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ITAR COMPLIANCE

RJ

Has any 07FFL holders received a letter from either the ATF or the US State Dept for the 2,250.00 fee to register? I have been speaking with the NRA last week about this and they said they might be able to help us with this. They also told me they have received alot of calls from other 07 FFL holders. If you have received a letter please PM me. I know I'm not the only one that does not like it. Just remember, if you are not at the table you are on the menu We all need to speak up or they are going to tax us right out of a job. Thanks
HILTS ACCURACY
CUSTOM RIFLES
 
We were required to get ours several years ago now. I would be interested in finding out more about this. Its alot of extra money that we need to payout every year just so we can ship out of country.

bobby
 
Guess this fee (tax, levy, penalty, whatever?) has now just been extended to all FFL's who engaged in any gunsmithing activity including threading for brakes to making simple gun parts to potentically the mounting rifle/shotgun sight and scopes! This IS going to be a game changer according to NRA-ILA. Another EO, by guess who, was signed into action last week while we were sleeping. I plan to add a line item to my POS with the description ITARS Tax. Darn if I'm going to just increase my GS fees without making folks fully aware of what's actually going on. This is obviously designed to impose and hardship on the small smiths, and to drive them out of the business.

If any of you FFL holders, or ATF/State Depart./etc., have factual insight into the extent of this please share your information with the 'official' references.

Are there other professions where the government imposes a fee like this?
 
You are absolutely correct - ITAR - Dept. of Defense wants thier 2250 EVERY year and now 10% on ANY gun work!!

You should invoice the customer as a 10% ITAR tax. I do that and explain what it is before doing the work... I know I lose business with the 10% tax but EVERYONE who is in business in 2/5 years will be doing that as well or will be shut down!! It is just another backdoor liberal way to shut down the smithing community!

It is a brave new world we live in!

Barrel Brothers
 
This does not just apply to type 07 FFLs it applies to type 01 FFLs . Read the DDTC 07/22/2016 Gunsmith/Manufacturing directive. It is easy enough for the State Department to get the names and addresses of all type 07 FFLs. The BATF compliance inspectors are requesting during inspections to see all Licensee's "M-Number" certification issued by the DDTC. If the Licensee/Gunsmith appears to be manufacturing the inspector advise the Licensee to get registered with the DDTC/ITAR. It also has been reported that the unregistered licensee is reported to the DDTC/ITAR. The consequences are sever for violators.Most attorneys that have been contacted have advised their clients to pay the fees and let the system take it's course. It may or may not get resolved. Being the test case may not be your best option.
 
Our local ATF said this: "I am required to inform you of this..." and handed me the ITAR contact info. My beef are the words "INTERANTIONAL TRADE". Guess we will be the first they round up and execute.
 
My beef was $2,280.00, bank has to get their $30.00 for the wire transfer, failure to comply could mean up to $1,000,000.00 in fines and 20 years in the Federal pen.
 
If a shop is making pre-fit barrels and they never touch a customers rifle are they still on the hook as a manufacturer?
 
Two weeks after this latest ITAR crap, I get a unannounced spot audit from the ATF. (Seattle office)

I do not, and never have manufactured a firearm that is, if you use the term "manufacture" in it's honest, and intended form.

(more on this a little later)

I have a 07 FFL.

Ten years ago, when I first applied for a Gunsmith FFL the agent told me I better get a 07 manufacturer FFL "just in case".

This is how they laid it out to me a few weeks ago.

After reviewing my part time business activity the ATF agents stated that I do come under the auspices of ITAR, and needed to pay the $2,250.00.

Why?
Because I'm a firearms manufacturer.
Why am I a manufacturer in the eyes of the ATF?
Because I bought several guns over the past ten years, and refinished them.
Yes... Refinished them in Cerakote, and added scopes to a few of them.

YES! This is what the ATF agents told me. Because I owned the firearms, and Cerakoted them, and scoped a few of them, I was in fact in the eyes of the ATF a "manufacturer of firearms"

Now... the ATF agents said that If I do such work for customers, then it is a "service", and then I'm not a "manufacturer of firearms".

You cant make this crap up!
On principle alone, I surrendered my FFL on the spot.

Think about it... If I were a used car lot, who bought a few cars, re-painted them, maybe put a new radiator in a few of them, then by the ATF's definition of what manufacturing is, then I am in fact a, "manufacturer of cars" !
 
