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The following comes from NSSF and was originally reported by Ammoland here. It’s an internal memo describing ATF’s new push to regulate licensed FFLs more strictly:

NSSF has learned of a recent ATF internal memorandum that we wanted to share with our members:

“On June 23, 2021, President Biden and Attorney General Garland announced the Administration’s Comprehensive Strategy to Prevent and Respond to Gun Crime and Ensure Public Safety. ATF’s role in the Strategy is essential, and includes refocusing our FFL inspection and administrative action policies. As we have previously discussed, to ensure ATF effectively executes our role in the Strategy, effective immediately, all Field Divisions shall implement the following:

1) Field divisions shall in all instances utilize Crime Gun Intelligence Analytics (CGIA) and other data driven tools in determining prioritization of inspection resources. The factors that shall be considered include, but are not limited to, the following:
      a. The extent to which firearms sold by the dealer are later used in criminal activity:
     b. The time between the sale of a firearm and its use in a crime;
     c. The number of recoveries associated with shootings, domestic violence, and other violent offenses; and
     d. Additional information developed by local law enforcement partners.

2) Absent extraordinary circumstances, an inspection that results in a finding that an FFL has willfully committed any of the following violations shall result in a revocation recommendation:
     a. The transfer of a firearm to a prohibited person;
     b. Failing to conduct a required background check;
     c. Falsification of records, such as a firearms transaction form;
     d. Failing to respond to an ATF tracing request;
     e. Refusing to permit ATF to conduct an inspection in violation of the law.

ATF will be amending ATF O 5370. l D, Federal Firearms Administrative Action Policy and Procedures to incorporate these requirements. The updated Order will also set forth revised procedures for processing FFL inspections that result in findings of violations listed above or other violations that merit revocation, but that may warrant an alternate recommendation after consideration of whether extraordinary circumstances exist. Inspections where the Director, Industry Operations determines an alternate recommendation to revocation is appropriate shall continue to be routed to the Deputy Assistant Director Industry Operations, Office of Field Operations DAD(IO). The DAD(IO) will approve or deny the recommendation and advise the field division, accordingly. The circumstances of those cases will be briefed to the ATF Director each month during the Director’s Monitored Case Briefings.

Additionally, FFL inspections conducted in states that separately license firearms dealers that result in violations of state law or revocation, shall be shared with the regulatory counterpart in that state. Any questions about what information can be shared outside ATF should be routed to Division Counsel.

If you have any questions, please contact Chief Field Management Staff, Kyle Lallensack, at (414) 305-3660.”


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  1. They’ve already regulated the hell out of ILLinoyed FFL holders. Some 50%`are gone or moved to greener pastures ie Indiana. A gunshop I frequent Sheepdog in Mokena,ILL is opening a new store in Dyer,Indiana soon. .

      • Yeah my error…I shoot and buy at Point Blank Mokena sometimes. If they ever get Dyer open I’m sure I’ll frequent them. My buddy moved very close to the new store.

  2. Not real bad, is it? Maybe we need to investigate car dealers the same way. Any dealers who sell cars that are later involved in traffic violations will have to answer for it. And hardware store managers. And computer sales companies. If your stuff is involved in crime after you sell it, you must answer for it!!

    And farmers too. If criminals eat cereal made from the grain they grew, they need to be held accountable.

    That’s not really Gestapo, is it?

      • Or robberies and ram raids. The chain of responsibility will go back through every registered owner, to the dealer, and manufacturer. Under Progressive ideals, all must be punished for their crimes, real and imagined, against the state.

  3. Translation: We will close your place of business as often and for as long of periods as we deem necessary to pour over your records until we find the most minor infraction. We will then also impound your records of transfer and your inventory while you await trial… sorry, no cashless bail for you undesirables.

    • “…until we find the most minor infraction.”

      Indeed. Any “mistake”, “error”, “smudge”, is prima facie evidence of intent to circumvent FFL regulations. There is no need to find/prove intent because the intention of every FFL is to sell guns to prohibited persons, and create a supportive pathway for “straw purchases”.

      Every FFL, and every employee or associate of an FFL is likely a prohibited person themselves, yet to be discovered as trafficking in guns. How can this be? Really? That’s a question?

      It can be because people only have guns in order to kill other people. If you can think it, you have a propensity to do it. So, people wanting to kill other people are naturally attracted to locations where firearms are sold by other likely undiscovered prohibited persons.

      No one needs a gun. Well, except for double barrel shotguns to be used only to scare off burglars by shooting the shotguns out the back door. And make a bunch of noise that will prevent any criminal from continuing to commit the crime in progress.

  4. tiny shop i visited yesterday in libertyville had a couple hundred various pieces (a 35k parker!) and some ammo. he said if the back room wasn’t already set up like a bank vault they would have had to close due to new restrictions.

  5. My first reaction: Nothing is really changing, and this is just window-dressing meant to soothe the anti-gun lobbyists that Something Is Being Done.

    FOPA is still alive and well in constraining the DOJ and preventing them from regulatory asshattery where FFLs are concerned.

    • That was my reaction: at least the way it’s worded suggests that they will simply be more active in enforcing existing regulations. If it’s really true that a particular dealers guns turn up at crime scenes at a greater-than-average rate, it seems reasonable to take a closer look at that dealer.

      As long as there is clear due process, the ATF complies with the law, and the investigation is done in good faith.

