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.
