Client Gifts for Financial Advisors: Custom-Label Liquor and Gift Rules

Financial advisors and wealth managers live on relationships and referrals, so client gifts matter. They also come with more rules than most industries: your firm's gift policy, the industry gift rules that apply to you, and the tax treatment of what you spend. This guide covers how advisors can give liquor gifts that feel personal, stay inside the lines, and keep the firm's name in front of clients. It is general information, not compliance, legal or tax advice. 21+ only.

Start with your firm's compliance policy

Before you pick a bottle, check your firm's gift policy with your compliance team. Many firms set their own limits, require pre-approval for gifts, and ask you to log what you give and to whom. Policies differ between broker-dealers, registered investment advisers, banks and insurance firms, and between firms of the same type. Your compliance team's answer is the one that counts.

What FINRA Rule 3220 says

For FINRA member firms and their associated persons, FINRA Rule 3220 limits gifts to $300 per individual per year when the gift is given to a person, employee or representative of another business and relates to the business of the recipient's employer. FINRA's text says gifts are valued at cost, excluding tax and delivery charges, and that gifts to the same recipient are added up over the year. The rule's supplementary material also says it does not apply to gifts to individual retail customers, and it covers exceptions such as personal gifts for infrequent life events and de minimis or promotional items. FINRA amended the rule effective March 30, 2026, so read the current text and ask your compliance team how it applies to each recipient on your list, especially gifts to centers of influence such as CPAs, attorneys or other professionals at other firms.

Other gift rules can apply too, depending on how you are registered and who the recipient is. When in doubt, ask compliance before you order.

The tax side: the IRS $25 rule

Separate from compliance, the IRS generally limits the deduction for business gifts to $25 per recipient per year, with some exceptions. Our guide Are Business Gifts Tax Deductible? The IRS $25 Rule and Liquor explains the basics. It is general information, so check with your tax advisor.

Why a custom-label bottle works for advisors

Your firm's name stays on the shelf

A custom-label bottle carries your brand on the label. It sits on a client's bar cart long after the holiday card is gone. See client appreciation gifts for how companies use it.

The same gift for every client

Every client on the list gets the same bottle, label and presentation. That consistency is fair, and it makes it simpler to document a single gift and its value for your compliance team.

Sized for a book of clients

Bourbon and rye programs start at about one barrel, roughly 200 bottles. For other spirits and ready-to-drink formats, program size is confirmed on your quote. Spirits are bottled in 750ml. If your book is a few hundred households, see private barrel bourbon and custom-label whiskey. For a handful of bottles, an engraved stock bottle may fit better; our engraved vs custom-label guide compares the two.

Shipped to each client

Our licensed retailer partners ship to most US states; eligibility is confirmed at checkout. An adult 21 or older must sign for each delivery.

How to plan an advisor gift program

1. Get compliance sign-off first. Share the recipient list, the gift and its value, and follow your firm's approval and logging process.
2. Split your list. Retail clients, centers of influence at other firms, and your own team can fall under different rules. Ask compliance how each group is treated.
3. Set the budget by tier. Our guide to how much to spend on client gifts walks through it.
4. Plan the timing. Lead times are the same as our creator drops, roughly 10 weeks, through label design, federal label approval and bottling. Start well before the date you have in mind.
5. Request a quote. See how it works, then Request a quote with your list size, spirit and dates.

Your brand. Your bottle. We handle it.

FAQ

Can financial advisors give clients liquor as a gift?

Often, yes, but it depends on your firm's gift policy and the rules that apply to you and each recipient. Check with your compliance team before ordering. This is general information, not compliance advice. Request a quote

What is the FINRA gift limit?

FINRA Rule 3220 limits gifts to $300 per individual per year when they go to a person at another business and relate to that employer's business. FINRA's text says the rule does not apply to gifts to individual retail customers. Your firm may set its own, stricter limits, so confirm with compliance.

Are client gifts tax deductible for advisors?

The IRS generally caps the business gift deduction at $25 per recipient per year, with some exceptions. See our guide to the IRS $25 rule and check with your tax advisor.

What's the minimum order for a custom-label program?

Bourbon and rye programs start at about one barrel, roughly 200 bottles. For other spirits and ready-to-drink formats, program size is confirmed on your quote. Request a quote

How long does a custom-label program take?

Lead times are the same as our creator drops, roughly 10 weeks. We can't promise delivery by a specific holiday, so plan early. Request a quote

Can each bottle ship to a different client?

Yes. Our licensed retailer partners ship to most US states; eligibility is confirmed at checkout. An adult 21 or older must sign for each delivery.

Do I pay upfront?

Corporate gifting is paid upfront, after you approve your quote and before design starts. Request a quote

Handled gifts are for adults of legal drinking age (21+). Please enjoy responsibly. This article is general information, not compliance, legal or tax advice.