Dustin J. O’Quinn
In January of 2012 two Houston, Texas companies each agreed to pay $2 million to the Department of Homeland Security (DHS) and to adhere to strict revised Immigration compliance programs set forth by the DHS’ Immigration and Customs Enforcement (ICE) agency as part of a non-prosecution agreement. These penalties were the result of in-depth ICE I-9 Audits, which can be caused in part by the issuance of Social Security “No Match” letters.
After approximately a four-year hiatus, the U.S. Social Security Administration (SSA) resumed issuing “No Match” letters in 2011 to notify employers when company wage documentation is inconsistent with SSA information. For these two Houston companies, failure to resolve the “No Match” issue led to the agreements in which ICE promised not to prosecute. However, the employers are still under criminal investigation and subject to criminal prosecution despite their measures to correct past mistakes. Both employers were enrolled in E-Verify.
To view a summary of ICE’s increased enforcement and investigative activities, visit ice.gov.