As we prepare for President-elect Trump’s second term, we expect to see some of the same policies and immigration trends from his first term. One of those is a significant increase in Form I-9 audits and worksite enforcement investigations.

Employers can best prepare by understanding how to correctly fill out and maintain the Form I-9, conducting internal audits to ensure accuracy and compliance and updating their internal procedures for responding to an audit. As we anticipate these audits and investigations to ramp up in the next few years, it’s beneficial for employers to have clear expectations about why these investigations occur, what happens during them and what rights and obligations they have.

What is a Form I-9 audit? 

Employers are required by law to use Form I-9 to verify that all employees hired after Nov. 6, 1986, are authorized to work in the United States. Companies must maintain I-9 forms for all current employees as well as former employees for at least three years from the first day of employment or one year from the date employment ended, whichever is longer.

A Form I-9 audit is initiated when the Department of Homeland Security’s Immigration and Customs Enforcement agency (ICE) Homeland Security Investigations (HSI) serves the employer a written Notice of Inspection (NOI).

The NOI generally includes:

  • The time and date the agency expects to conduct the inspection
  • Contact information for the ICE agent who is in charge of the inspection
  • Which documents will be inspected
  • Deadline by which the employer must respond to the NOI

HSI may also request that the employer provide supporting documentation, which may include but is not limited to: a copy of the employer’s payroll, a list of active and terminated employees, articles of incorporation and business licenses. Employers have at least three business days to produce the I-9 forms and supporting documents requested in the NOI.

During the Form I-9 audit, HSI will be looking for both technical and substantive violations. Technical violations are typically procedural errors that can be corrected by the employer within 10 business days of the violation being reported by HSI.

Substantive violations are more serious and include failure to complete the Form I-9, failure to complete the Form I-9 within three business days, accepting fraudulent documents and failing to properly verify the documents. These errors are not allowed to be corrected.

What triggers a Form I-9 audit? 

A Form I-9 audit may be triggered by complaints from the organization’s current or former employees, whether they observed unfair or questionable hiring practices or believe their job was lost to an undocumented worker.

Many times, an audit is initiated due to potential red flags in data or trends within a particular industry or region. The Department of Homeland Security uses software to analyze their extensive database of immigration and employment verification data, searching for anomalies and inconsistencies that may indicate noncompliance.

What rights do employers have during a Form I-9 audit? 

Employers should cooperate with ICE agents during a Form I-9 audit. However, they should also be aware of their rights and ensure employees know theirs as well.

Employer rights during Form I-9 audits:

  • Employers do not need to allow ICE HSI agents access to the workplace (beyond “public” areas, like a lobby or waiting area) without a judicial warrant
  • Employers can take the full three days after the NOI is received to collect documentation and seek counsel from their immigration attorney
  • Employers have the right to remain silent, not sign any documents and speak with an attorney before answering questions from agency representatives
  • Employers have the right to contest fines or negotiate a lower fine that comes as a result of the I-9 audit

Employers should seek counsel from their immigration attorney if subject to a government audit or investigation.

What results from a Form I-9 audit? 

After conducting the Form I-9 audit, the auditing agency will notify the employer of its findings in writing. A Notice of Inspection Results means the organization was compliant. If any violations were identified during the audit, an employer may receive one of these notices:

  • Notice of Suspect Documents: An employee’s documentation does not match the employee, or the documentation is not valid for employment
  • Notice of Discrepancies: The agency was unable to identify an employee’s eligibility to work in the United States
  • Notice of Technical or Procedural Failures: An error was identified on at least one form and the employer has 10 business days to make corrections
  • Warning Notice: Violations were identified, but the employer is expected to comply in the future
  • Notice of Intent to Fine: May be issued for substantive violations, uncorrected technical or procedural errors, known hire violations and/or continuing to employ unauthorized employees

What is a worksite enforcement investigation? 

A worksite enforcement investigation, sometimes referred to as a “raid,” typically takes place when ICE agents are attempting to detain employees they believe are working in the United States unlawfully. ICE agents may come to a workplace to target specific workers as part of an ongoing investigation or question all workers who are present.

