Lewis & Black, LLC
IMI Galil Micro Parts Kits

Lewis & Black successfully secured an entire tender of surplus select fire IMI manufactured Galil Micro Assault Rifles (MAR) straight from an active Israeli unit that were auctioned off in Jerusalem last fall. With the requisite Israeli export and US State Department, ATF and CBD import permits in hand, we brought them into our secured in-house Foreign Trade Zone for disassembly and destruction of the receivers and barrels pursuant to our approved ATF cut schematics. The resulting original IMI parts kits are now available for your own unique MAR build. This may be the last remaining opportunity to own an original IMI Galil MAR parts kit as we’ve been informed there do not appear to be any remaining surplus MARs in Israel. lewisandblack.com

IMA Inc.
Original U.S. WW II Thompson M1928A1 SMG Complete Parts Set—Super Select Condition

This is it, the legendary WW II Thompson sub-machine gun! Simply put, this is not only the best M1928A1 set we offer, but it is the easily the best on the market today. Complete lower frame assembly, finned barrel with compensator and horizontal fore grip and grip mount which has been carefully removed from the demilled receiver, internal components: M-1928 bolt assembly, smooth actuator, lock, op. spring, guide, buffer and breech oiler, ejector, frame latch and spring together with adjustable Lyman rear sight, with detachable butt stock assembly. Includes all components of an M1928A1 except for the demilitarized receiver, available separately. ima-usa.com

Apex Gun Parts
Galil ARM Parts & Parts Kits

Apex Gun Parts is proud to offer a wide selection of Israeli Galil parts! For a limited time we are carrying Galil ARM parts kits chambered in 5.56x45mm NATO. These kits were sourced from Israel and will be in very good condition. These Galils share many similarities with the AK family, and we offer everything from magazines and kits, down to the individual replacement part. Please note that Apex Gun Parts does not sell any functional firearms. www.apexgunparts.com

IMA Inc.
Original British WW II Bren .303cal MkI MkII Parts Set with Demilled Receiver

Original Item: Still retaining the original choice live barrel, IMA is pleased to offer a small selection of now really hard-to-find British WW II Bren Gun Parts Sets complete with torch cut receivers imported over 10 years ago. Includes the following:

Demilled Mk 1 receiver with Mark 1 drum back sight assembly.
Mark 2 barrel assembly with regulator.
Mark 2 bipod, non-adjustable. Styles vary.
Late Mark 1/early Mk 2 butt /lower assembly with bent steel butt plate.
All relevant internal parts as photographed.
Each set comes with a standard Bren Box Magazine where permitted.

Now that live barrels are no longer importable, and with the introduction of an BATF approved semi-automatic Bren system, this may very well be your last opportunity to get a hold of one of these excellent WW II parts sets. Receiver and parts manufacturers vary; most are marked Enfield or Inglis. ima-usa.com

DOUBLESTAR CORP.
The DoubleStar “Oops” Kit

When working on your AR-15, sometimes parts break or fly away into the abyss never to be seen again. For these times, DoubleStar has created the “Oops” Kit. Complete with the most commonly lost and broken small springs and detents, the “Oops” Kit will save your AR when things go south.

Kit contains:
4 Takedown detent springs
4 Takedown detents
2 Buffer detents
2 Buffer detent springs
2 Firing pin retaining pins
2 Extractor springs with bumper pads
2 Selector springs/ ejector springs
2 Selector detents

Find the “Oops” Kit at star15.com/oops-replacement-kit

Apex Gun Parts
1919a4 Parts & Accessories

Apex Gun Parts offers a massive selection of Browning 1919 belt-fed machine gun parts and accessories. Whether you are building or maintaining your 1919, our website features hundreds of products like fire control groups, barrels, grips and even rivets. These parts include a variety of original manufacturers, so you’ll be sure to find what you are looking for. Please note that Apex Gun Parts does not sell any functional firearms. www.apexgunparts.com

DOUBLESTAR CORP.
The Ace by DoubleStar C39 and C39 V2 Receiver Block

Ace by DoubleStar is proud to announce the addition of the C39 and C39 V2 Receiver Blocks to their extensive lineup of stock kits. These receiver blocks work with the rock-solid Ace folding stock and modular kits. Just choose the stock and folder you want to complete the kit. Made from 7075 Aluminum and hard-coat anodized, the C39 and C39 V2 stock sets are sure to make your rifle the perfect fit. Find the C39 Block at star15.com/c39-receiver-block-c39rb. Find the C39 V2 Block at star15.com/c39-v2-receiver-block-c39v2rb.

