In a recent ceremony at its new headquarters in Arlington, VA, ICE celebrated the addition of 37 companies to the IMAGE program. The IMAGE program began in January 2007 with only nine members. The newest members hail from a diverse range of geographic locations and industries, including, employment services, aviation, transportation, construction, high technology, shipping and manufacturing. Of the 37 companies who enrolled in the program, 26 signed on as full members, while 11 companies chose to join as "associate members." Despite these newest additions, it is clear that many employers remain hesitant to join. In an effort to improve enrollment in the program, this June ICE announced a new type of membership which include a two year "grace period," otherwise known as "Associate Membership." Employers who choose to join the program as "Associate Members" may defer the requisite ICE audit for up to two years. This policy change was geared at easing potential enrollees’ fears that their voluntary enrollment could be detrimental to business by attracting ICE’s attention, which could lead to raids and other investigations. A case in point is Smithfield Foods. Despite being raided in January 2007, Smithfield foods recently signed on to the IMAGE Program as an Associate Member. At this time, the complete impact of these new additions and policy changes is yet to be seen.

As always, GT will continue to provide updated information on the IMAGE program and ICE’s continuing aggressive raids and enforcement efforts as they become available.