US Citizenship and Immigration Services (USCIS) and the Department of Justice Special Counsel for Immigration-Related Unfair Employment Practices recently issued jointly prepared guidance to employers that conduct their own internal Form I‑9 audits. This is the first time that the two agencies have combined to offer guidance at this level, and it is expected that the agencies will take the position that employers are “on notice” of its content. As such, employers whose practices are inconsistent with the guidance may be less able to avoid liability for their actions, even if well-intended.