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06/17/2025

An Employer’s Playbook for ICE Audits and Workplace Raids

Source: Fisher Phillips, June 9, 2025

Immigration enforcement across the country has raised tensions at workplaces across all industries, with federal officials ratcheting up the pressure – what if your business is next? This Insight will provide you with a detailed playbook: proactive steps to take to minimize the chances that you’ll face an immigration audit or raid, and practical steps to consider should immigration officials arrive at your workplace. We’ve also created two checklists for you to use as a recap for the key pieces of guidance.

⚠️ Before We Begin: Know The Risks - Employers that commit immigration violations face significant penalties:

• Civil Fines: Up to $2,861 per I-9 violation, up to $5,724 for knowingly hiring undocumented workers, and up to $28,619 per worker for repeat offenders.
• Criminal Penalties: Business leaders can face up to 10 years in prison and $250,000 in fines for knowingly employing undocumented workers.
• Asset Seizure: Conviction may trigger forfeiture of assets and profits linked to the violation.
• Loss of Government Contracts: You could be debarred from federal contracting under an Executive Order.
• Business Disruptions: ICE raids can bring immediate work stoppages, trigger media attention, and disrupt morale.

🛠️ Take Steps To Minimize The Likelihood Of A Raid - You’ll want to take proactive steps to minimize the chances that you’ll face ICE enforcement activity. Click here for a Proactive ICE Audit and Raid Preparation Checklist.

• Establish I-9 Compliance...
• Conduct Regular I-9 Audits...
• Employee Training...
• Establish a Rapid Response Plan...
• Run Mock Scenarios...
• Consider Using E-Verify...

📂 Know How To Respond If ICE Initiates An Audit - The most common way in which your business might end up interacting with enforcement officials is through an audit. An ICE audit, often initiated through a Notice of Inspection, requires employers to produce I-9 forms and additional records within three days. Click here for an Immediate Action Steps If ICE Shows Up Checklist.

• Contact Legal Counsel Immediately...
• Gather and Verify Documentation...
• Review Findings and Correct Minor Errors...
• Take Corrective Action Immediately...

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