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Title page 1

Contents 3

Highlights 2

Letter 6

Background 9

Most Lobbyists Are Complying with Federal Lobbying Disclosure Requirements 14

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

For Most Quarterly Lobbying Disclosure Reports, Lobbyists Provided Documentation for Key Elements, Including Income and Expenses 16

For Most Quarterly Lobbying Disclosure Reports, Lobbyists Filed Contribution Reports for All Listed Lobbyists 21

Some Lobbyists May Not Have Properly Disclosed Their Previously Held Covered Positions 21

Lobbyists Reported No Criminal Convictions on Quarterly Lobbying Disclosure Reports for This Year's Review 23

Most Lobbyists Did Not Report Working with Affiliated Organizations 23

Some Lobbyists Amended Their Quarterly Lobbying Disclosure Reports After We Contacted Them 23

Most Contribution Reports Disclosed Political Contributions Listed in the Federal Election Commission Database 24

Most Lobbyists Reported Some Level of Ease in Complying with Quarterly Lobbying Disclosure Requirements 25

U.S. Attorney's Office for the District of Columbia Continues to Enforce the Lobbying Disclosure Act 28

The U.S. Attorney's Office Has Resources and Authorities to Enforce Lobbying Disclosure Act Compliance 28

Status of LD-2 Enforcement Efforts 31

Status of LD-203 Enforcement Efforts 33

Status of Civil and Criminal Enforcement Actions 36

Justice Against Corruption on K Street Act of 2018 Enforcement 36

Agency Comments 36

Appendix I: List of Lobbyists and Clients from the Random Sample of Quarterly Lobbying Disclosure (LD-2) Reports 39

Appendix II: List of Lobbyists from the Random Sample of Contribution (LD-203) Reports 43

Appendix III: Objectives, Scope, and Methodology 48

Appendix IV: GAO Contact and Staff Acknowledgments 56

Related GAO Products 57

Tables 3

Table 1. Reasons Lobbyists in Our Sample Amended Their Quarterly Lobbying Disclosure (LD-2) Reports, August 2024 to December 2024 24

Table 2. Numbers and Percentages of Contribution (LD-203) Reports That Omitted One or More Political Contributions, 2015-2024 24

Table 3. Names of Lobbyists and Clients Listed on Random Sampling of Quarterly Lobbying Disclosure (LD-2) Reports Filed for the Third and Fourth Quarters of 2023... 39

Table 4. Names of Lobbyists Listed on Random Sampling of Contribution (LD-203) Reports with Contributions Listed, Filed Year-End 2023 or Midyear 2024 43

Table 5. Names of Lobbyists Listed on Random Sampling of Contribution (LD-203) Reports Without Contributions Listed, Filed Year-End 2023 or Midyear 2024 45

Figures 4

Figure 1. Typical Lobbying Disclosure Process 11

Figure 2. Comparison of Newly Filed Lobbying Registrations (LD-1) to Initial Quarterly Lobbying Disclosure (LD-2) Reports, 2015-2024 15

Figure 3. Estimated Percentage of Quarterly Lobbying Disclosure (LD-2) Reports with Documentation for Income and Expenses, 2015-2024 17

Figure 4. Estimated Percentage of Quarterly Lobbying Disclosure (LD-2) Reports with Differences in Reported and Documented Amount of Income and Expenses, 2015-2024 18

Figure 5. Extent to Which Lobbyists Provided Documentation for Various Reporting Requirements, 2015-2024 20

Figure 6. Estimated Percentage of Quarterly Lobbying Disclosure (LD-2) Reports Where Listed Lobbyists Filed Contribution (LD-203) Reports for Their Organizations... 21

Figure 7. Estimated Percentage of Quarterly Lobbying Disclosure (LD-2) Reports Where Listed Individual Lobbyists May Not Have Properly Disclosed One... 22

Figure 8. Ease of Complying with Quarterly Lobbying Disclosure (LD-2) Requirements, 2015-2024 25

Figure 9. Ease of Understanding Key Lobbying Terms, 2015-2024 27

Figure 10. Overview of the Process for Addressing Noncompliance with the Lobbying Disclosure Act 29

Figure 11. Status of Lobbying Disclosure Act Referrals for Failure to File Quarterly Lobbying Disclosure (LD-2) Reports, 2015-2024 (as of December 2024) 32

Figure 12. Status of Lobbying Disclosure Act LD-203(R) Referrals for Lobbying Firms' Failure to File Contribution Reports, 2015-2024 (as of December 2024) 34

Figure 13. Status of Lobbying Disclosure Act LD-203 Referrals for Lobbying Firms That Employ Individual Lobbyists Who Failed to File Contributions Reports, 2015-2023... 35

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