The act contains criminal sanctions, in essence, for breaching the act. The most common or potential violation would be a failure to register, as when one is engaged in lobbying activities for which one should register. There are also provisions for fraudulent disclosures. That might be a little more difficult to do if you were seeking to do that.
So those are the sanctions. As Ms. Shepherd mentioned earlier, the limitation period for a prosecution has been extended in the new Lobbying Act, under the Federal Accountability Act, and the penalties have been increased as well, so that sanction is a stronger one at this point.
With respect to the Lobbyists' Code of Conduct, the sanction for a breach of the code has always been, since 1997, that the registrar--and now the commissioner--would have reason to believe they should commence an investigation. There would be an investigation following that, and a report of the findings of the registrar, or now the commissioner, and the conclusions would be tabled before both Houses of Parliament.
So the sanction, I think, was to be a shining of the light upon the activities in question and a report that would be public. In fact, I believe the case of Mr. Makhija has been mentioned in the four reports in question. This one individual was investigated by Ms. Shepherd's predecessor, the registrar, and his four reports were indeed written and tabled before both Houses of Parliament in early 2007--in March, I believe it was. Those are publicly available and in fact have been online at the Office of the Commissioner of Lobbying website.
So that is the sanction for breaches of the code, and that hasn't changed in amendments to the Lobbying Act.