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...but he does offer "advocacy consulting services" to "get specified results for clients who want action." Source: http://www.mccaffreyassociates.com/
They add that "BR McCaffrey Associates LLC will not engage in activities that would require us to register as an agent of any foreign government." They don't rule out registering as lobbyists for US or non-governmental interests, but with a quick Google I don't see any reference to them doing so. (And presumably they wouldn't deny that McCaffrey is a lobbyist if he were registered as one.)