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Update
June 29, 2020
DLLC Releases Guidance for Restaurants Holding Series 6 and 7 Liquor Licenses
 

Earlier this evening the Arizona Department of Liquor Licenses and Control (DLLC) published a guidance document for implementing Executive Order 2020-43 which requires bars to shut down for 30 days. 

As you may recall from our previous update, the Executive Order stated that restaurants and bars holding a series 6 or 7 liquor license and whose "primary business is the sale or dispensing of alcohol" must pause in-person operations.  Our hope was that the guidance from DLLC would provide clarity on the issue.  However, the guidance as issued fails to address how an establishment should determine if they fall into this category.  Specifically, DLLC states that:

"The Department cannot provide guidance to its thousands of licensees regarding the nature of their business.  Each licensee unsure of the requirements are encouraged to consult with their own legal counsel regarding compliance with Executive Order 2020-43."

The guidance does go on to reference several sources restaurants can utilize in determining if they fall under the exemption.  The ARA is analyzing these references and will provide a further update once a clearer picture, if any, emerges.  In the meantime, the ARA cautions all restaurants holding a series 6 or 7 license to carefully consider whether to continue to operate without clear guidance.  DLLC stated in their guidance that they will immediately suspend licenses of establishments they feel fall under the order.

The ARA will continue to provide updates as more information becomes available.

 

For questions or more information contact Dan Bogert

 

 
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