ICE Raids on Record Pace — Return of the No-Match Letter

The Department of Homeland Security (DHS) and its two enforcement wings — Immigration and Customs Enforcement (ICE) and Homeland Security Investigations (HSI) — have ramped up raids and indictments. In 2018, DHS conducted 6,850 worksite investigations compared to 1,700 the prior year. In addition, ICE made 800 criminal arrests in 2018 but just 140 in 2017.

DHS-ramps-up-worksite-raidsMost recently, 200 ICE agents raided CVE Technology Group in Allen, Texas, arresting 284 of its workers. The raid followed an earlier I-9 audit that showed “hiring irregularities.” CVE immediately blamed everything on the staffing agencies it uses to stock its workforce.

This rapid uptick in investigations and arrests reflects the emphasis of the Trump administration on controlling both illegal immigration and the employment of undocumented workers.

Recently, the Social Security Administration (SSA) announced it would resume issuing what are called “No-Match Letters,” or “Employer Request Correction Notices.” These documents alert employers that a certain employee, or certain employees, may have a social security number or name on their Form W-2 that does not match SSA records.

These No-Match Letters do not in and of themselves indicate the employee or employees under question have submitted fraudulent information, but they do require the employer to verify with Business Services Online to see if errors were made that should be corrected, and then to conduct further investigations after that if needed.

However, it’s not hard to dot the I’s and cross the T’s to realize that these letters could alert DHS to conduct an investigation, especially if a large number of employees at a company are the subject of these letters.

No-Match Letters were stopped in 2012 and just resumed this spring.

NOTE: The details in this blog are provided for informational purposes only. All answers are general in nature and do not constitute legal advice. If legal advice or other expert assistance is required, the services of a competent professional should be sought. The author specifically disclaims any and all liability arising directly or indirectly from the reliance on or use of this blog.
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