Lobbying, FARA and Disclosure Analyst
Instructions
We map paid influence on a federal matter from the public record: who registered to lobby on it, for which clients, on which issues, before which agencies, for how much; whether any of that work was done for a foreign principal; and which of the people doing it held a covered government post before. This is the investigator’s influence map and the professional staff member’s disclosure research, rebuilt from filings anyone can read without compulsion.
This skill is the method. Case catalogues stay where they are: public-corruption-ombudsman and trump-corruption-accountability-tracker keep their cases and point here for how to read the filings.
Use a different skill when:
- the question is who owns or controls a company, its sanctions exposure or its corporate
profile — use corporate-intelligence-investigator (company due diligence lives there; we cross-reference it, never restate it);
- the question is political donations, PACs or FEC schedules —
campaign-finance-transparency; - the question is contracts, grants or exclusions —
federal-spending-contracts-investigator; - the question is what §207 itself prohibits, or a member’s or official’s own ethics filings —
congressional-ethics-and-disclosure; we apply its rule text to lobbying, we do not restate it;
- the task is a network graph across many entities — use
network-analysis-specialistwith the
influence map as input.
Method, in order: scope the subject (§1), read LDA filings (§2), read FARA filings (§3), match filings to the subject without name-match errors (§4), run the revolving-door check (§5), add political-intelligence context where it applies (§6), then assemble the outputs (§7).
1. Scope the subject
Write down, before any search:
| Field | Example | Why |
|---|---|---|
| Subject | a bill, rule, contract, agency action, or a named company or person | Sets what counts as a match |
| Window | the quarters the matter was live | LD-2 is quarterly; search the window, not “ever” |
| Agencies and committees | the bodies with jurisdiction | LD-2 lists houses and agencies contacted |
| Issue codes | the LDA general issue areas that fit | LD-2 activity is filed per issue code |
| Foreign angle | any foreign government, party or company involved | Decides whether §3 runs |
2. LDA filings: LD-1, LD-2, LD-203
The Lobbying Disclosure Act (2 U.S.C. §1601 et seq.) requires three filings we use, all public on LDA.gov:
| Form | What it is | What we read |
|---|---|---|
| LD-1 registration | A registrant (lobbying firm or in-house employer) registers for a client | Registrant, client, general issue areas, listed lobbyists and their covered positions, any foreign entity with an interest |
| LD-2 quarterly activity report | One per registrant–client pair per quarter | Issue codes, specific issues (bill numbers, rules), houses and agencies contacted, lobbyists per issue, income or expenses |
| LD-203 contribution report | Semiannual, by registrant and by each lobbyist | Contributions to candidates, leadership PACs, and certain event and honorary payments |
Data. api.lda (scripts/lib/osint_api/lda.py, LdaClient, host lda.gov) searches filings by client name: scripts/ca_research.py api api.lda ". It returns registrant, client, issue codes, income or expenses, filing type and year, and the filing’s document URL. Its people mode (search by lobbyist_name) is built and tested but **not enabled** in agent-base/osint-sources/taxonomy.yaml, because a lobbyist-name search is a name match that returns many different people; enabling it is an editor’s decision, not this skill’s. For a person, use LDA.gov’s own search and treat every hit as a candidate until §4 confirms it.
Amounts. LD-2 reports income (outside firms) or expenses (in-house) for the quarter, per client, in the bands and rounding the form allows. It is not a per-issue or per-contact figure; never divide it across issues or present it as the cost of one meeting.
LD-203 is filed per lobbyist and per registrant, not per client. A contribution on an LD-203 links to the lobbyist, not to any client they represent. Campaign-finance analysis of those contributions belongs to campaign-finance-transparency.
3. FARA filings
The Foreign Agents Registration Act (22 U.S.C. §611 et seq.) requires a person acting in the United States as an agent of a foreign principal, in a covered capacity, to register with the Justice Department’s FARA Unit. Filings are public on FARA eFile (efile.fara.gov).
| Document | What we read |
|---|---|
| Registration statement | The registrant, each foreign principal, the nature of the work |
| Exhibit A | Information about each foreign principal |
| Exhibit B | The agreement or understanding with that foreign principal, including terms and fees |
| Short form registration statement | Each individual (partner, employee) who works on the account |
| Supplemental statement | The six-month activity report: contacts, activities, receipts, disbursements, political contributions |
| Informational materials | Material the agent distributed for the principal, filed with the Unit |
| Amendments | Changes to any of the above |
LDA or FARA. An agent of a foreign commercial principal who registers under the LDA may be exempt from FARA registration (22 U.S.C. §613(h)); the exemption does not cover a foreign government or foreign political party as principal. So a foreign company’s lobbying can sit in LDA filings (the LD-1 discloses foreign entities with an interest) rather than in FARA. Search both before concluding that no foreign-principal work exists.
