Physical and procedural security measures for FFL pawnbrokers.

It has been stated that each year the BATF receives thousands of reports of the theft/loss from federally
licensed firearms dealers. As a pawnbroker, the risk of criminal activity for those that deal in firearms
increases for those individuals seeking to target that aspect of the business. In many incidents, the criminal
will spend a considerable amount of time casing (evaluating) the business to determine their weaknesses
or vulnerabilities only to later try and capitalize on these. While it may be impossible to eliminate all risk, as
a pawnbroker with an FFL there are many ways to reduce the risk by “hardening the target” and making
criminals think twice about their activity. The following are considered the best practice physical security
and procedural controls to reduce that risk. While some of the following measures require time and capital
expenditure, others can be implemented at no cost and in little to no time.

  • Only show one firearm to a customer at a time. If the customer requests to see another firearm,
    that firearm should be adequately secured first prior to showing the other one.
  • Install trigger locks or plastic ties on all firearms; at a minimum, on all firearms on display. In
    addition, trigger locks should be available for purchase where firearms are sold in accordance with
    federal law.
  • Ensure that the showroom floor/retail firearms storage/display area is constantly staffed while
    customers are in the store. Generally, two employees are recommended. Note: CCTV coverage
    alone would not suffice for the mere presence of an employee.
  • All firearms should put on display and removed from displays when no customers are present;
    before business hours or after business hours. All perimeter doors should be locked during this
    time and if the premises alarm system is setup in such a manner, the premises perimeter contacts
    should be armed. If it is not feasible to secure all retail long guns in a secure room at night, low
    value retail long guns may be left in the showroom if there is adequate facility perimeter hardening
    (i.e. doors, walls, roof, other accessible openings, etc.) and the long guns are adequately and
    securely cabled to a fixed structure (i.e. wall) within the showroom during non-operational hours.
  • All showcases should be secured with a high security lock and remain locked when not in
    immediate access. Smash resistant glass or glazing should be installed on the top and all four sides
    in order to slow access to firearms and deter thieves, forcing them to spend minutes, rather than
    seconds, breaking through. In addition, all firearms should be adequately and securely cabled to a
    fixed structure (i.e. wall or showcase) within the showroom during operational hours.
  • All permanently issued access control devices (keys, cards, alarm codes, combinations) should be
    issued formally by receipt, to include the date, signatures of the persons involved, and a statement
    advising the recipient of their responsibilities to protect the device. A register should be used to
    document the location and issuance of all access devices providing access to the facility and
    firearms storage (to include access device storage containers). All locks (entrance and those
    providing access to firearms), alarm codes, and combinations should be routinely changed annually
    or sooner if an access code holder is terminated, there is suspected compromise, or there is a
    change in employment status where the person issued no longer requires such access. Restricted
    access keys should be audited monthly, where the daily activity does not suffice for accountability,
    with the results documented.
  • Ensure all ingress/egress facility access points, firearms transaction areas, firearms storage (i.e.,
    showcases, safe/vault, etc.) and handling areas (i.e., gun-smithing) are covered by adequate CCTV
    camera coverage. Make sure video recordings are retained for at least 30 days. Should any
    incidents occur, they should be reported for insurance purposes. In addition to the 30 day storage
    of video recordings, these incidents should be saved on a separate storage device for future use
    and investigative purposes
  • Follow state and federal requirements pertaining to legally accepting or transferring firearms from
    customers, to include the proper reporting, serial number checks, and actions related to suspicious
    sellers.
  • A register of all firearms should be kept on-site to include the make, model, caliber, serial number,
    and other identifiable features of the firearm. Furthermore, all firearms should be audited
    (inventoried) under dual control (by two people) on a specified and frequent basis.
  • Ensure the layout of the store allows for unobstructed views of all firearms and remove any items
    that may cause blind spots.

Other considerations. Please consider that in states permitting concealed and open carry of firearms,
there is a reasonable expectation by the public that firearms dealers are “2nd Amendment Friendly” and
permissive of carry in their stores. While this may be the case, continue to ensure safe practices are made
known and enforced. Ensure that all firearms remain holstered at all times. Firearm aficionados can be
eager to show off their new “pieces” or latest custom modifications. While firearm handling safety is of
primary concern yet again here, also consider how an onlooker might view this scene from a distance – in
the worst case, this could be mistaken as a robbery in progress!

Badger Firearms lawsuit:
http://archive.jsonline.com/watchdog/watchdogreports/wounded-officers-lawsuit-against-badger-gunssettles-
for-1-million-b99632780z1-361609031.html

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