922r Compliance question

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I recently bought an AMD 65 rifle (a Hungarian AK) which from the factory has two 922r compliance parts in the mag. I had asked in the rifle section where I might fight parts to add two us made parts to my other surplus mags to keep the rifle compliant . I as told there though, that I didn't need to worry about it, as only the manufacturer was responsible for the assembly and thus I could use surplus mags in the rifle with no modification - I was planning to replace the floorplates and followers (even though to sell the rifle with a non-modified mag would be illegal?). Is this true? I always assumed that BATFE would construe me putting a mag in the rifle as the assembly of the rifle, and thus an unmodified mag would not be 922r compliant.

Essentially, I'm confused, do I have to modify my mags to avoid breaking the law or am I allowed to use unmodified surplus mags since I'm not the assembler/manufacturer?

I've always thought it was a rather dumb law and now I'm really confused about it and I would very much like to avoid breaking the law, so please teach me a bit about this 922r mumbo-jumbo.
 
This is a huge greyish area.

Yes, the law applies to the person assembling the firearm and has nothing to do with who owns it or sells it.

But yes, in theory, the ATF considers inserting a magazine as "assembling" for the purposes of nailing your hide to the wall.

Except that there don't seem to be any cases we can point to where such a thing actually happened, so it is hard to pick out exactly how could ever be applied/charged/prosecuted.

The safest bet is to use compliant mags. Well, the safest bet is to trade off a couple more parts and make the rifle itself complaint, but that's up to you.
 
Thanks for the reply, Sam1911. I guess that still leaves me looking for us made floorplates that fit the metal surplus mags (the ones on K-Var say they don't work with metal mages).
 
As I understand 922r, You can't have over a certain number of foreign made parts on a gun and use non-US high cap mags in it. The parts they look at are very specific as well, things like the receiver, barrel, PG, muzzle break, FCG, mag plate, follower, etc. There are a few more but I can't remember them all. Anyway, putting US made floorplates and followers in the mags essentially makes them "US made" so they don't run afoul of 922r. If you want to use unmodified surplus mags you need to replace parts on the rifle itself with US made ones. This is generally what most people that own newer (because pre-922r rifles don't count) AKs do.

I don't know the US parts count on the AMD 65 specifically but most AK users just swap out the FCG and the furniture which makes the whole rifle compliant and you can use whatever mag you want.

As for enforcement of the law. I don't know that anyone's ever been charged under 922r since you can't tell at a glance if a part is US made or not. But the issue I'd say is this, if you ever shoot anyone with that gun, and local LEOs or the BATFE start taking a close look at it, do you really want a weapon that's a "grey area." Personally I say switch the parts and save yourself the lawyer's fees.
 
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