Is giving a bottle of wine a bribe? What if it goes to a government official in China? What if 10 more of your employees also gave the same official a nice gift while he was considering a contract with your company? A new anti-bribery tool from TRACE International aims to keep corporate gifts on the up-and-up.

“Most companies have their arms around how to do due diligence or training,” said Alexandra Wrage, president of TRACE. “But they were careening around … complaining they couldn’t get a good grasp on the scope of gifts, hospitality, and travel” that might lead to possible violations of anti-bribery laws.