X PRODUCTS

X-15 Drum Magazine–50-Round Capacity

Awesome has arrived just in time for the New Year! Proven, reliable, full auto capable; the X Products X-15 50-Round Drum magazine is perfect for AR-15 owners. Made primarily of aluminum, the X-15 is engineered to last a lifetime. That’s why X Products stands behind each one of their American-Made drum magazines with a lifetime warranty. SAR New Year SALE PRICE: $149.95–Use coupon code X15-SAR to SAVE $50, offer valid through 1/15/18. www.xproducts.com

FIME GROUP

REX Pistol TruGlo Tritium Night Sights

FIME Group, LLC, manufacturer, importer and exporter of the finest, high-quality firearms from around the world, is now offering TruGlo Tritium Night Sights for REX pistols. The REX Zero-1 Pistol TruGlo Tritium Night Sights use the brightest tritium available. Featuring CNC-machined steel construction, these night sights are high-quality to stand up to demanding situations. The front and rear dots glow green in low and night lighting and appear white in daytime lighting. The smooth, snag-resistant design fits standard holsters. www.fimegroup.com

SMITH & WESSON

M&P M2.0 Compact Series

Smith & Wesson Corp. announced the addition of its new M&P M2.0 Compact pistol series to the recently released M&P M2.0 pistol family. Available in 9mm and .40 S&W, the M&P M2.0 Compact pistol series builds upon the popularity of the new M&P M2.0 platform in a versatile, carry-size configuration. The M&P M2.0 Compact pistol is purpose-built for both personal and professional use.

The M&P M2.0 Compact pistol series offers consumers a reliable, striker-fired pistol that delivers a compact carry advantage with the advanced M2.0 feature set, including an aggressively-textured grip, four interchangeable palmswell inserts and light, crisp M2.0 trigger with a tactile and audible reset. The pistol features a solid, molded polymer frame designed for comfort and durability, as well as the optimal M&P pistol 18-degree grip angle for a natural point of aim. Chambered in 9mm and .40 S&W with a 4” barrel, the M&P M2.0 Compact pistol comes standard with a white-dot front sight and a white two-dot rear sight and either a 15-round 9mm or a 13-round .40 S&W magazine. www.smith-wesson.com

Schmidt & Bender GmbH & Co. KG

1-8×24 PM II ShortDot Dual CC

With the 1-8×24 PM II ShortDot Dual CC, Schmidt & Bender sets new standards and winning the Bundeswehr tender, Rüstsätze Patrouillenkon figuration G28, Anteil Optik“ (Military Equipment Patrol Configuration G28, Optics). The compact 2-in-1 system combines a red dot in the second focal plane with an illuminated reticle in the first focal plane. This combines the advantages of a reflex sight with those of a conventional riflescope, providing an ideal solution for from short to medium distances. www.schmidt-bender.de

365+ TACTICAL EQUIPMENT

Dillon Knob

Powder measure knob for the Dillon press Powder thrower with clicks for easy adjustment. Unlike other competitors, this knob is laser etched with 50 graduations giving the user reference points when adjusting. Two steel spring-loaded balls generate smooth and repeatable clicks. Easy to setup between multiple loads or even calibres, very precise 50 clicks per turn. Testing on pistol powders one click increments is about 0.015 grains. The Dillon Factory screw requires a wrench when adjusting the amount of powder to dispense in your powder thrower. This knob is labeled with graduations for orientation and easily allows the user to hand adjust the powder dispenser without the need for tools. Works on Dillon 1050, 650,550, SDB and 900 presses. www.365-plus.com

