Ballard Partners Q3 Report for Aldyl Energia Shows $200,000 Income; Ketchel and LaRosa Listed as No Longer Expected to Lobby

Ballard Partners filed its first quarterly lobbying report (LD-2, 2026 Q3, covering 2026-07-01 to 2026-09-30) for client Aldyl Energia C.A., signed 2026-10-15. It reports lobbying income of $200,000.00 for the period (a good-faith estimate rounded to the nearest $10,000), under issue code FUE and the specific issue “Oil, Gas and Energy issues related to Venezuelan operations.” Contacts are listed with the “White House Office, State - Dept of (DOS), Energy - Dept of.”

Ketchel: removed, not omitted. The lobbyists who acted in the issue area are listed as Brian Ballard and Scott Wagner only. Micah Ketchel is not omitted silently: line 23 (“previously reported individual who is no longer expected to act as a lobbyist for the client”) names him, together with Michael LaRosa. The filing does not say whether Ketchel made any lobbying contact between the LD-1 and this report, and it gives no date or reason for the removal. Because he is absent from line 18, the report does not list him as having lobbied in the quarter.

Foreign interest (line 19). The report states that Aldyl Argentina S.A., Habitar Partners SA and Julian Santiago Arostegui, “as parent companies/and or ultimate owners of Aldyl Energia C.A.,” have interests in the issues reported.

Ketchel background and the revolving-door rules (text, not a conclusion). Per the 2026-09-15 LD-1, Ketchel reports White House and State service in 2025. A Substack report (secondary) says he was a senior advisor to Waltz at the UN and that Ballard announced him as a partner on 2025-11-19, and that a disclosure shows him lobbying for UG Solutions LLC in Q1 2026. Waltz left the national security adviser post in May 2025 (AP, widely reported); the exact dates Ketchel left each post were not found in a primary source.

• 18 U.S.C. 207(c)(1) bars a covered “senior” former official, for 1 year after service ended, from knowingly communicating with employees of the department or agency where he served in the prior year, on behalf of another, with intent to influence official action. Coverage under 207(c)(2) depends on pay level or appointment category, which this pass did not establish for Ketchel.
• Biden’s ethics-pledge order (EO 13989), with its lobbying restrictions on appointees, was revoked on 2025-01-20 (EO 14148), and no replacement Trump ethics order was found as of a February 2025 law-firm alert; this pass did not search for later ones. Whether any pledge applied to him is therefore unresolved here.
• The registration (effective 2026-08-01) falls after the one-year anniversary of Waltz’s May 2025 exit, but possibly before the one-year anniversary of Ketchel’s own departure (he joined Ballard around 2025-11-19). Dates unverified; no violation is asserted.

Dates, by kind. 2026-10-15: LD-2 signature date. Reporting period 2026-07-01 to 2026-09-30. Lead credited to Ken Klippenstein’s Substack note.

Prior entry: 2026-09-15–ballard-partners-registers-aldyl-energia-venezuela-oil-lobbying-ketchel-listed.