Just days after pausing immigration raids at farms, hotels, and food plants, the Trump administration is now doubling down on mass deportations — leaving U.S. employers scrambling to understand what’s coming next.
The conflicting messages — first offering relief for industries that rely on immigrant labor, then calling for stepped-up enforcement — have created confusion and risk for businesses nationwide. Many are left wondering whether the workers they depend on will be targeted, and what liability they themselves might face if immigration officials show up at their workplace.
We’ve guided employers through every major immigration shift, and this one is no different. Simplify your immigration program with Boundless. Learn more.
A Whiplash Policy Shift
Last week, Immigration and Customs Enforcement (ICE) quietly paused most worksite raids in the agriculture, hospitality, and food processing sectors. That directive followed backlash from business leaders and members of the Trump administration who warned that sudden enforcement actions were harming industries with chronic labor shortages.
But in the days since, the administration has taken a harder line. Homeland Security leadership issued a directive over the weekend pushing ICE agents to ramp up arrest numbers and intensify enforcement, including at workplaces. While large-scale worksite actions must now be approved by senior officials, there are no longer assurances that certain industries will be shielded.
This reversal has left many employers in a precarious position: unsure if they’re in the clear or on the front lines of federal immigration enforcement.
What Employers Should Do Now
With federal messaging still evolving, employers should take proactive steps to prepare for possible immigration enforcement, whether through site visits, audits, or employee arrests.
1. Audit Your I-9s
Now is the time to conduct an internal review of your Form I-9 records. Make sure all forms are:
- Fully completed and signed by both employee and employer.
- Stored properly (paper or digital, but consistently).
- Corrected if errors are found, using clear annotations and dated corrections.
Consider working with an immigration attorney or compliance specialist to review your records if you employ a large or at-risk workforce.
2. Know the Difference Between a Warrant and a Request
If ICE agents arrive at your worksite, it’s important to understand your rights and responsibilities:
- ICE must have a judicial warrant to enter private areas of your business.
- You can request to see the warrant and confirm its validity before granting access.
- Agents may present a so-called Notice of Inspection for I-9s, which gives you three business days to comply.
Train your managers and reception staff on how to respond to these situations calmly and legally.
3. Train HR and Supervisors on Protocols
Ensure your HR team and supervisors know what to do if:
- ICE contacts your business by phone or in person.
- An employee is detained or arrested.
- A raid occurs during working hours.
Having a written Standard Operating Procedure (SOP) can reduce panic and ensure legal compliance in high-stress scenarios.
4. Communicate Carefully with Employees
Avoid making assumptions or sharing legal advice with employees. However, you can:
- Remind workers of their right to remain silent.
- Encourage employees to keep personal documentation up to date.
- Reassure staff that your company is monitoring the situation and values their contributions.
Open, clear communication builds trust and may reduce the fear and absenteeism that sometimes follow high-profile enforcement actions.
5. Stay Informed and Connected
Enforcement priorities are changing fast. Stay plugged in by:
- Subscribing to alerts from the Department of Homeland Security (DHS), U.S. Citizenship and Immigration Services (USCIS), or industry associations.
- Following news from trusted immigration policy outlets
- Consulting with legal counsel if you’re unsure how federal changes apply to your business
The Bottom Line for Employers
The Trump administration’s immigration enforcement strategy is evolving in real time. For now, there are no guarantees that any sector is off-limits — even those that were briefly reprieved. The best course of action for employers is to prepare, stay informed, and ensure your workplace is in full compliance with immigration law.