FIME GROUP

REX Tactical Pistol

The Rex Zero 1T (Tactical) pistol continues the excellence in production, quality and value that Arex of Slovenia has become known for since the introduction of the Rex Zero 1 to the US in 2016 with FIME Group, LLC, as the official importer. The Tactical model has more options than ever before in the Rex Zero series of pistols, including the new ROR (Rex Optics Ready) platform. Adding on to the proven quality and craftsmanship of the basic features, the Tactical model now offers the following enhancements to increase shooter experience and customization ability. www.fimegroup.com

SMITH & WESSON

M&P Shield M2.0 Pistol Series

Smith & Wesson Corp. launched a new M&P Shield M2.0 pistol series, including the M&P Shield M2.0 pistol with Integrated Crimson Trace Laser. Available in 9mm and .40 S&W, the M&P Shield M2.0 pistol family builds upon the popular M&P M2.0 platform, delivering professional-grade features and proven performance in a slim, lightweight and easy-to-carry profile that incorporates the enhanced M2.0 feature set. www.smith-wesson.com

WHITE RIVER

FC-7 and FC-5-B Survival Knives

Designed for heavy-duty use in real combat survival situations the Firecraft will also make an excellent heavy use defensive knife. Every part is 100% U.S. made.

A five-inch-long full length slab handle is made from heavy-duty green canvass Micarta with an orange liner. The handle is contoured to make heavy cutting or chopping easy. The deep index finger choil cut makes high pressure whittling or precision cutting easy. The grooves at the top of the blade (called jimping) are very course for additional cutting traction even with gloves or mittens on and also form a rasp like surface for making find sawdust for ease of fire starting.

Just in front of the finger guard area is a cutout for more efficient striking of a ferro rod fire starter, and one is included with each knife and is attached to the tough Kydex sheath—an optional ultra-heavy-duty leather sheath is available at extra cost.

The hand honed flat profiled stonewashed finish blade comes leather stropped razor sharp and is thick and deep for efficient cutting or chopping. One side of the knife handle features a polished stainless steel metal dish like cutout (divot) for use with a survival fire bow. www.whiteriverknives.com

AIMPOINT

“The Driven Hunt Experience”

Aimpoint, the originator and worldwide leader in red dot sighting technology, released at the end of September, the web game “The Driven Hunt Experience,” which is available on Aimpoint’s websites. This game is now followed up by the introduction of an app with the same name, available for mobile phones. Earlier this year Aimpoint also released “The VR Experience” by Aimpoint designed to fully immerse the user in dynamic and realistic hunting scenarios.

The app version of “The Driven Hunt Experience” will be released on November 10, 2017. It will be available for downloading at Google Play and App Store. It includes the same hunting scenarios as the web game: wild boar hunting, deer hunting and duck hunting. Using your mobile to actively move around with a 360° view and experience the grand hunting environments adds an extra dimension to the experience. The games were created in cooperation with Divine Robot, www.divinerobot.com, a Swedish software development company. www.aimpoint.com

IRONSIDE ARMORY

Ironside Armory BobCat Upper

The Ironside Armory BobCat Upper is chambered in 223 Wylde and has a 7.5-inch Parkerized barrel with a 3.5-inch extension to give it an integral suppressed look. Designed for close quarters engagement and smaller compartment storage, the Bobcat is ideally used with a pistol brace combination. The Bobcat comes with a 10-inch free float keymod rail and an ambi-charging handle. www.ironsidearmory.com

16th Annual Firearms Import/Export Conference—Getting Better Every Year

The F.A.I.R. Trade Group and National Shooting Sports Foundation (NSSF) exceeded all expectations with the 16th Annual Firearms Import/Export Conference. The conference was held August 2-4, 2017, at the Grand Hyatt in Washington, DC, and was attended by over 300 industry members, attorneys, consultants and government representatives.

