Stay Ahead of the Freeze- Your Employer’s Guide to ICE Compliance and Navigating Worksite Enforcement

November 24, 2025

Following the 2024 presidential election, prognosticators predicted that President Donald Trump’s second administration would usher in a significant increase in immigration enforcement by U.S. Immigration and Customs Enforcement (ICE). Those predictions have proven accurate.

During the first Trump administration, ICE dramatically increased worksite enforcement. Between fiscal years 2017 and 2018, worksite enforcement investigations surged by 405%, accompanied by a sharp rise in worksite‑related arrests. The second Trump administration has continued that effort.

Since January 2025, ICE has conducted worksite immigration raids across a wide range of industries, from a specialty beverage manufacturer to car washes. Public reports indicate at least 40 worksite enforcement actions resulting in over 1,100 arrests within the first seven months of 2025 alone. These operations have spanned the nation, from Martha’s Vineyard and Nantucket to Nashville to Los Angeles.

On September 4, 2025, ICE executed its largest single‑site immigration raid to date, detaining 475 individuals at a Hyundai Motor battery plant in Georgia. Thomas Homan, appointed as “border czar,” has signaled a return to an era of heightened worksite enforcement.

The increase in immigration enforcement shows no signs of slowing. As a result, employers must proactively prepare for potential ICE actions and understand the legal and cultural obligations and risks involved.

Legal Background

The Immigration Reform and Control Act (IRCA) of 1986 requires employers to verify and document the identity and work eligibility of every hire. This process requires employers to obtain an Employment Eligibility Verification Form I-9s from each employee. Employees must complete their portion of the I-9 by the end of their first day of employment, and employers must complete the remaining portion within three business days from the employee’s start date. Applicants and employees without proper documentation are subject to detention and removal. Companies employing undocumented workers may face civil and criminal penalties.

Forms of Worksite Enforcement

Worksite Raid

ICE may discover a company’s or an individual’s failure to comply by initiating what the agency refers to as “worksite enforcement.” In common parlance, however, this form of enforcement is known as a “raid.”

ICE is permitted to enter public areas of the workplace without a warrant. However, ICE can only enter private areas of a worksite for limited purposes, including executing warrants, pursuing a fleeing suspect, and responding to emergency situations where they have probable cause to believe a crime has been committed and relevant evidence may be destroyed.

Only a judicial warrant signed by a federal or state judge permits entry into private areas of the workplace to conduct a search.

Conversely, an administrative warrant, which is signed by ICE rather than a judge, does not permit the ICE agents to conduct a search of private areas.

Read more