ATF and TTB:  Is Another Divorce on the Horizon? What’s Going on with the Agency?

By Robert M. Tobiassen, Compliance Consultant and former Chief Counsel, TTB

Forward by John Hinman:  We asked Rob why TTB was structured the way it was, what we can expect to happen as the 2019 budget is implemented and what kind of TTB enforcement policies will be in place going forward.  He responded with the history and status of the agency, and his prognosis for the future, based on his long experience in Washington DC. This article is must reading for every professional in the alcoholic beverage industry who interfaces with the TTB.

Introduction

Disruption is the descriptive word du jour used by every industry experiencing change and challenges in its global supply chain, manufacturing models, distribution channels, and attracting and retaining consumers.   The Trump Administration is similarly disrupting Executive Branch agencies through its political appointees, program change mandates, and budget reallocations.   TTB is not exempt from this disruption and the fiscal year 2019 proposed budget foreshadows a possible second divorce for ATF and TTB that could alter the culture of TTB.  Industry members and other stakeholders learned lessons from the first agency divorce in 2003, specifically about how criminal law enforcement agencies function. It behooves everyone today to pay heed to these lessons of history as the proposed budget moves forward.