DEPARTMENT OF THE TREASURY
                BUREAU OF ALCOHOL, TOBACCO AND FIREARMS
                         WASHINGTON, DC 20226

                              SEP 1 1999

                                                           903050:GKD
                                                           3311

Dear :

This refers to your letter of July 4, 1999, in which you asked
about modifying a SAR-8 rifle.  As we advised you in our previous
letter of April 2, 1999, PSG-1 style rifles are prohibited from
importation under section 925(d)(3) of Title 18 United States Code
(U.S.C.)); therefore, assembly of a PSG-1 style rifle from imported
parts is prohibited under Title 27, Code of Federal Regulations
(CFR), Part 178, section 178.39.  Assembly of a PSG-1 style rifle
prior to April of 1998, was not prohibited under section 178.39,
since the PSG-1 rifles were not prohibited from importation at that
time.

You also inquired about a SAR-8 rifle manufactured in February
1994, which was modified by installing an HK-91 flash suppressor
and replacing the original thumbhole stock with an HK-91 stock. 
Such rifles have been prohibited from importation since July, 1989;
therefore, assembly of the rifle from imported parts would also be
prohibited as provided in section 178.39.  Please note that
firearms involved in any willful violation of this regulation are
subject to seizure and forfeiture as provided in 18 U.S.C. section
924(d)(1).

Additionally, the SAR-8 rifle as modified would meet the definition
of a semiautomatic assault weapon as that term is defined in
section 921(a)(30) of Title 18 U.S.C.  Section 922(v)(1) of Title
18 U.S.C. provides that it shall be unlawful for any person to
manufacture, transfer, or possess a semiautomatic assault weapon.

                                 - 2 -

Mr. 

However, a semiautomatic assault weapon, which was lawfully
possessed under Federal law on the date of enactment of the
subsection (September 13, 1994) is excluded from the prohibition in
section 922(v)(1).  Even if the semiautomatic assault weapon was
lawfully possessed prior to September 13, 1994, it could still not
be altered to PSG-1 configuration, since assembly of the PSG-1
style rifle from imported parts would be prohibited under section
178.39.

We trust that the foregoing has been responsive to your inquiry. 
If we can be of any further assistance, please contact us.



                           Sincerely yours,

                               [signed]
                          Edward M. Owen, Jr.
                   Chief, Firearms Technology Branch