Firearms Compliance Inspections

Learn what firearms licensees can expect from an ATF compliance inspection. There is a separate process for federal explosives licensees and permittees (FEL/FEPs).

ATF is responsible for licensing persons engaged in manufacturing, importing, and dealing in firearms. Individuals and entities licensed to engage in these businesses are known as federal firearms licensees or FFLs.

FFLs must comply with the federal firearms laws and implementing regulations, including the Gun Control Act (GCA) and the National Firearms Act (NFA). These statutes and regulations are designed to protect the public from the criminal use of firearms. GCA regulations include provisions specifically aimed at preventing illegal firearms trafficking and ensuring the successful tracing of guns recovered during criminal investigations (crime guns).

Inspection Process

ATF’s industry operations investigators (IOIs) conduct inspections of FFLs to ensure compliance with applicable federal, state and local laws and regulations, and educate licensees on the specific requirements of those laws and regulations. IOIs also review the required records kept by FFLs to identify individuals potentially associated with illegal firearm trafficking or involved in other criminal activity.

Below is the general process for compliance inspections.

When and Where

Compliance inspections happen during the licensee’s business hours at their business premises. This may also include the inspection of off-site storage locations, if any.

Generally, ATF will not give advance notice prior to conducting a compliance inspection.

If a licensee refuses to comply by not letting the IOI enter the business premises or inspect their inventory and records, this is considered a willful violation of the GCA and ATF will pursue revocation of the license.

What to Expect

The IOI will introduce themselves to the licensee, show their ATF credentials, and explain why they’re there. They will also provide their contact information for any follow-up questions.

During an inspection, the IOI will conduct the following activities (not necessarily in this order):

  • Review business operations, including ownership and responsible person information
  • Evaluate the licensee’s internal controls and security measures
  • Verify that licensee is in compliance with state and local laws
  • Conduct a complete physical inventory of firearms
  • Review the acquisition & disposition (A&D) record, also known as the bound book
  • Review all ATF forms, including Forms 4473
  • Suggest voluntary actions or steps the licensee can take to improve compliance

If the IOI finds any violation or discrepancy, the FFL will be advised of those findings. At the end of the inspection, the IOI will sit down with the licensee to go over the final report of violations, if any. The IOI will document the licensee’s response to the violations, including any corrective actions the licensee has taken. Later, the licensee will receive a physical or digital copy of the signed report of violations. Additionally the IOI will review the federal firearms regulations with the licensee, who will have an opportunity to ask questions.

Inspection Results and Recommendations

If an IOI finds violations during an FFL inspection, the nature and extent of the violations will determine next steps. When willfully committed, some regulatory violations pose public safety risks, and will result in ATF issuing a notice that it will revoke the license.

In addition to a refusal to allow an IOI to conduct an inspection, each of the following violations, absent extraordinary circumstances, will also result in ATF issuing a notice of revocation:

  • Transferring a firearm to a prohibited person
  • Failing to conduct a required background check
  • Falsifying records
  • Failing to respond to a trace request

Where circumstances, such as repeat violations, demonstrate a willful disregard of the law, ATF’s obligation to protect public safety may also warrant issuance of a notice of revocation.

If the violations do not warrant a notice of revocation, ATF has several ways to guide the FFL toward corrective actions toward future compliance. These methods include issuing a report of violations, sending a warning letter, and holding a warning conference (or meeting) with the industry member.

In fiscal year 2020, ATF’s firearms compliance inspections resulted in the following recommendations:

Result of firearms compliance inspection Number of inspections by FFL type Total inspections
01 02 03 06 07 08 09 10 11
No violations 2,348 236 2 61 516 77 4 17 16 3,277
Report of violations 798 285 1 0 193 9 0 2 1 1,289
Warning letter 477 164 0 0 149 9 1 2 2 804
Warning conference 152 64 0 0 88 2 0 0 0 306
Licensee went out of business or surrendered their license 73 5 0 3 12 2 0 0 1 96
Revocation/denial of license 20 6 0 0 12 1 0 1 0 40
Other dispositions 5 0 0 1 3 1 0 1 0 11
TOTAL 3,873 760 3 65 973 101 5 23 20 5,823

Please note that the numbers provided above are for the most notable areas, and do not include all items identified by an industry operation investigator during an inspection.

View inspection data for each field division

Type Description
01 Dealer in Firearms Other Than Destructive Devices (Includes Gunsmiths)
02 Pawnbroker in Firearms Other Than Destructive Devices
03 Collector of Curios and Relics
06 Manufacturer of Ammunition for Firearms
07 Manufacturer of Firearms Other Than Destructive Devices
08 Importer of Firearms Other Than Destructive Devices
09 Dealer in Destructive Devices
10 Manufacturer of Destructive Devices
11 Importer of Destructive Devices

Common Violations

In fiscal year 2020, the most frequently cited violations during ATF firearms inspections included:

27 CFR 478.125(e) Failure to maintain an accurate/complete/timely acquisition and disposition (A&D) record of firearms
27 CFR 478.124(c)(1) Failure to obtain a completed ATF F 4473
27 CFR 478.21(a) Failure to complete forms as prescribed
27 CFR 478.124(c)(3)(iv) Failure to record NICS contact information on an ATF F 4473
27 CFR 478.123(a) Failure to maintain an accurate/complete/timely manufacture or acquisition record
27 CFR 478.124(c)(5) Failure by transferor to sign and/or date an ATF F 4473
27 CFR 478.124(c)(4) Failure to record firearm information on an ATF F 4473
27 CFR 478.124(c)(3)(i) Failure to verify or record identification document on ATF F 4473
27 CFR 478.123(b) Failure to maintain an accurate/complete/timely licensee disposition record
27 CFR 478.126a Failure to report multiple sales or other dispositions of pistols and revolvers

Questions

If you have questions about a particular ATF inspection or about ATF inspections in general, please contact your local ATF office.

Last Reviewed August 3, 2021