On July 5, 2019, the Alcohol and Tobacco Tax and Trade Bureau (“TTB”) issued TTB Industry Circular 2019-2 advising that certain eligible beer, wine, and spirits wholesalers and importers shall have until December 31, 2019 to disclose previously unreported changes in control or change in proprietorship of the wholesaler’s business without civil or criminal penalties for failure to disclose such changes within thirty (30) days as required by 27 U.S.C.A. § 204.
