Federal firearms license (FFL) holders are under far more scrutiny these days than they have ever been before.  An FFL is the license a person or business needs to be a licensed gun seller.    The Gun Control Act (GCA) of 1968, codified in 18 U.S.C. Sect. 923(a), requires firearms dealers to maintain a license from the Attorney General.  But the Attorney General, after notice and a hearing, has the power to revoke a license if the holder has “willfully violated” any provision of the Gun Control Act.  But what is a willful violation?