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Proposed Rule2026-19642

Department of Justice; Response to Correspondence Requesting Rulemaking

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Published
September 25, 2026

Issuing agencies

Justice Department

Abstract

This document responds to 10 submissions received by the Department of Justice ("DOJ" or "the Department") or its components that asked the Department or a component to initiate rulemaking. After reviewing these submissions, the Department declines to initiate rulemakings in response to them.

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<title>Federal Register, Volume 91 Issue 185 (Friday, September 25, 2026)</title>
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[Federal Register Volume 91, Number 185 (Friday, September 25, 2026)]
[Proposed Rules]
[Pages 60905-60908]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2026-19642]


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Proposed Rules
                                                Federal Register
________________________________________________________________________

This section of the FEDERAL REGISTER contains notices to the public of 
the proposed issuance of rules and regulations. The purpose of these 
notices is to give interested persons an opportunity to participate in 
the rule making prior to the adoption of the final rules.

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Federal Register / Vol. 91, No. 185 / Friday, September 25, 2026 / 
Proposed Rules

[[Page 60905]]



DEPARTMENT OF JUSTICE

Office of the Attorney General

8 CFR Chapter V

27 CFR Chapter II

28 CFR Chapter I

[Docket No. OAG196; AG Order No. 7205-2026]


Department of Justice; Response to Correspondence Requesting 
Rulemaking

AGENCY: Office of the Attorney General, Department of Justice.

ACTION: Petitions for rulemaking; denial.

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SUMMARY: This document responds to 10 submissions received by the 
Department of Justice (``DOJ'' or ``the Department'') or its components 
that asked the Department or a component to initiate rulemaking. After 
reviewing these submissions, the Department declines to initiate 
rulemakings in response to them.

DATES: September 25, 2026.

FOR FURTHER INFORMATION CONTACT: 
    For submissions to the Executive Office for Immigration Review: 
Jamee E. Comans, Acting Assistant Director, Office of Policy, Executive 
Office for Immigration Review, 5107 Leesburg Pike, Suite 2500, Falls 
Church, VA 22041; telephone: (703) 305-0289.
    For submissions to the Bureau of Alcohol, Tobacco, Firearms, and 
Explosives: Vivian Chu, Office of Regulatory Affairs, Enforcement 
Programs and Services, Bureau of Alcohol, Tobacco, Firearms, and 
Explosives, U.S. Department of Justice, 99 New York Ave. NE, 
Washington, DC 20226; telephone: (202) 648-7070.
    For other submissions: Christina Greer, Senior Counsel, Office of 
Legal Policy, Department of Justice, Room 4254, 950 Pennsylvania Avenue 
NW, Washington, DC 20530; telephone: (202) 514-5739.

SUPPLEMENTARY INFORMATION:

I. Background

    The Administrative Procedure Act provides that ``[e]ach agency 
shall give an interested person the right to petition for the issuance, 
amendment, or repeal of a rule.'' 5 U.S.C. 553(e). The Department and 
its components have reviewed the submissions requesting rulemaking 
listed in Sections II and III of this Notice and decline to initiate 
the requested rulemaking actions for the reasons provided below.

II. Submissions Relating to Immigration Issues

A. Submission From 100 Law Professors Dated May 27, 2021

    On May 27, 2021, 100 law professors submitted correspondence, 
``express[ing their] views'' on the construction and application of the 
``unable or unwilling'' element of the ``refugee'' definition. 
Recently, the Attorney General issued a decision \1\ concluding that 
the legal framework within Matter of A-B-, 27 I&N Dec. 316 (A.G. 2018), 
is the best reading of the statute, inclusive of the ``unable or 
unwilling'' element of the refugee definition. See Matter of S-S-F-M-, 
29 I&N Dec. 207, 208 (A.G. 2025). Moreover, the Attorney General 
instructed that inquiries regarding the proper application of the 
``unable or unwilling'' standard ``are legal questions appropriately 
resolved as part of the Attorney General's authority to issue 
`controlling' decisions `with respect to all questions of law.''' Id. 
at 209 (quoting Immigration and Nationality Act (``INA''), 103(a)(1), 8 
U.S.C. 1103(a)(1)). Accordingly, as there is now current controlling 
agency precedent on the ``unable or unwilling'' standard, which 
specifically concludes that the issue is a legal question best left to 
case-by-case adjudication, the Department declines to undertake 
rulemaking as suggested in the law professors' submission. The petition 
for rulemaking is, therefore, denied.
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    \1\ Attorney General Pamela Bondi directed the Board of 
Immigration Appeals to refer the case for her review pursuant to 8 
CFR 1003.1(h)(1)(i). See Matter of S-S-F-M-, 29 I&N Dec. 207, 207 
(A.G. 2025).
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B. Submission From Jonathan M. Kaufman Dated January 5, 2022

