Failing to Amend your TTB Permit after a Change in Ownership / Management / Control Can Cost You!

I am the most boring winemakers’ lawyer in the PNW. I read lists of new winery applications and I read the TTB’s recent offers in compromise. A recent one caught my eye – a $12,000 penalty for the most frustrating of reasons.

The licensee failed to update the TTB with a change of ownership, management, or control. The TTB assigned a penalty of $103,334.85. (GASP.) Luckily, the licensee was able to negotiate this down to $12,000.

So, what is this big misdeed? It’s simple. Alcohol licenses, although assigned to an entity, are personal in nature. So any changes in ownership of an entity – or changes within the entity – must be reported to the TTB within 30 days. See 27 CFR 27.1.42.

But…how? Easy-peasy. Go into your TTB Permits Online account and amend your permit to delete, add, or amend. If you don’t think you’ve got an account (very possible if your bonded winery number starts with the number 1 or is a three-digit number), just mail in your TTB form 5120.25 to good ol’ Cincinnati.

Don’t forget to change your permit with your state liquor agency!