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Investigation case summary – CTF Partners Limited

Wednesday 6th November 2019

Organisation or person investigated 

CTF Partners Limited (“CTF Partners”)

Matter(s) investigated

Compliance by CTF Partners with the Transparency of Lobbying, Non-party Campaigning and Trade Union Administration Act 2014 (‘the Act’).

Registrar’s decision

CTF Partners has robust compliance procedures in place and is not engaging in activities that would require registration under the Act.

Summary of rationale for decision

In response to enquiries, CTF Partners has provided satisfactory clarification and explicit assurance as to the particular services it does (and does not) offer to clients, as well as full details of compliance training and monitoring materials it has used since the Act came into force.


Summer 2019  Media reporting of association of members of CTF Partners with senior politicians who were and/or subsequently became Government Ministers. In view of the Registrar, in this context, CTF Partners’ consultancy services offer to prospective clients raised a heightened risk of possible consultant lobbying activity, which would be in breach of the Act.
8 July 2019  Letter from Registrar to CTF Partners. Explained remit of Registrar, legislation and guidance on consultant lobbying, and asked for a response, including comprehensive assurance if no consultant lobbying activity is undertaken.
10 July 2019  Reply from CTF Partners, stating that it did not provide services within the scope of the Act.
12 July 2019  Further letter from Registrar to CTF Partners detailing some particular concerns and asking for a more detailed response to these.
19 July 2019  Reply from CTF Partners, giving clarification on the nature of the services offered to its clients in relation to Government.
7 August 2019  Email on behalf of Registrar to CTF Partners, seeking details of relevant compliance training and monitoring within CTF Partners.
20 September 2019  Reply from CTF Partners repeats content of its letter of 19 July, without providing the additional information requested.