    On January 5, 2022, Jonathan M. Kaufman submitted correspondence 
requesting that the Department engage in rulemaking to implement the 
William Wilberforce Trafficking Victims Protection Reauthorization Act 
of 2008 (``TVPRA''), Public Law 110-457, 122 Stat. 5044, asserting that 
his client is entitled to a decision from an Immigration Judge that has 
been informed by regulations promulgated in accordance with the TVPRA. 
Although described in the correspondence as a petition for rulemaking, 
this letter more squarely seeks resolution of issues for a particular 
case that are more appropriately addressed through the administrative 
adjudication or appeals process.
    Additionally, the Department is already considering potential 
regulatory action to implement the TVPRA and declines to take 
additional rulemaking action at this time. See, e.g., Spring 2025 
Unified Agenda, RIN 1125-AA70, Implementation of Section 235 of the 
William Wilberforce Trafficking Victims Protection Reauthorization Act 
of 2008; Treatment of Unaccompanied Children, <a href="https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202504&RIN=1125-AA70">https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202504&RIN=1125-AA70</a> [<a href="https://perma.cc/QM54-QS29">https://perma.cc/QM54-QS29</a>]. Should the Department decide to engage in rulemaking on 
these topics in the future, the public is welcome to comment on any 
proposed rule the Department may publish, as appropriate.

C. Submission From Members of Congress Dated October 30, 2023

    On October 30, 2023, four members of Congress (Senators Richard J. 
Durbin and Alex Padilla and Representatives Jerrold Nadler and Pramila 
Jayapal) submitted a letter to former Attorney General Merrick Garland 
and former Department of Homeland Security (``DHS'') Secretary 
Alejandro Mayorkas requesting rulemaking to amend custody procedures, 
including: shifting the burden of proof in bond proceedings; requiring 
consideration of an alien's ability to pay bond when setting a bond 
amount; providing aliens the opportunity to request review of mandatory 
detention determinations under section 236(c) of the INA, 8 U.S.C. 
1226(c); and scheduling periodic assessments of detained aliens to 
identify unreasonably prolonged detention. Since this letter was 
submitted, President Donald J. Trump issued an Executive Order titled 
``Securing Our Borders,'' which establishes that it is the policy of 
the

[[Page 60906]]

United States ``to take all appropriate action to secure the borders of 
our Nation'' by ``[d]etaining, to the maximum extent authorized by law, 
aliens apprehended on suspicion of violating Federal or State law, 
until such time as they are removed from the United States.'' E.O. 
14165, 90 FR 8467 (Jan. 20, 2025). The Department does not believe that 
the requested actions comport with this directive. As such, the 
Department denies the petition for rulemaking. Should the Department 
decide to engage in rulemaking on these topics in the future, the 
public is welcome to comment on any proposed rule the Department may 
publish, as appropriate. The Department also notes, with respect to the 
request to provide aliens the opportunity to seek review of mandatory 
detention determinations, that Department regulations already provide 
that aliens who are removable because of criminal or terrorism-related 
grounds, and are therefore subject to mandatory detention under section 
236(c)(1)(A)-(C) of the INA, 8 U.S.C. 1226(c)(1)(A)-(C), may seek ``a 
determination by an [I]mmigration [J]udge that the alien is not 
properly included within'' that class of aliens. 8 CFR 
1003.19(h)(2)(ii).

