In January 2020, IBAC commenced Operation Clara to determine if a former Victorian Government Minister misused his public position on the board of the Victorian Planning Authority (VPA) to favour the Australian Education City (AEC) consortium in their East Werribee project proposal, or attempted to improperly influence public officers involved in the East Werribee project.

IBAC's investigation found Mr Theophanous improperly lobbied in favour of the AEC by failing to declare a conflict of interest or register the AEC as a client on the Victorian Register of Lobbyists. He tried to advance his private lobbying business by telling clients he had access to staff and information within the VPA,  sought payments from the AEC, and in lieu of direct payment for his lobbying activities, obtained other benefits from the AEC and a special adviser to the AEC, namely donations to his daughter's 2018 campaign for the State electorate of Northcote.

Operation Clara highlights the pressing need for reforms to the regulation of lobbying in Victoria and makes recommendations to ensure those regulations are in step with other states and territories.