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Great analysis. I deal with conflict of interest regularly in my grant reviews. One grant can't distribute funds to people that have conflicts. I had a grantee ask if they only worked so many hours with a conflict does it still count. It's very black and white in my position if you work at all for a conflict then you can't receive funds. I can see this as a gray area because I am sure they can receive gifts up to a certain amount (at least for my agency that's the rule).