D. Submission From Marta Alicia Mejia Alvarenga Dated September 11, 
2023

    Marta Alicia Mejia Alvarenga (``Mejia Alvarenga''), through 
counsel, submitted correspondence dated September 11, 2023, titled 
``Petition for Rulemaking Concerning the ```Unable or Unwilling'' 
Standard, the Proper Application of That Standard, and the Meaning of 
the Statutory ``One Central Reason'' Test' (Matter of A-B-, 28 I & N 
Dec. 307, 309 (A.G. 2021)),'' in which Mejia Alvarenga requests that 
the Attorney General issue regulations clarifying certain requirements 
for asylum and a related form of protection from removal. The petition 
invokes President Joeseph R. Biden's Executive Order titled ``Creating 
a Comprehensive Regional Framework to Address the Causes of Migration, 
to Manage Migration Throughout North and Central America, and to 
Provide Safe and Orderly Processing of Asylum Seekers at the United 
States Border,'' see E.O. 14010, 86 FR 8267 (Feb. 2, 2021), which 
ordered the Attorney General and Secretary of Homeland Security to 
promulgate regulations within 270 days addressing certain requirements 
for asylum and protection claims, id. at 8271, a deadline that had 
passed by the time of the correspondence. Mejia Alvarenga also 
expresses ``surpris[e]'' that a ``draconian standard'' for determining 
whether a foreign government was or will be unable or unwilling to 
provide protection from a persecutor was applied to her asylum 
application and that the Department defended its application on 
judicial review. Finally, Mejia Alvarenga asks that the Attorney 
General issue the requested regulations unilaterally without the 
concurrence of the Secretary of Homeland Security, if obtaining such 
concurrence would ``slow down'' the process.
    The Department declines to initiate rulemaking in response to this 
correspondence for three reasons. First, on his first day in office, 
President Trump revoked the Executive Order Mejia cites in her 
petition. See Sec. 3(a), E.O. 14159, 90 FR 8443, 8443 (Jan. 20, 2025) 
(``Protecting the American People Against Invasion''); Sec. 2(u), E.O. 
14148, 90 FR 8237, 8238 (Jan. 20, 2025) (``Initial Rescissions of 
Harmful Executive Orders and Actions''). Thus, the basis for Mejia 
Alvarenga's request for rulemaking has been revoked. Second, although 
labeled as a petition for rulemaking, the document more squarely 
relates to Mejia Alvarenga's since-resolved challenge to her removal 
order and her arguments as to the proper standard to apply for 
determining whether a government is ``unable or unwilling'' to provide 
protection from a persecutor. Notably, the Fifth Circuit has denied her 
petition for review of her removal order. Mejia-Alvarenga v. Garland, 
95 F.4th 319 (5th Cir. 2024). In so doing, the Fifth Circuit concluded 
that the formulation of the ``unable or unwilling'' standard applied to 
her--that is, whether the government condones the harm or is completely 
helpless to protect the alien--is ``interchangeable'' with the ``unable 
or unwilling'' standard. Id. at 324 (citing Gonzales-Veliz v. Barr, 938 
F.3d 219, 233 (5th Cir. 2019)). Third, the Department is otherwise 
unable to evaluate Mejia Alvarenga's request for rulemaking because she 
provides no other reasons why the Department should grant her broad 
request and fails to identify any specific regulatory changes that she 
wants the Department to pursue. For these reasons, the Department 
declines to initiate a rulemaking in response to Mejia Alvarenga's 
correspondence. If the Department's view changes, Mejia Alvarenga is 
welcome to comment on any proposed rule it may publish, as appropriate.

E. Submission From Sandra Beatriz Bustamante Leiva Dated September 11, 
2023

    On the September 11, 2023, Sandra Beatriz Bustamane Leiva and her 
sons, through counsel, submitted a letter titled ``Petition for 
Rulemaking Concerning `Circumstances in Which a Person Should Be 
Considered a Member of a ``Particular Social Group,'' as That Term is 
Used in 8 U.S.C. 1101(A)(42)(A)' (Ex[e]cutive Order No. 14010, 86 FR 
8267, 8271 (Feb. 2, 2021)).'' The correspondence requests that the 
Department take regulatory action so that their cases can be ``reviewed 
under new regulations.''
    The Department notes that the Executive Order cited as the basis 
for the correspondence, Executive Order 14010, ``Creating a 
Comprehensive Regional Framework to Address the Causes of Migration, to 
Manage Migration Throughout North and Central America, and to Provide 
Safe and Orderly Processing of Asylum Seekers at the United States 
Border,'' has been revoked by two Executive Orders signed by President 
Trump on January 20, 2025. See E.O. 14159, 90 FR 8443; E.O. 14148, 90 
FR 8238. Accordingly, the Department will not be issuing rulemakings as 
directed by Executive Order 14010. Should the Department decide to 
engage in rulemaking on these topics in the future, the public is 
welcome to comment on any proposed rule the Department may publish, as 
appropriate.

