For any firm monitoring conflicts of interest, gifts and entertainment (G&E) is a core component. You need to know who’s giving what, who’s receiving it, and whether such activities are aligned with your firm’s policies. From a high level, it’s simple compliance stuff.
But like many compliance tasks, G&E preclearance can be voluminous for compliance teams and downright frustrating for employees. In the eyes of the employee, it’s easy for preclearance to be seen as yet another layer of red tape taking time away from higher ROI activities.
Of course, the compliance officer would dispute that claim. Doing G&E wrong can be very, very costly. Just ask the firm who recently received a $10 million FINRA fine after investigators found a pattern of excessive non-cash compensation flowing through gifts, meals, and entertainment. At its core, the case was about weak controls. Gifts and entertainment weren’t sufficiently tracked, thresholds weren’t enforced, and the firm failed to establish an adequate supervisory system.
Suddenly, the ROI of robust compliance seems much more real. Your firm’s ability to document, review, and restrict activity is a key safeguard against real financial and reputational harm.
Preclearance isn’t always easy
Nonetheless, it’s hard not to empathize with employees when you take off your compliance hat and just look at G&E preclearance forms for what they are. For someone not closely involved with compliance work, these forms can be unnecessarily dense, cumbersome, and unintuitive.
Let’s say a group of employees plans to take some key clients to a football game. Which employee is submitting the preclearance request? One of them? All of them? If the former, how easy is it for the chosen employee to accurately list the other employees in the request? And how does the employee accurately break down the cost of the gift among the clients?
What begins as a simple request by an employee trying to do the right thing can become a headache without intuitive forms – and a burden for the compliance supervisor who will inevitably be responsible for reconciling these questions.
How Comply is optimizing G&E workflows
This is where Comply comes in. We’ve been hard at work simplifying G&E preclearance in the Comply Platform. We know it’s a high-volume, high-impact area, and have introduced a number of enhancements to make the process simpler for both employees and supervisors.
A flexible “Additional Employees” field
An “Additional Employees” field now appears by default in all G&E templates, and you can rename or reorder it to match your internal workflow. Group activities often create ambiguity; this change gives you more control over how those details are captured. For example, if two employees are taking a client to a football game, both could be accounted for in a single G&E request by utilizing this new field.
Optional single third-party selection
Some firms want each request tied to a single recipient. Others need flexibility for multiple recipients. The new toggle lets you enforce one-recipient submissions when appropriate.
Simplified value inputs for bulk requests
Instead of relying on three linked value fields and automated calculations, you can opt to use two straightforward manual fields: “Total Value” and “Value Per Person.” This reduces confusion and gives employees a more straightforward way to enter cost information – helpful in cases with multiple recipients.
Preclearance API
Beyond the mechanics within G&E forms, we’ve also optimized the broader process with our G&E Preclearance API – an integration that allows firms to connect expense systems such as Concur directly to the Comply Platform, creating a bidirectional flow of G&E data. Employees submit their information in the expense tool they already use, and the request is automatically evaluated against the firm’s G&E rules inside Comply.
This single-entry workflow cuts down on duplicative entries, removes inconsistencies between systems, and reduces the time compliance teams spend reconciling records. Once a decision is made, the status syncs back to the expense platform, keeping both systems aligned.
Bringing clarity to preclearance
These enhancements are part of Comply’s investment in simplifying preclearance across the Comply Platform. The goal is to reduce noise, remove unnecessary complexity, and give both employees and compliance teams a workflow that works the way compliance actually operates.