In Quebec, we don’t have administrative penalties, although the lobbyist commissioner has made a suggestion to have administrative penalties for very specific offences. Not all offences would necessarily be subject to administrative penalties with opportunity to appeal, since that is already the way it works with the commissioner’s power to impose disciplinary measures.
At the moment, disciplinary measures could be imposed on a lobbyist who has gravely or repeatedly breached the provisions under the act. We have used this power before. We first have to give the lobbyist a notice of intent, with an opportunity to make comments. It has been the case that the comments have made the commissioner back off. If there are no comments, the commissioner may decide to impose measures, which could be appealed before the Court of Quebec within 30 days.
In my opinion, we can have mechanisms in place to establish security indicators for those likely to be penalized.