F. Submission From the American Civil Liberties Union, et al., Dated 
April 15, 2024

    The American Civil Liberties Union (``ACLU'') and 52 other 
organizations filed a petition dated April 15, 2024, titled ``Petition 
for Rulemaking to Promulgate Regulations Governing the Provision of 
Interpreters for Affirmative Asylum Interviews,'' in which they request 
that DOJ and DHS promulgate regulations governing the provision of 
interpreters for affirmative asylum interviews before U.S. Citizenship 
and Immigration Services (``USCIS''). The Department thereafter 
received letters supporting the petition from the New Mexico Immigrant 
Law Center, American Gateways, the American Translators Association, 
and the Florence Immigrant & Refugee Rights Project, among other 
organizations.
    The Department is denying this petition because the Department does 
not have authority to amend regulations governing interviews before 
DHS's asylum officers. As the petition for rulemaking recognizes, 
authority over the adjudication of asylum applications is divided 
between DOJ and DHS. The Homeland Security Act of 2002 (``HSA''), 
Public Law 107-296, 116 Stat. 2135, as amended, transferred the 
authority over affirmative asylum

[[Page 60907]]

applications from the Attorney General to the Secretary of Homeland 
Security. See HSA 451(b)(3), 6 U.S.C. 271(b)(3). Accordingly, DHS has 
authority over the consideration of affirmative asylum applications and 
the concomitant procedures for such matters pending at USCIS. See INA 
103(a), 208(b), 8 U.S.C. 1103(a), 1158(b). The petition for rulemaking 
seeks an amendment to 8 CFR 208.9(g)(1), a DHS regulatory provision 
located in chapter 1 of title 8 of the Code of Federal Regulations. 
That provision governs interpreters in affirmative asylum interviews 
before USCIS and outlines the procedures applicable before USCIS in the 
affirmative asylum context--matters that are within the exclusive 
purview of DHS. Accordingly, the Department declines to initiate the 
rulemaking requested by the petition to amend the applicable DHS 
regulation.

G. Submission From Amica Center for Immigrant Rights Dated July 12, 
2024

    In a petition for rulemaking dated July 12, 2024, the Amica Center 
for Immigrant Rights, on behalf of itself and 28 other organizations, 
urged DOJ and DHS to adopt regulations allowing for Immigration Judge 
review of supervision conditions for aliens enrolled in the 
Alternatives to Detention (``ATD'') programs overseen by DHS. The 
organizations' stated concerns were based on the expanded use of ATD 
programs, the lack of meaningful review of ATD conditions for specific 
aliens, and the alleged harms caused by the use of such ATD programs.
    For the same reasons described in Section II.C of this Notice, the 
Department denies the petition. Specifically, since the petition was 
submitted, President Trump issued an Executive Order entitled 
``Securing Our Borders,'' which establishes that it is the policy of 
the United States ``to take all appropriate action to secure the 
borders of our Nation'' by ``[d]etaining, to the maximum extent 
authorized by law, aliens apprehended on suspicion of violating Federal 
or State law, until such time as they are removed from the United 
States.'' E.O. 14165, 90 FR 8467. The Department does not believe that 
the requested actions comport with this directive. As such, the 
Department denies the petition for rulemaking. Should the Department 
decide to engage in rulemaking on these topics in the future, the 
public is welcome to comment on any proposed rule the Department may 
publish, as appropriate.

