With immigration enforcement intensifying under a second Trump administration, U.S. employers should prepare for heightened inspections and potential raids.

The administration’s early 2025 actions signal a strong focus on workplace compliance, following promises of the “largest deportation program in American history.”

Preparing for increased enforcement

Employers should prepare for Immigration and Customs Enforcement (ICE) visits by developing a coordinated response plan with HR, leadership, and legal counsel.

Key steps include:

Establishing protocols for staff who may encounter ICE agents
Designating an authorized point of contact to communicate with agents
Training employees to manage law enforcement interactions
Creating detailed response plans for both scheduled audits and unexpected raids
Conducting regular internal I-9 audits and maintaining comprehensive documentation of all employment verification processes

Managing response readiness

ICE agents may arrive without notice, and receptionists should have a script ready. An employee can say, “I cannot give you permission to enter. You have to speak to my employer.”

You may wish receptionists to keep agents limited to the lobby, or you may want agents directed to less conspicuous waiting area.

Public areas like lobbies and parking lots are accessible without a warrant, so clearly mark private spaces for “employees only.” Consider running drills to ensure the team is prepared.

Understanding employer rights and obligations

Employers must understand the difference between administrative and judicial warrants. While judicial warrants signed by a judge must be complied with, administrative warrants issued by DHS/ICE do not require immediate compliance. It’s crucial to know the limits of ICE authority and your legal obligations.

Impact on business operations

In case of arrests, designated contacts should inquire about detainee locations for families and attorneys. They should also notify employee family members if the employer has emergency contact information on file.

The aftermath of an ICE enforcement action can be challenging to navigate, with impacts on business operations, employee morale, and public perception. Develop a crisis communication plan to keep communication channels open and address stakeholder concerns.