At SCE&G, the local power company, we followed the 20/50 rule with the feds. No single gift worth more than $20 or a total of $50 per year.
When we held educational seminars for customers this was often an issue. The total value of morning refreshments, lunch and afternoon refreshments exceeded $20. The legal guideline was that if it was something offered to a broad group of customers then it was OK for government peeps to accept it. We created a form that the feds could use to pay for the event if their organization required it, problem solved. South Carolina also had a "blind trust" sting on bribery with numerous people charged. The State agency folks were equally nervous. Some wouldn't attend, some would pay and some didn't pay.
During customer visits some fed folks refused to accept anything. Some would ask about going to lunch or for the typical trinkets we had.
Almost a big problem. I managed the corporate relationship with the federal customers. Crazy but I was just about the only one that understood the FAR and federal contracting in the Fortune 500 company. For a small State we had a big DOD presence and the typical list of agencies. Fort Jackson, Shaw AFB, McEntire, 2 Navy hospitals, Parris Island MCAS, Naval Weapons Station, Coast Guard, NOAA, Border Patrol, a bunch of GSA buildings, etc. We were trying to get a 1/4 acre site for an underwater transmission cable crossing in Beaufort SC. The Navy had an unused corner of their property on the river. Our local manager and a transmission/substation engineer went to talk to the Navy Captain Base Commander. He agreed to provide the land. If it had been private property it would have been worth more than $250K. On the Navy site it was valued at $10k. Under federal regs they could only sell it for that minor value.
The CPT knew that it was worth a ton of money so he asked for a donation, "Would SCE&G consider an additional donation to our MWR fund to build a recreational dock for the employees?" Our folks said, "I'm sure we can do that, how do we make out the check?"
Two weeks later, Friday at 3 PM, I hear about this story while talking to the local manager. "(excitedly) We got a great deal, I have the check in my drawer and will take it over there on Monday, do you want to come?" "Uhhhh ..... NO. Please don't do anything and don't talk to anyone about this until you hear back from me or the legal group."
Because most power companies are sole source vendors to the feds and the feds can buy more than just electricity, gas and steam (energy services: lighting system upgrades, new HVAC, repairs to their electric grid, surge protection equipment, etc.) they get real comfortable taking with us, we see them frequently and attend their social functions. In this case the CPT wasn't thinking.
Called our General Cousel to explain what happened ... under the FAR, this guy solicited a bribe and we are required to report it. There are big penalties for not reporting and worse if we pay it. General Counsel knows nothing about fed regs and knew that I did, and asked, "So what do you think we should do?" I doubt the CPT remembered that we're a federal contractor, we do one-page sole source deals with them quite often. If you agree, I'll call him on Monday and say, "I understand you met with a couple of our folks about the transmission crossing, it's great that the Navy can help with that. About the MWR thing, do you realize that we're a federal contractor?", and see what he says. You can also call the $500 Washington law firm that you use for advice and see if they agree or take my free advice (a standing joke, he often called to ask for advice then called the $500 guy to confirm it).
The call happens and the CPT's response was, a 5 second pause then, "We're glad to assist SCE&G. We'll issue the invoice for the $10k land value and that's all that's needed. Thanks for calling and look forward to seeing you next time you are here." The check disappeared and was never spoken about again. At our next meeting the CPT gave me a firmer than normal handshake, a smile and said, thanks for keeping me out of the frying pan.
Making that type payment is normal in commercial transactions. It was a good reminder for our engineering and management teams that taking me along to meetings was advisable.
Working with the feds one had to know 3 languages: English, FAR and utility speak.