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Title page

Contents

Highlights 2

Letter 6

Background 9

Lobbyists Filed Disclosure Reports as Required for Most New Lobbying Registrations 14

For Most LD-2 Reports, Lobbyists Provided Documentation for Key Elements, Including Income and Expenses 15

For Most Lobbying Disclosure Reports, Lobbyists Filed Political Contribution Reports for All Listed Lobbyists 20

Lobbyists May Not Have Properly Disclosed Their Previously Held Covered Positions 20

Lobbyists Reported No Criminal Convictions on LD-2 Reports for This Year's Review 22

Some Lobbyists Amended Their Disclosure Reports after We Contacted Them 22

Most LD-203 Contribution Reports Disclosed Political Contributions Listed in the Federal Election Commission Database 22

Most Lobbying Firms Reported Some Level of Ease in Complying with Disclosure Requirements and Understood Lobbying Terms 23

U.S. Attorney's Office for the District of Columbia Continues to Enforce the LDA 26

The U.S. Attorney's Office Has Resources and Authorities to Enforce LDA Compliance 26

Status of LD-2 Enforcement Efforts 28

Status of LD-203 Referrals 29

Status of Civil and Criminal Enforcement Actions 33

Justice Against Corruption on K Street Act of 2018 Enforcement 34

Agency Comments 34

Appendix I: List of Lobbyists and Clients for Sampled Lobbying Disclosure Reports 36

Appendix II: List of Sampled Lobbying Contribution Reports with and without Contributions Listed 39

Appendix III: Objectives, Scope, and Methodology 44

Appendix IV: GAO Contact and Staff Acknowledgments 52

Related GAO Products 53

Table 1. Reasons Lobbyists in Our Sample Amended Their Disclosure Reports (LD-2) from July 2023 to February 2024 22

Table 2. Numbers and Percentages of Political Contribution (LD-203) Reports That Omitted One or More Political Contributions, 2014-2023 23

Table 3. Names of Lobbyists and Clients Selected in Random Sampling of Lobbying Disclosure Reports Filed in the Third and Fourth Quarters of 2022 and... 36

Table 4. Lobbyists in Sample of Lobbying Contribution Reports with Contributions Listed, Filed Year-End 2022 or Midyear 2023 39

Table 5. Lobbyists in Random Sample of Lobbying Contribution Reports without Contributions Listed, Filed Year-End 2022 or Midyear 2023 41

Figure 1. Typical Lobbying Disclosure Process 11

Figure 2. Comparison of Newly Filed Lobbying Registrations to Initial Lobbying Disclosure (LD-2) Reports, 2014-2023 15

Figure 3. Estimated Percentage of Quarterly Lobbying Disclosure (LD-2) Reports with Documentation for Income and Expenses, 2014-2023 16

Figure 4. Estimated Percentage of Lobbying Disclosure (LD-2) Reports with Differences in Reported and Documented Amount of Income and Expenses, 2014-2023 17

Figure 5. Extent to Which Lobbyists Provided Documentation for Various Reporting Requirements, 2014-2023 19

Figure 6. Extent to Which Lobbyists on Lobbying Disclosure (LD-2) Reports Filed Contribution Reports for All Listed Individual Lobbyists, 2014-2023 20

Figure 7. Estimated Percentage of Lobbying Disclosure (LD-2) Reports Where Listed Individual Lobbyists May Not Have Properly Disclosed One or More Covered Positions... 21

Figure 8. Ease of Complying with Lobbying Disclosure Requirements, 2014-2023 24

Figure 9. Ease of Understanding Key Lobbying Terms, 2014-2023 25

Figure 10. Status of Lobbying Disclosure Act Referrals for Lobbying Disclosure Reports (LD-2), 2014-2023 (as of January 2024) 28

Figure 11. Status of Lobbying Disclosure Act Referrals for Political Contribution Reports, Lobbying Firms Only (LD-203(R)), 2014-2023 (as of January 2024) 30

Figure 12. Status of Lobbying Disclosure Act Referrals for Political Contribution Reports, Lobbying Firms with Noncompliant Individual Lobbyists (LD-203),... 32

Figure 13. Status of Lobbying Disclosure Act Referrals for Political Contribution Reports, Individual Lobbyists (LD-203), 2014-2022 (as of January 2024) 33

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