Seyfarth Synopsis: Following the wave of Notices of Inspection (NOI) at 77 Northern California businesses last month, Immigration and Customs Enforcement’s (ICE) Homeland Security Investigations (HSI) agents are continuing to spread the cheer with NOIs targeting businesses in Southern California this week. Serving NOIs throughout the greater Los Angeles area, the inspections appear industry agnostic. The NOIs delivered by HSI agents and auditors notify businesses that they must produce their employees’ Forms I-9, Employment Eligibility Verifications within 72 hours. The notices often include a list requesting additional company information and documents as well.
Local HSI offices are keeping ICE’s Deputy Director Thomas Homan’s promise of increasing its activities not just across the nation but more specifically targeting sanctuary cities and states like California. It is important to note that businesses receiving the NOIs are not all within the service, manufacturing, agriculture, or traditional “infrastructure” sectors. Employers across industries should take a look at their Form I-9s and overall immigration compliance – the time to figure things out is not during the 72 hours after a NOI is issued.