According to his mates in the ACCG:
I wonder whether the Bavarian Minister of Economic Affairs, Martin Zeil, can actually read English? Or is he just signing what somebody has pushed under his nose? To what "overly repressive documentation requirements" is he referring? An export licence or dealer's declaration? ("overly"?). This "chain of ownership documentation", where in the CPIA is any mention made of this? In what way does an MOU between Italy and the US actually impact the numismatic trade between Bavaria and the US? (actual wording of the CCPIA art 307 please, not made up stuff). What on earth is this German guy talking about? Who voted for him, Bavarian coin elves?Bavarian Minister of Economic Affairs, Martin Zeil, registered his government's opposition to import restrictions on coins saying in a letter to the State Department that proposed restrictions "would negatively impact the legitimate numismatic trade between Germany and the United States of America and also people to people contacts between US and German citizens." He pointed out that because of the MOU's overly repressive documentation requirements "Legal trade would then hardly be possible between Germany and the United States." Collectors argue that over the past 600 years literally millions of ancient coins have been bought and sold without any requirement for chain of ownership documentation (provenance).
.