PolicyBrief
S. 3212
119th CongressNov 19th 2025
AIM Act
IN COMMITTEE

The AIM Act eliminates numerous existing restrictions on the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) regarding firearms data, record-keeping, licensing, and import regulations.

Chris Van Hollen
D

Chris Van Hollen

Senator

MD

LEGISLATION

AIM Act Removes Safeguards on Gun Data, Lowers Bar for Federal Firearms License Revocation

The aptly named ATF Improvement and Modernization Act of 2025 (AIM Act) is essentially a massive legislative cleanup bill designed to strip away nearly two decades of restrictions placed on the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF). If you’ve ever heard of the “Tiahrt Amendments” or the rules preventing the ATF from creating a national gun registry, this bill is focused on making those restrictions disappear. It systematically removes funding limitations and statutory prohibitions that have previously kept the ATF from centralizing records, fully utilizing trace data, and aggressively enforcing rules against licensed gun dealers.

The End of the 24-Hour Rule: Permanent Background Check Records

One of the most consequential changes is buried in Section 5, which eliminates the requirement that records from the National Instant Criminal Background Check System (NICS) be destroyed within 24 hours. For years, this 24-hour limit has been the key legal barrier preventing the federal government from creating a comprehensive, searchable database of gun owners, often referred to as a national gun registry. The AIM Act repeals this requirement across seven different appropriations acts dating back to 2004. The immediate, real-world impact is that the ATF will now be legally empowered to retain permanent records of all approved NICS checks. While the government might argue this is necessary for law enforcement investigations, for gun owners and privacy advocates, this is the infrastructure for a national registry, which fundamentally shifts the landscape of firearms data privacy.

License Revocation Just Got Easier

This bill significantly changes the game for the roughly 50,000 Federal Firearms Licensees (FFLs)—the gun stores, manufacturers, and importers—who operate legally. Currently, the ATF must prove a dealer “willfully” violated the law to revoke their license. Sections 12 and 14 of the AIM Act change this standard to a “knowing” violation. This is a huge legal difference. “Willfully” implies an intentional, bad-faith effort to break the law, while “knowingly” simply means the dealer was aware of the action, even if they didn't realize it was illegal or if it was a minor administrative error. For the small, independent gun shop owner, this means the threshold for losing their entire business just got dramatically lower, increasing the regulatory risk for every transaction.

Centralizing Data and Increasing Oversight

Beyond the license standard change, the bill gives the ATF broad new data collection and enforcement tools. Section 3 removes the prohibition against the Department of Justice centralizing or consolidating the acquisition and disposition records maintained by FFLs. This means the paper records of every gun sale kept by dealers could be digitized and centralized by the government. Furthermore, Section 4 eliminates the ban on the ATF requiring FFLs to conduct mandatory physical inventory checks. Up until now, dealers couldn't be forced to physically count their inventory, but now the ATF can mandate it. This adds a new layer of regulatory burden and compliance costs for licensed dealers, who are already juggling complex federal regulations.

Reducing Judicial Review and Accountability

Perhaps the most concerning change for FFLs facing enforcement action is found in Section 13, which severely limits how courts can review ATF decisions. The bill removes the right to “de novo” review, which is a legal term meaning the court could look at the case fresh and make its own determination. Instead, the court must now give deference to the Attorney General’s initial decision. Even worse, the court is restricted to only considering the evidence that was part of the original administrative record. If an FFL is fighting a license denial or revocation, they will not be allowed to present new evidence in court to defend themselves. This drastically tilts the scales of justice in favor of the ATF, reducing the accountability of their enforcement decisions.

What About Gun Tracing and Imports?

Finally, the bill wipes away the restrictions that prevented the ATF from using firearms trace data to draw “broad conclusions about firearms-related crime” (Section 2). This means law enforcement will be able to analyze and share trace data much more widely than before. Additionally, Sections 7 and 10 remove restrictions on the ATF’s ability to regulate the importation of certain surplus military firearms and shotguns, giving the agency more leeway to deny import applications based on their suitability for “sporting purposes.” In short, the AIM Act is a comprehensive overhaul that removes nearly every major legislative check on the ATF’s power to collect data, regulate dealers, and enforce firearms laws.