As reported by the New York Times, President Trump has instructed Immigration and Customs Enforcement (ICE) to resume large‑scale, unannounced workplace operations and to hit an internal target of roughly 3,000 arrests per day. Field agents have been told to prioritize industries that “rely on long‑time immigrant labor,” and DHS officials confirm that the prior, short‑lived pause on work‑site raids has been rescinded.
Why this matters to every U.S. employer:
- Civil and criminal exposure is back on the table. Under Section 274A of the Immigration Reform and Control Act (IRCA), paperwork violations alone can reach well into six figures (and sometimes more), and knowing hires can expose owners and managers to criminal liability.
- Government audits of internal documents are going to become more common. ICE routinely issues a Notice of Inspection 3‑to‑5 days before arriving onsite; any errors discovered after that window cannot be retro‑fixed and will count as “aggravating.”
- Public relations & productivity hits are real. Mass arrests on the shop‑floor disrupt operations and devastate morale; advance planning limits both.
Immediate, practical steps that can be taken:
- Conduct an internal I‑9 audit before ICE does it for you. Verify you have a complete Form I‑9 for every active employee, correct technical errors, and document the fixes.᠅
- Refresh onboarding and reverification processes. Make sure HR is using the current edition of Form I‑9 and the correct list of acceptable documents.
- Draft a rapid‑response plan for raids or subpoenas. Front‑desk staff should know how to verify a warrant, whom to call, and where agents may—and may not—go inside the facility.
- Stay alert for policy whiplash. As we learned in the last six months, guidance can flip overnight; keeping counsel looped‑in is the cheapest insurance policy you can buy.
How Joseph & Hall PC can help:
Our team performs confidential I‑9 audits, mock inspections, trainings, and on‑site rapid‑response training nationwide. We are already assisting clients who have received new Notices of Inspection and are actively providing webinars and trainings for employers ahead of any government action to minimize liability.
If your company has not reviewed its I‑9 files recently, or if you simply want a second pair of eyes, now is the moment. Please reach out to us directly at (303) 297‑9171 to schedule an emergency audit or training session.
