FFL Import & Export Regulations 5 — Questions and Answers
Question 1: Section 922(r) of the GCA prohibits assembling a semi-automatic rifle from imported parts if more than how many of its components are imported?
- 5
- 7
- 10 (Correct answer)
- 15
Correct answer: 10
18 U.S.C. § 922(r) and 27 CFR § 478.39 prohibit assembling a non-sporting semi-automatic rifle if it contains more than 10 imported parts from the defined list of 20 components.
Question 2: A licensed exporter under ITAR fails to file a required export report with DDTC. The maximum civil penalty per violation under 22 U.S.C. § 2778(e) is:
- $10,000
- $100,000
- $1,000,000
- $1,302,588 (inflation-adjusted) (Correct answer)
Correct answer: $1,302,588 (inflation-adjusted)
ITAR civil penalties are subject to Federal Civil Penalties Inflation Adjustment Act increases; as of recent adjustments, the per-violation cap exceeds $1.3 million.
Question 3: The Wassenaar Arrangement is relevant to US firearms exporters primarily because it:
- Prohibits all exports of small arms to non-NATO countries
- Establishes multilateral guidelines that inform US export control lists and licensing decisions (Correct answer)
- Replaces ITAR for exports to participating countries
- Requires UN approval for all firearms exports over 1,000 units
Correct answer: Establishes multilateral guidelines that inform US export control lists and licensing decisions
The Wassenaar Arrangement on Export Controls for Conventional Arms and Dual-Use Goods provides an international framework whose control lists influence US ITAR and EAR categories.
Question 4: When an FFL importer uses ATF Form 6A (Release and Receipt of Imported Firearms), what event triggers the need to complete and submit this form?
- When the Form 6 import permit is approved
- When the firearms are released from US Customs custody (Correct answer)
- When the firearms are first listed in the acquisition/disposition record
- When the importer transfers the firearms to a dealer
Correct answer: When the firearms are released from US Customs custody
ATF Form 6A must be completed upon release of imported firearms from US Customs and forwarded to ATF within 15 days to confirm the actual importation.
Question 5: Under EAR, Export Control Classification Number (ECCN) 0A501 covers which items?
- NFA machine guns and short-barreled rifles
- Firearms (other than USML) including semi-automatic pistols and rifles moved off the USML in 2020 (Correct answer)
- All ammunition and propellants
- Firearm silencers and suppressors
Correct answer: Firearms (other than USML) including semi-automatic pistols and rifles moved off the USML in 2020
ECCN 0A501 was created in 2020 when many conventional firearms were transferred from USML Category I to the CCL, requiring BIS licensing rather than ITAR for most exports.
Question 6: A US FFL exports a pistol to a foreign buyer using an incorrect ECCN, resulting in an unlicensed export. Which federal agency has primary enforcement authority?
- ATF
- BIS Office of Export Enforcement (OEE) (Correct answer)
- FBI
- DHS Homeland Security Investigations (HSI)
Correct answer: BIS Office of Export Enforcement (OEE)
BIS's Office of Export Enforcement (OEE) has primary jurisdiction over EAR violations, including use of incorrect ECCNs that bypass licensing requirements.
Question 7: An importer seeks to bring in a foreign-manufactured machine gun manufactured after May 19, 1986. Which law categorically bars this import for civilian transfer?
- National Firearms Act of 1934
- Gun Control Act § 922(o)
- Hughes Amendment to the Firearm Owners Protection Act of 1986 (Correct answer)
- Brady Handgun Violence Prevention Act
Correct answer: Hughes Amendment to the Firearm Owners Protection Act of 1986
The Hughes Amendment (§ 922(o)) banned civilian possession of machine guns manufactured after May 19, 1986, effectively barring post-'86 imports for civilian transfer.
FFL Import & Export Regulations 5
Section 922(r) of the GCA prohibits assembling a semi-automatic rifle from imported parts if more than how many of its components are imported?