Dynamic leader with over 24 years at the US Department of Justice, ATF, excelling in regulatory oversight and compliance. Proven track record in leading change and building coalitions, achieving significant civil settlements. Expertise in firearms and explosives regulations, complemented by strong communication skills to foster partnerships across federal and state agencies.
TOP SKILLS
Leading changeUnlike many traditional career paths, atf industry operations must embrace constant self-analysis and evaluation of our effectiveness if we want to meet our operational goals. like any thriving market driven industry, the firearms and explosive industries evolve to consumer demands and perceived opportunity for profitability. technology is implemented to improve industry productivity, reduce overhead, and at times to circumvent legal interpretations, in which atf industry operations provides oversight and accountability. additionally, expanding our regulatory objectives to include accountability within the alcohol and/or tobacco industries should be considered when the potential of non-compliant industry practices leads to the funding of criminal enterprises.Department of defense contractors and subcontractors as manufacturers of munitions and/or destructive devices are members of both the firearms and explosives industry. at various stages in the production of such devices, these materials often meet the definition of an explosive and eventually a firearm, which requires contractors to hold either or both a federal firearms and explosives license depending on what they specifically produce. once manufactured, the destructive devices are subject to government testing in adherence with the applicable government contract. devices that fail to meet quality control expectations are frequently retained and sold to u.s. domestic defense companies and to u.s. state department approved entities. the licensed industry members will also incorporate production overruns intending to commercially distribute them to those same potential customers. the practice is directly related to increasing the profitability of each production. as such, the destructive divides are required to be marked for traceability and processed through the atf nfa division (for manufacture, transfer, and export) when introduced into these non-department of defense markets.In 2015/2016, regulatory investigative findings from the atf nashville, tampa, and kansas city field divisions disclosed there was a failure to mark destructive devices and maintain a record of manufacture or a record of disposition related to the products’ interstate commerce. the instances of the violations were documented from a historical standpoint, so the numbers of instances for the failed markings for the tennessee and iowa facilities were 5 million and 5.4 million, respectively. the number of instances for the failed disposition record was 71,252 for the tennessee facility and 54,688 for the iowa facility. the industry member transferred unmarked and unregistered destructive devices without the required nfa division notification and approval for interstate commerce. the iowa facility misrepresented information to the nfa division by attempting to register devices while reporting false dates of manufacture, resulting in thousands of the devices being distributed to the u.s. state department approved entities. the tampa industry member used a department of defense contract to obtain explosive materials to manufacture the destructive devices for non-dod customers. the explosive components (high, explosives, fuse, and initiators) used in the manufacture of the devices did not have the required markings under the gun control act or safe explosive act, which would only be allowable under a u.s. government contract. the tampa industry member distributed 321 destructive devices to a storage facility that did not hold a federal firearms license and did not have a special occupational tax stamp. these cases involved subcontractors that crossed into seven different atf field divisions.The operations conducted in violation of the gun control act (gca), national firearms act (nfa), and safe explosives act (sea) were benefiting the industry financially through reduced operational costs, and expanded products for commercial distributions. the operations had a direct negative impact on the traceability and accountability of destructive devices. i faced two significant challenges: 1) find a reasonable corrective action with components of the department of defense, and 2) evaluate how the operational failures of the industry members and subcontractor industry members had not been identified by atf in prior compliance investigations nationally. to correct the immediate concern of determined contraband destructive devices, i coordinated with multiple agencies within the department of defense to ensure products critical to the u.s. government were readily available. additional destructive devices were coordinated for destruction as agreed to by atf counsel and representatives for the applicable industry members. in reviewing atf’s historical investigative reports, i determined that overall, the industry operations investigators nationally did not understand our jurisdictional authority as related to department of defense contractors, nor how such industry members should conduct operations to be compliant to the regulations. industry members further confused the issues by identifying firearms and explosives as "commercial" when being investigated by the defense contract management agency, but identifying them as “under government contract” when being investigated by atf. in briefing atf’s field operation’s senior executive service leaders, i summarized atf’s failures regarding efforts to regulate this industry. the subject matter is too complex in nature to present in basic training, and none of the advanced training programs for industry operations directly addressed the department of defense contractors. further, the atf industry operations manual did not provide the necessary guidance to successfully determine compliance to the gca, nfa, and the sea.
