THIS WEEK’S TOP STORY

Rare Declinations by DOJ’s National Security Division Demonstrate Potential Benefits of Voluntary Disclosure — but Could Obscure the Risks

In a recent speech, Matthew R. Galeotti, the head of the DOJ’s Criminal Division, discussed changes in how the DOJ intends to conduct corporate enforcement. The speech, which followed the recent announcements of declinations by the National Security Division, provides insight into how the DOJ is likely to conduct its investigations and make charging determinations as well as guidance to companies on how to navigate a DOJ with changing enforcement priorities. Morgan Lewis partners Justin Weitz, Loyaan Egal and Katelyn Hilferty and associate Moshe Klein encourage companies to remember that self-disclosure has downsides, too.

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Caught Between Conscience and Career: An E&C Leader’s Confession

The mental health crisis among ethics and compliance professionals has remained largely unspoken despite its prevalence. Drawing on personal experience and CCI's "2025 Compliance Officer Working Conditions" report, an anonymous ethics and compliance leader in the defense industry examines the misaligned reporting structures, competing priorities with legal departments and professional isolation that create conditions where toxicity thrives while resources dwindle — and yet, why practitioners remain dedicated to their mission even as organizational structures systematically undermine their effectiveness and wellbeing.

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Outsourced Compliance: A Strategic Response to Regulatory Strain

Regulatory uncertainty and stretched compliance teams are creating new pressures for firms navigating an evolving enforcement landscape, even as the SEC appears to be taking a more targeted approach to violations. STP Investment Services’ head of compliance, Lori Weston, examines how outsourced compliance services can provide immediate access to experienced professionals with regulatory knowledge and operational capacity, while offering the pattern recognition and industry perspective that internal teams may lack time to develop, particularly when paired with regulatory technology solutions.

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SPOTLIGHT ON AI

Planning Your AI Policy? Start Here.

Effective AI governance begins with clear policies that establish boundaries for workplace use. Bradford J. Kelley, Mike Skidgel and Alice Wang of Littler Mendelson reveal how well-designed AI policies can help organizations balance innovation with risk management, providing a framework for tool approval, data security, training and vendor management that addresses the complex legal and operational challenges of AI adoption.

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