OK, if I have a completely imported AMD-65 kit, what do I have to do to make it 922 compliant?  I read somewhere that if you permanently attach the US-made muzzle extension to the barrel that it will 'convert' the barrel into a US part.  Is this true?  I wondered how to count this since the brake and barrel are imported but there would be this US-made part sandwiched in between them.

And, what's the cheapest route to gain 922 compliance, given the muzzle extension and the receiver?

add a G2 fcg..(that alone counts as 3 parts!!!!!) that gives you your 5 parts

Tapco currently has an AMD-65 combo. For 109.99 you get the kit, the barrel extension, and the G2 double-hook group. With the receiver that makes five parts I think...

Quoted: I read somewhere that if you permanently attach the US-made muzzle extension to the barrel that it will 'convert' the barrel into a US part.  Is this true?

AFAIK, the barrel, barrel extension, and muzzle attachment count as 3 separate parts. Putting the US made extension still leaves you with an imported barrel.

If you buy a US made Mag Follower you should have your 7 US parts which is what you will need on that or  6 if you get the US made extended brake

These are also compliance parts:
Pistol Grip
Gas Piston
New Stock.
All of those are available at Tapco as well.

What parts below AREN'T found in the AMD?  I don't want to mess with US magazines.  I plan on definitely replacing the red parts with US parts.  This is my understanding of what is found on the AK/AMD.

(1) Frames, receivers, receiver castings, forgings, or stampings
(2) Barrels
(3) Barrel extensions
(4) Mounting blocks (trunions) QUESTION... does the front and rear trunion count as one part each?
(5) Muzzle attachments
(6) Bolts
(7) Bolt carriers
(8) Operating rods
(9) Gas pistons
(10) Trigger housings
(11) Triggers
(12) Hammers
(13) Sears
(14) Disconnectors
(15) Buttstocks
(16) Pistol grips
(17) Forearms, handguards
(18) Magazine bodies
(19) Followers
(20) Floorplates

This gives me 10 imported parts allowing me to use imported magazines IF the front/rear trunion is counted as one item together.  If they are counted as one imported item per trunion, then I might have to go with the US made Tapco extended muzzle break.

Are there any problems with my list as it stands?

Quoted: (4) Mounting blocks (trunions) QUESTION... does the front and rear trunion count as one part each?

There are no trunnions on an AK.  The trunnion is the mounting block for the barrel.  The stock tang or rear block is NOT a trunnion.  A U.S. made stock tang or rear block does NOT count towards reduction of the imported parts count.

If a rifle had multiple separate blocks to retain a barrel in a receiver, they would all be considered trunnions.  Like with the upper and lower handguards, multiple trunnions would all need to be replaced with U.S. pieces to count as a single item on the list.

The BATFE uses the word trunnion only to describe a block for mounting a barrel in a receiver, frame, or carriage.



Your parts list is pretty much correct for the AMD-65.  If you use a combo brake/barrel extension (like the Tapco, FAC, Moses, or make one from scratch) you combine the extension and brake into a single piece.  All of the above options will take care of the legal barrel length issue and count as a single U.S. part.  Since the combo brake/extension is a muzzle attachment, you effectively eliminate the barrel extension as a separate part.

If you use the following U.S. parts:

Receiver
Tapco extended brake
Tapco gas piston
G2 trigger group (hammer, trigger & disconnector)

those will count as 6 parts off the list.  Since the extended brake eliminates the barrel extension from the list, you would have 16 countable parts.  This would let you keep the original pistol grips (if desired).

So the only REAL choice I have when building this is whether I want to have the original wooden handguards... if I want to keep them, I need to get the extended muzzle break.  If I want to use the original brake (w/extension), I have to swap out the grips.  Correct?

Only the actual pistol grip counts.
The forward grip is only part of the forearm.
The entire forearm must be US made in order to count it.

Quoted: So the only REAL choice I have when building this is whether I want to have the original wooden handguards... if I want to keep them, I need to get the extended muzzle break.  If I want to use the original brake (w/extension), I have to swap out the grips.  Correct?

Yeah, the AMD-65 is kind of limited because of the barrel extension requirement and the fact that you cannot count a U.S. grip on the front as a handguard replacement.  You can replace the folding stock with a standard buttstock, or replace the straight gas tube with a slightly modified standard gas tube and use standard upper and lower handguards.  This would give you a couple extra options.  If you could have someone make a copy of the folding buttstock, that would work as a U.S. part.  

To do this, you'd only need to machine the hinge block that fits into the rear block of the receiver, bend a piece of steel tubing, and cut the oval for the shoulder rest.  Weld these parts together and you've got a U.S. made AMD-65 buttstock.  You could use the original rubber buttpad and you'd have an original looking replacement part.

Personally, I like the 65 with the wood pistol grips.  I don't care for the plastic ones though...  I'm building one of my 65's with a U.S. pistol grip and a blonde hungarian stock set (including upper and lower handguards).  I'm going to use a modified L1A1 flash hider as a barrel extension to meet the legal length requirement.  Because of the imported flash hider, I will need to have the U.S. pistol grip in addition to my receiver, gas piston, and trigger set to meet parts count compliance.

Actually, only replacement of the pistol grip at the trigger would count for parts compliance.  Like Maxxx93 said, the front grip is not a pistol grip and replacing it with a U.S. made one would only affect the parts count if you change the metal shroud with a U.S. made version too.  There are currently no makers of the AMD-63/65 lower handguard shroud in the U.S.

I talked with Mr. Ken Ward of Tapco regarding the number of compliance parts.  He said that the AMD-65 only needs 5 compliance parts, just as any other AK type rifle.  The following is what he said.

1.  The barrel extension is NOT a compliance part: even the Tapco flash suppressor extension does NOT count as a compliance part.

2.  Tapco trigger assembly does count as 3 parts.  US reciever counts as 1 part.  US made mag follower counts as 1 part.    BOTH rear and front grips count as 2 parts.  This is seven compliance parts.

The problem I have noted with the minimum number of compliance parts is I get varying numbers (5, 6, or 7), and what parts actually count as compliance parts.  I note a great lack of help from the ATF site.  What is there is vague and confusing: nothing is spelled out in stone for each particular type rifle.  Thus, WE are left to decide what meets compliance.  I have further noted that some state that the front grip does not count, because it is still attached to the original sheet metal foreguard.

So, where does the truth sit?  Can anyone give a definative answer with proof positive?

None of this is meant as a flame or insult to anyone.  I find this whole situation very frustrating and confusing.  Until I find out otherwise, I am going with what Mr. Ward said; he is in the business.

I would think that the ATF would specifically list what counts and what doesn't count per each type of rifle (AK, FAL, G3, CETME, UZI, etc.), AND a distributor would sell a compliance parts set with the minimum number of parts to make the firearm legal, with a copy of the ATF letter that states such.  In this manner, we would KNOW EXACTLY what ATF requires, AND have a copy of the official letter to show it.

If the Tapco extension/flash suppressor is made in the USA it certainly should be a compliance part, since it is replacing a muzzle extension that is foreign.