If you close all the excessive secrecy loopholes and you empower the commissioner and give the resources to the commissioner so they can be doing timely investigations, then the abuse of the loopholes will be much more difficult, because they'll be much more restricted. Delays will not be tolerated, because the commissioner will be right on top of them. In terms of the penalties, they are generally called administrative monetary penalties, AMPs, and the lobbying commissioner is called to impose them on lobbyists, as well. They are a common method of having fines, on a sliding scale depending on the significance of the violation, that are imposed on people who are committing the violation.
It is always determinable who has decided something in terms of refusing to disclose a document. The commissioner would investigate, find who was responsible, and then fine them with an AMP.