Compliance Stuff

On February 13, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) launched a  new webpage  to confidentially accept whistleblower tips on fraud, money laundering, and sanctions violations. This Q&A with Jane Norberg, co-chair of Ogletree Deakins’ Whistleblower and Compliance practice group, is designed to help employers understand the legal considerations and whistleblower protections. 00:00 24:53 Quick Hits FinCEN has launched a confidential webpage for reporting tips on fraud, money laundering, and sanctions violations, enhancing support for whistleblowers . Whistleblowers reporting violations to FinCEN are protected from retaliation by their employers and may receive rewards ranging from 10 percent to 30 percent of monetary sanctions that exceed $1 million , once new regulations are finalized. Q: What types of whistleblower tips are considered under this new website? A:   FinCEN’s Office of the Whistleblower accepts tips rela...

Effective January 1, 2026, New York’s LLC Transparency Act imposing beneficial ownership reporting on New York LLCs and foreign LLCs authorized to do business in New York goes into effect. Despite the interim final rule (IFR) issued by the Financial Crimes Enforcement Network (FinCEN) in March 2025 revising the definition of “reporting company” for purposes of the federal Corporate Transparency Act (CTA) exempting entities formed under the laws of a U.S. state or tribal authority from reporting under the CTA, the New York Limited Liability Company Transparency Act (NYLLCTA) survives and will go into effect on January 1, 2026 . The NYLLCTA applies to both limited liability companies (LLC) formed in the state of New York or LLCs formed in any other state (foreign LLCs) that are registered to do business in the state of New York. As a result, LLCs formed under New York law or registered to do business in New York (each a “reporting company) must file either the required beneficial ownersh...

We continue our series on the legal and regulatory challenges facing individual coverage health reimbursement arrangements (ICHRAs); this time, we are focusing on the fintech-related requirements that may apply to ICHRA vendors. In  part one  of our series, we summarized an array of health benefit plan and third party administrator compliance requirements with a brief mention of money transmission considerations. In  part two , we further explored other health benefit plan compliance issues as well as tax and insurance agency topics. In part three (this article), we explore an array of financial services laws and regulations that may apply to many ICHRA vendor activities, many of which may surprise you. Overview Some ICHRA vendors see themselves as merely the administrators of a simple employee benefit, striving to provide excellent user experiences, streamlined processes, and robust healthcare benefit administration services. So why would financial services laws and reg...

  In 2025, many companies will prioritize investments in technology and building supply chain resilience.  The incoming Trump administration is poised to bring significant changes to the U.S. business landscape, reshaping the economic and regulatory environment at both federal and state levels. Additionally, the  Corporate Transparency Act,  now entering its second year, continues to influence compliance requirements and business operations across industries.  As companies look ahead, these considerations will be at the forefront of their 2025 strategy. With that in mind, let’s look at key business and legislative trends for large companies in the coming year, how these trends will affect business strategy, and tips for preparing for the year ahead.  This article covers: Business trends to watch in 2025 Agentic AI AI governance Tax policy changes Cybersecurity threats Trade policy changes Navigating climate impacts Legislative trends to watch in 2025 AI reg...