      • Sure sure sure, except one thing. It seems gun dealers in certain shall we say “hoods” are constantly faced with a dilemma . You see, a certain segment of the population sends a legitimate looking person into the store to purchase one or several firearms, now this person passes all the background checks and states that they are purchasing the firearm for themselves. What’s a store owner to do? You can’t profile? right? I mean if they did that then the would have zero customers in certain “hoods”. They can’t just pick up and move their businesses, some of which have been around for decades, and they do have more legitimate “law abiding” regular customers than criminals. So what’s the answer? No guns for a certain segment of the population? Move out of certain “hoods” to other areas? Grocery stores did that and now the complaint is that there are “food deserts” in cities. Hmm? I don’t know. The atf can investigate whomever they want but those ‘bad’ dealers usually aren’t. They sell guns, someone comes in to buy guns, they pass the background checks, they pay the $$$ they get their guns! You tell me how to fix it.

  6. Details of how the JBT (Jackbooted Thugs) implement

    b. The time between the sale of a firearm and its use in a crime;

    • That information is the time differential between the first sale by an FFL to the date of the crime. The longer the time, the less likely that the FFL engaged in any illegal practice, but a guy who walks out of the store with a brand new gat and guns down the gangbanger on the next block may raise some eyebrows.

      • All of this is a smoke screen to cloud the various studies in the past, taken via interaction with actual felons, that have shown that the VAST majority of firearms (can’t speak for other types of weapons) used in the commission of all criminal activities do not come from FFLs or legal transfers, but from dealings with other criminals. And, of course the rub here is that the transferor and transferee are both already involved in illegal activity (that would mean, breaking one or various existing laws for the mentally-challenged around here) by merely being in close proximity to a firearm in the first place. Several of those major studies were funded in part by the US Government, but of course the results were suppressed by the very people who funded it because the results didn’t fit the narrative that spawned the study in the first place. And the results of other academically-satisfactory studies by John Lott, among others, are generally scoffed at by the same people burying the results of their own.

        It’s very easy to disprove the notion that FFLs are fueling violent crime in the US using actual data, but it is far more simple and convenient to just make up the stats in order to push the narrative that privately-owned firearms in the US are a problem of immense magnitude.

      • Time differential? I’m sorry I forgot to mention no one who has ever come in to buy a gun has been wearing their “potential criminal” sign, same goes for their “I will commit a crime shortly after buying this gun” sign.
        Time differential my ass.

    • They can come and inspect/audit any time they like. The FFL holder or responsible party has to be present. So once you have the FFL you have no choice unless you want your license recoked

      • Bingo. Therefore the inspections are not “illegal” but a term of your license. Many businesses are subject to similar restrictions on inspections, e.g., any place that sells food itens, factories for OSHA, you name it.

  7. Obviously any business or person, no matter what they sell, actively and knowingly involved in criminal acts deserves to be discovered and prosecuted.

    Problem is the ATF is, at the highest levels, rife with personal and political agendas, arrogance and a blood soaked history of incompetence that has killed their own officers, officers of other agencies and a hell of a lot of innocent men, women and children.

    The only action reasonable to take with the ATF is disbanding it and banning all employees from Federal employment.

    One exception I hear a lot of good things about their explosive experts. Shift them to being non LEO FBI staff. Strictly scientific, technical and analytical types. No guns, not ever.

    Shift the duty of investigating criminal enterprise involving firearms to the FBI.

    • enuf…….The Fraudulent Bureau of Intimidation is not any better ! These abuses are what happens when constitutional rights which the government has no legal right to interfere with are regulated and licensed. This brings about the tyrannical government that the second is to protect us against.

  8. “ driven..”
    Translation: Whatever crapped up statistics or human written software tells us to do. Another step towards machines managing humans. (is ATF human?)

  9. Obviously Gun Control and its racist and nazi baggage is in the driver’s seat while The Second Amendment sits at the back of the bus.

    Head to any range and ask Gun Talking Rambos to define Gun Control and and maybe on a good day you’ll get one in ten that come close. On the other hand it answers the question why Gun Control is alive and well and why politically inept history illiterate Rambos are being driven around and around by an agenda rooted in racism and genocide. It is indeed a pathetic sight.

  10. And with the giddy anticipation of a 6 year old on Christmas Eve the ATF plots the so many ways they work to crush the 2nd Amendment and legal soon to be illegal gunowners out of existence. Wonder where the jail space is for the millions of potential criminals they will create with the stroke of an Administrative Agency pen??

    • They won’t send anyone to prison. They just want to confiscate the firearms and charge you with a felony so you can’t buy anymore. That’ll be good enough for them.

    • Lots of camps. Camps that will be inadequately resourced, over crowded (if there is accommodation at all), poor to nonexistent medical and sanitation, and guarded by ANTIFA and BLM volunteers.

      Probably located along the path of the Great Lakes to Seattle canal project.

  11. I had a discussion with someone from Oregon.
    I could not get across to them you can not purchase a firegunm and have a marijuana med card. They argued you can in Oregon. Maybe that’s the FFL types their going after?
    Nah, the ATF is just going to hit FFL’s so hard a single shot .22 will cost $8000. It’s how you get limit “the undesirables ” from owning a firegunm.

  12. I’m still not convinced that “Rogue Dealers” are the realbproblem or that much of a threat, the way this Senile Sack O’ Scheiße says it is..

    Smoke and Mirrors.

  13. Seems to me that someone, might I suggest the U.S. Congress, needs to tell the ATF precisely where to get off, pointing out to this agency that it’s job is to investigate arson, collect alcohol and tobacco taxes, and see to the proper enforcement of existing federal firearms related law. They are not to engage in the lobbying of congress for any purpose. That having been said, under no circumstances is The ATF to get anywhere near lobbying for or against the enactment of legislation concerning firearms. Seems to me that the ATF very badly needs a refresher in High School History Class, where they should have learned about the U.S. Constitution, and it’s most interesting first 10 amendments.

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