Circular A-133 ensures regular, detailed auditing of all substantial grant recipients. OMB promulgated these requirements in 1990 largely to provide a higher level of assurance that federal funds are spent properly than would be the case if the government relied solely on its own audit resources. Nevertheless, the government retains the right to conduct such additional audits as it deems necessary, a right that government agencies exercise on a regular basis. There are also sanctions for organizations that violate the prohibition on the use of federal funds. If the violation is unintentional or minor, the principal sanction is that the organization must reimburse the government for the misspent funds.
Criminal sanctions apply in appropriate cases.
In other words, it is already illegal to use federal grant money to lobby for continued receipt of such funds. This same Code section requires recipients of federal funds to file reports with the granting agency certifying that federal funds have not been used for prohibited lobbying. They must also disclose the name of any person identified in registration forms filed pursuant to the Lobbying Disclosure Act of 1995 who made lobbying contacts on behalf of the grantee. Failure to comply subjects the grantee to a fine of from ten thousand to one hundred thousand dollars. Clearly, current law already has in place mechanisms for preventing the misuse of federal funds.