On October 14, 2026, Manhattan District Attorney (DA) Alvin Bragg announced the formation of a Corporate Crime and Antitrust Task Force that will “focus on complex investigations targeting fraud and misconduct by corporations and corporate executives, including antitrust violations, health care and other consumer fraud.” The task force has broad jurisdiction that could cause it to examine corporate conduct with nationwide impact, rather than New York-specific conduct. Namely, its mandate is “to hold organizations fully accountable for corporate criminality, deter industry-wide misconduct, and catalyze systemic reform.”
As discussed in our previous posts, the US Department of Justice (DOJ) has adopted a more targeted approach to corporate investigations, while New York City agencies, like the Manhattan DA, are increasing their focus on corporate enforcement. The Manhattan DA’s new task force exemplifies a continuation of the trend of state and local enforcement agencies trying to take a more active role amid the DOJ’s shifting priorities. Companies with operations in New York City should consider whether their compliance and training programs account for this evolving enforcement environment.
The new task force
Bragg described the task force’s goal as achieving “systemic accountability” by focusing on executives, corporations, and broader systems and structures. The press release provided examples of the DA’s “approach to tackling systemic issues,” including:
- A multifaceted campaign against ghost guns, including prosecuting violent offenders, manufacturers and traffickers; partnering with Gov. Kathy Hochul and the legislature to increase criminal penalties and create new safety standards; and calling on 3D printer manufacturers to voluntarily adopt new safeguards.
- Prosecuting cryptocurrency crimes, including overseas terrorism financing operations, while working with New York legislators to advance a bill that would make it illegal to operate a virtual currency business in New York without a license.
As these examples demonstrate, the new task force likely will seek to make an impact not only by prosecuting alleged crimes, but also by advocating for new legislation and calling on companies to make voluntary changes.
It appears that an early focus of the task force will be on labor and consumer issues impacting affordability. In August, the DA’s office signed a memorandum of understanding with the New York City Department of Consumer and Worker Protection (DCWP) to facilitate information sharing between the two agencies and strengthen DCWP’s referral of civil matters to the DA’s office for criminal review. As we discussed previously, the DCWP is emerging as an increasingly consequential enforcement agency, with labor and consumer protection issues at the top of its agenda. Taken together, these developments suggest that labor-market competition may receive attention from the new task force.
The task force will be led by Matthew Bogdanos, a 40-year veteran of the DA’s office, who will be supported by approximately five assistant DAs and two investigative analysts. According to the press release, the task force’s personnel have experience handling “financial services fraud, securities fraud, and antitrust matters.”
The task force could draw on a range of New York statutes to prosecute corporate entities, including the Donnelly Act (New York’s antitrust statute) and the Martin Act (New York’s securities fraud statute). In addition, the DA could rely on broad New York Penal Law provisions, such as those covering fraudulent schemes, healthcare fraud, and commercial bribery.
Notably, while the Donnelly and Martin Acts provide the New York Attorney General (NYAG) broad authority to serve pre-suit civil investigative demands, the DA’s pre-suit investigative authority is limited to narrower grand jury subpoenas. However, the NYAG is generally permitted to share evidence with the DA, so the new task force may find it valuable to coordinate with the NYAG – particularly with its Antitrust, Investor Protection, Consumer Frauds and Health Care Bureaus. Companies that receive investigative inquiries from the NYAG should be aware that any documents produced could be shared with the DA’s office for potential use in a parallel criminal proceeding.
Expanding state and local corporate enforcement
The new task force is part of a broader expansion of state and local corporate and antitrust enforcement – often with implications reaching beyond the particular state or local jurisdiction. For example, in recent years, state attorneys general have challenged proposed mergers, investigated potential competition concerns involving algorithmic pricing, examined chatbot platforms for privacy issues and prosecuted alleged bid-rigging schemes. State and local enforcement agencies often join forces in bringing and settling enforcement actions.
At the same time, recent amendments to state antitrust laws have increased the potential penalties for violations. California raised the maximum criminal fine for corporations from $1 million to $6 million per violation and authorized civil penalties of up to $1 million per violation. Colorado increased the maximum civil penalty from $250,000 to $1 million per violation and the maximum criminal fine for corporate violators from $1 million to $5 million. Washington replaced its previous $900,000 corporate penalty cap with a maximum of up to three times the economic benefits as a result of the violation.
Key takeaways
- In light of these developments, companies should consider monitoring state and local enforcement priorities and legislative efforts, independently of developments at the federal level.
- Companies should also consider reviewing and updating their antitrust and fraud compliance policies and training to address conduct likely to attract scrutiny from the DA’s office.
- Companies should be sensitive to the risk that information they provide to the NYAG or another agency with civil investigative authority may be shared with the DA’s office to aid in criminal prosecution.
Contributors
Rebekah Donaleski
Sarah Egoul