H. Submission From the American Bar Association Dated December 12, 2024

    On December 12, 2024, the American Bar Association (``ABA'') 
through its President, William R. Bay, submitted correspondence 
recommending that DOJ and DHS expedite Federal regulations that enhance 
protections for individuals seeking asylum due to ``gender-based 
violence.'' Specifically, the ABA recommended that DOJ and DHS: (1) 
amend procedural standards regarding credibility assessments and 
interpretations of the nexus prong and the particular social group 
ground for asylum and withholding of removal; (2) develop and implement 
trauma-informed procedures, training, and safeguards for all 
interviews, hearings, and adjudications of ``gender-based'' claims for 
protection; and (3) implement procedural safeguards to minimize the 
risk of re-traumatization during interviews and hearings.
    The Department believes that the Attorney General's recent decision 
in Matter of S-S-F-M-, 29 I&N Dec. 207, provides sufficient clarity 
regarding particular social group and nexus standards. Moreover, 
procedural standards regarding credibility assessments and 
interpretations of the nexus prong are sufficiently defined and 
explained in the regulations and case law. See INA 208(b)(1)(B)(i), 8 
U.S.C. 1158(b)(1)(B)(i) (establishing that the protected ground must be 
``at least one central reason for persecuting the applicant''); id. 
1158(b)(1)(B)(iii) (establishing the factors required for a credibility 
determination); Matter of S-S-F-M-, 29 I&N Dec. at 209-210. Finally, 
Immigration Judges receive robust training, and training requirements 
do not need to be addressed through regulation. See, e.g., 
Massachusetts v. E.P.A., 549 U.S. 497, 527 (2007) (``[A]n agency has 
broad discretion to choose how best to marshal its limited resources 
and personnel to carry out its delegated responsibilities.''). 
Accordingly, the ABA's request is denied.

III. Submissions Relating to Other Subjects

A. Submission From the American Clinical Laboratory Association Dated 
September 30, 2024

    The American Clinical Laboratory Association (``ACLA'') submitted a 
petition dated September 30, 2024, pertaining to the Eliminating 
Kickbacks in Recovery Act of 2018 (``EKRA''), 18 U.S.C. 220. EKRA 
penalizes anyone who ``pays or offers any remuneration (including any 
kickback, bribe, or rebate) . . . to induce'' a referral of a patient 
to a lab, as well as anyone who solicits such remuneration. 18 U.S.C. 
220(a)(1)-(2). EKRA was enacted after the Department of Health and 
Human Services noted that abusive patient-brokering practices affected 
private health insurance plans and that there was a gap in enforcement 
because the Anti-Kickback Statute prohibited kickbacks impacting only 
public payors and did not apply to privately insured patients. Elayne 
J. Heisler & Jonathan H. Duff, Cong. Research Serv., R45423, Public 
Health and Other Related Provisions in P.L 115-271, the SUPPORT for 
Patients and Communities Act at 60-61 (updated Dec. 3, 2018).
    ACLA's petition requests that the Attorney General issue rules to 
permit a laboratory or any other employer to provide remuneration, in 
any manner (including variable compensation), to an employed sales 
representative provided that the employee does not knowingly and 
willfully provide materially false or misleading information to 
healthcare providers or patients. This appears to circumscribe the 
scope of the statute to apply only in situations involving fraud, which 
is already prohibited under other statutes. In addition, it would 
contradict existing legal authority that recognizes that sales 
representatives providing misleading information ``is not a necessary 
set of circumstances'' for violating EKRA, although ``it is 
sufficient.'' United States v. Schena, 142 F.4th 1217, 1226 (9th Cir. 
2025). It also misunderstands the legislation's core purpose: 
preventing financial incentives that could compromise patient care. 
Even in the absence of fraud, such arrangements are harmful because 
they deprive patients of choice and lead to unfair competition, 
overutilization of services, unnecessary testing, and increased health 
care costs. See Schena, 142 F.4th at 1224-25 (kickback payments to 
physicians that induce referrals are illegal under EKRA); see also 
United States v. Miles, 360 F.3d 472, 481 (5th Cir. 2004) (discussing 
an Anti-Kickback Statute case in which a sale representative's 
``judgment was shown to have been improperly influenced by the 
payments'' without any fraudulent misrepresentations); HHS-Office of 
Inspector Gen. Advisory Opinion No. 98-10 (Aug. 31, 1998) (Anti-
Kickback Statute Advisory Opinion), <a href="https://oig.hhs.gov/documents/advisory-opinions/385/AO-98-10.pdf">https://oig.hhs.gov/documents/advisory-opinions/385/AO-98-10.pdf</a> (certain marketing arrangements that 
include compensation based on a percentage of sales ``appear to be 
associated with an increased potential for program abuse,

