Top 10 Reasons the ATF Revokes FFLs

By Kristy Bauer Carney

Under the Biden Administration’s new ‘Zero Tolerance Policy’, the ATF has been directed to crack down on “rogue” gun dealers, meaning even a single violation could result in an FFL being revoked. With stricter regulations and increased pressure from the ATF, it's more critical than ever that FFLs are FULLY compliant to ensure protection from license revocation.

We’ve compiled a list of the top 10 ATF violations the are leading to license revocation under the new policy. As you look through this list, think through your own processes.

  • Are you still handling firearm transactions manually? Manual processes take longer and have an exponentially higher risk of error.
  • Are your processes digital but you’re bouncing between multiple systems to complete forms, process transactions and update your A&D book? This still leaves you exposed to human or procedural errors that could cost you your license.
  • How much time are you wasting, and you still have a chance of error?

The only way to completely mitigate risk is with a fully integrated and fully compliant digital system. Read on to see the common violations that are now cause for revocation and how you can avoid them with Bravo Point of Sale and E4473.  

Top 10 Violations Leading to FFL Revocation  How to Avoid Violations with Bravo 
Failure to complete a 4473  Built into the sales workflow, the E4473 cannot be skipped or forgotten.
Unsigned 4473s  All signatures are required before the transaction can be completed, including any second signature for purchasers who received a “HOLD” on their background check.
Expired permits and/or drivers' licenses Automatically validates dates preventing expired documentation and/or identification or certifications from being accepted.
Transferee answers a yes to 21b-k and the 4473 is “approved” regardless  Sale of firearm not “allowed” if any Yes/No questions have been improperly answered.
Not logging firearms in or out of the A&D book A&D book entries are automated when firearm inventory is added, sold, or transferred to another FFL.
Logging in firearms before receipt The firearm serial number is required data, users can not bring a firearm into inventory without it.
Not recording transfers to other FFLs A&D book entries are automated when firearm inventory is added, sold, or transferred to another FFL.
Adding a second firearm to a completed 4473 Usually a sign of employee theft, the E4473 cannot be altered once the sale is closed.
Failing to respond to a trace request (24 hours or less) Trace requests take seconds and proper credentials can be issued to trusted employees in the case of vacation. 
Failure to report multiple gun purchase (must happen the date of the sale) Easy, automated form fill completion of the 3310.4 & 3310.12. 

All of these most common citations, and subsequent loss of FFL under the ‘Zero Tolerance Policy,’ are easily avoidable using Bravo Store Systems suite of FFL solutions.

Want to learn more about how Bravo can help you simplify compliance? Schedule a demo.

About the Author

Kristy Bauer Carney | Head of Product Management

As Head of Product Management at Bravo, Kristy is responsible for leading Bravo's development roadmap. Kristy has over 15 years of experience working across all levels of pawn and FFL. Having worked as a pawnbroker and in sales and product development for multiple pawn software companies, including PawnMaster, she's a pro at understanding industry trends and market outlooks, and how that can impact Bravo customers. She is a product expert who knows what matters to pawnbrokers, and is known to go above and beyond to help develop the best solutions for their needs.


Kristy holds Masters certificates in Internet Marketing from the University of San Francisco and UX Design from the UX Design Institute in NY. She lives in Stoddard, WI with her husband, son, dog and two cats.