Before you send
Client gift policies, limits and etiquette
Most client-gift mistakes are not about taste. They are a gift the client was not allowed to accept, sent at the wrong moment, or built on a personal detail that should have been left alone. This page covers the rules to check and the lines not to cross.
This is a practical guide, not legal advice. Rules change and differ by country, state, industry and employer. When the value is more than a token, ask the client what they can accept, and ask your own compliance team.
The client's own gift policy comes first
Many companies cap the value of gifts their staff may accept, ask them to declare gifts in a register, or ban some kinds outright: cash, gift cards, travel, anything during a tender. You will rarely find the number in public. The simplest route is to ask your contact, or their procurement team, before you send anything beyond a card or a small consumable.
- Gift cards and vouchers are treated as cash under many policies.
- Hospitality (an event you attend with them) is often treated differently from a gift; check both.
- Food shared with a team is usually the easiest gift to accept.
Anti-bribery rules
Anti-bribery law does not forbid client gifts, but it forbids gifts given to win or keep business improperly. What matters is intent, value, frequency and timing.
- United Kingdom: the Bribery Act 2010 sets no value threshold. The Ministry of Justice's guidance says bona fide hospitality that is reasonable and proportionate is not the target of the Act. Read the guidance.
- United States, foreign officials: the Foreign Corrupt Practices Act prohibits giving anything of value to a foreign official to obtain or keep business. The DOJ and SEC Resource Guide discusses gifts and hospitality. Read the Resource Guide.
- Timing: never send a valuable gift while a contract, renewal or tender is being decided. Send after the decision.
Public-sector clients
Government staff work under the strictest rules. Assume the answer is no unless you know otherwise.
- US federal employees: the standards of conduct (5 CFR 2635.204) allow unsolicited gifts of $20 or less per occasion, and no more than $50 a year from the same source, with other exceptions. Read 5 CFR 2635.204.
- State and local government: rules vary by state and city, and some ban gifts from vendors entirely. Check the state ethics commission for the client's state.
- Elsewhere: most governments publish a code of conduct for officials. Search for the client's department and “gifts and hospitality”.
For public-sector clients, a handwritten note or a card is the safe choice.
Regulated industries
- Financial services (US broker-dealers): FINRA Rule 3220 caps gifts per person per year in relation to the recipient's employer's business. Check the current limit on finra.org.
- Healthcare (US): payments and transfers of value from drug and device makers to physicians and teaching hospitals are reported publicly under Open Payments, and industry codes restrict gifts to healthcare professionals. Read about Open Payments.
Tax: what you can deduct
In the US, a business can deduct no more than $25 of business gifts per recipient per year, with exceptions for small branded items and some packaging and shipping costs. See IRS Publication 463, “Gifts”. Other countries have their own rules; ask your accountant.
Cultural norms
Customs differ widely, and a well-meant gift can carry the wrong meaning. If the client is from a culture you do not know well, ask a colleague who does. A few commonly cited examples:
- In Japan, presentation and wrapping matter, and sets of four are often avoided because the word for four can sound like the word for death.
- In Chinese-speaking cultures, clocks are often avoided as gifts because of their association with death.
- Alcohol, and food that is not halal or kosher, can be wrong for observant Muslim or Jewish recipients. Never assume anyone drinks.
- Holiday gifts assume a holiday. A new-year card or a gift at a business milestone avoids that.
Sensitive personal topics
A researched gift should be built on what the person shares in public about their work and interests, and nothing else. Leave out:
- Health, diet and weight, pregnancy, and anything medical.
- Religion, politics and causes they have not backed in public.
- Family details, children and relationships.
- Anything found in a private source, or that they would be surprised you know.
The test: if the recipient asked “how did you know that?”, the answer should be a public post, talk or interview they would be glad you read.
Checklist before you send
- Is anything being decided right now? If so, wait.
- Do you know what their employer lets them accept?
- Is it a gift card or cash equivalent? Check again.
- Does it touch health, religion, family or politics? Change it.
- Does it assume they drink, eat something or celebrate something? Confirm.
- Is there a handwritten line that says why you chose it?