Data. api.fara. The client ships disabled by default (set CA_ENABLE_FARA=1 only once efile.fara.gov’s terms are confirmed to allow automated access). While it is disabled, use FARA eFile’s own search by registrant or foreign principal and record each document’s eFile URL.
4. Matching filings to the subject
The commonest error in this work is a name match treated as an identity match.
- Clients and registrants match on the filing’s stated name, address and description, not on
a similar name. Record the LDA client ID or the FARA registration number once confirmed.
- Specific issues must name the subject (a bill number, rule docket, contract or program).
An issue code alone (“TAX”, “DEF”) is context, not a match.
- People match only on a second identifier: a filing that states their covered position, a
firm biography, a financial disclosure, or a dated press release. A lobbyist name alone is a candidate, never a finding.
- Unmatched candidates stay in working notes and never reach the influence map.
Each matched row records the filing URL it came from. A row without a URL is removed.
5. Revolving door (absorbs #21)
The revolving-door check asks, for a person who moved between a covered government post and the private side: when did they leave, which cooling-off window applied, did they register to lobby, and for clients with business before their former office?
Windows. 18 U.S.C. §207: (c) 1 yr, (d) 2 yr, (e) by role; rule text in congressional-ethics-and-disclosure §3.
An administration’s ethics pledge can lengthen a window for those who signed it; check the pledge in force on the person’s departure date. A window bars contacts, not employment: taking a job at a firm inside the window is not a violation, and registering as a lobbyist is not one either.
Registration after departure. The LD-2 lists each lobbyist per issue area with a “Covered Official Position (if applicable)” field and a “New” box; a lobbyist added for a client must disclose any covered executive or legislative position held in the 20 years before first lobbying for that client. The LDA.gov REST API returns this as lobbying_activities[].lobbyists[].covered_position (with new) on each filing. api.lda does not surface that field today (its projection omits it; a revolving-door mode is deferred to backlog), so read it from the filing JSON or the filing’s print view: open the document URL api.lda returns and read each issue area’s lobbyist list.
Method, per person:
- Fix the departure date from a primary record (agency or committee announcement, the person’s
own financial disclosure, a dated press release). Firm press releases date the hire, not the departure.
- Classify the former post (senior, very senior, legislative) only from a primary source; if it
cannot be confirmed, the window column says “unconfirmed”, never a guessed date.
- Compute the window end from the departure date.
- Search LD-1 and LD-2 filings listing the person after the departure date; record each
registration, its client and its first quarter.
- Compare each client’s issues and agencies contacted with the person’s former jurisdiction.
- Record the result in the revolving-door ledger (Appendix). An overlap between a client’s
issues and a former jurisdiction is a pattern worth reporting, not a violation.
Worked shape. A tracker row reads: date, person, from (post), to (firm), party. That is the shape the ledger extends with departure date, window end, registrations after departure and source. Keep the tracker mixed-party, as the movement itself is: a table that lists one party’s departures is not an output of this skill.
6. Political intelligence
Political intelligence is the sale of information about pending government action to investors. The STOCK Act of 2012 directed GAO to report on its role in the financial markets; GAO-13-389 (2013) is that report. Do not state how large the industry is, or that GAO could not size it, until that is read from the report itself (verify). Use it as context when a client’s interest in a matter looks market-driven; whether a seller of political intelligence must also register under the LDA turns on whether they make lobbying contacts, and that is a statutory question for congressional-ethics-and-disclosure and counsel, not a finding we make.
7. Assemble the outputs
- Influence map: one row per subject × registrant × client × issue × agency × quarter, with
the amount and filing URL (Appendix). FARA rows use the foreign principal as client and the supplemental statement period as the quarter.
- Revolving-door ledger: one row per person (Appendix), CSV.
- Every row passes §4. Sum amounts only within one registrant–client–quarter, never across
issues.
Sources
Primary:
- Lobbying Disclosure Act, 2 U.S.C. §1601 et seq., and the Lobbying Disclosure Act Guidance
(Clerk of the House and Secretary of the Senate) — https://lobbyingdisclosure.house.gov/ldaguidance.pdf — confirmed via ca_research.py 2026-10-31: covered-position disclosure on LD-1 and LD-2, the 20-year look-back for new lobbyists.
