From the earlier post about unlicensed deals in Washington state:

> Washington law is particularly severe when it comes to the unlicensed sale of insurance. Under the law, anyone who knowingly sells, solicits, or negotiates insurance without the proper state license can be punished with a prison sentence of up to 10 years, as well as a civil penalty of up to $25,000 for each violation.

http://www.buzzfeed.com/williamalden/80-of-zenefits-deals-in...

Important consideration here may be that zenefits employees would possibly be liable. Does anybody know if they were made aware of the issues before Nov 2015?

Out of interest, do Credit Default Swaps fall into that category of "insurance"?

No

technically Sacks could be under the hook also for non-compliance...

Depends but it's possible. Given the decision though it was important to distance themselves, both culturally and legally. Anybody who is seen to contribute to non-compliance WILL NOT be celebrated. What the regulators want to see, what the employees need to see. In fintech/regtech, if you contribute to making others in the company non-compliant you should be dead to the company - not because they necessarily did anything "evil" or anything like that, just because that's how it HAS to be treated.