In fact, since the enactment of ATF's Zero Tolerance policy, there has been a 200% increase in FFL revocations. This is due to the agency's new interpretation of the word "willful." 

Congress has made clear that, when revoking a license, ATF is required to prove that an FFL "willfully" violated the law before the statutory punishments can be levied. 

This deliberate addition to the law by Congress presented a problem for ATF, as virtually all gun dealers are well-intentioned, law-abiding people who always attempt to comply with the law.  

Therefore, to claim "willfulness" to violate the law by people who almost uniformly try to follow the law -- ATF had to get creative.  

Now, ATF claims that a single manual, potentially given to an FFL decades ago, proves that the FFL knew the law and thus "willfully" decided to violate it.