By: Friedrich Seiltgen

Copyright © 2023

A copy of the updated “Federal Firearms Administrative Action Policy and Procedures” (ATF Order 5370.1E) obtained by Gun Owners of America (GOA) shows the Biden Administration’s plan for getting rid of firearms by getting rid of dealers.

The ZERO tolerance policy of the BATFE is designed to revoke the FFLs and crush gun dealers in an effort to weaponize the ATF against firearms dealers and owners.

The GOA report findings:

  • ATF gun store revocations at the highest rate in 16 years.
  • ATF revoked 92 licenses in 2022, the most since 2008.
  • The total more than triples the number of licenses revoked in 2021, when a similar number of dealers were inspected.
  • The total number of licenses revoked in 2022 exceeds years when two times as many stores were inspected.
  • Another 136 dealers received warning conferences; the steepest penalty inspectors can recommend without revocation.”
  • Between January and September of 2022, ATF field offices in Charlotte, Columbus, Houston, Louisville, New Orleans, and St. Paul revoked licenses more frequently than they issued “warning conferences,” which are a much less severe penalty than ATF’s own manual deems is necessary to “assess the FFL’s potential to achieve compliance and determine any potential risks to public safety and firearm traceability.”
  • a 200% increase in FFL revocations since ATF’s Zero Tolerance policy was enacted.
  • ATF will now revoke a license on “initial violations” unless “extraordinary circumstances” show that revocation is inappropriate.
  • Under the Biden regime, the fact that there has been “[o]ne instance of a violation … does not constitute extraordinary circumstances and will not be an acceptable reason for an alternate recommendation.”
  • Retroactive License Revocations: GOA has recently learned that ATF is reopening old cases dating back to at least July 1st, 2021, and revoking the licenses of gun stores to whom ATF previously issued a Warning Letter or held a Warning Conference and who subsequently returned to compliance with the law and rectified their mistakes.
  • In other words, even a single honest mistake in the past can now cost an FFL its license. These abusive ATF actions to reopen and punish old cases are in direct contravention of a DOJ Inspector General report recommending that ATF not engage in such retroactive sanctions.

The numbers show that, under the Biden Administration, the ATF has changed its focus from regulating the gun industry to destroying it by whatever means possible—eliminating access to firearms by putting as many gun dealers as possible out of business.

In my opinion, the most effective policy cited by GOA being used to destroy the dealer network is the “Federal Firearms Regulations Reference Guide.” All new FFLs are given a copy or usually a link to the document, and the FFL is then instructed to sign a form entitled “Acknowledgement of Federal Firearms Regulations.”

This document is nothing more than ATF manufacturing evidence designed to be used later against the FFL to revoke their license. According to ATF, one signature by an FFL acknowledging that he has received a copy of the laws and extensive regulations demonstrates that the FFL knows, understands, and remembers all of the multitudes of obligations under the law. If an FFL later accidentally violates one of those rules, that’s too bad. According to ATF, by signing the form, the FFL “indicated that he understood all of the information provided by signing and dating the Acknowledgement of the Federal Firearms Rules and Regulations.”

In other words, “publications and information provided to the FFL” are designed from the beginning of the licensing process to be used as evidence of “willfulness” sufficient to revoke licenses, on the theory that a person being handed an ATF rulebook, “establish[es] the knowledge element of willfulness” in the commission of a paperwork crime. The end result is that every violation of any statute or ATF regulation is deemed to be “willful”—potentially leading to the loss of a license.

They’re coming for your guns.

That’s all for now, folks! Please keep sending in your questions, tips, and article ideas. And as always – “Let’s Be Careful Out There.”

Friedrich Seiltgen is a retired Master Police Officer with 20 years of service with the Orlando Police Department. He conducts training in Lone Wolf Terrorism Counterstrategies, Firearms, and Active Shooter Response. His writing has appeared in RECOIL,, The Counterterrorist Magazine, American Thinker, Soldier of Fortune, Homeland Security Today, Off Grid, and The Journal of Counterterrorism & Homeland Security International. Contact him at [email protected].