Before ICE Knocks: Building an Employer Response Program That Survives Real Enforcement

Many employers still believe they can tighten up their I‑9s or formalize a response plan once enforcement activity begins. That assumption is no longer correct. Recent enforcement guidance and shifts in interpretation have narrowed employers’ ability to cure errors or remediate risk once ICE is on the doorstep.

In today’s enforcement environment, response planning is only as strong as the underlying I‑9 program behind it. Full readiness requires more than legal compliance alone; it demands operational and investigative insight that goes beyond traditional immigration law practice.

This session, led by John Connolly and John Shofi of Guidepost Solutions and Morgan Bailey of Mayer Brown, focused on what readiness means before an ICE visit, including:

  • Assessing I‑9 accuracy and document validity
  • Identifying patterns of identity fraud
  • Determining who may be unauthorized to work
  • Training frontline staff to recognize high-risk issues in real time

These are areas where legal counsel and HR teams benefited from the added dimension that experienced investigators and former enforcement officials bring.

Drawing on direct enforcement and audit experience, the panel dived into:

  • How ICE and HSI evaluate employer preparedness in the first moments of a worksite visit
  • Why small missteps in document review, authority designations, or recordkeeping can lead to fines, expanded audits, or criminal referrals

Whether advising clients or managing workforce documentation internally, attendees gained a practical, immediately applicable framework grounded in how enforcement unfolds, not how plans are written to work on paper.

 

Watch the Webinar

MSU Institutional Assessment + RA
MAGELLAN Monitorship
Empire/Liberty Review