White House border czar Tom Homan confirmed in a recent interview that the administration plans to significantly scale up worksite enforcement, with a specific focus on criminal exposure for employers, not just arrests of undocumented workers. Employers across historically targeted sectors should treat this as a strong signal to get ahead of I-9 compliance now, and not wait until increased audits begin. 

Interview Highlights 

• Worksite Enforcement Is Expanding: Homeland Security Investigations (HSI) has a team dedicated to worksite operations — including investigators from prior high-profile cases — and the Administration has confirmed it wants substantially more activity going forward, not a continuation of current volume. 

• Criminal Cases Are the Stated Priority: The current approach is described as “all about criminal cases,” aimed at employers who circumvent the law, rather than simply arresting undocumented workers. Human trafficking, forced labor, and peonage are cited as recurring findings at worksites, and the Department of Justice (DOJ) is reportedly participating directly in enforcement planning — a signal that referrals for prosecution, not just civil penalties, are the focus. 

• A Centralized “Warehouse” Model for I-9 Audits: A new plan would stand up a centralized unit staffed by contractors to conduct batch I-9 inspections. Cases that surface criminal or administrative violations would then be referred to HSI agents. In practice, this industrializes the audit pipeline: I-9 review may increasingly come from a centralized screening operation rather than only a field investigation triggered by a specific complaint or tip. 

• No-Match Letters and Interagency Data-Sharing Are Back: Restrictions on sharing Social Security no-match letter data that limited information-sharing in recent years have been rescinded. ICE is now coordinating with the Social Security Administration and the Department of Labor, with the IRS also involved in tracing financial flows connected to worksite violations. 

• The Strategic Target Is the Employer: The stated emphasis has shifted away from lower-level worksite arrests toward holding employers criminally responsible — a materially higher risk profile than past enforcement operations. Agriculture, meatpacking, construction, hospitality, and staffing-agency-dependent industries remain the sectors most likely to draw attention. 

What This Means for Employers 

The practical exposure here is broader than a routine I-9 paperwork violation. Employers, particularly those using staffing agencies or subcontractors in previously targeted sectors, should expect: 

• A higher likelihood of I-9 audit activity, potentially through the centralized “warehouse” review process rather than only a field visit. 

• Renewed Social Security no-match letter follow-up, meaning discrepancies that may have gone unaddressed in recent years could now trigger agency inquiries. 

• Criminal, not just civil, exposure where HSI develops evidence of knowing employment of unauthorized workers, trafficking, or forced labor — a materially higher stakes proposition than a fine. 

• Increased scrutiny of subcontractor and staffing-agency relationships because liability can extend beyond direct hires to how a company monitors its labor supply chain. 

Recommended Action Items 

Employers should consider taking the following steps now, ahead of any increase in enforcement activity: 

1. Conduct a proactive I-9 self-audit, prioritizing any locations or business units in sectors with a history of enforcement attention. 

1. Review staffing-agency and subcontractor relationships to confirm those partners maintain compliant I-9 and work-authorization practices, since liability can extend beyond direct hires. 

1. Revisit internal procedures for handling Social Security no-match letters to ensure discrepancies are addressed promptly and consistently. 

1. Confirm escalation protocols so that any HSI inquiry is routed immediately to counsel, given the shift toward criminal, not just civil, exposure. 

1. Review training for HR and hiring managers on current I-9 completion and retention requirements, particularly considering the anticipated increase in centralized audit activity. 

Our Perspective 

This is a policy signal, not a new regulation, and it tracks with other immigration enforcement trends that have increased in recent months. The direction of this latest phase of the Administration’s enforcement agenda moves toward a more systematic, higher-volume I-9 review paired with a genuine focus on criminal cases against employers, not simply administrative penalties. Companies in sectors with any history of enforcement attention, or that rely on staffing agencies or subcontractors to fill labor gaps, should implement a proactive I-9 self-audit before a warehouse-generated I-9 inspection notice arrives. 

Should you have any questions about I-9 compliance, worksite enforcement risk, or your company’s audit readiness, please contact your Meltzer Hellrung professional.