Anticorruption
“Without strong watchdog institutions, impunity becomes the very foundation upon which systems of corruption are built. And if impunity is not demolished, all efforts to bring an end to corruption are in vain. “
— Rigoberta Menchú, Nobel Prize laureate.
“The fish rots from the head down”
— Ancient proverb
To combat corruption, the newly created Citywide Department of Public Integrity will be the exclusive office in city government for investigating corrupt agencies and employees. When it comes to corruption, no agency will be permitted to police itself. The new office will have the power to prosecute offenders and ban them from holding jobs in city government. The prosecutions will be transparent, using a newly created Citywide Corruption Court to fast-track cases. The new structures outlined below will insulate agencies from political encroachments. Working with lawmakers, CDPI will enjoy complete independence.
The failure to stop corruption is a failure of political leadership. At bottom, the issue is not complicated: every citizen bears the hidden costs of corruption. Corruption at the top is like a cancer that infects the whole body. But corruption anywhere causes massive disruption, interferes with city services, and causes waste and inefficiency.
To deter it, a strong anticorruption system is paramount. If the anti-corruption system is weak—and ours has many weaknesses—the result is more and worse corruption. We have seen this again and again. We have had two successive Mayors embroiled in scandal for doing favors for contributors and supporters—one resulting in a 3-year federal investigation (de Blasio) and another resulting in a federal indictment (Adams).
When I am Mayor, this sad spiral stops. I will treat corruption forcefully and transparently. I will use every tool at my disposal to expose existing corruption and give it no home in city government. Among other actions, I will issue an Executive Order that puts teeth into anticorruption enforcement (the “Day 1 Order”). Six of the key aspects are:
1. New citywide anticorruption agency with broader powers. The Day 1 Order will transform the Department of Investigation (DOI) into a new and broader agency named the Citywide Department of Public Integrity (CDPI).
By reorganizing existing agencies and functions under the New York City Charter (Chapters 1, 8, and 11), including DOI, I will create CDPI as a gold standard in anti-corruption enforcement. I will choose the Commissioner wisely, give the agency new power and authority, and work with law makers to give it full independence (which may require a revision of the NYC Charter).
The Commissioner. A team of experts will help select the first CDPI Commissioner: Cyrus R. Vance, Jr., Daniel R. Alonso, Nicolas Bourtin, Todd Harrison, Jennifer Rodgers, Edwin H. Stier, and Alan Vinegrad (biographies attached).1 The Selection Panel will go through a rigorous process to vet candidates and provide me with the three best. I will appoint one. This Panel may not consider any candidate who contributed to my Mayoral campaign or served on my Policy Council. The Panel will only consider senior current or former prosecutors with substantial experience prosecuting corruption cases. The 3 top candidates will be subjected to intensive vetting.
Transparency. The public should have access to instances when there is contact between CDPI and City Hall. To assure this, the Day 1 Order will require CDPI to list prominently on its website every contact between it and City Hall, which will include the identity of the City Hall official involved in the communication, the date of the contact, and the purpose.
Scope. The Day 1 Order will take self-policing out of every agency and replace it with a robust and elite team of lawyers and investigators, supplementing the dwindling ranks of inspectors general that now sit within DOI. The Day 1 Order will re-assign existing watchdog functions from the agencies to CDPI. When any allegations of corruption surface in any agency, the Day 1 Order will require immediate referral to CDPI. This includes corruption complaints filed with the CCRB. Henceforth, no City agency will be permitted to investigate any allegations of corruption by its employees. The Day 1 Order will require all City employees to cooperate with CDPI investigations on the threat of termination. CDPI will have broad power to suspend suspects during its investigations. CDPI will coordinate with federal and state prosecutors and investigative agencies in appropriate cases.
CDPI will also work proactively with agencies to prevent corruption by helping build better internal controls and conducting integrity audits, the results of which will be made public.
2. New Prosecutors and a New NYC Corruption Court. Unlike the old DOI, CDPI will have the power to prosecute corrupt employees with a team of elite anti-corruption prosecutors. There will also be a new forum to fast-track cases: a newly created NYC Corruption Court, which will be part of the Citywide criminal courts. I will work with the Office of Court Administration to create and fund this new forum. This new court will allow fair but faster prosecutions. All cases will be filed publicly and accessible on CDPI’s website with clear language, naming the defendant, the corrupt acts alleged, and the relief sought by CDPI. All evidence used during the prosecution will be available to the public on CDPI’s website.
Although current law would allow CDPI only to prosecute misdemeanors,2 these convictions will permit other disciplinary actions against corrupt employees, including termination, permanent bans against working for city agencies, and, where appropriate, loss of benefits. CDPI will also make referrals to federal and state prosecutors for further investigation and prosecution, as well as to the Comptroller so that audits can be conducted to determine whether additional internal controls are needed in the affected agency.
3. Independence of CDPI. To enhance CDPI’s powers, I will present legislation and, if necessary, call for a Charter Revision Commission. Like the Director of the FBI, the CDPI Commissioner should serve a 10-year term. The Commissioner should be removed only for cause and only by court order. The CDPI Commissioner should be completely independent of City Hall.
When this is done, in collaboration with city and state lawmakers, CDPI will be a national model for
anti-corruption integrity.
4. New Anticorruption Amnesty and Whistleblower Program. To give CDPI maximum effectiveness, the proposed legislation will create a whistleblower program specific to corruption in city agencies, with the power to grant amnesty to culpable whistleblowers in exchange for their full cooperation.