I. August 2 Optional Add-on Sessions

Two optional add-on sessions were offered to attendees. The first session, “The Ins and Outs of Export Documentation” was presented by NSSF consultant Kim Pritula. The second session, “ITAR Agreements, How to Prepare Applications, Amendments, and Implement Approvals” was presented by attorneys Johanna Reeves and Katherine Heubert, both from the law firm Reeves & Dola, LLP. The seminar structure of these sessions provided registrants a valuable opportunity to dive into compliance fundamentals in a smaller-group atmosphere. Both sessions received high praise from attendees, and conference representatives have confirmed next-year’s conference will include optional add-on sessions again, although the topics have not yet been decided.

II. August 3 Presentations

Federal Search Warrants and Regulatory Site Visits—Know the Difference

The first full day of the session began with the presentation, “Federal Search Warrants and Regulatory Site Visits–Know the Difference.” The presenters were attorneys Jeff Beatrice, from the DC office of Bradley Arant Boult Cummings, and Teresa Ficaretta from the DC law firm Reeves & Dola. Mr. Beatrice outlined the tools federal agencies use in conducting criminal investigations, including interviews, grand jury subpoenas and criminal search warrants. He gave tips for conduct during execution of a search warrant and recommendations for answering questions and putting things in writing. Ms. Ficaretta gave a presentation on ATF regulatory compliance inspections, covering ATF’s authority to conduct warrantless inspections, how to prepare for an inspection and what to expect when ATF representatives arrive at the licensed premises. She also outlined sanctions ATF may impose on licensees who fail to conduct their businesses in compliance with the law.

Chemical Facility Anti-Terrorism Standards

The second presenter was Ms. Kelly Murray, Deputy Branch Chief, Compliance, from the Department of Homeland Security (DHS). Ms. Murray gave an overview of the requirements of the Chemical Facility Anti-Terrorism Standards (CFATS) that apply to certain “chemicals of interest.” The purpose of the CFATS program is to prevent an attack on a chemical facility that could cause death and injury. Ms. Murray explained that the term “chemicals of interest” is defined in implementing regulations to include certain compounds used in the manufacture of firearms and ammunition. Such chemicals include potassium nitrate, sodium nitrate, aluminum powder, RDX, HMX and PETN. She also explained that only threshold quantities of chemicals of interest are subject to CFATS, and certain other exemptions apply. If a facility is in possession of threshold quantities of the chemicals, then the facility must provide information to DHS so a risk assessment may be conducted.

Significantly, Ms. Murray pointed out that chemicals incorporated into articles are not subject to CFATS. Accordingly, propellant powder incorporated into complete rounds of ammunition is not subject to CFATS. Primers made with chemicals of interest are likewise exempt. Ms. Murray also indicated that facilities are excluded from the statute if they are owned by the Department of Defense.

Ms. Murray advised that DHS has authority to fine a facility if it fails to notify the agency it is in possession of threshold quantities of chemicals of interest. The agency also has the authority to issue an order to cease operations for a facility’s failure to comply with the law and regulations.

During a question and answer session Ms. Murray clarified that smokeless powder and black powder are not reportable as chemicals of interest.

This is the first Import/Export conference representatives from CFATS have attended, and attendees appreciated the information provided by the enthusiastic and knowledgeable DHS representative.

Foreign Military Sales Programs

Michael Slack from the U.S. Department of Defense, Defense Security Cooperation Agency, provided an invaluable and intriguing overview of the Foreign Military Sales (FMS) Program. Mr. Slack walked through the role of the FMS program in supporting the foreign policy of the United States through government-to-government sales of defense articles and defense services. He explained how FMS sales are made, the role of Congress and the conditions imposed on foreign partners. He also explained the differences between FMS and direct commercial sales.

The United States government provides a wide range of services and training to help U.S. exporters market their products abroad. Important information is available at http://export.gov/.

Lunch with Keynote Speaker Kevin Wolf

The conference keynote speaker was Kevin Wolf, former Assistant Secretary of Commerce for Export Administration in the Department of Commerce and now a partner with Akin, Gump, Strauss, Hauer & Feld. Mr. Wolf, always an entertaining and informative speaker, gave attendees an update on the status of Export Control Reform, which began during the Obama Administration.

