Did the Commissioner let off the lobbyists, hide her investigation records, and gut key ethical lobbying rules in Lobbyists’ Code, to get reappointed by the Trudeau Cabinet in December 2024 for another 7-year term?
Did the RCMP Commissioner let off the lobbyists and hide investigation records to get appointed by the Trudeau Cabinet in 2023-2024?
RCMP record confirms violations by SNC-Lavalin lobbyists were investigated, and reveals federal prosecutors’ secret decision not to prosecute violations of key rule in Lobbying Act – do other cases include violations by lobbyists from Facebook, WE Charity, Imperial Oil and associates of Jenni Byrne?
FOR IMMEDIATE RELEASE:
Monday, March 9, 2026
OTTAWA – Today, as federal Commissioner of Lobbying Nancy Bélanger is scheduled to testify this afternoon before the House Ethics Committee as it begins its 10-year overdue review of the federal Lobbying Act, Democracy Watch criticized Commissioner Bélanger for abusing her discretionary powers in secret rulings since 2018 letting off all lobbyists in 13 separate situations even though she had concluded they violated the federal Lobbying Act (and, therefore, she could have issued a public ruling identifying all the lobbyists and finding that they all violated the Lobbyists’ Code of Conduct).
Democracy Watch also criticized Commissioner Bélanger for clearly violating the federal Access to Information Act (ATIA) by delaying for 18 months (from June 2024 to December 2025) disclosure of her investigation records in the 13 cases, and then redacting 80-90% of key information, using invalid reasons that violate the ATIA’s disclosure requirements, in the almost 6,000 total pages of records she has disclosed.
Subsection 16.2(2) of the ATIA clearly requires the Commissioner to disclose all investigation records of completed cases within 30 days of receiving an ATIA request (with a reasonable extension of a few months allowed). The Commissioner’s records show that all 13 cases have been completed.
The Commissioner is hiding the following information about all 13 cases that she could have legally disclosed under the ATIA: the identity of the federal politicians, public officials and government institutions that were lobbied (and interviewed for the investigation); the business/organization lobbied for; any general issue lobbied about; the number of lobbyists involved in each case; all the allegations that were investigated (some are redacted); the date she initiated her investigation; the date she referred each case to the RCMP, and; the date the RCMP referred each case back to her. If the allegations of illegal lobbying were made publicly in any of the cases, it is also legal for the Commissioner to disclose the identities of the lobbyists who were investigated.
Commissioner Bélanger’s annual reports since 2018 also show that she has let off 98% of lobbyists she has found violating the Lobbying Act. Previous Lobbying Commissioner Karen Shepherd had an almost as bad enforcement record from 2007 to the end of 2017. And the Act has a “dirty dozen” loopholes that allow for secret lobbying, and the Code has huge loopholes that allow for unethical lobbying, and 10 key changes are needed to strengthen the enforcement system to make it independent, timely, transparent, effective and accountable. In her submission to the House Ethics Committee, Commissioner Bélanger has only recommended closing half of the dozen secret lobbying loopholes, none of the unethical lobbying loopholes, and making only two of the 10 needed enforcement changes.
Democracy Watch also criticized the RCMP for failing to prosecute fully any of the lobbyists involved in the 13 situations, and for continuing to fail to disclose almost all of its investigation records. Democracy Watch filed a request with the RCMP for its investigation records in 6 of the 13 cases in October 2023, and it clearly violated the ATIA for more than two years before it finally disclosed last week one heavily redacted (with no reasons given for any of the redactions), unclear document containing its mixed up combined investigation records for only 4 of the 6 cases.
Once Commissioner Bélanger concluded in each of the 13 cases that a lobbyist or lobbyists had violated the Act, she referred (as required under Lobbying Act ss. 10.4(7)) each case to the RCMP at undisclosed times since January 2018, and the RCMP referred the cases back to her at undisclosed times after letting the lobbyists off.
Commissioner Bélanger could then have issued a public ruling in each of the 13 cases naming the lobbyist and finding them guilty of violating the Lobbyists’ Code of Conduct (which requires lobbyists to comply with the Act, and has no limitation period on ruling on violations, and only requires proof on balance of probability, and has no penalty other than being named and shamed). A former Commissioner did this in a past case. Instead, Commissioner Bélanger buried all 13 cases and covered up the wrongdoing by the lobbyists without issuing a public ruling or identifying any of the lobbyists.
While the RCMP’s document is an unclear mix of records from 4 cases, it does reveal on one page (accidentally it seems) that one case involved investigating SNC-Lavalin lobbyists, very likely concerning lobbying during the Trudeau Liberal Cabinet/SNC-Lavalin scandal by former PCO Clerk Kevin Lynch for SNC-Lavalin that was not registered by CEO Neil Bruce (click here to see DWatch’s March 2019 complaint), and by SNC-Lavalin lawyer Robert Pritchard and others. This is clearly the same case as File #8 of the Commissioner of Lobbying’s 13 case files.
The RCMP’s document also reveals that it let off the lobbyists involved in at least one of the 4 cases (and likely more) because a federal Crown prosecutor told an RCMP investigating officer on an undisclosed date that one of the key provisions of the Lobbying Act known as “the 20% rule” (which sets the threshold for registration of officers and employees lobbying for a business or organization) was unenforceable and so would never lead to a prosecution.