Unlike a Form I-9 audit, ICE does not need to provide the employer with any prior notice. However, ICE does need to provide the employer with a warrant to enter the premises.

What rights do employers and employees have during a worksite enforcement investigation? 

Employers and employees still have certain rights during a worksite enforcement investigation.

  • Immigration officials are not allowed to enter private areas of a business without a warrant or consent from an employer
  • Employers have the right to refuse their consent to enter private areas of the business
  • The warrant must be signed by a U.S. District Court judge or a State Court judge
  • Employers can thoroughly review the judicial warrant, ensure that ICE agents follow the terms of the warrant and note any deviations from the terms
  • If the ICE agents only have an administrative warrant looking for an employee, the employer does not have to say if that employee is working on location that day and they do not have to take ICE to that employee

Stay compliant with BAL 

Whether your organization wants to conduct an internal Form I-9 audit as a precautionary measure, update its site visit protocol or finds itself in the middle of an investigation, BAL is equipped and ready to help. Our immigration legal experts are deeply knowledgeable about Form I-9 requirements and are experienced in navigating changes in policy and government enforcement trends. We have an entire team of professionals who can assist companies in running I-9 compliance and E-Verify programs, as well as manage complex matters such as I-9 audits and investigations.

Contact our team of immigration legal experts to discuss how we can help ensure compliance and a fair investigation.

In this week’s episode, BAL’s Michelle Gergerian and Victoria Ma discuss strategies employers can use to best position themselves for attracting and retaining top talent in the semiconductor industry.

Explore more episodes of the BAL Immigration Report podcast, available on AppleSpotify and the BAL immigration news page.

This podcast has been provided by the BAL U.S. Practice Group.

Copyright © 2025 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries, please contact copyright@bal.com.

Today, the Department of Homeland Security (DHS) announced the extension of Temporary Protected Status (TPS) for 18 months each for El Salvador, Sudan, Ukraine and Venezuela.

Key Points:

  • Regarding El Salvador’s TPS extension:
    • The 18-month extension dates are from Mar. 10, 2025 to Sept. 9, 2026 .
    • It was determined that an 18-month TPS extension is warranted because of continued conditions from environmental disasters that resulted in a substantial, but temporary, disruption of living conditions in the affected areas of El Salvador.
    • The extension allows approximately 232,000 current beneficiaries to re-register for TPS, if they continue to meet eligibility requirements.
    • Current beneficiaries under TPS for El Salvador must re-register in a timely manner during the 60-day re-registration period beginning when the Federal Register notice is published to ensure they keep their TPS and employment authorization.
    • DHS is automatically extending the validity of Employment Authorization Documents (EAD) previously issued under El Salvador’s TPS designation through Mar. 9, 2026.
  • Regarding Sudan’s TPS extension:
    • The extension allows eligible Sudanese nationals who arrived on or before August 16, 2023, to maintain TPS and Employment Authorization following vetting.
    • It was determined the extension was warranted due to ongoing armed conflict and extraordinary and temporary conditions that continue to prevent individuals from safely returning.
    • The extension allows approximately 1,900 current eligible beneficiaries to re-register for TPS, if they continue to meet eligibility requirements.
    • DHS is automatically extending the validity of EADs previously issued under Sudan’s TPS designation for 12 months.
    • U.S. Citizenship and Immigration Services (USCIS) will continue to process pending applications filed under the Sudan designation. Both initial applicants and re-registering current beneficiaries who have a pending Form I-821 or Form I-765 do not need to file either application again.
      • If USCIS approves an individual’s pending Form I-821, TPS will be granted through Oct. 19, 2026.
      • If USCIS approves a pending TPS-related Form I-765, it will issue the individual a new EAD that will be valid through the same date.
  • Regarding Ukraine’s TPS extension:
    • The extension allows eligible Ukrainian nationals who arrived on or before Aug. 16, 2023, to maintain TPS and Employment Authorization following vetting.
    • It was determined that an 18-month TPS extension is warranted because of conditions resulting from the expansion of the Russian military invasion into Ukraine.
    • The extension allows approximately 103,700 current eligible beneficiaries to re-register for TPS, if they continue to meet eligibility requirements.
    • DHS is automatically extending the validity of EADs previously issued under Ukraine’s TPS designation for 12 months.
    • USCIS will continue to process pending applications filed under the Ukraine designation. Both initial applicants and re-registering current beneficiaries who have a pending Form I-821 or Form I-765 do not need to file either application again.
      • If USCIS approves an individual’s pending Form I-821, it will grant TPS through Oct. 19, 2026.
      • If USCIS approves a pending TPS-related Form I-765, it will issue the individual a new EAD that will be valid through the same date.
  • Regarding Venezuela’s TPS extension:
    • This extension allows eligible Venezuelan nationals who arrived on or before July 31, 2023, to maintain TPS and Employment Authorization following vetting and runs from April 3, 2025, to Oct. 2, 2026.
    • It was determined that an 18-month TPS extension is warranted based on the severe humanitarian emergency the country continues to face due to current political and economic crises.
    • Approximately 600,000 eligible current Venezuelan beneficiaries can retain TPS through Oct. 2, 2026, if they re-register and continue to meet TPS eligibility requirements.
    • DHS is automatically extending the validity of certain EADs previously issued through April 2, 2026.
    • USCIS will continue to process pending applications filed under previous Venezuela designations. Both initial applicants and re-registering current beneficiaries who have a pending Form I-821 or Form I-765 under Venezuela 2023 do not need to file either application again.
      • If USCIS approves an individual’s pending Form I-821, USCIS will grant TPS through Oct. 2, 2026.
      • If USCIS approves a pending TPS-related Form I-765, USCIS will issue the individual a new EAD that will be valid through the same date.