Bureau of Alcohol, Tobacco, Firearms and Explosives—Panel

Marvin Richardson, Assistant Director for Enforcement Programs and Services, lead an hour-long panel made up of officials from the ATF Office of Enforcement Programs and Services. The ATF officials provided important updates from their respective offices as follows: Curtis Gilbert, Deputy Assistant Director of Enforcement Programs and Services, Andy Graham, Deputy Assistant Director of Field Operations, Krissy Carlson, Chief of the Firearms and Explosives Industry Division, Earl Griffith, Chief of the Firearms and Ammunition Technology Division, Alphonso Hughes, Chief of the National Firearms Act Division, Gary Taylor, Chief of the Firearms and Explosives Services Division and Andrew Lange, Chief of the Office of Regulatory Affairs.

ATF has always provided significant support to this conference. Indeed, the agency worked with the F.A.I.R. Trade Group back in 2002 to bring together government and industry representatives to publicly discuss issues and challenges specific to munitions imports. Although the agency no longer sponsors the conference, it continues to be a critical part. This year, ATF brought close to 50 of its officials and employees to the conference, who remained available to attendees throughout the entire day, and made up the majority of the conference round tables, which took place in the afternoon of August 2.

Field Operations

Standard Operating Procedures (SOPs) for DOD contractors. ATF is in the process of developing such SOPs, but the target date for release is not known.

The ATF Major Inspection Team (MIT) consists of 30 Industry Operations Investigators specially trained to conduct inspections of large-volume manufacturers, importers and dealers. The goal behind the MIT is to yield faster inspections with less disruption to the industry member. In 2016, ATF deployed four MITs. The number of MIT inspections have increased in 2017 to six, as of the date of the conference.

The current number of Industry Operations Investigators throughout the entire country is 790, but 48 more are expected to come on board in 2018. On the date of the conference, ATF field divisions had 162 active inspections of federal firearms licensees. According to ATF, the results indicate a high level of compliance.

Office of Regulatory Affairs

The new Executive Orders on reducing regulations and controlling regulatory costs impose significant barriers to ATF’s ability to amend the regulations. This includes the F.A.I.R. Trade Group petition to change the Form 9 from an application to a notice. While ATF views the F.A.I.R. petition positively, its ability to move forward on the rulemaking is hampered significantly by President Trump’s Executive Order 13771 (Jan. 30, 2017), which requires removal of two regulations for each new regulation.

eRegulation project: Available at https://regulations.atf.gov, project will link ATF regulations to related published information, including rulings, open letters, Federal Register publications and a regulation timeline showing recent revisions.

Firearms and Ammunition Technology Division

Six new Firearms Enforcement Officers (FEOs) have been hired and trained, bringing the total number of FEOs to 12. The increase has resulted in a reduction in processing time for firearms classifications to 30 to 90 days.

The processing time for most marking variances is now 30 days.

In 2017 to date, the Firearms Industry Services Branch has processed 250 firearms classifications.

National Firearms Act Division

This new Division, established in April 2017, is made up of two branches: the NFA Industry Processing Branch, headed by Amy Stely, is responsible for industry forms processing and has 29 employees. The second branch, the NFA Government Support Branch, has nine employees and is headed by David Howell. This branch processes special (occupational) tax applications, Form 10 processing, exemption applications under section 479.33 and industry expedite requests for government and law enforcement. The Government Support Branch also provides expert testimony in ATF cases.

The Division is currently evaluating business processes with the goal of streamlining those processes. So far, the review has resulted in new processes for data entry so that the process now takes 72 hours instead of two to three months.

There is still a backlog of Form 4 transfer and registration applications received before the effective date of ATF Rul 41F. To address the backlog, the Division has adopted new processes for applications to transfer firearms to trusts, and employees are working overtime each week. The goal of the Division is to reduce Form 4 processing from nine months to six months.

Firearms and Explosives Services Division—Imports

The current processing time for the Form 6 permit application is 13 to 15 days.