[[Page 60908]]

particularly overutilization and excessive program costs'').
    While framed as a narrow exception, allowing variable compensation 
to sales representatives could effectively reintroduce the very 
kickback structures EKRA was designed to eliminate. Adopting a 
requirement that employees not knowingly and willfully provide false 
information would set a high bar for enforcement that could hinder 
efforts to prosecute cases where laboratories intentionally implement 
commission-based payment systems to directly reward referrals. The 
existing EKRA framework already permits reasonable employee 
compensation structures unrelated to referral volume, while restricting 
arrangements that create direct financial incentives for increasing 
referrals.
    Finally, any claimed regulatory burden imposed by EKRA on the 
laboratory industry is substantially mitigated by the law's age and 
established status. EKRA was signed into law by President Trump on 
October 24, 2018, and it has now been in effect for almost eight years, 
providing ample time for laboratories to adapt their business models 
and compliance programs to align with its requirements. The laboratory 
industry also has operated successfully under similar Anti-Kickback 
Statute restrictions for variable compensation in connection with 
Medicare and Medicaid for decades, with clear understanding of 
compliant compensation structures. See United States ex rel. Lutz v. 
Mallory, 988 F.3d 730, 738 (4th Cir. 2021) (``[F]ederal appellate 
courts have frequently, and indeed invariably, upheld Anti-Kickback 
Statute violations based on commission payments to third parties.''); 
United States v. St. Junius, 739 F.3d 193, 210 (5th Cir. 2013) (``The 
Anti-Kickback Statute prohibits receiving commissions in return for 
referring a Medicare patient to a Medicare provider.''). The Department 
has used its criminal enforcement power under EKRA judiciously and 
there are no allegations in the request for rulemaking that it has 
overreached. For these reasons, the Department denies ACLA's petition.

B. Submission From Howard S. Spokane Dated July 13, 2021

    In July 2021, the Bureau of Alcohol, Tobacco, Firearms, and 
Explosives (``ATF'') received a petition for rulemaking that suggested 
ATF create a new licensing requirement for people possessing ``high-
velocity'' ammunition, which was developed for military use (the 
petitioner stated this was explained in Wound Ballistics, a 1940s 
publication) and causes much more severe injuries than conventional 
ammunition. The petitioner suggested that this licensing requirement 
include: (1) a law enforcement right to periodically inspect to ensure 
the ammunition is stored safely; and (2) a psychiatrist's certification 
that the applicant does not suffer from or have a history of mental 
illness.
    ATF declines to pursue this rulemaking. The Gun Control Act of 
1968, as amended, prohibits the manufacture, importation, and 
distribution of ``armor piercing ammunition,'' 18 U.S.C. 922(a)(7)-(8), 
and also requires that individuals engaged in the business of importing 
or manufacturing ammunition be licensed under 18 U.S.C. 922(a)(1)(B). 
However, there is no statutory authority to regulate the sale or mere 
possession of standard ammunition. As a result, ATF cannot establish a 
licensing framework to possess high-velocity ammunition, as the 
petitioner requests. To the extent that the petitioner considers high-
velocity ammunition to also be armor-piercing ammunition, ATF also 
cannot pursue the petitioner's request because determining whether 
ammunition is armor-piercing is a materials-based assessment under the 
law and does not measure or test velocity. If a given high-velocity 
ammunition is determined to be armor-piercing due to its materials, it 
will already be regulated under ATF's current framework and additional 
regulation would be unnecessary. Moreover, even in cases of armor-
piercing ammunition, ATF does not have statutory authority to license 
possession.

    Dated: September 21, 2026.
Todd Blanche,
Attorney General.
[FR Doc. 2026-19642 Filed 9-24-26; 8:45 am]
BILLING CODE 4410-BB-P


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