On February 17, ICE issued 1,000 Notices of Inspection (NOI) across the country in a firm demonstration of the Obama administration’s ongoing commitment to a worksite enforcement strategy that focuses on employer compliance and much higher administrative fines. We were contacted by employers across the country to help prepare their responses. We were even contacted by an employer who handed their I-9s to the Agents who came to serve the NOI -- no 3 days, no advice by counsel, no waiver explained, no copies, no time, no receipt. What were you thinking, Mr. ICE agent? Not to worry, we worked it out with like adults. 

Seriously those fortunate companies who did not receive a NOI should take advantage of their good fortune and ensure that they are in compliance now. The coast is not clear. One or two additional rounds of audits are expected during this calendar year. This administration has continued to make it clear that the days when immigration compliance could be ignored and considered the “cost of doing business” are long gone. 

ICE is assertively pursuing companies where tips and leads come in,  These administrative reviews have been quite lucrative. It will be very interesting to track this latest round of audits in terms of timing and outcome.