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It makes me both angry and very sad that the Federal Government bullies and threatens the very people that uphold and support not on the 2nd Amendment but EVERY Amendment. Those that make the laws should be totally ashamed of themselves. Running rough-shod over those that work in the arms industry, in any capacity, by threatening them with huge fines and asinine prison terms is a very sad day for this country and cheapens and prostitutes what was fought for from the birth of this nation. When will it reach the point were we not only say no, But HELL NO. We might join that football ass and just protest. Respectable people who appreciate firearms LIVES MATTER.......................like everybody else.

Wait, it's the doorbell, probably the ATF and I haven't even hit "Post Reply" yet
 
You all do understand this is 100% unenforceable right? Not only is there not an agency to do it, the state department has never asked the atf for a list of ffl holders. That means they have no one to enforce this fee, dont know whom to enforce it on, and even if you have an 01 or 07 that does not necessarily mean you are manufacturing by the state departments definition. Totally unenforceable.
 
Holding a FFL is a matter of public record easily pulled up on ATFE web site in 2 minutes. Name of business, contact name, address, classification of license held, etc. You should also understand that the current administration would rather go after its' own citizens than prevent illegal immigration, keep the financial squeeze on Iran so they can't get a nuke, flat out lie to the American public about what the (un)Affordable Care Act will do, lie about what happened in Bengazi, Libia, , bug out of Iraq after spending untold amounts of American Blood and treasure and winning without leaving a substantial force behind to insure the'win' holds, be honest about how the government is 'dealing' with Isis, or to even prevent voter fraud or food stamp fraud, for that matter. Congradualtions, you are now on the list of deplorables!.
Alex Wheeler said:
You all do understand this is 100% unenforceable right? Not only is there not an agency to do it, the state department has never asked the atf for a list of ffl holders. That means they have no one to enforce this fee, dont know whom to enforce it on, and even if you have an 01 or 07 that does not necessarily mean you are manufacturing by the state departments definition. Totally unenforceable.
Click to expand...
Yes, but if "they" decide to make an example of you, your life will change for the worse for whatever is left of it. What's to keep ATFE from asking for your ITAR registration as well as your LLC registration (if you're a LLC) when you're inspected? What's to stop them from 'writing you up' for NOT having the ITAR registration number and then reporting you to the DDTC, and then have the DDTC send the U.S Marshalls or the FBI to come see you, personally? Yes, letters have been sent,,,,, by ACGG, NSSF, The U.S. House of Representitives and the U.S. Senate. This administration has done a very good job of ignoring letters and doing as it darned well pleases, whether good for the American Public, good for trade with other nations, good for National security or good for jobs. The only reprive might be if Hillary ISN'T elected. If they don't take Trumps' phone away, so he can't "twitter" nonsense in the wee hours of the morning, she just might become the next occupant of the White House........ Things will really get tough then, you'll have to install uni-sex/bi-sexual rest rooms, or close the doors!
 
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The atf and state department dont talk. The ATF cant and wont ask for ITAR registration. It has nothing to do with them at all. The only way the state department would know if you were manufacturing by their definition would be to physically come by your shop and inspect you records of exactly what was done, which your not even required to keep. I have no dog in this fight as I was registering before this even came up. But the reality is, any real action based on this new definition is very very unlikey.
 
Alex Wheeler said:
You all do understand this is 100% unenforceable right? Not only is there not an agency to do it, the state department has never asked the atf for a list of ffl holders. That means they have no one to enforce this fee, dont know whom to enforce it on, and even if you have an 01 or 07 that does not necessarily mean you are manufacturing by the state departments definition. Totally unenforceable.
Click to expand...
Oh, it's enforceable! With the ATF being a federal law enforcement organization within the United States Department of Justice, I'd rather not challenge them.
 
Alex Wheeler said:
The atf and state department dont talk. The ATF cant and wont ask for ITAR registration. It has nothing to do with them at all. The only way the state department would know if you were manufacturing by their definition would be to physically come by your shop and inspect you records of exactly what was done, which your not even required to keep. I have no dog in this fight as I was registering before this even came up. But the reality is, any real action based on this new definition is very very unlikey.
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You're 100% incorrect. The ATF agents that spent two days with me went over all that you are saying they do not.
In fact they also told me that because the Washington State Dept Licensing Firearms Division did not have their own enforcement agency that they also try and help them out as well, which they did when visiting me. When I stated I did not have to share with them my Pink copies of the State Pistol Applications (when they asked for them) they said that was fine. They would just come back with a State official with a Court Order in hand and get them that way. Then they said that it was up to me. I then handed over my State pink copies.
 
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