Your FFL Compliance Program Just Became Your Golden Ticket
ATF Just Changed the Game. FFLGuard Already Wrote the Playbook.
The 2025 ATF Administrative Action Policy (Order 5370.1H) gives credit to Federal Firearms Licensees who demonstrate real, operational compliance programs. That means your compliance system is no longer just a formality—it’s a strategic advantage.
What Changed?
Under the new Administrative Action policy, ATF is now required to evaluate mitigating factors—like documented procedures, internal policies, and training—before taking enforcement action. This shift signals the end of Zero Tolerance and a return to common-sense oversight.
What It Means to YOU
ATF now formally considers mitigating factors like documented SOPs, training, and compliance programs when evaluating licensees. That gives proactive FFLs a golden ticket to avoid revocation—and an opportunity to demonstrate compliance like never before.
What FFLGuard Provides
✅ The Law Plus Guidelines™ – Attorney-drafted, field-proven processes
✅ Automated documentation tools to show your work and protect your license
✅ World-class training—with all-new video content rolling out now, including:
- 4473 step-by-step tutorials
- Common errors and how to prevent them
- Real-world compliance scenarios
✅ 15+ years of unmatched results—zero revocations for clients who follow our program
Frequently Asked Questions
The 2025 ATF Administrative Action Policy (Order 5370.1H) instructs investigators to weigh mitigating and aggravating factors such as written compliance programs, self-reporting, and corrective action before recommending enforcement. The policy encourages documented firearm compliance programs and clear procedures that demonstrate a licensee’s good faith during compliance inspections.
FFLGuard provides structured compliance resources that help firearm dealers, gun manufacturers, and Federal Firearms Licensees stay ready for ATF inspections. Through attorney-written guidelines, training, and automated documentation tools, licensees can organize records, demonstrate corrective actions, and present compliance efforts that may influence ATF decisions during administrative reviews.
If an inspection uncovers potential issues, ATF Industry Operations Investigators may issue a Report of Violations or a Warning Letter. FFLGuard helps clients document corrective actions, address regulatory concerns, and prepare thorough responses that support compliance with federal firearm laws
ATF repealed its Enhanced Regulatory Enforcement Policy, aka Zero Tolerance policy, on April 7, 2025. ATF Order 5370.1H now governs enforcement decisions, emphasizing discretion and the weighing of mitigating factors. Order 5370.1H is an internal enforcement directive, not a new law, but it changes how ATF evaluates compliance and license revocation recommendations.
FFLGuard’s program includes The Law Plus Guidelines™, detailed instruction on ATF Form 4473, background check procedures, and training for firearm compliance inspections. The ATF recognizes written compliance programs as mitigating factors, not formal requirements, when determining enforcement actions.
Willful or repeated violations of the Gun Control Act can lead to revocation. Minor or unintentional regulatory errors typically result in warnings or corrective action requests. Having clear documentation and corrective follow-up helps show a licensee’s intent to comply with federal regulations.
A Responsible Person is anyone who has the authority to direct management, policies, or practices affecting firearm activity. Each Responsible Person must submit fingerprints, a 2×2 photo, and undergo a background check as part of the FFL application, except for Type 03 licensees. This information is submitted on ATF Form 7 or 7CR.
FFLGuard assists with documentation and legal responses directly to ATF and provides counsel if further administrative or legal action follows. The program helps licensees present mitigation evidence, corrective actions, and compliance documentation that may affect ATF’s enforcement decisions.
FFLGuard supports all Federal Firearms Licensees, including firearm dealers, distributors, gun manufacturers, and home-based FFLs where local zoning laws allow business operations involving firearms. Each plan is designed to support compliance with federal firearm laws and regulatory oversight.
ATF has legal authority under 27 CFR §478.23 to conduct warrantless compliance inspections during regular business hours or when the premises are open for business. FFLGuard provides best practices for maintaining compliance during those hours and for handling inspections lawfully and professionally.