Kafka - esque.
Deliberately re-writing the rules so that past compliance is now used against FFLs. The determination of willful violations is now made by a computer software program. I have no doubt the code within the program results in a revocation decision 99% of the time.
100 FFLs run out of business in 2020 and 1,000 in 2022. It's quite clear what is going on.
If they can't outlaw guns then they will just choke off the supply of FFLs so that you can't buy one.