The DOJ has not announced specific criminal investigations or charges tied to algorithmic pricing. The scope of conduct that triggers criminal liability—as opposed to civil enforcement—remains subject to case-by-case factual development, particularly around what constitutes sufficient evidence of "agreement" among competitors versus independent algorithm use.
Attorneys representing companies in hospitality, car rental, procurement, bidding, and salary-setting markets should treat this as a direct warning. The DOJ is explicitly rejecting the premise that algorithmic systems reduce antitrust exposure. Instead, federal enforcers view pricing software as creating documentary evidence—logs, timestamps, data-sharing records—that can establish intent and coordination more readily than traditional collusion. Companies currently using shared pricing platforms or considering their adoption should conduct compliance reviews focused on data governance, algorithm architecture, and competitor information flows.