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BUILDING INDUSTRY ASSOCIATION of Philadelphia

News & Resources

Guidance on 2025 Immigration Enforcement Actions

Many members may have concerns about the possibility of a U.S. Immigration and Customs Enforcement (ICE) agent arriving at a construction jobsite. The National Association of Home Builders' (NAHB) legal team prepared a document outlining best practices for business owners to follow in the event ICE arrives on site.

When ICE Comes Calling was published during the first Trump Administration, but the guidance is still valid for those who want to be prepared for an ICE enforcement action today.

There are two types of ICE visits: Administrative Audits and Raids Authorized by a Judge. The Administrative Audit begins when ICE issues a Notice of Inspection (NOI) to com- pel the production of Forms I-9 and related materials. By law, employers are provided with at least three business days to produce the Forms I-9. A subpoena (a court order to produce documents) may also accompany the NOI. In a Raid Authorized by a Judge, the ICE officer must have a warrant, and will often have a subpoena, that authorizes the immediate inspection and review of the employer’s premises and the files. A raid occurs much less frequently than an administrative audit. Nonetheless, an employer should be prepared for either occurrence.

Download and review the guidance document to learn more and share with your trade partners.

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