US_Dragunov met with the ATF and received some clarification.
Brian, let me know if I quoted this correctly:
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Ok....So after an in-person sit-down meeting with ATF officials at their office, here is some of the information that was gathered and confirmed during the meeting:
1) Yes, the new study DOES in fact effectively ban the Saiga-12 ver 030 from further import permit approval due to the picatinny rail under the gas block
2) Yes, we already have an existing and valid import permit for this (Saiga -030) shipment and it is still good
3) Yes, as long as shotguns do not have any of the "offending" features as listed in
the "study" than they may be imported now with a pistol grip
4) No, it is doubtful that the batch of Saiga-12 ver. 030s will have the pistol grip as they are already made and we are just finishing paperwork (but we will see)
In summary...if you want a Saiga-12 ver 030 get one now while you can, and yes we have plans for many other cool versions and models that I think you all will like.
Does that mean that if the shotgun has the ability to accept a high capacity magazine it will not be imported?
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NO...what it means is if the shotgun is imported with high capacity magazines OR the high capacity magazines are imported separately for it then it is not importable.
If you stick a high capacity magazine into a shotgun that would otherwise not be allowed to be imported than you have to deal with 922(r).
So Saiga-12s are fine as long as no one imports magazines with a capacity of more than 5 rounds, and if you use U.S. made high cap mags then you need to be 922(r) compliant.