ATF Advocacy

We advocate with ATF on behalf of our clients.  ATF advocacy arises in two general situations.  The first situation is where a client is proactively attempting to identify its compliance obligations.  The second situation is where a client is subject to adverse ATF action.     

In the adverse action context, we assist with compliance audits, warning conferences, and revocation proceedings.  We also negotiate ATF Compliance Plans and FFL Discontinuance Agreements (the latter allowing a client to wind-up its business in an orderly fashion).  

In the proactive compliance context, we assist clients with determination letters (seeking a written opinion from ATF regarding the application of regulations), requests for variances, and licensing. 

Representative Matters:

· Successfully resolved (via settlement) dozens of ATF revocations of dealer federal firearms licenses in jurisdictions across the United States.
· Settled high-stakes revocation for big box sporting goods retail client with 39 stores across 5 states.
· Settled high-stakes revocation for investment banking client with 18 retail pawn shops in multiple states.
· Settled high-stakes revocation for client with multiple retail pawn shops in multiple states.
· Have 100% success rate in winning adverse hearings of ATF revocations of manufacturer and dealer federal firearms licenses in jurisdictions across the United States.  
· Successfully negotiated dozens of agreements with ATF related to the discontinuance of “revoked” federal firearms licenses under conditions allowing the orderly transition of operations to new ownership so as to ensure business continuity and asset preservation.
· Advise ATF-regulated clients in relation to post-audit “warning conferences”, including developing, drafting and presenting compliance plans/programs.  
· Advised ATF-licensed manufacturer specializing in Cerakote application in effort to reverse and clarify ATF’s position that the application of Cerakote is a “manufacturing activity” requiring a manufacturing FFL.
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· Assist product manufacturers (military and consumer) in preparing written requests and obtaining product classifications from ATF Firearms and Ammunition Technology Division.