2026年10月19日

Manhattan District Attorney’s Office Launches Corporate Crime and Antitrust Task Force

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The New Task Force

On October 14, 2026, Manhattan District Attorney Alvin L. Bragg, Jr. announced the formation of the Office’s first Corporate Crime and Antitrust Task Force (the “Task Force”). The Task Force will investigate complex fraud and misconduct by corporations and their executives, including antitrust violations and health care and other consumer fraud, with the stated goal of holding organizations “fully accountable for corporate criminality.”

Leadership and Resources

The Task Force is led by Matthew Bogdanos, a veteran of the Office, and is staffed by approximately five Assistant District Attorneys and two investigative analysts with experience in financial services fraud, securities fraud, and antitrust matters. It will draw on the Office’s investigators, forensic accountants, and Financial Intelligence Unit, which analyzes data from the Financial Crimes Enforcement Network (“FinCEN”), making Bank Secrecy Act reporting a potential source of leads.

Looking Upstream: A Continuation of Efforts to Seek Systemic Accountability

The Office frames the Task Force as an expansion of its existing practice of looking upstream to the entities that enable and profit from crime, including its past efforts in:

  • Pressing 3D-printer and technology companies to adopt safeguards against ghost gun production, helping secure first-in-the-nation safety standards for 3D printers sold in New York;
  • Proposing, with New York State Senator Zellnor Myrie, the CRYPTO Act, which would criminalize operating an unlicensed virtual currency business in New York;]
  • Investigating large-scale fencing operations that resell stolen retail merchandise; and
  • Seizing websites that serve as conduits for crime, including the September 2026 seizure of 12 domains allegedly selling non-consensual AI-generated deepfake videos, and urging a major social media platform to remove accounts impersonating a pro bono legal organization.

Companies may face similar pressure if their products, platforms, or business arrangements potentially facilitate others’ misconduct, and should be prepared to demonstrate adequate safeguards.

Part of a Broader White Collar Expansion

DA Bragg’s announcement follows reported departures of prosecutors with antitrust, securities and market manipulation expertise from the U.S. Department of Justice. New York state and local authorities’ enforcement efforts appear to be seeking to fill perceived gaps in federal white collar enforcement. As a result, companies that previously calibrated compliance primarily to federal enforcement priorities should now consider also including the Office in their risk assessments.

In addition to the new Task Force, the Office’s August 2026 memorandum of understanding with the New York City Department of Consumer and Worker Protection (“DCWP”) allows certain civil matters to be referred for criminal prosecution. The Office has also recently brought significant corporate cases, including a $76 million fraud case and a 2025 indictment of a construction company and its executives for an alleged scheme involving unpaid workers compensation insurance premiums.

Areas of Heightened Risk

While the Office has not identified specific targets or cases, DA Bragg’s announcement highlights the following areas of heightened risk:

Criminal antitrust: The inclusion of antitrust signals that the Manhattan DA intends to more aggressively investigate criminal competition-law violations in addition to the office’s traditional fraud focus. Criminal antitrust enforcement has historically been the province of the U.S. Department of Justice’s Antitrust Division, with the New York Attorney General’s Antitrust Bureau as the State’s principal competition enforcer. However, New York’s Donnelly Act (N.Y. General Business Law § 340 et seq.) imposes criminal penalties for price-fixing, bid-rigging, market allocation, and certain other anticompetitive agreements, and the Manhattan DA may use it more actively, including against wage-fixing and other employer collusion in employee-focused sectors such as health care, food service, and retail. The Donnelly Act already provides a framework for coordination: Section 347 requires a district attorney to give the New York Attorney General reasonable notice of an intended prosecution and permits the New York Attorney General to appear and direct the district attorney’s role in the matter. It remains to be seen how the Task Force will coordinate with the New York Attorney General—as well as with the US DOJ—in practice. Companies could face multiple inquiries into the same conduct, such as competitor information sharing and algorithmic pricing.

Corporate and financial fraud: Given the Task Force’s securities fraud experience and access to FinCEN data, financial institutions, investment firms, and companies with significant New York payment flows may see increased inquiries and grand jury subpoenas. These companies should consider whether their anti-money laundering (AML) and sanctions controls could be characterized as insufficient in preventing the facilitation of customer misconduct.

Health care and consumer fraud: The Office specifically identified these areas as priorities. Given the Office’s new partnership with DCWP, deceptive pricing, fee, and subscription practices, as well as health care billing and coding, may receive criminal (and not merely civil) scrutiny, particularly where the conduct is large-scale or long-running, or involves retaliation.

Individual executive exposure: The focus on corporate executives means senior management may be investigated alongside the entity.

Key Takeaways

  • Treat the Manhattan DA as a significant corporate enforcer. Companies based in, operating in, or transacting through Manhattan, including via New York banks, should include the Office in enforcement risk assessments.
  • Revisit antitrust compliance. With criminal state-law exposure in mind, refresh training and controls for sales, pricing, HR, recruiting, and procurement personnel on competitor communications, trade associations, pricing tools, and no-poach, non-solicitation, and wage-setting arrangements.
  • Assess upstream exposure and strengthen fraud and AML controls. Evaluate whether your products, platforms, or services could be characterized as enabling third-party misconduct and whether existing safeguards are adequate, and ensure suspicious activity monitoring, escalation, and recordkeeping are robust and well documented.
  • Prepare for subpoenas, parallel proceedings, and individual exposure. Update protocols for grand jury subpoenas, search warrants, and DA inquiries, including preservation, privilege, and employee escalation, as state criminal process differs from federal practice. Because certain civil matters may be referred for prosecution, and parallel inquiries from DCWP, the Office, the New York Attorney General, and federal authorities are possible, prepare responses to civil regulators with potential criminal exposure in mind. Assess early whether executives or employees need separate counsel, review indemnification and advancement arrangements, and consider a privileged internal review to identify and remediate issues before a referral or investigation.

Companies operating in or transacting through New York should consider reassessing their compliance programs in light of the Task Force. Please contact Mayer Brown with questions or for advice on responding to inquiries from the Task Force or other New York enforcement agencies.

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