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I carved out a few minutes today to submit a comment to the CPAC on the Italy MOU renewal, just a few hours before the closing. I tried to write something different from the last time I supported the previous incarnation of the Italy MOU and my previous one (on Egypt). It probably would have benefited from editing, I'm not very happy with it, but I was too short of time today to write more briefly. It has two parts, the first more or less addresses the bits you are supposed to, the second the issue I personally think more pressing:
Only 105 characters remaining Tracking Number: 1jz-8hts-2mk6Dear Professor Gerstenblith, esteemed Committee members,The US market for antiquities of the ‘classical’ cultures of Europe is immense, innumerable objects including antiquities dug up several decades ago are already circulating on it and are available for US collectors and dealers. Artefact smuggling however, linked as it seems today with various forms of criminal activity, is a persistent problem for no-questions-asked antiquities markets such as this. The scrutiny of documentation of licit export of items freshly-arriving on such markets (as per article 3 of the 1970 UNESCO Convention in question) has therefore an important function in helping curb this negative phenomenon.Fighting international heritage crime, antiquity smuggling in particular is in the interests of the international community as a whole, the co-existence of nations and the fostering of good relations by emphasising the role of cultural bonds which should unite them and not be a source of dispute.To turn to the questions posed by 19 USC 2602, the Italian government already takes measures consistent with the Convention to protect the country’s rich cultural heritage. For example it complies with Art 5 of the Convention, through the existence of the Ministero per i Beni e le Attività Culturali and a specialized police unit Comando Carabinieri per la Tutela del Patrimonio Culturale. It really seems to me inappropriate for the US (which has neither) to presume to stand judgement over their efforts in considering whether agreeing to help them fight international culture crime s per the obligations it accepted in becoming a state party of the 1970 UNESCO Convention.Recent cases of artefact seizures within Italy and at the US borders (reported in the media and highlighted in the social media and known to the committee) show not only the efficiency of the means used by Italy to fight international cultural crime but also the continued need for such measures and international collaboration in fighting the problem. The threat of today’s antiquities market and its greedy buyers to the world’s archaeological and cultural heritage is as great now as it has been in the past. Damage continues to be done to the archaeological sites of Italy by people seeking collectables which can be turned to commercial profit. There were reports a few weeks ago about the arrest of a gang handling artefacts taken from clandestine raids on Pompeii World Heritage Site. To suspend the continued policing of imports of cultural property entering the USA would only benefit culture criminals involved in this pillage and those who unwittingly finance it by buying its products no-questions-asked.A measure of the extent of this problem is provided by the hundreds of US-based collectors and dealers mass-mailing comments to this docket urging the lifting of import controls on certain types of artefacts and apparently representing prevalent attitudes in the industry and hobby. Without import controls checking that the imported material has been legally exported, one may predict that increasing amounts of material of questionable origins would quickly reach this sector of the US market – to the apparent satisfaction of the dealers and collectors here asking the CPAC to recommend allowing it. Such attitudes continue to be a threat to the world’s archaeological heritage and the image of the USA abroad.It is difficult to see within the framework of the 1970 Convention and existing laws any other available means of preventing smuggled items penetrating the major antiquities market of a country like the US other than scrutinty of fresh material as it arrives.For these reasons, I urge the CPAC to recommend renewing the existing CCPIA MOU with the Republic of Italy, and for the USA to continue to enforce the implementation of the 1970 UNESCO Convention.In addition, however, I wish to use this opportunity to express unease and dissatisfaction with the current piecemeal, selective and extempore manner in which the USA, almost alone among the states parties, has chosen to impement this important convention. As Committee members are only too aware, those markets – in particular of the so-called ‘minor’ antiquities – have altered immeasurably since the CCPIA was first debated and enacted. There are now very few countries in the world where the archaeological heritage is to any degree safe from pillage by artefact hunters, including metal detector users. It would be useful to initiate discussions on the way to extend the coverage of US legislation to all of the world’s heritage threatened by pillage due to the greed and carelessness of participants in the global antiquities trade, of which a major part goes through the hands of US-based dealers and private collectors. Thank you.Paul Barford