a result of a dispute over the release of Justice Department documents related to the scandal, on June 28, 2012, in a vote largely along party lines in a Republican-controlled House, Attorney General Eric Holder became the first sitting member of the Cabinet of the United States to be held in contempt of Congress. At Holder's request, President Barack Obama had invoked executive privilege for the first time in his presidency in order to withhold documents that "were not generated in the course of the conduct of Fast and Furious." In 2016, a federal court ruled that the records in question were not covered by privilege; a House lawsuit to try to recover the records was settled and the matter dropped in April 2019, after control of the House had shifted to Democrats. Background ATF gunwalking operations were, in part, a response to longstanding criticism of the bureau for focusing on relatively minor gun violations while failing to target high-level gun smuggling figures. U.S. firearms laws currently govern the possession and transfer of firearms and provide penalties for the violation of such laws. “Gun trafficking”, although not defined by statute, essentially includes the movement or diversion of firearms from legal to illegal markets. A 2009 GAO report on efforts to combat arms trafficking to Mexico notes that straw purchasing is not in itself illegal, although it is illegal to provide false information in connection with a purchase. Four federal statutes govern U.S. commerce of firearms domestically and internationally. Many states supplement these federal statutes and have firearms laws of their own that are stricter. For example, some states require permits to obtain firearms and impose a waiting period for firearm transfers. Domestic commerce and importations into the United States are generally regulated under the National Firearms Act of 1934 (NFA) and the Gun Control Act of 1968 (GCA). The exportation of firearms from the United States is regulated by the Arms Export Control Act of 1976 and, to a lesser extent, the Export Administration Regulations (EAR). Defendants are often prosecuted and convicted under provisions of statutes such as the GCA that make it unlawful for certain persons to be in possession of firearms, govern the transaction process of obtaining firearms (e.g., straw purchases), and contain penalties for the use of a firearm in a crime of violence or a drug trafficking crime, or penalties for knowingly or fraudulently smuggling goods