Business courtesies are lawful and normal, and they are also the mechanism through which improper influence is most often alleged.
Principles first. Anything given must be modest, infrequent, transparent, provided for a legitimate business purpose, permitted by the recipient’s own rules, and never given to obtain an improper advantage or at a time when a decision is pending.
Thresholds and approvals. A value below which no approval is needed, a band requiring manager approval, and a level requiring compliance approval. Lower thresholds for government officials, with pre-approval for anything of value.
Prohibited categories. Cash and cash equivalents including gift cards; anything during a tender or regulatory decision; travel and accommodation not tied to a genuine business purpose; and anything to a family member of a counterparty.
Recording. A register capturing giver, recipient, organisation, value, purpose, date and approval. The register is the control; a policy without one cannot be tested.
Accurate books. Expenses must be recorded in the accounts for what they actually were. Mischaracterisation is itself a violation of books and records provisions regardless of the underlying propriety.
Public sector rules. Recipients’ own gift rules frequently prohibit what the giver’s policy would allow, and the stricter rule governs in practice.
Training aimed at the people who host clients, not at compliance staff.