That's a good question.
In the case of a person who is supposed to be in the registry, but is not, I would conduct an investigation. If I have reasonable doubts that the person should have been in the registry, I have to suspend my investigation and report it to the RCMP.
The Office of the Commissioner of Lobbying is on the lookout then. If the file comes back to us, I could make a report to Parliament to explain the situation. But is it worth the effort to investigate someone who was supposed to be in the registry, in accordance with the Code? I do not really have the resources for that.
I would probably advise you that this person was supposed to be in the registry. If the person is not in the registry, that is a violation of the Lobbying Act, and I have to report it to the RCMP.