New York City’s Expanding Role in Corporate Enforcement

For years, corporate counsel have mapped enforcement risk by looking primarily to Washington. That map is now out of date: New York City is emerging as a more formidable regulator. 

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 (Task Force) to pursue corporate misconduct. And in January 2026, Mayor Zohran Mamdani appointed Samuel Levine, the former Director of the Federal Trade Commission’s (FTC) Bureau of Consumer Protection under Chair Lina Khan, as the Commissioner of New York City’s Department of Consumer and Worker Protection (DCWP).

For any businesses operating in New York, the question is no longer whether the City matters in the regulatory environment. The question is how to best prepare for increased scrutiny.  Here, we dive into the City’s entry into white collar and consumer protection enforcement and what companies could consider doing to anticipate investigations and enforcement actions.

White Collar

In remarks announcing the Task Force, DA Bragg framed white collar enforcement as especially urgent at a time when “faith in both private and public institutions [is] really low.” The first-of-its-kind Task Force will prioritize fraud and other forms of misconduct, with a focus on consumer fraud among healthcare companies, the food services industry, and retailers. Notably, the Task Force will not only target corporations, but also their executives, to “deter industry-wide misconduct.” This focus could also extend to out-of-state companies if their conduct meets the required commercial nexus for criminal prosecution in Manhattan. The Task Force—led by Matthew Bogdanos, an Assistant District Attorney with nearly four decades of prosecutorial experience—builds on DA Bragg’s expansion of the Office’s white collar enforcement efforts. The Task Force is expected to expand upon the work of the City’s Worker Protection Unit and Stolen Wage Fund, including by pursuing wage-fixing investigations and utilizing the office’s financial intelligence unit. Additionally, in August 2026, the DCWP announced a partnership with the District Attorney’s Office in part to combat wage theft. This information-sharing arrangement may support the Task Force as it looks “upstream” to investigate potential criminal conduct.

Consumer Protection Creation of the Task Force is the latest in a series of actions on the consumer protection front under Mayor Mamdani. With Samuel Levine now leading the DCWP, the City’s consumer-protection priorities increasingly reflect issues that were also prominent during Levine’s tenure at the FTC.. Levine has stated that he sees DCWP’s role as “taking on the biggest corporations” and has pointed to labor (including delivery workers), renters, and consumers as constituencies of particular importance for the DCWP.

Under Levine, the DCWP has prioritized rulemaking and enforcement actions relating to junk fees, “click to cancel” subscription rules, “all-in price” mandates, deceptive advertising, algorithmic workforce practices, and AI-enabled harms such as voice cloning scams. Levine has also reiterated his longstanding opposition to so-called “surveillance” pricing—a practice where businesses use a specific consumer’s data, for example location, browsing history, and purchase patterns—to set prices unique to that purchaser. DA Bragg, for his part, has said that his office intends to use New York State’s antitrust laws to target companies that collude to keep wages low—including through criminal prosecutions.

For instance, recent DCWP enforcement actions have resulted in significant settlements involving alleged consumer-protection and delivery-worker-law violations. Levine also created a new Research and Analytics Division to strengthen DCWP’s investigative capacity, and (alongside Mayor Mamdani) proposed a city-level private right of action for unfair business practices (the POWER Act).

Key Takeaways

• Compliance remains key.  DCWP and other city regulators have signaled their intent to scrutinize an increasingly wide swath of corporate conduct.  New York City’s entry into the regulatory space comes amid a changing federal enforcement environment and as state attorneys general are becoming increasingly active in the enforcement landscape. In the face of the City’s expanding enforcement activity, companies operating in the five boroughs may wish to consider reassessing their investigations functions and compliance strategies—in particular with respect to consumer protection and AI—to proactively address increased scrutiny from DA Bragg, Commissioner Levine, and other regulators. This could include staying abreast of recent developments, documenting their practices, conducting refresher trainings, identifying material risk areas, and ensuring accurate reporting channels.
• Algorithmic pricing remains top of mind for regulators. As we previously discussed, algorithmic pricing will continue to be a pressing issue, particularly in New York: Governor Kathy Hocul signed the state’s Algorithmic Pricing Disclosure Act in May 2025. Companies could consider reviewing their pricing disclosures, including marketing materials, to make sure they are accurate and clearly state that consumer data may be used in pricing algorithms. They may also consider appropriate testing of dynamic pricing algorithms to guard against improper bias and discrimination and audit their services and pricing practices for compliance with applicable privacy laws. Finally, companies may wish to assess the practices of their third-party suppliers.
• Regulatory scrutiny of AI platforms continues to evolve. Those operating on the cutting edge of AI should continue to engage with legislators and regulators regarding policy priorities, while also monitoring and adjusting internal compliance practices in the face of rapidly evolving regulatory change. In September 2026, New York City Council Speaker Julie Menin announced a package of AI bills that would require third-party validation of AI systems for data quality, bias, privacy and security, plus a human-operated “kill switch” before they can be marketed, sold or deployed in the City. The bills would also create private rights of action for harms from AI chatbots and foreseeable AI misuse, add disclosure and advertising rules, and offer whistleblowers 25 to 50 percent of the funds recovered by the City. Simultaneously, the New York Department of Financial Services (NYDFS) is spearheading the implementation and enforcement of New York’s landmark Responsible AI Safety and Education (RAISE) Act, which requires developers of the largest frontier AI models to ensure implement transparency, governance, and catastrophic risk guardrails.  These developments, as well as similar developments at the federal and state level around the country, underscore the importance of a proactive approach to address evolving compliance requirements while continuing to engage with policymakers to promote innovation in this rapidly evolving sector.

Our team, which has already been advising on New York’s evolving regulatory and enforcement landscape, includes a former FTC commissioner and attorney advisers, a former Consumer Financial Protection Bureau (CFPB) attorney, a former Chief of the Criminal Division in the U.S. Attorney’s Office for the Southern District of New York (SDNY), a former Chief of SDNY’s Complex Frauds and Cybercrime Unit, and a former state Attorney General, among others. Freshfields brings substantial experience with consumer-protection investigations, enforcement and rulemaking, including matters in which federal, state, and local enforcement authorities may pursue parallel proceedings. We would be happy to discuss these developments and how they impact your organization.

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