The agency is not the last word. A licensee dissatisfied with a posthearing decision — one revoking or suspending the license, denying the application, or imposing a civil fine — may under 18 U.S.C. 923(f)(3) file a petition for judicial review, within 60 days after receipt of the final notice. That petition should be filed with the U.S. district court for the district in which the applicant or licensee resides or has their principal place of business. It is the third clock in this chapter and the longest, and the one people most often assume does not exist.

Filing does not by itself keep the business open, and this is where the chapter’s protections stop being automatic. Where the Director finds that justice so requires, he MAY postpone the effective date of a suspension or revocation, or authorize continued operations under the expired license, pending judicial review. May, not shall — and finds that justice so requires is a discretionary judgment, not a condition a licensee can satisfy by filing correctly. Everything up to the posthearing decision ran on entitlements; from here on it runs on discretion.

One more duty waits at the end, and it is a separate obligation rather than part of the petition — the third and last of this chapter’s three clocks. The first is the 15 days to request a hearing; the second is the 60 days to petition a court; this one begins only once the proceedings are finally disposed of. On final disposition of proceedings to disapprove or terminate a license — by revocation or denial of renewal — the former licensee has 30 days, or such additional period as the Director approves for good cause, to liquidate the former licensee inventory to a licensed importer, manufacturer or dealer, or to transfer it to a responsible person to whom disposition is not prohibited by law, as § 3.5 set out. A business that has spent months contesting a revocation still has that clock to run when the contest ends.