People who are otherwise serious about the global scourge of bribery get frustrated when anyone raises the issue of gifts as bribes. Surely, most people will say, we haven’t reached the point where holiday gift-giving is so risky that we can’t hand out bottles of wine or silks tie and scarves. Even the enforcement agencies seem a bit exasperated. In its recent Foreign Corrupt Practices Act guidance, the U.S. Department of Justice sought to reassure the business community, emphasizing their focus on “. . . single instances of large, extravagant gift-giving (such as sports cars, fur coats and luxury items).” The U.K.’s Serious Fraud Office went further, dismissing the idea that they would be investigating “tickets to Wimbledon or bottles of champagne.”
So why, then, are companies still plagued by the labor-intensive policies that most companies implement to screen and approve gifts to customers and other decision makers? There are two forces at work here.
