N.Y. Laws » CHAPTER Penal / PART Specific Offenses / TITLE Offenses Involving Fraud / ARTICLE Bribery Not Involving Public Servants, and Related Offenses
New York Consolidated Laws

N.Y. Penal Law § 180.03 (2026)

Commercial bribing in the first degree

✓ current as of May 2026
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§ 180.03 Commercial bribing in the first degree.
  A person is guilty of commercial bribing in the first degree when he
confers, or offers or agrees to confer, any benefit upon any employee,
agent or fiduciary without the consent of the latter's employer or
principal, with intent to influence his conduct in relation to his
employer's or principal's affairs, and when the value of the benefit
conferred or offered or agreed to be conferred exceeds one thousand
dollars and causes economic harm to the employer or principal in an
amount exceeding two hundred fifty dollars.
  Commercial bribing in the first degree is a class E felony.
Notes of Decisions
Cited in 31 cases, 1985–2017 · leading case: People v. Wolf, 772 N.E.2d 1124 (N.Y. 2002).
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People v. Wolf, 772 N.E.2d 1124 (N.Y. 2002). · cites it 2× “In 1983 the Legislature created the felony crimes of first degree commercial bribing and commercial bribe receiving by adding an additional element to the definitions of the corresponding prior commercial bribery class A misdemeanors: that the bribe “causes economic harm to the…”
Johnson v. Nextel Commc'ns Inc., 780 F.3d 128 (2d Cir. 2015). “The district court also dismissed plaintiffs’ bribery cause of action, determining that N.Y. Penal Law § 180.03 does not provide a private cause of action.”
PHILIP MORRIS, INCORP. v. Grinnell Lithographic Co., 67 F. Supp. 2d 126 (E.D.N.Y 1999). · cites it 6× “N.Y. Penal Law § 180.03 . As a threshold matter, the Court notes that the statute does not itself create a private right of action.”
Fuji Photo Film U.S.A., Inc. v. McNulty, 640 F. Supp. 2d 300 (S.D.N.Y. 2009). · cites it 2× “N.Y. Penal Law § 180.03 . Section 180.08 prohibits the receiving of bribes under the same circumstances detailed in Section 180.”
First City Nat'l Bank & Trust Co. v. Fed. Deposit Ins., 730 F. Supp. 501 (E.D.N.Y 1990). · cites it 2× “§ 1341 , 1343; N.Y. Penal Law § 180.03 (McKinney 1988). A.”
Philan Ins. Ltd. v. Frank B. Hall & Co., Inc., 712 F. Supp. 339 (S.D.N.Y. 1989). · cites it 2× “§§ 1341 and 1343; commercial bribery, N.Y.Penal Law § 180.03; and transportation of stolen money, 18 U.”
Wint v. ABN Amro Mortg. Grp., Inc., 19 A.D.3d 588 (N.Y. App. Div. 2005). · cites it 2× “), dated March 10, 2004, which granted the defendant’s motion pursuant to *589 CPLR 3211 (a) (7) to dismiss the first cause of action, to recover damages for fraud and violation of Penal Law § 180.03, and to dismiss the class action allegations set forth in the remaining causes…”
Fisher v. Equicredit, 19 A.D.3d 541 (N.Y. App. Div. 2005). · cites it 3× “In an action, inter alia, for money had and received, and to recover damages for fraud, violation of Penal Law § 180.03, tortious interference with contract, inducement of breach of fiduciary duty, violation of General Business Law § 349, and unjust enrichment, arising from the…”
Sardanis v. Sumitomo Corp., 279 A.D.2d 225 (N.Y. App. Div. 2001). “Commercial bribery of the nature alleged is a felony under New York law (Penal Law § 180.03), but the statute makes no mention whether a private right of action is created thereby.”
Slifer-Weickel, Inc. v. Meteor Skelly, Inc., 140 A.D.2d 320 (N.Y. App. Div. 1988). · cites it 2× “dated May 16, 1984, the plaintiffs commenced this suit against the defendants Meteor and Bagley asserting, in relevant part, causes of actions based upon allegations of (1) tortious interference with the plaintiffs’ business relations with Ponds, (2) tortious interference with…”
Am. Fed'n of State, Cnty. & Mun. Employees Dist. Council 37 Health & Sec. Plan v. Bristol-Myers Squibb Co., 948 F. Supp. 2d 338 (S.D.N.Y. 2013). “” N.Y. Penal Law § 180.03 . And the Senate Report discussing § 2(c) emphasizes that “[t]he relation of the broker to his client is a fiduciary one.”
Niagara Mohawk Power Corp. v. Freed, 265 A.D.2d 938 (N.Y. App. Div. 1999). “, that defendants conferred a benefit upon plaintiff’s employee, without plaintiffs consent and with the intent to influence the employee’s conduct (see, Penal Law § 180.03; Southmark / Envicon Capital Corp.”
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