Q: Client has advised that they have secured a manufacturer FFL in addition to their dealer FFL. By separate case (14931) we have explained ITAR requirements regarding registering with DoS if manufacturing. If client actually intends to import or export, they should explain proposed operations so ATF requirements can be addressed and a new case will be opened to cover ITAR beyond licensing. A determination needs to be made if client is manufacturing per DoS and ATF requirements. Related to this is if client is manufacturing by ATF standards, assistance will be needed regarding A&D entries/ retention, marking firearms, NFA reporting and other pertinent requirements.
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