On February 18, 2011, U.S. Immigration and Customs Enforcement (“ICE”) announced a nationwide wave of I-9 investigations and demands for document review affecting more than 1,000 companies across all 50 states. These enforcement actions, affecting businesses of all sizes, reaffirms the current Administration’s commitment to increase immigration sanctions against U.S. employers.

Who is Being Targeted?

According to an e-mail statement, ICE claimed that “inspections will touch on employers of all sizes and in every state in the nation — no one industry is being targeted, nor is any one industry immune from scrutiny.” Although audits are usually performed in the state where a company’s headquarters are located, ICE is now reportedly instructing agents to audit other branches of companies if records suggest that non-compliant practices or records may be pervasive. ICE has recently opened an employment compliance center in the Washington, D.C. suburb of Crystal City, Va., with full-time agents ready to serve in support of ongoing worksite audits across the country.

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