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Technically, just minding one's own business can be a felony. Knowing of a felonious act and not reporting it is itself a felony, ("misprision of a felony") though violations are hard to prove and prosecutions are not common.
The whole law is essentially stupid and the ATF has to try to enforce it as best they can because they took an oath to do so. And smart people keep trying to invent absolutely useless things that will "almost but not quite" violate the law - for no reason other than to be able to say they are almost but not quite violating the law.
Jim
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