FFL Compliance Checklist

1. Daily Operations

Review business operations, including ownership, state and local licenses or permits, and responsible person information to ensure all is current.


Screen/background-check new hires to ensure they are “non-prohibited.”  Annually check all employees.  Create a “self- reporting” program for employees if they become prohibited.


Create your Operations Manual (Standard Operating Procedures) for required activities.


Post your FFL/SOT.


Post the Youth Handgun Safety Act poster and distribute pamphlets with handgun transfers.


Provide a locking security device with every handgun transfer.


Train employees and keep written/digital training records, meeting minutes, disciplinary write-ups, etc.


Provide “Prohibited Persons” training.  For example, THE NSSF provides such resources through the Don’t Lie for the Other Guy program: https://nssfrealsolutions.org/programs/dont-lie-for-the-other-guy/


Respond to all traces within 24 hours, keep proof of your response.


Print/download the daily NICS History Query in eNICS.


Run and download your monthly NICS Query History report and save it to a monthly PDF file.


Review eNICS daily for Delayed transactions and update box 27D with respective dates. Contact customers for firearms that have moved to Proceed, Denied and for Brady Date expirations. File Denied or cancelled (and not transferred) 4473s separately. \Every 4473 that has a NICS/state control number in Box 27B MUST be retained for life of FFL.

Maintain an “ATF Communication Log” to document any correspondence with the ATF or local law enforcement, unusual activities, staff training, straw-purchase activities, and reports, etc.


Segregate and tag/label personal (owner) firearms separate and away from FFL inventory.


File non-required documents you keep for transfers such as copies of IDs, receipts, gun tags, handgun permits, etc. in your “Buddy File” (business records file not subject to ATF inspection).


Prevent a Burglary - Review internal and physical security controls and test alarms and security cameras monthly. – For guidance use the NSSF Operation Secure Store program: https://nssfrealsolutions.org/programs/operation-secure-store/

2. Acquisitions and Dispositions

Inspect markings on every firearm and use information engraved/stamped on the firearm to complete acquisitions. Never use invoices, shipping documents, marketing documents/packages/cartons to enter the required information into the bound book/A&D records. Include manufacturer AND importer if not manufactured in the United States.


Acquire and dispose firearms on the same day received or transferred.


Every firearm secured in the FFL licensee’s premises overnight must be logged into a bound book including new acquisitions, used guns, pawns, FFL transfers received, gunsmithing.


Maintain separate bound books for a. retail, b. gunsmith/repair, c. NFA.


DO NOT dispose firearms until the firearm has left the licensed premises.


At a minimum, conduct monthly or quarterly serial-number inventories.


Back up electronic A and D and 4473s (server stored) daily, and as required.


Dispose firearms that are (a.) sold/redeemed/transferred to customers, (b.) sent out as an FFL-to-FFL transfer, (c.) sent to another FFL for repair or manufacturing, (d.) destroyed by the store, and (e.) confiscated by law enforcement.


On FFL-to-FFL transfers, list the FFL business name and FFL license number in the “acquired from” or “disposed to” sections.


For FFL-to-FFL transfers, obtain a copy of the license for the “send to” FFL and check FFL EzCheck prior to shipping to an address. https://fflezcheck.atf.gov/FFLEzCheck/


Conduct monthly inventories comparing all firearms on hand to your Bound Book and then then the Bound Book to guns on hand. Commonly known as a “Gun to Book & Book to Gun” inventory process. Look for firearms details and guns not acquired or despised timely.

3. ATF Inspections

Implement a best practice to be “Inspection-Ready” every day.


Review all past ATF correspondence and visits and prevent any re-occurrence of prior violations documented.


Understand and follow all ATF, State and local transfer requirements and restrictions.


Prepare for your next inspection if you have not been inspected within the last 3 years or if you received any prior ATF Adverse Actions or Warnings or recently have high numbers of traces or have been added to the Demand 2 program.


Review the recent 12 months of completed Form 4473s as the ATF inspector (IOI) is required to audit/review the prior 12 months of transfer activity records when they conduct an inspection. Additional records may be checked if necessary.


Understand and communicate the ATF Zero Tolerance program to all employees. Focus on: (a.) transferring a firearm to a prohibited person, (b.) failing to conduct a required background check, (c.) falsifying records, (d.) failing to respond to a trace request, (e.) refusing to permit ATF to conduct an inspection, (f.) missing firearms, (g.) failing to verify and document buyer eligibility, (h.) maintain records needed for successful firearms tracing, and (i.) reporting multiple sales of handguns or long guns.

4. Firearm Transfers (Form 4473 and FFL Transfers)

Ask for the customer’s photo ID prior to every transfer. Confirm (a.) ID is not expired, (b.) “in- state” for handguns/others, (c.) 21 or over for handguns/others, (d.) current address, and (e.) middle name or middle initial.


Begin section A before section B and proceed in order.


Customers MUST sign and date recertification for any transfer that does not occur on the date in Box 23.


Compare and ensure all personal info in section B info MATCHES photo ID presented.


Check that ALL section 21 questions are answered accordingly, with nothing left blank or indicating prohibited.


DO NOT accept any expired or out of state concealed weapon permits or purchase permits where carry permit background check exemptions are permitted.


Before transferring to anyone in “Delay” status, view and print the eNICS status screen and print the time-stamped report as proof of current Brady Expiration Date status prior to the transfer. File with your business records/“Buddy File.”


Complete all “denied” and “cancelled” transfers where a background check was initiated and logged into box 27B.  Complete through box 35 – DO NOT enter a “date transferred” in box 36.


Utilize the “Rule of 2” – create a discipline that 2 employees review every transfer PRIOR TO the firearm being released to the customer. Mandate that a 3rd person review the completed 4473s BEFORE they are filed.


During the transfer form review, look for the correct information entered into each box/section. DO NOT rush this process. EVERY BOX/ENTRY MUST make sense!


Make corrections / updates, as necessary.  You MUST have the correct information in the right location on your Form 4473s and in your A & D records PRIOR to the ATF Investigators (IOIs) arriving. Be sure customers and employes add their initials and dates to any corrections made to the Form 4473 or A&D records. DO NOT use white-out to correct errors on any federal records.


Do not transfer a gun if 30 days have passed since the date on Form 4473, Box 27a.


Do not transfer a delayed transfer prior to the Brady Expiration date (verify using eNICS).


Print your NTN Statues History detailed report for every NTN received (file in “business/Buddy File) and print a monthly NTN History Query report or PDF file and retain digitally for future reference.


When transferring a “Delay”, be sure to mark an item in BOX 27D with an update date.


When accepting a document for Box 26B (alternate proof of current address or name), list the issuing authority and name of the document. You are not required to keep copies.


If filing by transaction number, account for all transaction numbers.


If processing a Military/Active-Duty transfer, military photo ID and the PCS orders must be used together. A state-issued driver’s license should not be used with PCS orders.


Review and complete all Denials for completeness. You are required to keep all Denials and FFL dealer and FBI-NICS “Cancels” (any Form 4473 with a NICS or state control number in box 27B where the firearm was not transferred). File separately forever.


Make corrections accordingly for pre-transfer and post-transfer errors. Initial and date every correction (customer and employee). DO NOT falsify records.


Complete and submit/send required multiple handgun (3310.4) and multiple rifle (3310.12) forms daily and attach to the respective 4473. Maintain “proof” of sending, faxing, or emailing the forms with your business records/”Buddy File.”


Use the Form 4473 Continuation Sheet when transferring more than 3 firearms.

Updated on: 03/07/2025