- LDA.gov filing records and REST API — https://lda.gov/api/v1/filings/ — confirmed 2026-10-31:
LD-2 print view shows “Covered Official Position (if applicable)” and “New” per lobbyist; filing JSON carries lobbying_activities[].lobbyists[].covered_position. Replaces the earlier [U].
- Foreign Agents Registration Act, 22 U.S.C. §611 et seq.; DOJ FARA Unit —
https://www.justice.gov/nsd-fara — and FARA eFile — https://efile.fara.gov — confirmed 2026-10-31: eFile documents list registration statements, short form registration statements, supplemental statements, exhibits, amendments and informational materials.
- 18 U.S.C. §207 — https://www.law.cornell.edu/uscode/text/18/207 — with 5 C.F.R. §2641.204
(https://www.law.cornell.edu/cfr/text/5/2641.204) and OLC, *Who Qualifies as a “Very Senior” Employee Under 18 U.S.C. §207(d)* (https://www.justice.gov/olc/file/1078066/dl) — confirmed 2026-10-31: one year for senior employees (§207(c)), two years for very senior (§207(d)). Replaces the earlier “verify current terms” label.
- OGE, 18 U.S.C. §207 Applicability Chart —
https://www.oge.gov/Web/oge.nsf/0/6F0B33C29C0E772E852585B6005A1BB7/$FILE/Combined%20Senior%20Employees.pdf — confirmed 2026-10-31: an ethics pledge can extend the §207(c) window.
- GAO-13-389, *Political Intelligence: Financial Market Value of Government Information Hinges on
Materiality and Timing* — https://www.gao.gov/products/gao-13-389 — confirmed 2026-10-31 as the STOCK Act-mandated report; the “no data to size the industry” summary stays [U] until read.
Practitioner:
- Revolving Door Project, OpenSecrets, LittleSis — personnel and lobbying tracking across LDA,
FARA and financial disclosures; use as leads, confirm every row against the filing.
Cross-references
corporate-intelligence-investigator— company ownership, sanctions and corporate profile; we
cross-reference it and never restate it.
public-corruption-ombudsman— keeps its corruption case catalogue; points here for method.trump-corruption-accountability-tracker— keeps its FARA case table; points here for method.network-analysis-specialist— graphs the influence map across entities.patriot-private-citizen-inclusion-gate— required before naming staff below senior level.congressional-oversight-procedure— committee jurisdiction, used in §5 step 5.member-intel-profile— the dais book; an influence map for the hearing’s subject can inform
its conflict flags.
campaign-finance-transparency— campaign finance and FEC schedules.federal-spending-contracts-investigator— federal contracts and grants.congressional-ethics-and-disclosure— §207 rule text and congressional ethics disclosures.
Safety
- Not legal advice. Whether conduct violates the LDA, FARA or §207 is for counsel and the
enforcing agencies. Route readers to qualified counsel.
- A registration is not wrongdoing. Lobbying and registering under the LDA or FARA are
lawful and disclosed by design. Report what the filing says, not what it implies.
- An unregistered-agent finding is the Justice Department’s call, never ours. We may report
that a filing we expected is absent from FARA eFile and LDA.gov after searching both; we never state that a person “is an unregistered foreign agent” or “violated FARA” absent a charge or adjudication.
- Allegation vs. finding vs. charge. Keep the three distinct in every sentence; a referral or
complaint is not a charge.
- No impersonation of government authority. We read public filings; we never present
ourselves as acting for DOJ, a committee or an ethics office.
- Partisan symmetry. Revolving-door and influence tables cover every party the record shows;
a one-party tracker is not an output of this skill.
- Private persons. Staff below senior level are not public figures by default; they pass
patriot-private-citizen-inclusion-gate before being named.
- Estimates labelled. Any amount not stated in a filing, or any window end resting on an
unconfirmed departure date, is labelled.
Appendix: influence map and revolving-door ledger
Influence map (one row per subject × registrant × client × issue × agency × quarter):
| Subject | Registrant | Client (or foreign principal) | Issue (code; specific issue) | Agency / house contacted | Quarter | Amount (income or expenses; as filed) | Filing URL |
|---|---|---|---|---|---|---|---|
Revolving-door ledger (CSV, one row per person):
person,from,to,departure_date,s207_window_end,registrations_after_departure,source
| Column | Content |
|---|---|
person |
Full name as filed |
from |
Former post and office or committee |
to |
Firm or employer after departure |
departure_date |
ISO date from a primary record, or unconfirmed |
s207_window_end |
ISO date computed per §5, or unconfirmed |
registrations_after_departure |
Semicolon-separated registrant/client/first-quarter triples from LD-1/LD-2, or none found |
source |
URLs for the departure date and each registration, semicolon-separated |
