Gifts and Entertainment Compliance Software
Affinisio(GNE) reviews the gifts, hospitality, entertainment and expenditure employees are offered, and those your organisation gives, before either is accepted or committed. The organisational gift register is maintained automatically and records disposition. Built for financial-services employee compliance and for corporate anti-bribery programmes alike, it serves firms answering to FINRA in the United States, to the FCA in the United Kingdom and to the MiFID II inducements regime across the European Union, and programmes framed by the FCPA, the EU Anti-Corruption Directive, Sapin II and the UK Bribery Act.
Corruption, Bribery and Other Conflicts of Interest, Managed by Affinisio(GNE) at the Point of Offer
See what is being offered before anyone accepts it. Limits, exemptions and prohibitions apply themselves, aggregate across employees and counterparties, and leave a record.
GNE
(Compliance Officers)
Ask before you accept, and get an answer that fits the situation. Declare a gift in the currency you were offered it, and let the policy work out whether it is allowed.
GNE
(Employees)
Gifts Inward: Gifts Employees Receive or Are Offered
Empower your compliance with Affinisio(GNE). Ensure a detailed review for all conflicts of interest. Automate your compliance policies and request for structured data in requests, intelligently designed to ask the right questions in the right situations so that you can apply judgement with ease and clarity.
An employee discloses a gift or an invitation before accepting it. Affinisio(GNE) asks what the situation calls for, applies the limits you have set, and routes it to the reviewers you have named.
Cash and cash-equivalent items carry a built-in treatment you can configure further. Everything else, from a business lunch to a seat at a match, is reviewed on the rules you set for its category.
How a gift was received is a fact that changes the answer. Record whether it came to a named person, to a position, or to the organisation itself, and let that shape the review and the decision.
Return, donate, raffle or distribute what cannot be kept, and close it with evidence. Upload the courier receipt, the donation confirmation or the record of distribution against the entry.
The organisational gift register fills from the approval flow rather than from a second administrative task. Context, decision and disposition stay attached to the entry that produced them.
A gift that has arrived is not a gift that has been accepted. Record physical receipt, hold the item in custody pending review, and record acceptance separately when the decision is actually made.
Where the value is not obvious, a person records the figure they have assessed and the reasoning behind it. Define what counts as excessive, in the currency the gift was offered in.
Set one acceptable value, or segregate by seniority, role, department and counterparty type. Exempt the categories your policy excludes, prohibit outright the ones that no approval should reach.
Every gift is receivable in its own right, and every gift also counts. Affinisio(GNE) checks the single item and the running total, across employees and counterparties, over the period you set.
A gift received from an organisation is saved as an indirect relationship of the firm, and surfaced when that organisation appears again in another disclosure or another review.
Gifts Outward: Gifts Provided by Employees or the Organisation
Extend your compliance with Affinisio(GNE). Clear gifts, hospitality and entertainment before they are committed, not after they are given. Categories, values and recipients shape the review, and every decision leaves a record you can produce on demand, integrated with your preferred expense management system.
An employee raises a gift, a meal, an event or a sponsorship before it is committed. What is being given, and to whom, shapes the questions asked and the reviewers it reaches.
Anything directed at a public official or a state-owned entity is recorded distinctly and routed on its own terms, so the activity carrying the sharpest exposure never sits in a general list.
Colleagues acting separately can reach the same recipient. Totals are aggregated across the organisation, so what one counterparty received is visible even when no single giver came close to a limit.
An event you host and a ticket you hand over are not the same thing. Record whether your own people attended, because that fact changes the treatment and no limit alone can settle it.
Gifts, hospitality, meals, travel, sponsorship and prizes each carry their own review path. The category shapes what is asked, so a reviewer receives what the decision actually needs.
What you give is saved as an indirect relationship of the firm too. Given and received are held against the same organisation, so you see the whole of a counterparty relationship rather than half of it.
Features
Compliance Software for Gifts and Entertainment, Given and Received
The same gift or entertainment received can need two different answers, depending on who it reached, from whom, and when. Affinisio(GNE) shapes the review around those facts, applies the limits you maintain yourself, and records receipt and acceptance as two separate decisions.
What is given is judged the same way. Who it reached, whether your own people were present, and what that recipient has already received from colleagues elsewhere in the firm all shape the review, before anything is committed rather than after it is given.
Contextually Intelligent
Segregated Processes for Gifts and Entertainment, Given or Received
A value limit alone cannot answer the question. A finance employee is offered a phone by a vendor. Sales takes an associate to lunch. Marketing puts sports tickets up as prizes. Each is shaped by who, from whom and when, with clarifications recorded in the flow and conditions attached to an approval where they are needed.
Custom Flows by Type or Value
Adaptive Review based on Type or Value of Gift or Expenditure
Gifts received may need additional valuation. Additional conflicts clearances may be required for cash or cash-equivalent gifts. Affinisio(GNE) carries built-in treatment you can configure further depending on the type and nature of potential conflict based on your governance structure
Self-Maintainable Policy Values
Set and maintain acceptable value limits
Self maintain acceptable levels for gifts and entertainment. Apply a common rule, or segregate by seniority, role, department and counterparty type. Choose the period they are measured over, exempt the categories your policy excludes, and prohibit outright what should never be offered. Limits change; when they do, the change is yours to make.
