We think so. At the end of the day, our industry is best served when the larger population improves its economic position while reducing its compliance risk. From this you can infer that we are in the best position when FFLs collaborate on firearm compliance learning opportunities, new technology and lessons learned. Unfortunately, we find those who have yet to modernize their firearm compliance programs spending more time and money, reactively, to address open issues. When your business is distracted it becomes a strategic disadvantage.
Compliance with what you might ask? Well, a myriad of regulations and agencies including but not limited to ATF, ITAR / Export, Import, FCPA and even merchant processing and credit card standards such as PCI. Not only are there multiple regulations, but each one continues to evolve through a series of rulings and legislative action, such as Export Control Reform. Compliance in our industry affects every type of FFL – Firearm manufacturers, wholesalers, dealers and pawn shops and even private citizens. In an ideal model, firearm compliance is a strategic initiative for your FFL. It is embedded in the culture of your business, enabled by best-in-class technology and continuously monitored and improved.
The nature of firearm compliance has outgrown its’ less mature reactionary focus to achieve equal standards with other business metrics. The operational functions that drive an FFL should think about how compliance can affect their broader livelihood. For example, Logistics personnel need to critically think about the implications when moving “receiving” from one part of a plant to another. Product Management needs to consider compliance before sending a newly engineered product to the factory floor. And even your IT function should consider the implications to regulated data and transactions, especially the Book of Acquisition and Disposition when tweaking your ERP or POS system. In short, Compliance should become part of your culture.
“But we just had a mock ATF inspection, we’re fine!” you might say. Remember, we aren’t the only ones watching and benchmarking performance – the ATF is too. Do you think investigators and agents view leaders and laggards the same? Do you ship products in the wrong box? Can you reconcile 100,000 serial numbers to you’re A&D Book, across multiple addresses, in less than two days time? Can you find a specific serialized firearm someplace more specific than “somewhere” in your 200,000 sq. ft. warehouse?
Firearm Compliance as a discipline is evolving and maturing. We liken the compliance function to where Quality was before modern Japanese manufacturing methods. In its precursor days, quality management was focused on individual events or actions that took place, and were coordinated by a single person. Over time, quality became a strategic objective, equal on par with other business metrics. Quality has eventually been embedded into the fabric of every financial and operational decision and evaluated across the Company rather than with each singular event.
Compliance is going through the same evolution. Where it once was event-focused and reactive – and under the domain of a single person – it is now continuous and proactive – and being built into many layers of the organizational hierarchy for future-proofing the business.
The benefits of proactive Compliance leadership include the following:
– Enhanced repeatability and sustainability through disciplined, process-oriented actions
– Internal controls embedded in processes to drive a high-probability of desired outcomes
– Flexibility to adapt to the highly volatile legislative environment
– Lower overall cost of Compliance through analytic monitoring
– Increased transparency and improved working relationships with key regulators such as the ATF
– And, perhaps most important to the industry, is that it embeds Compliance in the culture of the operation, permitting management the time and mental focus needed to run their business
Compliance is a Process, not a Project Improving compliance is more than just implementing the latest and greatest technology. It requires discipline, accurate data and persistent checks, balances and improvements to drive behavior. A methodical approach facilitates the achievement of compliance objectives. Moreover, such methodologies create a repeatable environment that reduces FFL risk, allowing management to focus on running the business and achieving a competitive advantage.