Regulators increasingly look to customer-facing arrangements to assess whether compliance expectations are embedded in commercial reality. Sell-side contracts shape pricing behavior, market access, use of intermediaries, data flows, export and sanctions exposure, tariff pass-through, and post-sale obligations.

Most compliance problems announce themselves. This one does not. Your plan has been operating under the CARES Act, SECURE 1.0, and SECURE 2.0 for years, your participants have received communications describing those features, and your recordkeeper has administered them faithfully. The only thing that could be missing is the plan language. That gap is permitted by law, but not for much longer, and if you are about to finalize plan highlights, enrollment materials, plan notices, or similar materials for 2026, the gap could be written into another round of participant communications.

In the latest episode of Energized by Foley, Deanna Reitman sits down with Rod Hutchinson for an inside look at one of the most essential — and least understood — forces behind the energy industry: structured commodity finance. From crude and LNG to refined products, Rod explains how these financing structures help move energy from the wellhead to the end user, making global supply chains possible.