Increased immigration enforcement and a reduction in illegal
entry into the United States remain among the Trump
administration's highest priorities. Notably, Acting ICE
Director Thomas Homan has reportedly ordered Homeland Security
Investigations (ICE's investigative arm) to increase its
worksite enforcement actions by "four or five times" in
the new fiscal year.1 In the past, ICE conducted
worksite raids to arrest employees who lacked work authorization in
the United States. While worksite raids have not yet occurred under
this administration, they are expected to return soon, this time
targeting aggressively both employers and employees.
Under the previous administration, ICE focused resources to an
unprecedented degree on Form I-9 audits to ensure employers
complied with technical Form I-9 requirements and that employees
had work authorization. While the previous administration focused
almost exclusively on employers, the new administration is likely
to target