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FMG Law Blog Line

IMAGE Raises the Bar for Immigration Enforcement Practices

Posted on: March 29th, 2013

By: Kelly Morrison

In Georgia, the mandatory E-Verify date is creeping closer. As of July 1 of this year, every employer with 10 or more employees will be required to register and use the online program, which verifies employment eligibility information recorded on the Form I-9.

But E-Verify is only the tip of the compliance iceberg. While Washington debates the future of immigration compliance, Immigration and Customs Enforcement (ICE) is already moving beyond E-Verify, encouraging employers to implement a lengthy list of “best practices,” which it identifies with the acronym “IMAGE” (ICE Mutual Agreement Between Government and Employers). Cobb County recently made waves by agreeing to this voluntary partnership with ICE, and has considered proposals to extend the requirement to all its contractors.

In order to be IMAGE-certified, an employer must: (1) complete an IMAGE questionnaire through ICE; (2) enroll in E-Verify within 60 days; (3) establish a written hiring and employment eligibility policy that mandates an internal I-9 audit at least once per year; (4) submit to a Form I-9 inspection by ICE; and (5) review and sign a formal partnership agreement with ICE.

Although this program has been in existence since 2006, it is only now beginning to gain traction—mostly among employers whom ICE solicits to act as “industry leader” examples in implementing these recommended best practices. Most employers understandably find these suggestions onerous and will not rush to implement them. It is important to understand, however, that these “best practices” represent ICE’s view of the future of immigration compliance, and at least some of these measures are likely to be incorporated into future legislation.

ICE’s IMAGE program and best practice recommendations can be viewed here.

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