Oh the tangled web our government weaves. One might assume that the Department of Homeland Security’s Immigration and Customs Enforcement (ICE) agency is the only entity that will appear on the doorstep asking to inspect Form I-9s and conducting an immigration-related investigation. However, immigration enforcement actions can start through inspections by a number of different entities including:
- USCIS (Fraud Detection and National Security (FDNS))
- Risk Assessment Program Fraud Study
- Targeted site visits
- Administrative site visits
- USCIS E-Verify inspections (Compliance Tracking and Management System (CTMS))
- DOJ (Office of Special Counsel for Immigration Related Unfair Employment Practices (OSC))
- DOL (Employment Standards Administration or Wage and Hour Division)
- IRS
- SSA
- State and Local Police
Inspections by any of these entities can result in immigration enforcement actions. Employers need to be wary of viewing an inspection by any of these entities in a vacuum, because even though one agency is at the door, it doesn’t mean another isn’t very far away