In 2020, the ATF conducted firearms compliance inspections of more than 5,800 FFLs across the country. These inspections evaluate compliance with federal firearms laws and regulations to protect the public from the criminal use of firearms, prevent illegal firearms trafficking, and ensure the successful tracing of firearms used in crimes. However, effectively maintaining compliance and reducing inspection risk remain challenges for firearms businesses – especially when you never know when the ATF may come knocking on your door.
Inspection success starts with a thorough understanding of the regulations and ATF inspection process, knowing what constitutes a violation, and developing a solid compliance program. At the upcoming 2022 Firearms Industry Conference (FIC), to be held virtually and in-person April 21–27, firearms law attorneys will lead educational sessions on common inspection violations, how to take proactive compliance action, and how to avoid license revocation.
From internal controls to security measures, physical inventory to firearms transaction records, ATF industry operations investigators (IOIs) will evaluate every aspect of an FFL’s operation during an inspection. But with seemingly every aspect of your business under review, where should your audit start?
Thankfully, the ATF provides an annual list of the 10 most frequently cited inspection violations. In 2020, all violations were related to the completion or storage of ATF Forms 4473. During FIC On-Air, Orchid’s Scott Grigerek will address these common failures, and more, in two virtual sessions, “Identifying, Correcting and Eliminating 4473 Errors” and “Proper Numbering, Storage and A&D Recording for 4473 Firearm Transfers.”
Of course, ATF inspection violations go beyond Forms 4473. In “Managing The Retail Compliance Function in a Changing Paper/Tech World” on the last day of the conference, Orchid CEO, Jon Rydberg, and Orchid VP and Lead Attorney at FFL Law, Phil Milks, will discuss the complexity of simultaneously managing core compliance responsibilities, firearm transfers, NFA firearms, and state laws at a modern retail FFL.
ATF Compliance Inspections
Generally, the ATF will not give advance notice of an upcoming inspection, making it that much more important to always be ready. To cover the basics, Phil Milks will break down what to expect during an ATF inspection in FFL-specific FIC On-Air sessions, “Manufacturing FFL Inspection Prep Tips” and “Retail FFL Inspection Prep Tips.”
For a deeper dive into compliance inspections, Milks will be joined by leadership from the ATF in Atlanta to discuss the inspection process and recent updates in detail. Notable firearms law attorney, Stephen Halbrook, will then follow up their session the next day with a breakdown of inspection violations, Report of Violations, the ATF revocation process, and the latest ATF regulatory actions during “Navigating ATF Compliance Matters and Revocations.”
Together, attendees will hear insight on firearms compliance inspections directly from the ATF, as well as attorneys with significant experience witnessing inspections, working independently alongside IOIs, and examining ATF regulations.
Interested in learning more? Registration for FIC 2022, including FIC On-Air™, pre-con FIC Workshops and the main conference, is open now. Sponsorships are also available and include complimentary tickets for industry partners. A portion of all ticket sales and sponsorships will be donated to Project ChildSafe.
To register to attend or sponsor FIC 2022, visit orchidadvisors.com/FIC.