Why FFLs should care
The term “willfully” is central to important firearms licensing and enforcement provisions. ATF proposed adding a regulatory definition to its Gun Control Act regulations, which could affect how the agency describes the standard in administrative actions and compliance guidance.
Current status
Comments closed August 6, 2026. Until a final rule takes effect, do not treat the proposed text as the operative regulation. Regardless of the final wording, written procedures, employee training, documented corrections, and prompt escalation of known compliance problems remain sensible controls.
Primary source: ATF — Defining “Willfully” for Firearms Violations (1140-AA88) ↗
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