Integrated Valuation Process
A recorded valuation, with its reasoning
Where the value of a gift is not obvious, Affinisio(GNE) facilitates an independent valuation and records the basis for it. The valuation travels with the request into review and into the register, so the judgement is visible rather than assumed.
Auto-Maintain Gift Register
Receipt, decision and disposal, recorded as they happen
The register populates from the review itself rather than from a separate unconnected task, so that governance is visible end to end. Record how each gift was dealt with, whether returned, donated, raffled or distributed, and close it with the evidence attached, from a courier receipt to a donation confirmation.
Patterns across Counterparties
What one entry cannot show you
A gift refused still tells you something. Affinisio(GNE) holds refused and returned items in the record alongside accepted ones, and aggregates across employees and counterparties, so a counterparty approaching many of your people is visible even when no single entry breaches anything.
Integrated Management
One platform for gifts and entertainment, given and received
Manage gifts as goods and entertainment as services in one place, inward and outward together. Connect your HRMS for hierarchy and governance data, single sign-on and directory services for access, your expense management system where what was approved needs to be compared with what was given, your own mail server, and an API for the rest. Deploy on-premises inside your own estate, in a private cloud you manage, hybrid, or hosted.
More than a software application, AFFINISIO IS YOUR COMPLIANCE AND GOVERNANCE CENTRE.
All applications in the Affinisio Suite integrate seamlessly with each other and are backward and forward compatible. Data is shared amongst the applications whenever you upgrade.
Get AFFINISIO now!
Have questions? Connect with the Affinisio team.
Affinisio(GNE) FAQs
Does Affinisio(GNE) support FINRA and FCPA compliance?
Affinisio(GNE) supports firms answering to FINRA in the United States, and anti-bribery programmes framed by the FCPA. It covers gifts and entertainment in both directions: what employees are offered, and what your organisation gives. Employees disclose before accepting or committing, the limits you maintain are applied, and receipt and acceptance are recorded as two separate decisions. Every item is checked in its own right and against the running total for that employee and that counterparty.
Does Affinisio(GNE) support FCA and UK Bribery Act compliance?
Affinisio(GNE) supports firms answering to the FCA in the United Kingdom, and anti-bribery programmes framed by the UK Bribery Act. Offers are recorded, not only acceptances: an employee declares an invitation or a gift when it is made, and a refusal leaves a record in the same way an acceptance does. Hospitality your organisation provides is cleared before it is committed, with the recipient, the category and whether your own people attended all shaping the review.
Does Affinisio(GNE) support MiFID II, Sapin II and EU Anti-Corruption Directive compliance?
Affinisio(GNE) supports firms answering to the MiFID II inducements regime across Ireland, the Netherlands, Malta, Cyprus, Germany, France and Denmark, and anti-bribery programmes framed by the EU Anti-Corruption Directive and, in France, by Sapin II. Inducements and minor non-monetary benefits are handled as categories you define, so a research seminar or a working lunch follows a different path from a gift. Employees declare in the currency they were offered, and conversion against your limits is automatic.
Which markets does Affinisio(GNE) serve?
Affinisio(GNE) serves the United States, the United Kingdom, Ireland, the Netherlands, Malta, Cyprus, Germany, France and Denmark as its primary markets, and can also service organisations in India whose obligations follow from linkages to those jurisdictions. For an Indian firm the same register and the same review serve its domestic policies as well, including those framed by the Prevention of Corruption Act and by SEBI and AMFI codes of conduct. Affinisio(GNE) is deployable globally.
What is the FINRA gift limit, and how does Affinisio(GNE) apply it?
FINRA Rule 3220 sets the limit at $300 per person per year, raised from $100 with effect from 30 March 2026 (Regulatory Notice 26-05). It is an aggregate limit per recipient rather than a limit per gift, and gifts from the firm and from its associated persons to the same recipient are counted together. Affinisio(GNE) checks both: the individual gift in its own right, and the running total for that recipient. Aggregation is automatic and switched on by default, and the period it is measured over is yours to set, whether calendar, financial or rolling. The limits themselves are yours to maintain, so when a threshold moves you change it without waiting for us.
How does Affinisio(GNE) handle a gift received by more than one person?
A hamper sent to a team, or a table at an event, reaches more than one person. Affinisio(GNE) splits the value across the employees who received it, so each person’s share counts against their own limit and against the running total for that counterparty. Splitting applies to what your employees receive. What a recipient organisation does with something your firm gives is governed by its own policies rather than by yours, so Affinisio(GNE) does not split on the outward side.
Can Affinisio(GNE) be deployed on-premises, and where is the data held?
Yes. Affinisio(GNE) can be deployed on-premises inside your own estate, in a private cloud you manage, in a hybrid arrangement, or hosted. On an on-premises deployment the data never leaves your estate: disclosures, valuations, approvals, the gift register and the record of indirect relationships all reside internally and within your control.
Promotional codes – Gifts and Expenses
Gift Expenses Paid for Personally.
Concert Tickets – Gifts Expenses Policy
Gifts and Expenses – Sports Tickets.
What’s New
On-Premises vs SaaS – The Primer
FCPA – What Exactly Is It?
Gift, Entertainment Policies – What Does it Mean, Really?
