POLICY AT PLAY CONT.
2025 Guidance For ICE
Raids & Audits
BY DON SHANDY & JASON ORTEGA
W
ithin hours of the inauguration,
the Trump Administration issued
several executive orders aimed at
enforcing immigration laws. As a
result, NWPCA has received several
inquiries from member companies
regarding the process and how they can be prepared to show
their compliance should a US Immigration and Customs
Enforcement ("ICE") raid occur. is memo has been
prepared to assist with those preparations. Please consult
your attorney to further develop an appropriate plan.
As background, the new administration declared a
national emergency at the southern border, and the
Department of Homeland Security ("DHS") rescinded a
Biden-era policy that restricted enforcement at sensitive
locations such as schools, hospitals, and places of worship.
As of the date of this guidance, these directives are
primarily focused on (1) persons in the United States
without lawful status who have committed crimes,
and (2) individuals who were previously eligible for
humanitarian parole programs or refugee programs.
ICE has already reported a substantial increase in ICE
raids, and DHS recently issued a final rule that raises
monetary penalties for Form I-9 violations. Given the
crescendo of immigration enforcement, employers should
take proactive measures to prepare for ICE audits and raids.
