I’m at Compliance Week. You seriously wish you were too. It’s a fantastic conference.

I was talking to a government official—one who deals with FCPA—who shall remain unnamed*, talking about gift-giving scenarios and why they were problematic, and how to handle them. Such as: situations where you’d be giving a benefit to the children of a government official. I said that it was tough to approve.

The unnamed government official said something very interesting, that I thought it was worth it to pass along. We were discussing the difference between “influencing” a government official and corruptly influencing that official.

He said, in essence: don’t forget that we look at these things in context. Is your gift-giving policy a real one? Is it enforced within the company? Did this go through your process? Did you document—once again, Tom Fox is right—your approval process?

Plus, is your overall program a real one? Have you operationalized a policy? Or do you have a paper program?

Every issue is viewed in the context of your overall program, and how seriously you take your anti-corruption responsibilities.

Good to know.

*I often hear, “who shall remain nameless.” This is wrong. That is, if the person you don’t identify was given a name at birth, it’s wrong. “Nameless” means that the person doesn’t have a name. “Unnamed” means you’re not going to identify the person. Absent a very strange circumstance, it’s always more correct to say “who shall remain unnamed.” Sorry, the grammar geek in me is coming out.