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Thursday, November 27, 2025

Ramp Up of Employers-Focused Immigration Crackdowns Underway—What Employers Can Do to Prepare - Atkinson, Andelson, Loya, Ruud & Romo

Reports on Sunday, June 15, 2025 indicated that immigration enforcement activities in large cities, including Los Angeles, will be increasing. Recent comments from Tom Homan, White House Executive Associate Director, Enforcement and Removal Operations, have signaled that the federal government will be ramping up its targeting of employers as a part of this next round of enforcement. These statements at first appeared to be at odds with other recent statements by the President, in which he appeared to be cooling off on enforcement actions related to the agricultural and hotel and leisure industries. However, after a brief suspension, raids in those industries have resumed as well. Given that multiple administrative officials are using similar language--that enforcement efforts were being “stepped up” -- it is likely that raids in California will increase, with a focus on urban areas.

What do employers need to know?

I-9 Audits

An I-9 audit will begin with a Notice of Inspection which may either be mailed or hand-delivered by agents of the Department of Homeland Security (“DHS”). These notices will typically provide an employer with three (3) days to produce the requested documents, which may include I-9 documentation, payroll records, Social Security Administration correspondence, and other employment-related documentation. DHS will often seek to review these documents at the worksite or place of business. It is important that employers involve legal counsel in this process...



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