Additional Information: These extensions only apply to individuals already in the United States and who are current beneficiaries of TPS for El Salvador, Sudan, Ukraine and Venezuela. Federal Register notices for each respective country explain eligibility criteria, timelines and procedures necessary for current beneficiaries to re-register and to renew their EADs. Federal Register Notices for Sudan, Ukraine and Venezuela were not yet published on the date of this alert.

This alert has been provided by the BAL U.S. Practice Group.

Copyright © 2025 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries, please contact copyright@bal.com.

U.S. Citizenship and Immigration Services (USCIS) has reached the cap for the additional 20,716 H-2B visas made available for returning workers for the first half of fiscal year 2025 with start dates on or before March 31, 2025.

Key Points:

  • The cap was established under the Department of Homeland Security H-2B supplemental cap temporary final rule for FY 2025 (FY 2025 TFR).
  • Jan. 7, 2025, was the final receipt date for petitions requesting supplemental H-2B visas under the FY 2025 first half returning worker allocation.
  • Petitions are still being accepted for H-2B nonimmigrant workers with start dates on or before March 31, 2025, for the additional country-specific allocation of 20,000 visas for nationals of Colombia, Costa Rica, Ecuador, El Salvador, Guatemala, Haiti and Honduras, and those exempt from the congressionally mandated cap.
  • As of Jan. 7, 2025, USCIS received petitions requesting 3,678 workers under the 20,000 visas set aside for nationals of Colombia, Costa Rica, Ecuador, El Salvador, Guatemala, Haiti, and Honduras.
  • Petitioners with start dates on or before March 31, 2025, whose workers were not accepted for the 20,716 returning worker allocation are encouraged to file under the country-specific allocation while visas remain available.
  • Additional information on the FY 2025 supplemental visa is available here.

Additional Information: The FY 2025 TFR was published on Dec. 2, 2024, with an immediate effective date. USCIS immediately began accepting H-2B petitions with start dates on or before March 31, 2025, for the 20,716 returning worker allocation for the first half of FY 2025, and the 20,000 allocation for nationals of Colombia, Costa Rica, Ecuador, El Salvador, Guatemala, Haiti and Honduras who are exempt from the returning worker requirement.

