ATFE Issues

Imports of USMIL Items
Advising U.S. importers on the requirement to register as an importer of Defense Articles on the U.S. Munitions Import List (USMIL) in 22 CFR 447.21, including relationship between USMIL and the ITAR’s U.S. Munitions List.
Preparing and submitting ATF Form 6 applications for permits to import Defense Articles
Advising on the scope, availability, and process for using exemptions to ATFE permit requirements for imports, including the exemption for imports to support U.S. Government contracts.

ATFE Firearms & Explosives Licensing
Assistance in preparing and obtaining a Federal Firearms License (FFL) for importing, manufacturing, or dealing in firearms, ammunition and destructive devices.
Providing guidance on the requirements applicable to the import, export, and dealing in firearms and destructive devices under the Gun Control Act and the National Firearms Act, as implemented in the ATFE regulations in 27 CFR Parts 478 and 479.
Advising on the requirements of federal explosives law (18 U.S.C. §§ 841-848), as well as the regulations implementing those provisions (27 C.F.R. Part 55) that require registration and, in some cases permits, to deal in explosive materials.

Representative Matters

● We assisted a U.S. client with obtaining a license to deal in certain explosive materials that are used in the manufacture of weapons systems, and successfully obtained a waiver of the storage requirements on the basis that the client buys and sells – but does not take possession of – the explosive materials at issue.

● Successfully obtained an ATFE permit for the permanent import of a non-U.S. unmanned aerial system for purposes of marketing and demonstration in the United States.

● Assisted a U.S. manufacturer in successfully obtaining a Federal Firearms License for the importation of destructive devices so that it can import foreign-origin grenade launchers and missiles for purposes of integration with weapons systems sold to the U.S. Government and non-U.S. Government customers.