“What Two Former Texas U.S. Attorney’s Office Heads Want Business Leaders to Know About DOJ Corporate Enforcement in 2025”

Leigha Simonton and Scott Hogan co-authored The Texas Lawbook article, “What Two Former Texas U.S. Attorney’s Office Heads Want Business Leaders to Know About DOJ Corporate Enforcement in 2025.”

In the article, Simonton and Hogan share seven reasons why there has never been a more important time for businesses to keep compliance frameworks in place and, if possible, provide even more resources to them, including:

1. False Claims Act enforcement will fill gaps in FCPA enforcement.  
2. Criminal prosecution of executives for all manner of corporate misconduct will continue.
3. Businesses will pay heavy sums to avoid criminal prosecution.
4. The Criminal Division whistleblower program is here to stay, and DOJ has expanded its reach. As the May 12 memo also noted, 
5. The DOJ’s revised voluntary disclosure guidelines set up a race to report between the whistleblower and the company.
6. No matter the administration, DOJ is likely to investigate a company whose allegedly bad conduct becomes front-page news.
7. Bad actors in a company can do irreparable damage, no matter whether the government intervenes.