This alert has been provided by the BAL U.S. Practice Group.

Copyright © 2025 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries, please contact copyright@bal.com.

The Department of Homeland Security announced a final rule that permanently increases the automatic extension period for employment authorization and Employment Authorization Documents (EAD) that will become effective on Jan. 13, 2025.

Key Points:

  • The final rule permanently increases the automatic extension period for employment authorization and Employment Authorization Documents available to certain EAD renewal applicants from up to 180 days to up to 540 days.
  • The final rule will continue to help prevent eligible renewal EAD applicants from experiencing a lapse in employment authorization and/or the validity of their EAD due to lengthy processing times.
  • The final rule will become effective on Jan. 13, 2025, and will apply to certain timely filed renewal EAD applications pending or filed on or after May 4, 2022.

Additional Information: More details on the DHS December 2024 announcement can be found here.

This alert has been provided by the BAL U.S. Practice Group.

Copyright © 2025 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries, please contact copyright@bal.com.

On Jan. 8, U.S. Citizenship and Immigration Services (USCIS) issued policy manual guidance to clarify how it evaluates evidence to determine O-1 visa eligibility, including adding examples of evidence for individuals in critical and emerging technologies.

Key Points:

  • The O-1 nonimmigrant visa is intended for individuals possessing extraordinary ability in the sciences, arts, education, business or athletics, or who have a demonstrated record of extraordinary achievement in the motion picture or television industry and have been recognized nationally or internationally for those achievements.
  • Updates include:
    • Clarifying that beneficiary-owned separate legal entities can file a petition on the beneficiary’s behalf
    • Guidance regarding evidentiary criteria for O-1A and O-1B nonimmigrants
    • Examples of relevant evidence that may be submitted by an interested U.S. government agency
    • An example of an occupational change within a technological field
    • Clarifying the circumstances under which USCIS limits an extension of stay to one year

The updated guidance was issued in the USCIS Policy Manual, Vol. 2, Part M.

Additional Information: The updated guidance addresses President Biden’s Oct. 30, 2023, Executive Order on the Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence, which directs the Department of Homeland Security to modernize immigration pathways for experts in artificial intelligence and other critical and emerging technologies, including for O-1A nonimmigrants.

This alert has been provided by the BAL U.S. Practice Group.

Copyright © 2025 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries, please contact copyright@bal.com.

The Department of Labor (DOL) announced on Dec. 20 additional guidance on the 2024 Farmworker Protection Final Rule.

Key Points:

  • The additional guidance is based on court orders issued in Nov. 2024 in response to lawsuits brought by groups of farm and business organizations seeking to block implementation of the final rule.
  • DOL concluded that use of the current forms associated with the Farmworker Protection Rule is “infeasible in the short term”— including during the current peak H-2A filing season.
  • Employers can submit H-2A job orders and Applications for Temporary Employment Certification on the Foreign Labor Application Gateway (FLAG) system using applicable forms under the version of 20 Code of Federal Regulations part 655, subpart B that went into effect on June 27, 2024.
  • Waivers of the regulatory time period for filing new H-2A job orders and Applications for Temporary Employment Certification using the applicable forms under the version of 20 CFR part 655, subpart B in effect on June 27, 2024, will be granted for those employers impacted by DOL’s cessation of processing as a result of these court orders. However, this waiver does not extend to certified applications that are withdrawn and refiled.
  • Read the two-page additional guidance here.

Additional Information: On November 27, 2024, all initiated but unsubmitted, H-2A job orders and completed Applications for Temporary Employment Certification in FLAG using the forms associated with the Farmworker Protection Rule under the version of 20 CFR part 655, subpart B in effect as of June 28, 2024, were deleted to help prevent accidental submittals using incorrect versions of the forms and ensure DOL compliance with the court orders.

OFLC has ceased further processing of all pending H-2A job orders and Applications for Temporary Employment Certification using the revised forms in effect on June 28, 2024. Employers with pending job orders/applications have the option of requesting withdrawal of their pending H-2A job order or Application for Temporary Employment Certification using either the FLAG System online withdrawal function or submitting a request in writing to the OFLC at tlc.chicago@dol.gov (the unique FLAG H-2A job order or Application for Temporary Employment Certification case number must be used in the subject line of the email).

