On July 1, 2009, U.S. Immigration and Customs Enforcement (ICE) announced that it had issued Notices of Inspection (NOIs) to 652 businesses across the country as part of a “bold, new audit initiative.” ICE targeted these businesses for inspection as a result of information it had obtained “through other investigative means,” and did not disclose the names or locations of the businesses. ICE described its issuance of the 652 NOIs as the “first step in [its] long-term strategy to address and deter illegal employment.” As far as first steps go, this is a remarkable one considering that ICE issued only 503 NOIs during all of 2008. It also appears to have been an effective one—on July 7, 2009, ICE announced that it had reached a $40,000 fine settlement with Krispy Kreme Doughnut Corporation for various immigration law violations.

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