Dear ANS Member:
A comment period has been announced concerning potential import
restrictions on ancient coins of potential Italian and Afghan origin.
The practical impact of such restrictions could be severe as they
anticipate a shifting of the burden of proof to show provenance (chain
of title) onto importers of coins. Please note that although
legislation similar to the Afghan bill on Iraq passed Congress, that
bill HAS YET TO BE IMPLEMENTED. Thus, importers of coins (suppliers for
collectors) have yet to really feel the potential sting of import
restrictions under the applicable legislation.
A. Italy
In 1999, the US Cultural Property Advisory Committee recommended against
import restrictions on coins of potential Italian origin. Import
restrictions on other Italian cultural artifacts will expire on Jan. 1,
2006 unless renewed. CPAC is accepting public comments on the renewal
until August 24th. CPAC has refused to confirm whether or not it will
reconsider imposing import restrictions on coins. Thus, one must assume
that the issue may very well be addressed.
If you want to comment, letters should be faxed (not mailed) to the
following address and phone number. Note in the RE Line that the letter
relates to the Italian renewal:
Via Fax: (202) 260-4893
Mr. Jay I. Kislak
Chairman
Cultural Property Advisory Committee
United States Department of State
Room 334
301 4th St., SW
Washington, DC 20547
Re: Potential Request for Import Restrictions on Coins in Conjunction
with Renewal of Import Restrictions on Italian Cultural Artifacts
I should also note ACCG should be making the fax wizard available for
use for this campaign. It can be found at http://www.vcoins.com/fax/
B. Afghanistan
The House Ways and Means Committee Subcommittee on Trade is also
accepting comments on HR 915, a bill that would authorize import
restrictions on coins of a type that circulated in Afghanistan.
The comment period ends 9/2/05. Details on how to comment on this
legislation electronically can be found at the following link:
http://waysandmeans.house.gov/hearings.asp?formmode=view&id=3056
Finally, anyone interested in reviewing the arguments FOR import
restrictions made by the archaeological community should visit the SAFE
web site: http://www.savingantiquities.org/
Best wishes,
Peter Tompa
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