According to a survey of over 300 compliance and financial professionals, the leading challenge in managing employee conflicts of interest, at 68.5%, lies with gifts, entertainment and hospitality (GEH). Learn more about these survey results in our recent webinar, Policy to Practice: Mitigating Employee Conflicts of Interest.
Particularly during peak periods of gift and entertainment activity, such as the lead-up to the New Year and Lunar New Year for many cultures, communication is critical. Interoffice gift-giving like Kris Kringle activities and company drinks and results celebrations drive an increased volume of employees who need to follow the right processes.
Corporate gift-giving is also a rapidly growing market. The Global Corporate Gift Market Report 2025 Edition puts the total market revenue for corporate gifts at USD 881.6bn. Asia Pacific (APAC), holding 28.15% of that market share, is also accelerating. It grew by 68.92% from USD 171.05bn in 2021 to USD 248.17bn USD in 2025.
Regulators across the globe are also mindful of how GEH can result in employee conflicts of interest or even bleed over into potential bribery and corruption. Financial Institutions (FIs) regulated by FINRA are held to strict standards around gifts and entertainment under FINRA Rule 3220. The rule puts a strict limit around gifts as a means of improperly “influencing or rewarding employees of others” at $100. Read more about understanding the FINRA Gift Rule here. It should be noted that FINRA recently proposed an increase in what is considered a "nominal" value gift within the context of today’s economic environment, from $100 to $250.
As regulatory expectations change and adapt, it remains critical that firms understand the requirements within their respective jurisdictions, and where hard guidelines are absent, apply a common-sense approach to limits and acceptable or unacceptable GEH practices.
The stakes are high for individuals and firms alike to ensure compliance with GEH policies and regulations. In 2024, Hong Kong’s SFC banned two brokers for five years, following bribery convictions involving gifts and cash incentives. In 2025, the US regulator FINRA fined a financial services firm $10 million for providing excessive non-cash compensation to its clients in the form of expensive gifts, meals, and entertainment.
With peak activity ramping up and a growing corporate gift-giving market, timely communication and reminders to employees are imperative to ensuring compliance with GEH policies.
Consider these key communication tactics to help your firm and its employees stay out of the spotlight:
While it may not be appropriate to discuss instances of past GEH policy breaches within the firm as a warning to other employees, it is an opportunity to remind people of the consequences their decisions can have. By making the wrong choices, employees can not only put the firm at risk but also tarnish their reputations and professional profiles.
As Emily Wright, Founder of Wright Consulting & Coaching, explains in our webinar on Mitigating Employee Conflicts of Interest, “People can worry more about the embarrassment than the compliance… When people aren’t sure about their judgement, remind them to think about whether that gift or that party became a news headline. Would it impact the reputation of either the company or them as the giver or the recipient of that gift or that event?”
Consider how you can empower employees by equipping them with clear decision-making processes, such as:
Attestations are another important component of knowing employees understand and agree to comply with the GEH policy and broader employee conflicts of interest policies. While these attestations should happen annually at a minimum, compliance teams can struggle with the manual workload involved.
As with all aspects of employee conflicts of interest, technology can underpin consistent oversight of the risks and challenges across teams and across regions.
As Kelly-Ann McHugh, APAC Director at MCO, elaborates in our webinar on Mitigating Employee Conflicts of Interest, “Gifts and hospitality systems have been around for many years to automate this process… Having the GEH system, not really sitting in an HR system, but actually embedded with your other areas of conflicts of interest is really useful. The majority of my customers all require a pre-clearance of receiving or giving a gift or hospitality or charitable donation. There is generally a reprimand or some form of conduct issue if you don't, and this is important to be able to manage in the system. But not only that, once you have pre-cleared a gift, whatever value that might be, you want to automate some rules. For example, are people declaring gifts under $50? If so, let’s automatically approve it.”
Where technology shines even brighter is when multiple data sets are brought together to create a holistic view of potential conflicts. As Kelly-Ann notes, this “gives you an insight as to what the behaviour is in your organisation in totality, versus manual-based systems where you're not catching everything. You're not seeing a hundred percent of the population. And so by automating a system, like GEH and personal account dealing, you start to see some trends. Actually, people are trading 10 times in a month, and we shouldn't have our policies set around five in a month because we weren't detecting that before automating it. So implementing these systems and putting in the thresholds gives you insight into how you can update your policy long term. Our system, MyComplianceOffice (MCO), also allows you to check, did you actually give that gift? Did you receive that gift? If so, how much was it? Did it breach policy after you gave the gift? Again, let's check those rules.”
This centralisation of data around employee activity builds a robust picture of what is actually happening across multiple areas of conflicts of interest. For example, MCO’s complete compliance solution can check market sounding and material non-public information (MNPI) activity against GEH or Outside Business Activity (OBA) to quickly identify broader conflicts, all within one platform.
Compliance management software, such as MyComplianceOffice (MCO), brings holistic insights into employee behaviour, while adding automation to reduce the manual workload on compliance teams.
MCO’s GEH module enables firms to apply predefined rules in real time, such as auto-approving gifts under thresholds and flagging entries that require closer review. When employees log their activity, the system captures and tracks values, recipients, whether it was actually given or received, and whether it subsequently breached policy.
MCO also brings deep visibility into how employee behaviours align with policies across multiple areas of employee conflicts of interest. The system can extend across the entire Know Your Employee (KYE) landscape, including Personal Account Dealing to Outside Business Activities, Close Personal Relationships, Role and Responsibilities Needs, and even eCommunications Surveillance and Archiving. Compliance teams gain a complete picture and can more rapidly take corrective action, while proving to regulators they meet record-keeping requirements across all areas of employee conflicts of interest.
Consider your firm’s need for a comprehensive, automated compliance solution with full audit trails to gain a more responsive, risk-informed compliance framework across GEH and beyond.