White Papers & Research

Is Your Company Brand at Risk? Your Image Could be Tarnished without IMAGE

As the Obama Administration heightens the focus on the employer for immigration enforcement it is essential that you hold your staffing provider to the highest standard.


In early 2009, the U.S. Immigration and Customs Enforcement (ICE), a unit of the Department of Homeland Security (DHS), announced an enhanced focus on the employer rather than the unauthorized worker in worksite enforcement investigations, holding employers accountable and intensifying the agency’s investigations of companies that hire unauthorized workers. ICE has already dramatically increased Notices of Inspection. The agency has warned employers that it will also focus on criminal and administrative infractions, and debarment, stripping companies of their lucrative federal contracts, as a tool to drive compliance.

“With the new federal contractor rule going into effect and broad compliance and monitoring continuing to grow, it is increasingly critical that businesses look to staffing providers committed to best hiring practices. Adhering to the IMAGE principles, partnering only with subcontractors and providers that take compliance seriously, and committing to internal audits and corrective actions is the surest way for any company to mitigate its risks and protect its business.” – Julie Myers Wood, President, ICS, LLC and former Assistant Secretary of Immigration and Customs Enforcement

With this increase in enforcement, it is even more important to pay attention to the compliance practices of your staffing providers and the potential risk indirectly posed by that workforce.

In addition to enforcement actions, DHS is exerting regulatory pressure to bring companies into compliance. On September 8, 2009 the Federal Acquisition Regulation mandating E-Verify for federal contractors went into effect and signaled ongoing commitment to the E-Verify program. E-Verify has been a voluntary program to help certify that employees are legally authorized to work in the United States.

Bottom line, a company doing business with the federal government must participate in E-Verify. With few exceptions, employers must also flow down the federal E-Verify requirement to their subcontractors.