One day after Polymer80 won in court and started selling P80 kits with both jigs and frames for the first time since the Bureau of Alcohol, Tobacco, Firearms and Explosives’ (ATF) rule surrounding frames and receivers (Final Rule 2021R-05F), the ATF issued an open letter threatening to prosecute sellers of gun parts and tools if they “structure” transactions to avoid the regulation.
Structuring is a financial crime where a person or business structures deposits to avoid setting off red flags. After 9-11, when a person or a company deposit over $10,000, they must complete extra paperwork. The government runs additional checks to ensure they are not laundering money for a criminal enterprise or terrorist organization. Many people make smaller deposits over several days to avoid these extra checks. To discourage this, the government has made it a serious crime to structure transactions. Now the ATF is using the same standard for purchasing gun parts.
If Company A produces a blank frame and a jig and then sells the blank frame and directs the buyer to another site to buy the jig, the ATF seems to be saying that the company is structuring the transaction. This definition of “structuring” is a departure from any the government has ever used.
Click the link to read the whole article: ATF Warn of Structuring
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