There's really a lot of hyperbole going on about this right now.
Let's make it simple:
1) If you're not an FFL, stop worrying. Seriously. Neither the state department nor the ATF care (or are anywhere close to staffed) to investigate individuals doing things, or even doing things for a friend or neighbor, unless you're pumping out enough work to be considered "in the manufacturing business" (that is -- you run machinery that modifies/creates firearms and you do it in non-trivial volume). If you DO this kind of stuff, you should already be an 07 FFL (and if not, your problems existed LONG before this incident)
2) If you're an 01 FFL, you should know what already truly constitutes "manufacturing" and whether you need to convert to an 07
3) If you're an 07 and not paying ITAR fees, you are likely in the "sweet spot" for scrutiny, and are best advised to make sure you (and your lawyers) are totally aligned with the (often murky) definitions coming from the two agencies. Generally speaking, if you can't afford lawyers or annual ITAR fees, you probably shouldn't be an 07.
We can separately complain about the unfair barrier to entry that these ITAR fees create for small businesses, but that's a completely different matter (and, shockingly, those fees were signed into law by George Bush).
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- by OldCannon
- Sun Aug 07, 2016 3:17 pm
- Forum: Federal
- Topic: New Regulations Could Cost $2250/yr
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