Paget Barranco

In September 2025 – with little fanfare – the Consumer Protection Branch (CPB or the branch), an influential arm of the U.S. Department of Justice (DOJ), was dissolved and its functions divided between the DOJ's Criminal and Civil Divisions, in a move that could have a lasting impact on companies in highly-regulated consumer-facing industries.

While commentators continue to predict that AI will fundamentally alter the legal profession, and in many cases greatly reduce or eliminate the need for lawyers, real world examples continue to demonstrate that AI is far from perfect. AI outputs can be prone to “hallucinations,” which are assertions that sound confidently true, but are actually false, fictitious, or misleading. In the legal sphere, such hallucinations may manifest as made-up caselaw, fake statutes, or incorrect legal assertions.

As of August 1, 2024, a company that voluntarily self-discloses misconduct within 120 days of receiving an internal whistleblower report, and before DOJ reaches out to the company, will be eligible for a presumption of declination under the amended CEP.1 This applies even if the whistleblower had already submitted a report to DOJ. As Principal Deputy Assistant Attorney General Nicole M.