The main things we do to ensure compliance in the vast majority of cases—more than 99%—are primarily an email or a letter with some information about how the lobbyists can come into compliance, and a discussion.
The three most important tools in our tool box are a phone call, an email and a letter, and that's really it.
We do administrative monetary penalties on the basis of only the most egregious cases. We've had serious and repeated contraventions of the act.
When my investigators issue a determination, they do that on the basis of delegated authority, so that I can preserve my ability to do a reconsideration. They do that, and they examine a whole variety of aspects that may influence what an appropriate fee will be, and they do that quite transparently. That's all laid out in a determination of all the different considerations of what that fine is going to look like.