Whistleblowers have played an outsized role in federal law enforcement. Creating incentives and protections for them helps expose crimes faster. We will use that successful model against corruption in our City. The protections for whistleblowers will exceed those in federal law. The rewards to whistleblowers will be significant enough to encourage them to expose corruption. If the whistleblower was involved in, but not the leader of, a corrupt practice, the program will allow amnesty from prosecution. Taken together, this program will help bring corruption to light faster.
5. Favors to campaign contributors. The Day 1 Order will also prohibit anyone in City Hall from interceding with city agencies on behalf of any campaign contributor or anyone who worked on my Policy Council.
To the extent those persons use normal bureaucratic channels to address problems with the city, I will recuse myself from weighing in on any dispute that comes up through the normal bureaucratic process. Instead, I will have those disputes resolved without my input, direct or indirect.
6. Patronage appointments. I pledge never to make patronage appointments. When a Mayor makes appointments based on personal loyalty or as political favors, the seeds of corruption have been sown.
We saw this vividly in the Adams administration, but many past examples of the same problem exist. This will not happen in my administration. I will appoint Commissioners using the same process outlined above (using an expert panel to screen qualified subject-matter experts for the Commissioner positions) to remove even the appearance of patronage. This will assure everyone that I am not picking Commissioners based on personal considerations or repaying favors. Also, it will assure that I consistently appoint people with the highest competence and integrity.
Having carefully reviewed the NYC City Charter and NYS Constitution, I believe that prior mayors had the power to take these bold steps. They lacked either the vision or the will to do it. I have both.
Corruption in New York City is a serious problem. We need to treat it seriously and stop with half-measures. I will work tirelessly to give CDPI best-in-class tools and ample funding. My Administration will innovate to create maximum deterrence. We will leave no stone unturned until we have an anticorruption system that the public can trust.
Jim Walden,
Candidate for Mayor
Daniel R. Alonso has devoted much of his career to the intricacies of fraud and corruption prosecutions in state and federal courts—as a federal and New York state prosecutor, policy expert, state commissioner, and private lawyer. He formerly served as the Chief Assistant District Attorney in Manhattan as well as the Chief of the Criminal Division in the U.S. Attorney’s Office for the Eastern District of New York. Mr. Alonso currently serves, by appointment of Governor Hochul, on the New York State Commission on Prosecutorial Conduct, and was formerly a gubernatorial appointee to the New York State Commission on Public Integrity. He practices law in Manhattan.
Nicolas Bourtin served as an Assistant U.S. Attorney in the Eastern District of New York, focusing on organized crime and racketeering. In that role, he coordinated the Office’s collaboration with the Italian government on matters involving organized crime and led several successful collaborative efforts with the Italian Ministry of Justice, National Antimafia Bureau, National Police, Carabinieri and Guardia di Finanza, prosecuting a variety of federal offenses. He now serves as the Managing Partner of Sullivan & Cromwell’s Criminal Defense & Investigations group.
Todd Harrison began his career as an Assistant District Attorney in the New York County District Attorney’s Office and later served as an Assistant U.S. Attorney in the Eastern District of New York, where he became Deputy Chief of the Violent Crimes and Terrorism Section. His public service includes as Chief Counsel for Oversight & Investigations for the Energy & Commerce Committee in the House of Representatives.
Jennifer G. Rodgers served as an Assistant U.S. Attorney in the Southern District of New York for thirteen years. In that time, she served as Deputy Chief and Chief of the Organized Crime Unit, Chief of the General Crimes Unit, and Deputy Chief of the Appeals Unit. Thereafter, she served as the Executive Director for the Center for the Advancement of Public Integrity at Columbia Law School until 2018. She is currently a lecturer at Columbia Law School and an adjunct professor of clinical law at NYU School of Law.
Edwin H. Stier served as a prosecutor in federal and state offices within New Jersey for 17 years. His public service included serving as Chief of the Criminal Division of the U.S. Attorney’s Office in New Jersey, and as Director of the New Jersey Division of Criminal Justice, the nation’s largest and most powerful state-level prosecutorial agency. His many cases focused on public corruption, becoming one of the leading anticorruption lawyers—and a recognized expert—in the nation. Among his many other appointments, he serves as a Member of New Jersey Advisory Committee on Police Standards.
Cyrus R. Vance Jr. served as the District Attorney of New York County from 2010 to 2021, overseeing numerous high-profile cases and establishing specialized units to address complex crimes. His prior public service is varied and longstanding, including as a Special Assistant to the New York Attorney General, a member of Sentencing Commissions in two states, a member of a Task Force in New York to overhaul the Rockefeller drug laws, and as an investigative consultant on a panel investigating abuse of Native American children. He started his career as an Assistant District Attorney in Manhattan, handling cases involving murder, organized crime, public corruption, and white-collar crime.
Alan Vinegrad served as the United States Attorney for the Eastern District of New York, after holding several other leadership roles, including Chief Assistant U.S. Attorney, Chief of the Criminal Division and Chief of Civil Rights Litigation. He prosecuted the NYPD officers responsible for the sexual assault of Abner Louima and for the ensuing cover-up, as well as various public officials for corruption-related offenses. Among his many accolades and awards, he was the 2024 recipient of the prestigious American Inns of Court Professionalism Award.