ATF Publishes New Agency Direction and Invites Some Revoked FFL’s to Reapply

Posted on by Dillon Harris, Esq.

As many of our readers are likely aware, on April 7, 2025 ATF rescinded the Zero Tolerance Policy that was implemented under the Biden Administration. Under that policy, ATF classified certain types of violations found during compliance inspections as “zero tolerance” and would issue a Notice of Revocation, no matter the number or circumstances around those types of violations.

Now, ATF is launching what they call a “New Era of Reform.” Their webpage on this New Era of Reform contains numerous steps they claim to have already taken or are currently taking, including:

  • Publishing a new Administrative Action Policy that emphasizes firearm traceability and public safety and deemphasizes immaterial paperwork errors
  • Removing revoked FFL inspection reports from ATF’s public website
  • Establishing a classifications board and requiring all new firearm classifications to be reviewed and approved by the Office of the Director prior to publication
  • Reversing a ban on the importation of non-lethal training ammunition
  • Updating ATF Form 20 (Authorization to Transport Firearms) into a simplified notice-based system
  • Publishing an open letter reversing a ban on the importation of dual use barrels
  • Publishing a ruling to allow electronic signatures on NFA forms

In addition to these changes, anybody who has held an FFL is likely aware that ATF has long had a policy of blacklisting Responsible Persons whose FFL is revoked, preventing them from obtaining or being a Responsible Person on any FFL’s in the future. Under this new policy, ATF is “encouraging any federal firearms licensees that had their licenses revoked or surrendered under the Enhanced Regulatory Enforcement Policy [Zero Tolerance Policy] to reapply. Those applications will be judged under the new Administrative Action Policy.”

If you or someone you know had an FFL revoked for a Zero Tolerance violation, contact FICG today to discuss your options.

Firearms Industry Consulting Group® (FICG®) is a registered trademark and division of Civil Rights Defense Firm, P.C., with rights and permissions granted to Prince Law Offices, P.C. to use in this article.

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Published by Dillon Harris, Esq.

Dillon grew up in Kingman, Arizona. During high school he got his first exposure to the legal system, spending a summer working in the Mohave County Attorney’s Office working with attorneys and office staff in various practice areas. Dillon attended Northern Arizona University in Flagstaff, Arizona and received a Bachelor of Science degree in Criminology and Criminal Justice with specializations in Legal and Criminal Investigation, Legal and Court Justice, and Justice in Politics, Media, and Popular Culture. Throughout and immediately after college he held positions in both the Court Administration and Clerk of Superior Court departments of the Superior Court of Arizona in Coconino County where he was part of a team that was awarded the 2016 Strategic Agenda Award by the Arizona State Judiciary and the 2016 Merit Award by the Arizona Association of Counties. Dillon graduated cum laude from Vermont Law School and passed the Uniform Bar Exam in 2020. He is licensed to practice law in Pennsylvania and Maryland and handles cases in both states dealing with firearms or general estate practice. He is also admitted to the Third Circuit Court of Appeals and U.S. District Courts for the District of Maryland, the Middle District of Pennsylvania, the Eastern District of Pennsylvania.

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