Log in or Sign up
Coin Talk
Home
Forums
>
Coin Forums
>
Ancient Coins
>
Renewal of restrictions on coins from Italy - CPAC Meeting
>
Reply to Thread
Message:
<p>[QUOTE="7Triones, post: 4591127, member: 112344"]Back in 2010, Italy the State Department to restrict importation of ancient coins from Italy. It's time to renew the agreement with Italy. It's time to make your opinions heard. The last agreement didn't cover Roman Republican and Imperial coins. What Italy wants this time is secret.</p><p><br /></p><p>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.</p><p><br /></p><p>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: <a href="https://www.federalregister.gov/documents/2020/06/08/2020-12313/cultural-property-advisory-committee-notice-of-meeting" target="_blank" class="externalLink ProxyLink" data-proxy-href="https://www.federalregister.gov/documents/2020/06/08/2020-12313/cultural-property-advisory-committee-notice-of-meeting" rel="nofollow">https://www.federalregister.gov/documents/2020/06/08/2020-12313/cultural-property-advisory-committee-notice-of-meeting</a> The Federal Register notice also has a green "submit a formal comment button" which should allow you to comment directly.</p><p><br /></p><p>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 <i>exported from the State Party after the effective date of regulations. </i>(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.</p><p><br /></p><p><br /></p><p> <b> B. What You Can Do</b></p><p><br /></p><p> </p><p><br /></p><p>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. </p><p><br /></p><p> </p><p><br /></p><p>For comments, either comment through the Federal Register notice above or use <a href="http://www.regulations.gov/" target="_blank" class="externalLink ProxyLink" data-proxy-href="http://www.regulations.gov/" rel="nofollow"><i>http://www.regulations.gov</i></a><i>,</i> 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 <a href="https://www.regulations.gov/document?D=DOS_FRDOC_0001-5233" target="_blank" class="externalLink ProxyLink" data-proxy-href="https://www.regulations.gov/document?D=DOS_FRDOC_0001-5233" rel="nofollow">https://www.regulations.gov/document?D=DOS_FRDOC_0001-5233</a> (<b>Please note comments may be posted only UNTIL July 8, 2020 at 11:59 PM.)</b></p><p><br /></p><p> </p><p><br /></p><p>Please also note comments submitted in electronic form are not private. They will be posted on <a href="http://www.regulations.gov/" target="_blank" class="externalLink ProxyLink" data-proxy-href="http://www.regulations.gov/" rel="nofollow"><i>http://www.regulations.gov</i></a>. 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)).</p><p><br /></p><p><br /></p><p><b>C. What Should You Say?</b></p><p><br /></p><p><br /></p><p>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![/QUOTE]</p><p><br /></p>
[QUOTE="7Triones, post: 4591127, member: 112344"]Back in 2010, Italy the State Department to restrict importation of ancient coins from Italy. It's time to renew the agreement with Italy. It's time to make your opinions heard. The last agreement didn't cover Roman Republican and Imperial coins. What Italy wants this time is secret. 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: [URL]https://www.federalregister.gov/documents/2020/06/08/2020-12313/cultural-property-advisory-committee-notice-of-meeting[/URL] 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 [I]exported from the State Party after the effective date of regulations. [/I](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] B. What You Can Do[/B] 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 [URL='http://www.regulations.gov/'][I]http://www.regulations.gov[/I][/URL][I],[/I] 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 [URL]https://www.regulations.gov/document?D=DOS_FRDOC_0001-5233[/URL] ([B]Please note comments may be posted only UNTIL July 8, 2020 at 11:59 PM.)[/B] Please also note comments submitted in electronic form are not private. They will be posted on [URL='http://www.regulations.gov/'][I]http://www.regulations.gov[/I][/URL]. 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)). [B]C. What Should You Say?[/B] 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![/QUOTE]
Your name or email address:
Do you already have an account?
No, create an account now.
Yes, my password is:
Forgot your password?
Stay logged in
Coin Talk
Home
Forums
>
Coin Forums
>
Ancient Coins
>
Renewal of restrictions on coins from Italy - CPAC Meeting
>
Home
Home
Quick Links
Search Forums
Recent Activity
Recent Posts
Forums
Forums
Quick Links
Search Forums
Recent Posts
Competitions
Competitions
Quick Links
Competition Index
Rules, Terms & Conditions
Gallery
Gallery
Quick Links
Search Media
New Media
Showcase
Showcase
Quick Links
Search Items
Most Active Members
New Items
Directory
Directory
Quick Links
Directory Home
New Listings
Members
Members
Quick Links
Notable Members
Current Visitors
Recent Activity
New Profile Posts
Sponsors
Menu
Search
Search titles only
Posted by Member:
Separate names with a comma.
Newer Than:
Search this thread only
Search this forum only
Display results as threads
Useful Searches
Recent Posts
More...