The preliminary “Yes/No” question put in place by DOL to comply with court orders has been removed from the FLAG System.

The Labor Certification Process for Temporary Agricultural Employment in the United States (H-2A Workers) codified under 20 Code of Federal Regulations part 655, subpart B that went into effect on June 27, 2024 can be found here.

This alert has been provided by the BAL U.S. Practice Group. 

Copyright © 2025 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries, please contact copyright@bal.com.

The application filing window to submit an H-2B Application for Temporary Employment Certification for work start dates of April 1, 2025 or later opens on Jan. 1, 2025 at 12:00 a.m. Eastern Time.

Key Points:
  • H-2B applications requesting an April 1, 2025 work start date will be denied if they are filed before January 1, 2025 at 12:00 a.m. Eastern Time.
  • The Office of Foreign Labor Certification (OFLC) will follow established randomization procedures of all H-2B applications requesting a work start date of April 1, 2025 that are filed during Jan. 1 – 3, 2025.
  • Employers should be aware of the following OFLC guidelines to minimize possible delays or denials:
    • If OFLC identifies multiple applications that appear to have been filed for the same job opportunity, OFLC will issue a Notice of Deficiency.
    • If multiple filings are submitted during the three-day filing window, all applications will receive a Notice of Deficiency requesting that the employer demonstrate that the job opportunities are not the same.
    • Employers that fail to establish a bona fide need for each application will receive a non-acceptance denial for each application.

Additional Information: Employers are reminded that Foreign Labor Application Gateway (FLAG) System user accounts are solely for the use of the individual for whom they were created. Sharing the same user account is forbidden and is grounds for terminating FLAG access.

This alert has been provided by the BAL U.S. Practice Group.

Copyright © 2024 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries, please contact copyright@bal.com.

U.S. Citizenship and Immigration Services (USCIS) announced it will publish a revised edition of Form I-129, Petition for a Nonimmigrant Worker on Jan. 17, 2025.

Key Points:

  • Form I-129 has been revised to align with the H-1B modernization final rule and the H-2 modernization final rule.
  • The Jan. 17, 2025 edition of Form I-129 replaces the Apr. 1, 2024 edition of Form I-129 and will only be accepted if received on or after Jan. 17, 2025.
  • Form I-129 petitions received using the Apr. 1 edition of the form after Jan. 17 will be rejected. There is no grace period for the revised edition of Form I-129 because this revised edition is necessary for USCIS to apply the final rules.
  • For applicants filing Form I-129 by mail, the Apr. 1 edition will not be accepted if received on or after Jan. 17, 2025.
  • A preview edition of the revised form can be viewed here and instructions can be found here.

This alert has been provided by the BAL U.S. Practice Group.

Copyright © 2024 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries, please contact copyright@bal.com.

On Dec. 17, 2024, officials from the State Department and Mexican government dedicated the new U.S. Embassy Mexico City.

Key Points:

  • The new U.S. Embassy Mexico City is designed to accommodate the operational demands of one of the largest U.S. diplomatic missions globally.
  • The facility will consolidate 39 government agencies and over 1,700 staff currently based in different locations in Mexico City.
  • The expanded consular section, supported by industry-leading technology, will expedite the experience of hundreds of thousands of visitors annually.
  • More information about the new embassy can be found here.

Additional Information: The new embassy is a significant investment in Mexico City, Mission Mexico, North America and the Western Hemisphere and is designed to support one of the United States’ most significant diplomatic missions. The project has invested $310 million into the local economy and generated 2,500 jobs — 1,800 of which were in Mexico City. The facility is a model of optimal building performance, the new embassy integrates advanced security, sustainability, resilience and accessibility features.

This alert has been provided by the BAL U.S. Practice Group.

Copyright © 2024 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries, please contact copyright@bal.com.