Given the wording of the regulation, I can totally see how this could happen innocently. I'm in a position where throughout my career I have regularly received and responded to giant RFPs, and it's not at all uncommon that only a handful of people in the company are aware it's happening.
Granted, this is one of many reasons that I stay off of SLED and Fed teams, and I would hope that anyone on one of those would be aware of something like this, but not every company has distinct sales organizations for those verticals.
Given the wording of the regulation, I can totally see how this could happen innocently. I'm in a position where throughout my career I have regularly received and responded to giant RFPs, and it's not at all uncommon that only a handful of people in the company are aware it's happening.
Granted, this is one of many reasons that I stay off of SLED and Fed teams, and I would hope that anyone on one of those would be aware of something like this, but not every company has distinct sales organizations for those verticals.