It’s almost Black Friday, a reminder that for many Americans, the holiday season—and the gift giving that goes with it—is just around the corner. But in today’s highly active antibribery and anticorruption corporate enforcement environment, spreading the holiday cheer through gift-giving can be a dangerous game.
Companies that plan to give gifts to clients and partners in the coming months (or during any other holiday in any other season of the year) need to be aware of what they are gifting and who is receiving it. The Foreign Corruption Practices Act, which makes it illegal to give bribes to foreign officials, poses a particular difficulty in this space. It appears though, from new data collected by Deloitte, that some companies still don’t understand how important a compliant gift-giving program actually is.
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