows you to comment https://www.regulations.gov/document?D=DOS_FRDOC_0001-5233 (Please note comments may be posted only UNTIL July 8, 2020 at 11:59 PM.) Please also note comments submitted in electronic form are not private. They will be posted on http://www.regulations.gov. Because the comments cannot be edited to remove any identifying or contact information, the Department of State cautions against including any information in an electronic submission that one does not want publicly disclosed (including trade secrets and commercial or financial information that is privileged or confidential pursuant to 19 U.S.C. 2605(i)(1)). C. What Should You Say? What should you say? Provide a brief, polite explanation about why the renewal should be denied or limited. Question CPAC why it’s necessary to renew this MOU yet again when looting is under control and the real jeopardy to Italy’s cultural patrimony comes from poor stewardship by the Italian State. Indicate how restrictions will negatively impact your business and/or the cultural understanding and people to people contacts collecting provides. Coin collectors should add that it’s typically impossible to assume a particular coin (especially Roman ones) was “first discovered within” and “subject to the export control” of Italy. In fact, by far most Roman Imperial coins are found not in Italy, but on the Empire’s frontiers. You might add that Italian historical coins are very common and widely and legally available for sale elsewhere, and point out the absurdity of restricting coins freely available in Italy itself. Finally, you don’t have to be an American citizen to comment—you just need to be concerned enough to spend twenty or so minutes to express your views on-line. Comments from Italian collectors are particularly welcome!