The Justice Insiders: Giving Outsiders an Insider Perspective on Government

DOJ’s Cacophony of Whistles

Episode Summary

Host Gregg N. Sofer welcomes Husch Blackwell partner Christina Moore to the show to unpack recent remarks made by Deputy Attorney General Lisa Monaco concerning a new Department of Justice whistleblower program. Monaco described a “90-day sprint” to stand up the new program, which purports to enhance DOJ’s corporate enforcement efforts by offering financial incentives to individuals who come forward with information about violations of federal law. Gregg and Christina discuss the peculiarities of the program as it is understood presently, including questions regarding the anonymity of whistleblowers, the complications of multiple competing whistleblower programs, and the complexities of handling information in parallel proceedings. Gregg and Christina also explore the practical matter of how the newly proposed program should be addressed by corporate compliance professionals and the importance of properly staffing and resourcing such programs so that employees utilize in-house channels to surface potential instances of wrongdoing.

Episode Notes

Host Gregg N. Sofer welcomes Husch Blackwell partner Christina Moore to the show to unpack recent remarks made by Deputy Attorney General Lisa Monaco concerning a new Department of Justice whistleblower program. Monaco described a “90-day sprint” to stand up the new program, which purports to enhance DOJ’s corporate enforcement efforts by offering financial incentives to individuals who come forward with information about violations of federal law.

Gregg and Christina discuss the peculiarities of the program as it is understood presently, including questions regarding the anonymity of whistleblowers, the complications of multiple competing whistleblower programs, and the complexities of handling information in parallel proceedings.

Gregg and Christina also explore the practical matter of how the newly proposed program should be addressed by corporate compliance professionals and the importance of properly staffing and resourcing such programs so that employees utilize in-house channels to surface potential instances of wrongdoing. 

Gregg N. Sofer Biography

Full Biography

Gregg counsels businesses and individuals in connection with a range of criminal, civil and regulatory matters, including government investigations, internal investigations, litigation, export control, sanctions, and regulatory compliance. Prior to entering private practice, Gregg served as the United States Attorney for the Western District of Texas—one of the largest and busiest United States Attorney’s Offices in the country—where he supervised more than 300 employees handling a diverse caseload, including matters involving complex white-collar crime, government contract fraud, national security, cyber-crimes, public corruption, money laundering, export violations, trade secrets, tax, large-scale drug and human trafficking, immigration, child exploitation and violent crime.

Christina Moore Biography

Full Biography

A St. Louis-based partner on Husch Blackwell’s Healthcare and White Collar, Internal Investigations & Compliance teams, Christina represents clients in a wide variety of healthcare litigation and compliance matters, including insurance questions, reimbursement disputes, regulatory matters, and Department of Justice investigations. Previously, she served as an Assistant U.S. Attorney in Missouri for nearly a decade, often handling medical malpractice matters, healthcare fraud, and qui tam actions. She later accepted an in-house counsel role on the medical campus of a large private university, guiding the medical school, health sciences college, and nursing school, as well as a physician practice of more than 500 providers.

Additional Resources

Christina Moore and Madison Rector, “Let’s Make a Deal with DOJ: The Impact of the DOJ’s New Whistleblower Reward Program on Corporate Compliance,” Healthcare Law Insights, April 26, 2024

U.S. Department of Justice, “Deputy Attorney General Lisa Monaco Delivers Keynote Remarks at the American Bar Association’s 39th National Institute on White Collar Crime,” March 7, 2024

Michaels, Dave,“Justice Department to Pay Whistleblowers Who Tip on Corporate Crime,” The Wall Street Journal, March 7, 2024

Smagalla, David, “Justice Department to Flesh Out Whistleblower Program After 90-Day ‘Policy Sprint,’” The Wall Street Journal, March 8, 2024

Freedman, Robert, “DOJ said to be opening can of worms with whistleblower awards,” Legal Dive, March 12, 2024