FFL Import & Export Regulations 4 ā Questions and Answers
Question 1: Under the Import Regulations, which firearms are exempt from the sporting-purposes test because they are specifically listed as importable by statute?
- Military surplus bolt-action rifles chambered in NATO calibers
- Antique firearms manufactured before 1899 (Correct answer)
- Semi-automatic pistols with ambidextrous controls
- Any firearm valued under $500
Correct answer: Antique firearms manufactured before 1899
Antique firearms (manufactured before 1899 or muzzle-loaders) are exempt from GCA import restrictions, including the sporting-purposes test.
Question 2: A foreign manufacturer wants to permanently export rifles to a US FFL importer. Under ITAR, the transaction requires a State Department license in which form?
- DSP-5 (Permanent Export) (Correct answer)
- DSP-73 (Temporary Export)
- DSP-61 (Temporary Import)
- DSP-83 (Non-Transfer Certificate)
Correct answer: DSP-5 (Permanent Export)
DSP-5 is the permanent export license under ITAR used when defense articles leave the US or a foreign party ships USML items to a US recipient.
Question 3: Which regulation requires an FFL importer to mark imported firearms with the importer's name, city, and state if not already so marked by the foreign manufacturer?
- 27 CFR Ā§ 478.92(a)(2) (Correct answer)
- 18 U.S.C. Ā§ 922(p)
- 27 CFR Ā§ 479.102
- ATF Ruling 2016-1
Correct answer: 27 CFR Ā§ 478.92(a)(2)
27 CFR Ā§ 478.92(a)(2) requires importers to add their name, city, and state to any firearm that the manufacturer did not already mark with that information.
Question 4: Brokering activities under ITAR (e.g., arranging a foreign-to-foreign sale of USML firearms) require registration with DDTC under:
- 22 CFR Part 129 (Correct answer)
- 15 CFR Part 748
- 27 CFR Part 479
- 22 CFR Part 120 only
Correct answer: 22 CFR Part 129
22 CFR Part 129 governs ITAR brokering, requiring persons who broker USML transactions to register separately from exporters.
Question 5: Under ATF's sporting-purposes evaluation criteria, which of the following features on a semi-automatic rifle is most likely to result in an import ban?
- Thumbhole stock
- Detachable box magazine plus a folding stock (Correct answer)
- A bipod rail
- A muzzle brake
Correct answer: Detachable box magazine plus a folding stock
ATF's 1989 and 1998 import studies identified combinations of military-style featuresālike a folding stock with a detachable magazineāas disqualifying for sporting purposes.
Question 6: If an FFL discovers that imported firearms in inventory have missing or illegible country-of-origin markings, the correct action is to:
- Sell the firearms before ATF discovery to avoid liability
- Contact ATF to request a variance or clarification before further transfers (Correct answer)
- Re-mark the firearms using any available engraving tool
- Return all firearms to the foreign manufacturer immediately
Correct answer: Contact ATF to request a variance or clarification before further transfers
FFL holders with marking compliance issues should contact ATF's Firearms and Ammunition Technology Division for guidance or a variance before making transfers.
Question 7: Which OFAC program most directly affects an FFL considering a sale to a foreign buyer in a country under a US arms embargo?
- Specially Designated Nationals (SDN) List screening (Correct answer)
- Anti-Boycott Regulations
- Foreign Corrupt Practices Act (FCPA)
- Bank Secrecy Act (BSA) reporting
Correct answer: Specially Designated Nationals (SDN) List screening
OFAC's SDN List identifies embargoed individuals, entities, and countries; an FFL must screen all export transactions against it to avoid prohibited transfers.
FFL Import & Export Regulations 4
Under the Import Regulations, which firearms are exempt from the sporting-purposes test because they are specifically listed as importable by statute?