From my read on the actual regulation, I get that it says you must send a gun to a FFL. It does not prescribe how you determine you are sending it to a FFL. The law didn't change recently, the recommended practice that is acceptable to the ATF changed. No matter what method used, the sender is responsible for ensuring he is sending it to a FFL. So, if he wants a DNA test, you can either satisfy this sender or find another.
All the ATF did was say you've done due diligence by having a faxed copy of a FFL or going to the website. It's not a final legal ruling if you are prosecuted. It'll go a long way, but ultimately it'll be judged in court if you are prosecuted for sending it to a non FFL. At least that's my read.
