Compliance & Penalties


Investigations

The Integrity Commissioner, as Ontario’s Lobbyist Registrar, has the power to investigate potential non-compliance with the Lobbyists Registration Act, 1998. Individuals who have information about potential non-compliance with the Act can complete the form below.

The Act prohibits the Commissioner from releasing any information about ongoing investigations. Statistics and information about concluded investigations can be found in the Office's annual reports.

Penalties

If the Commissioner reaches a finding of non-compliance with the Act, the Commissioner may impose a penalty by making public the name of the lobbyist, a description of the non-compliance and any other information that the Commissioner considers necessary. The Commissioner may also prohibit a person found to be in non-compliance from lobbying for up to two years.
 

Prohibition

No person is prohibited from lobbying at this time.
 

Published Non-compliance

2020 - 2021

Amir Farahi, Consultant Lobbyist
In 2018 and 2019, Amir Farahi failed to comply with the Lobbyists Registration Act, 1998 as follows: 

- He lobbied for three clients without filing a registration as required by the Act. He lobbied for approximately six months for these clients without registering his lobbying;
- He failed to respond to requests for information from the Registrar in two matters;
- He failed to identify his lobbying goals for two clients; and
- He failed to provide the correct business name for one client. 

Mr. Farahi’s non-compliance seriously compromised the Act’s goal of transparency about his efforts to seek to influence the government. Mr. Farahi’s non-compliance may have initially been due in part to his lack of awareness of the Act, and his inexperience. However, after a colleague told him he was not registered under the Act, he still failed to take actions to come into compliance for well over a month. And, when he did register, his registrations were incomplete and at times inaccurate. In further breach of the Act, he failed to reply to the Registrar’s request for clarifying information. Overall, Mr. Farahi displayed repeated and troubling inattention to his obligations under the Act.  

The Registrar determined that the appropriate penalty was publication of Mr. Farahi’s name and a description of his non-compliance. The Registrar decided that it was not necessary to prohibit him from lobbying because Mr. Farahi has no previous incidents of non-compliance with the Act and the investigation arose because he attempted to comply with the Act. In addition, he had implemented new systems in his office to ensure future compliance with the Act. 
 
Amir Farahi did not breach the Act with respect to another client 
In 2019, some media attention focused on Mr. Farahi’s lobbying activities for another client. The Registrar investigated and determined that he did not lobby for the client. Lobbying under the Act is defined as communication with a public office holder in an attempt to influence, and Mr. Farahi did not communicate with any public office holder on behalf of the client. Therefore, he was not in breach of the Act with respect to the client. He was not required to file a registration.


Published penalty summaries issued in past years are available upon request by sending an email to info@oico.on.ca.