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ICE Strategy Memo Confirms Targeting Employers and Managers for Criminal Liability



by Todd P. Photopulos
Butler, Snow, O'Mara, Stevens & Cannada, PLLC - Memphis Office

November 6, 2009

Previously published on November 2009

For some time now, we have been reporting on the increase of worksite immigration enforcement activities by Immigration and Customs Enforcement (ICE). While our research had shown a dramatic switch from "cost of doing business" fines for paperwork violations to criminal prosecution of employers and their individual managers, the recent release of an internal ICE Memorandum confirms that this indeed is a purposeful strategy in ICE's efforts to engage in effective worksite enforcement programs.


 

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