Milford, MA Becomes the First U.S. Town to Enroll in ICE's IMAGE Program

Milford, Massachusetts, a town with more than 1,500 employees, has become the first U.S. municipality to partner with Immigration and Customs Enforcement’s (ICE) IMAGE (ICE Mutual Agreement between Government and Employers) program, an employment compliance initiative founded in 2006. According to the IMAGE program, members voluntarily submit to a Form I-9 audit, enroll in E-Verify, and receive training about proper hiring practices. Members also pledge to create a written hiring and employment eligibility verification policy, including an annual Form I-9 audit, and sign a formal partnership agreement that emphasizes employers’ commitment to maintaining a secure workforce and curtailing the hiring of undocumented immigrants.

Although critics contend that the IMAGE program preemptively invites government scrutiny, employers who partner with ICE also receive important benefits, such as reputational credibility and a greater likelihood of government leniency in the event of an enforcement action.

ICE's Latest Wave of I-9 Audits

On February 17, ICE issued 1,000 Notices of Inspection (NOI) across the country in a firm demonstration of the Obama administration’s ongoing commitment to a worksite enforcement strategy that focuses on employer compliance and much higher administrative fines. We were contacted by employers across the country to help prepare their responses. We were even contacted by an employer who handed their I-9s to the Agents who came to serve the NOI -- no 3 days, no advice by counsel, no waiver explained, no copies, no time, no receipt. What were you thinking, Mr. ICE agent? Not to worry, we worked it out with like adults. 

Seriously those fortunate companies who did not receive a NOI should take advantage of their good fortune and ensure that they are in compliance now. The coast is not clear. One or two additional rounds of audits are expected during this calendar year. This administration has continued to make it clear that the days when immigration compliance could be ignored and considered the “cost of doing business” are long gone. 

ICE is assertively pursuing companies where tips and leads come in,  These administrative reviews have been quite lucrative. It will be very interesting to track this latest round of audits in terms of timing and outcome.

Feel free to write in and share your own experiences.