Gifting compliance guide for startups, investor relations, and financial services.
Answer 4 questions. Get the exact regulations that apply to your business, recipient type, and budget — including the 2026 FINRA update most finance teams haven't caught up to yet.
FINRA Rule 3220 was just updated: the finance industry gift limit jumped from $100 → $300 per recipient — the first change since 1992. Deal toys are now explicitly exempt from the limit. Retail investors are now explicitly excluded from the rule entirely.
Physical gifts only. All figures are per recipient per year unless noted.
| Framework | Annual Limit | Who It Covers | Source |
|---|---|---|---|
| FINRA Rule 3220 — eff. Mar 30, 2026Broker-dealers & associated persons | $300 was $100 before March 2026 |
Employees of institutional clients, prospects, vendors, counterparties. Retail investors excluded. | FINRA RN 26-05 ↗ |
| FINRA Non-Cash Comp RulesRules 2310, 2320, 2341, 5110 — conformed to $300 (Mar 30, 2026) | $300 product-specific gifts to BD reps |
Registered reps of distributing broker-dealers receiving product-linked gifts from offerors (fund companies, etc.). | FINRA.org ↗ |
| MSRB Rule G-20Municipal securities — conforming amendment in progress | $100 not yet aligned with FINRA's $300 |
Employees of counterparties in municipal securities business. | MSRB Rule G-20 ↗ |
| SEC / Advisers Act (RIAs)Fiduciary standard — no hard limit set by SEC | ~$250 industry compliance norm |
Clients, prospects, institutional counterparties of SEC-registered investment advisers (most PE funds, larger VC funds, hedge funds). | Advisers Act §206 ↗ |
| ERISA Fiduciaries (DOL policy)Pension trustees, 401k plan managers | $250 DOL nonenforcement threshold |
ERISA plan trustees and fiduciaries — pension fund managers, 401k plan administrators. | DOL Enforcement Manual ↗ |
| Stark Law (Physician Gifts)Healthcare — strict liability | $535 non-monetary physical only (CY2026) |
Physicians and immediate family members who refer Medicare/Medicaid business. Strict liability — intent irrelevant. Limit adjusts annually for inflation (CPI-U). | CMS CPI-U Updates ↗ |
| Federal Employee Gift Rules5 CFR Part 2635 | $20 / $50 per occasion / per year |
Executive branch federal government employees. Congressional staff: $50/gift, $100/year. | eCFR ↗ |
| FCPA (Foreign Government Officials)Intent-based — no set dollar limit | ~$250 max before heightened scrutiny |
Foreign government officials, state-owned enterprise employees, international org staff. | DOJ FCPA ↗ |
| IRS Business Gift DeductionPub. 463 · IRC §274(b) | $25 tax-deductible per recipient |
All business gifts. Tax-deduction cap only — not a legal gifting limit. Spend more freely; only $25 is deductible. | IRS Pub 463 ↗ |
* No hard regulatory limit. Figure reflects prevailing industry compliance standard. Physical gifts only — cash, gift cards, and non-physical compensation excluded from all figures above.
Clear answers. Cited sources.
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Legal Disclaimer
The information on this page is provided by Bond and Beyond for general informational and educational purposes only. It is not legal advice and should not be relied upon as a substitute for advice from a qualified attorney. Regulations change, and the application of any rule depends on specific facts and jurisdiction. Bond and Beyond is not a law firm and does not provide legal services. Before acting on anything you read here — particularly in regulated industries (financial services, healthcare, government, etc.) — consult your own legal or compliance counsel. Reading this page does not create an attorney-client relationship. Bond and Beyond disclaims all liability for actions taken or not taken based on the contents of this page.