By Jennifer Parser
It is a good time to conduct an internal audit of I-9s because inspections and fines have not gone away and a new I-9 edition was published recently. An administrative law judge in the Office of the Chief Administrative Hearing Office fined a staffing company $276,000 in June 2017, reduced from the $367,000 originally imposed by Immigration and Customs Enforcement (ICE). While this is less than the highest fine of $605,250 imposed in 2015 on an events planning company for incomplete I-9s (there were only four missing I-9’s out of 339 employees), the reason for the staffing company’s fine was a failure to produce the I-9s to ICE within the three days of its request. So, Rule No. 1 taken from this latest large ICE fine: Have complete I-9s ready and available for inspection at all times.
Second, use the latest Form I-9. A new I-9 Form went into effect on July 17, 2017. The Jan. 1, 2107 version can be used until Sept. 17, 2017. After that, employers must only use the July 17, 2017 iteration. Rule No. 2: Never rely upon pre-printed I-9 forms. Always go to the website and download the latest version.
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