Current staffing levels in the Imports Branch: 6 Specialists and 6 Legal Instruments Examiners.

Form 6 import permit application currently under review, and a new revised version should be available soon.

In light of the recent Office of Foreign Assets Control sanctions imposed on the Russian firearms manufacturer Molot-Oruzhie, OOO, ATF will be providing guidance in the near future.

Firearms and Explosives Industry Division

Newest release of the State Laws and Published Ordinances publication, 32nd edition, is only available electronically on ATF’s website at www.atf.gov/firearms/state-laws-and-published-ordinances-firearms-32nd-edition.

A new Federal Firearms Regulations Reference Guide will be published soon, exact date to be determined.

ATF will publish new rulings on marking of firearms with synthetic frames, electronic storage of Forms 4473.

Round Table Sessions

For the last several years, since F.A.I.R. and NSSF first introduced the round tables to the conference agenda, the feedback has been extraordinarily positive. These sessions allow attendees to speak informally with representatives from federal agencies and outside experts. This year, F.A.I.R. and NSSF offered 25 tables with representatives from the Department of Homeland Security, Department of Commerce, Census, State Department, Customs, Treasury-OFAC, Alcohol and Tobacco Tax and Trade Bureau and ATF, as well as tables with outside experts on ITAR agreements, federal search warrants and regulatory site visits.

IV. August 4 Presentations

Panel on Prohibited and Embargoed Countries

The second full day of the conference began with an informative panel discussion titled “Prohibited and Embargoed Countries, the Government’s Perspective.” The panel was chaired by Johanna Reeves from Reeves & Dola, LLP, and the panelists were William Argue from Homeland Security Investigations; Elizabeth Cannon, a federal prosecutor from the Department of Justice, Export Control and Sanctions Section; and Steve Goodman, a Special Agent from the Counter-Proliferation Investigations Unit of Homeland Security Investigations.

Ms. Reeves opened the panel by stating that the goal of prohibiting exports of defense articles and defense services to prohibited and embargoed countries is to safeguard national security so this sensitive equipment may not be used against the U.S. She noted that globalization makes this a difficult goal. Panelists agreed that our export controls integrate with national security policies. Ms. Cannon noted there is no shortage of export cases involving the Export Administration Regulations and the International Traffic in Arms Regulations. Despite a high volume of prosecutions, she noted that defense articles continue to leave the country illegally. She noted how important it is for federal prosecutors to work with the licensing agencies and the intelligence community.

Mr. Goodman noted that export investigations are complex and working with members of industry is essential. He assured attendees that when they receive a visit from an investigator this does not mean they did something wrong. Mr. Goodman emphasized the importance of gathering information from industry members to prevent and deter illegal exports.

Ms. Reeves asked panelists to list potential red flags industry members should look for to identify potential unlawful exports. Mr. Argue emphasized the importance of knowing your customer and ensuring sellers know where their products are going. This is the case even if the products are being purchased for domestic use. Mr. Goodman stated that cash payments are suspicious, as are requests to ship products quickly. He also said multiple e-mails requesting the same products from different parts of the world bear further inquiry. Any inconsistencies from usual sale transactions should be viewed with caution.

All panelists urged industry members to contact federal investigators if there are any suspicious attempts to purchase their products. They recommended contacting the ICE tip line at 866-DHS-2-ICE. There is also an HSI tip form available online.

Update on State Department/DDTC IT Modernization

Kimberly Hancher from the Department of State Directorate of Defense Trade Controls (DDTC) provided an update on the State’s IT modernization project. She announced that the new Defense Export Control & Compliance System (DECCS) is up and running and will be handling commodity jurisdiction requests. DECCS will soon take over case tracking from the current MARY system and will eventually replace the DTrade system currently used for most licenses. The modernization process will improve security for State and users and include a dashboard to track the status of all license submissions.

