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FFL Watch — Compliance Checklist

ATF Inspection Prep Checklist

13 items · Last updated May 4, 2026
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Records & Documentation

Verify A&D bound book is current and accurate

Ensure all acquisitions and dispositions are logged within 24 hours with complete serial numbers, manufacturer, caliber, and type.

Reconcile physical inventory against A&D records

Conduct a full inventory count and cross-reference each firearm against your bound book entries. Document any discrepancies.

Review all Form 4473 entries for completeness

Check that all fields are filled in, dates are correct, NICS transaction numbers are recorded, and forms are signed.

Organize multiple transaction reports (Form 3310.4)

Confirm that all multiple handgun sales within a 5-day period have been reported to ATF and local law enforcement.

Physical Premises

Verify FFL license is posted and visible

Your current FFL license must be displayed at the licensed premises in a location visible to customers.

Confirm secure storage for all firearms

All firearms must be stored in a secure manner when the premises is unattended. Verify locks, safes, and alarm systems are functional.

Check that business hours and address match license

Your operating hours and physical address must match what is on file with ATF. Report any changes before the inspection.

NICS & Compliance

Audit NICS background check records

Ensure you have a NICS transaction number or state POC confirmation for every transfer. Verify no transfers were completed without a proceed or after a delay expired improperly.

Review denied transaction procedures

Confirm that all NICS denials resulted in no transfer and that denied 4473 forms are retained and flagged appropriately.

Verify compliance with state and local laws

Review any state-specific requirements (waiting periods, permits, registration) that apply in your jurisdiction beyond federal requirements.

Prepare employee access and training records

Document which employees have access to firearms and 4473 forms. Keep records of any compliance training completed.

Designate a point of contact for the inspection

Identify who will be present to speak with the IOI (Industry Operations Inspector) and ensure they have access to all records and keys.

Understand the current ATF enforcement posture: graduated administrative action (post zero-tolerance)

ATF Order 5370.1H (May 6, 2025) replaced the prior zero-tolerance policy with a graduated administrative action framework. Current ATF policy weighs willfulness, materiality, and prior compliance history before recommending license revocation — a single inadvertent paperwork error is no longer an automatic revocation trigger. This does NOT excuse non-compliance; serious or repeated violations (failure to run NICS, false statements on records, knowing transfers to prohibited persons) still result in revocation. Document any inadvertent errors with corrections per the single-line-through procedure and demonstrate good-faith compliance practices throughout the inspection.