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Immigration Compliance and Enforcement

October 8, 2009

ICE Reveals Worksite Enforcement Policy

In response to a Freedom of Information Act (FOIA) request filed by the American Immigration Lawyers Association, U.S. Immigration and Customs Enforcement (ICE) released an April 30, 2009 internal field memorandum outlining ICE's most recent worksite enforcement policy.  The memo, written by the Office of Investigations Director, disclosed the worksite enforcement strategy and methodology, as previously discussed in Dawn M. Lurie's July 2009 article titled: "Is That ICE Knocking At Your Door?"  The document confirmed ICE's intent to pursue criminal prosecution of employers via I-9 audits, and administrative and civil tools–including imposing civil fines and debarment.

Please refer to the attached memo and GT's Alert for further details.