State Department Export Licensing and Agreements

The final segment was on compliance under the International Traffic in Arms Regulations. The presenters, Tom Trotto, Drew Bayliss and Don Fanning, were all licensing officers from Licensing Division 6 at the U.S. Department of State, Directorate of Defense Trade Controls. Their presentation included an overview of DDTC and other federal agency stakeholders in export controls, export license application preparation and common critical errors with the license application forms or support documentation, DDTC policies on denying licenses or returning licenses without action (the dreaded “RWA”) and important pointers on how to avoid license denials and RWAs.

Conclusion

The 16th Annual Import/Export Conference provided members of the firearms industry with invaluable information about regulatory compliance. Unmatched in industry expertise, this pinnacle event in the firearms and ammunition industries continues to be the only conference strictly focused on import and export trades brought to the industry by the industry. Each year the conference gets better, and we look forward to attending again next year.

The information contained in this article is for general informational and educational purposes only and is not intended to be construed or used as legal advice or as legal opinion. You should not rely or act on any information contained in this article without first seeking the advice of an attorney. Receipt of this article does not establish an attorney-client relationship.

Having a Plan in Place Mitigates Stress During Emergencies

In previous editions of Small Arms Review, this column has discussed the need for having plans in place for disasters and calamities. To be sure, events such as hurricanes and civil unrest can stress the abilities of even the most well-prepared. Having a plan in place mitigates this stress. Many of you who have federal firearms licenses (FFLs) have recently taken a very close look at plans in place, and many of you have very likely made improvements to those plans. This is wise, and being prepared can lessen the impact of those events. But what about the ultimate disaster? Do you have a succession plan in place?

Many often quip that there are only two certainties in this world: death and taxes. Yes, it’s a pithy quip. It is also quite accurate. At some point, we all pass on. The passing of a licensee can present significant challenges to the licensee’s estate if specific plans are not in place to create an orderly succession. Complicating matters is that it is entirely possible that ATF’s field representatives may not be familiar with the nuances of navigating existing regulations and may not be able to offer proper guidance for a particular situation. This article is not a substitute for legal advice or estate planning, and the NFATCA highly recommends that you obtain professional guidance to be certain that your wishes and estate are properly managed in the event of your demise. Absent this guidance, things can become very murky, very fast. Let’s have a look at a recent tragedy in Texas.

A young licensee in Texas had operated a sole proprietor FFL manufacturer for many years. He was the only responsible person (RP) on his license and was able to keep up with the bookkeeping requirements of manufacturing National Firearms Act (NFA) items. And then, in an instant, he passed away. As the family began to recoil from the devastation, it was realized that there were a lot of things that needed to be taken care of—dozens of approved Form 4’s that needed completed 4473s, bound book reconciliation and the planning for and execution of wrapping up the business enterprise. The first call was to the ATF field office. That is where things got off track.

The field representative was under the impression that because there was no longer an RP on the license, everything would have to go to another FFL for final disposition. Obviously, this would be complicated and, ultimately, add additional expense for the customers awaiting their approved weapons. The NFATCA was able to help the family get moving in the right direction. The field representative was likely unaware that there is actually a very specific regulation that addresses this very situation. It is found in 27 CFR §478.56 Right of succession by certain persons:

(a) Certain persons other than the licensee may secure the right to carry on the same firearms or ammunition business at the same address shown on, and for the remainder of the term of, a current license. Such persons are:

(1) The surviving spouse or child, or executor, administrator, or other legal representative of a deceased licensee; and
(2) A receiver or trustee in bankruptcy, or an assignee for benefit of creditors.

(b) In order to secure the right provided by this section, the person or persons continuing the business shall furnish the license for that business for endorsement of such succession to the Chief, Federal Firearms Licensing Center, within 30 days from the date on which the successor begins to carry on the business.

In the case of this family, the Executor appointed by the deceased FFL’s will is able to carry on the business in a lawful manner. Inventory will be reconciled, customers will be taken care of and get their purchases with only a slight delay, and the affairs of the business can be completed in an orderly manner. Again, the NFATCA does not provide legal advice. We do help our members and the public get access to the right information. We are continuously reviewing our business plans for the coming years. Have a look at your own plans now.