The employer hears a knock at the door. Surprise! ICE is on the other side to serve the employer with a Notice of Inspection to audit Forms I-9. Of course, the employer repeats the ever-popular phrase, “Keep Calm and Carry On,” but what happens next? Thoughts may be racing through the employer’s mind such as, “Let’s fix our I-9s immediately, but we won’t tell our employees why we are completing new forms.” Or, “We should request as much documentation as our employees can present to make certain we are covered.” Or, the increasingly popular, “Let’s request new documentation from ‘foreign’ employees so we can tell ICE that we took extra precautions against ‘foreign’ workers.” According to the recently released list of best practices during an I-9 audit, these actions may put the employer in hot water with the Office of Special Counsel (“OSC”), which is a division of the Department of Justice.
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