On Tuesday evening, the offices of New York Attorney General Letitia James and Manhattan district attorney Cyrus Vance made clear that their investigation of the Trump Organization has moved to a new phase. A spokesperson for James made the announcement: “We have informed the Trump Organization that our investigation into the organization is no longer purely civil in nature. We are now actively investigating the Trump Organization in a criminal capacity, along with the Manhattan D.A. We have no additional comment at this time.”

As The New York Times reports, the two offices have been running parallel investigations since the start of 2020. While Vance had already made it clear that his investigation included the possibility of criminal charges, the announcement from James’ office makes it clear the state is also moving toward the potential of charges against those connected to the Trump Organization. And who might receive those charges seems clear enough.

Donald Trump is the Trump Organization, and the Trump Organization is Donald Trump. Of the over 500 “companies” that exist in the tangled nest of the overall holding company, almost all are 100% owned and controlled by a single person. If there are going to be criminal charges, it’s not hard to predict where they will land.

The mass of Trump companies is justifiably called Byzantine. It’s a deliberate labyrinth of connections, some of them intended to maximize Trump’s tax benefits—like the company that supposedly owns Trump’s planes and leases them to the other companies, all of which are just Trump, allowing for a double-dip on deductions. Other companies seem to exist for no purpose other than to make investigating Trump’s finances more complicated and more difficult to penetrate.

Though it was well-known that the New York attorney general was working through this tangle, until Tuesday night the threat to Trump appeared to be financial. When James conducted the investigations that led to the end of Trump’s fake “charitable foundation,” the matter was handled as a civil investigation, and the resulting agreement involved fines, along with restrictions on Trump and his family from operating any charity in the future, but jail sentences were not in the picture. The same was true when Trump reached a settlement of multiple lawsuits concerning Trump University. The most important claim came from New York state, but it was in the form of a civil suit by the Department of Education.

What’s happening now—both in the office of the Manhattan DA and at the New York AG—is a whole different animal. Earlier this year, Vance’s office obtained Trump’s tax returns and financial records after a prolonged court fight. The mention of the Manhattan DA in the announcement from James’ office makes it clear that the two investigations are no longer just running in parallel, but actively cooperating. 

What charges might Trump face? There’s always the lingering campaign violation that “Individual 1” was clearly involved in back during the prosecution of Michael Cohen. But the focus of Vance’s investigation appears to have been on a whole series of potential crimes involving bank fraud and tax fraud. It’s suspected that these crimes involve something that’s long been noted—how Trump inflated the apparent worth of his buildings when it came time to borrow, and then shrank them into insignificance when it was tax season. 

In addition to the criminal investigation, James’ office will continue with the civil investigation, which is good. That will make it easier to disassemble Trump’s paper empire and recoup the money he’s stolen from banks, investors, contractors, and taxpayers.