At least two of the interactions Mr. Dion cited in a detailed timeline were said to be initiated by SNC, according to the report, but weren’t logged in the federal registry.
A further two interactions between the company and government officials in which the remediation agreement was discussed, according to the report, were also not publicly disclosed. However, the Dion report does not make clear who initiated those discussions. Only communications that are initiated by lobbyists—not by government officials—and fit criteria laid out under the Lobbying Act must be reported.
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