This raises key questions: When did Crown prosecutors or the Commissioner make that this key provision of the Act was unenforceable? Did they inform the Commissioner of Lobbying and, if so, when did they do that? Why didn’t Crown prosecutors make that information public? The RCMP’s document also hides other reasons why none of the lobbyists were prosecuted.
Democracy Watch filed a complaint with the Information Commissioner about the violations of the ATIA by the Commissioner of Lobbying’s redactions of 80-90% of the disclosed investigation records, and the Information Commissioner is investigating the complaint. Democracy Watch also filed a complaint about the ATIA violations by the RCMP, and the Information Commissioner is investigating that complaint. Democracy Watch has also requested the RCMP’s records in the other 7 of the 13 cases.
Click here to see charts summarizing and linking to the heavily redacted almost 6,000 pages of records in the Commissioner’s 13 case files (Chart 1), and the RCMP’s one, heavily redacted, mixed up 227-page document about 4 of the cases (Chart 2).
Democracy Watch’s conclusion is that the letting off of all the lobbyists, and the multi-year disclosure delays and ongoing hiding of most of the investigation records, by Commissioner Bélanger and RCMP Commissioner Michael Duheme amount to a cover-up, quite possibly done by both to secure appointments to their positions by the Trudeau Cabinet in 2024.
“By negligently letting off all of the lobbyists in 13 cases who violated the federal lobbying law since 2018, and violating the law by hiding almost all their investigation records, the Commissioner of Lobbying and RCMP are covering up scandalous situations, protecting the lobbyists and the politicians and public officials they were lobbying, encouraging further violations, and making it even more clear the Commissioner should not have been re-appointed for a second seven-year term,” said Duff Conacher, Co-founder of Democracy Watch. “It’s shameful that the RCMP, whose top officers are chosen by and serve at the pleasure of the ruling party Cabinet, continues to take so long to investigate lobbyists who violate the law given they receive clear evidence from the Commissioner of Lobbying, and it’s shameful that they fail to prosecute fully all violations.”
“The RCMP’s negligently bad enforcement record of Canada’s lobbying law, similar to its negligently bad enforcement in the SNC-Lavalin and Aga Khan scandals involving former Prime Minister Trudeau, is more clear evidence that a new, fully independent federal anti-corruption police and prosecution force is needed, said Conacher.
If and when the full investigation records are disclosed, beyond the one disclosed RCMP document that reveals it and the Commissioner both investigated SNC-Lavalin lobbyists, the records may reveal that of the other 12 cases some are about:
1. The unregistered lobbying and favours for Trudeau Liberal Cabinet ministers that Kevin Chan and others at Facebook did (click here to see DWatch’s April 2018 complaint to the Commissioner);
2. The unregistered lobbying that WE Charity lobbyists did of Trudeau Liberal Cabinet ministers from January 2019 to August 2020, and the trip gifts they gave to former Liberal Finance Minister Bill Morneau and his family;
3. The lobbying by Imperial Oil of then-Conservative Party Leader Andrew Scheer, and by CPA Canada of Minister Karina Gould, at a May 2019 event they sponsored, and/or;
4. The lobbying done by associates of Jenni Byrne, then at top adviser to Conservative Party leader Pierre Poilievre.
Did Commissioner Bélanger hide her rulings (9 of the 13 cases were shut down by her and the RCMP from February 2023 to May 2024), fail to enforce the Lobbying Act and Lobbyists’ Code, and gut key rules in the Lobbyists’ Code (ignoring the opposition to the changes from a coalition of 26 citizen groups with 1.5 million total supporters, and 41 lawyers and professors, and 20,000+ voters – Click here for details), in order to have the Trudeau Cabinet reappoint her to a second seven-year term in November 2024?
Did former RCMP Commissioner Brenda Lucki let off the lobbyists because she was appointed by and served at the pleasure of former Prime Minister Justin Trudeau? Did former Deputy RCMP Commissioner and current RCMP Commissioner Michael Duheme fail to enforce the Lobbying Act effectively and hide investigation records from October 2023 until February 2026 (with more records still hidden) so Trudeau would appoint him first as Interim Commissioner in March 2023 and then as Commissioner in April 2024? The RCMP similarly covered up its investigation of the Trudeau Cabinet SNC-Lavalin scandal from July 2022 through to May 2024, and let Trudeau off also for unjustifiable reasons.
A national survey commissioned by Democracy Watch in January 2025 showed that more than 80% of Canadians are concerned about the corrupting effects of secret, unethical lobbying on politicians’ policy-making decisions, and want to know the details of all lobbying activities.
“The public’s high level of concern about secret, unethical lobbying, and the negligently weak enforcement records and excessive secrecy of the Commissioner of Lobbying and the RCMP, make it clear that all the secret lobbying loopholes need to be closed, along with all the unethical lobbying loopholes, and that the enforcement system must be made independent and strengthened to require the Commissioner to issue a public ruling in every case, and to empower and require her to penalize every violation with a sliding scale of high fines and prohibitions on lobbying for long time periods,” said Conacher.
– 30 –
FOR MORE INFORMATION, CONTACT:
Duff Conacher, Co-founder of Democracy Watch
Tel: (613) 241-5179
Cell: 416-546-3443
Email: [email protected]
Democracy Watch’s Stop Secret, Unethical Lobbying Campaign and Open Government Campaign and Government Ethics Campaign and Stop Bad Government Appointments Campaign and Stop Unfair Law Enforcement Campaign