As reported in today’s New York Times and Wall Street Journal, the Obama administration has begun a full scale audit of the I-9 records of employers all across the country, with an initial emphasis on companies located in New York and California. The Immigration and Customs Enforcement (ICE) agency of the Department of Homeland Security has already begun to conduct I-9 audit investigations of more than 600 companies, with many more audits expected on both a random and targeted basis in the coming months.

Employers face stiff sanctions for employing unauthorized workers, and can also be hit with fines for improperly completing the I-9 forms. It’s very easy for employers to make mistakes in completing the forms, and it’s often difficult to know which documents are acceptable proof of an employee's identity and authorization to work in the United States.

We recommend that you review your I-9 records carefully and consult with us if you have any questions about whether they comply with federal regulations.