Rude Eyes from Gubbio in the USA

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Coin collector and dealer Warren Esty writes:

I [have] added an early Italian aes rude to my site: Roman Republic. Aes rude. c. late 4th B.C. A pre-coin form of money in Italy. 22 x 22 x 7 mm. (Thick!) Thurlow/Vecchi plate 2, discussed page 15. unearthed near Gubbio, Umbria, Italy. Seldom offered. This piece is in the US and "early Italian" types like this are not supposed to be imported anymore. Fortunately, this one is completely legal.

Meaning he has the documentation that it was legally excavated and exported? Or it left Italy before the 1909 laws? Or is that merely "they-can't-touch-me-for-it-legal"? No details are cited.

In any case it is a total falsehood that "types like this are not supposed to be imported anymore". That is of course not what the Convention on Cultural Property Implementation Act actually says... Dealer's spiel, or genuinely uninformed coiney?

What makes these items floating around the US market an aes rude and not a lump of scrap copper alloy (unutilised raw ingot or casting waste) from a caster's hoard or metalworker's workshop floor? It seems to me that this is a very good example of the importance of context for understanding a dug-up artefact.