TTB Change of Control Enforcement Update

If you own a business that makes, imports, wholesales, exports, or produces alcohol, you need a permit from the Alcohol and Tobacco Tax and Trade Bureau (TTB). By law, if someone new takes control of your business, you have to notify the TTB within 30 days. If you don’t, your permit ends automatically.

The TTB is starting to send warning letters to companies that miss this 30-day deadline. These warning letters include similar language to the following:

When someone new takes over your business, you need to apply for a new permit within 30 days. This lets you keep running your business while the TTB reviews your application. If you don’t apply on time, your permit ends, and you’ll have to start over to get a new one. Without a permit, it’s illegal to keep operating, and you could face fines or even criminal charges. To fix this, you’d need to apply for a new permit and wait for approval.

Your application was late, so your permit ended. Running your business without a permit broke the law. This time, we’re not taking extra action against you, and we’ve gone ahead and issued your new permits. But you need to follow the rules from now on—know the laws and stick to them.

These warning letters might mean the TTB is going to become stricter enforcing the 30-day notification rule. If you have questions or need assistance providing the requisite notification, you can contact Saltzman Mugan Dushoff for advice or legal support.