Not correct.
It IS required for the gunsmith (engraver in this case) to have an FFL since he is taking in peoples firearms and holding them for work. However, Gunsmithing guidelines with the ATF allow the firearm to be returned directly to the same person who sent it to the gunsmith.
So, to summarize... your engraver (if he is above board) should be an FFL. You can ship directly to him and he can return directly to you.
If your engraver is NOT an FFL and he is not in the same state as you, then you are both considered “non-licensees” and an 3rd party FFL would be required on the receiving end of both trips to legally transfer the firearm to the recipient.
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B. Dudley
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