It may not be defined in the law, but it is defined in the dictionary. Willful is an adjective meaning "obstinately and often perversely self-willed; done deliberately; intentional."
Thus, an error (such as a clerical error) is by definition not willful. On the other hand, the ATF's behavior as described in the article does appear to be willful.
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That brings to mind another slimeball excuse:
"No controlling legal authority"...