If you haven’t been audited in the last three years, you will be in the next FIVE years.
The Bureau of Alcohol, Tobacco & Firearms (“ATF”) have increased their compliance inspection frequency almost fifty-fold over the last decade. Per a Washington Post series called “Following the Gun,” many inspections resulted in FFL revocations or, more frequently, the non-renewal of the federal firearms license.
As every retail firearms dealer knows, inconsistency in interpretation of the law leads to more mistakes by the dealer, and greater chances of losing their federal firearms license. According to the National Shooting Sports Foundation, sponsors of the SHOT SHOW each year, “[a] single violation, without warning, is enough” to have your FFL revoked.
Failure to engage a firearms savvy intermediary to intervene, fully assess all inspection activity, interface with ATF inspectors and agents throughout the process, and compare actions by ATF to inspections conducted elsewhere, could possibly result in the termination of a business that has thrived in the firearms industry for years.
The ultimate goal for any FFL is to be in such “super” compliance that they never get sucked into the quicksand that is an ATF Revocation Hearing. As it currently stands, this administrative process is slanted squarely against a licensee, with a “stacked deck” in favor of ATF and little chance of success for an FFL to avoid revocation. If you need further proof of this, simply read this Open Letter submitted to ATF in reply to their “Request for Comment” regarding the hearing process. No FFL can be sure to escape revocation unless their compliance levels are exceptional. Period.
And if this threat isn’t enough, there are plaintiffs who would hail you into their jurisdiction to review your business practices and sue you.