SHRM26 Debrief · Legal & Compliant HR · #2429

Raid Readiness: Preparing Your Workforce for ICE Worksite Actions

with David Jones

& Connie YANG

▶ Watch on the SHRM portal ~68 min, distilled

ICE enforcementimmigration complianceI-9 audits

"You just want to have some procedure in place so that you're not making important decisions when ICE is knocking on the door. That's the worst time to be doing that."

What it was about

Employers rarely face dramatic full-scale ICE raids. Most encounters are administrative warrants or I-9 audits with no legal authority to compel entry, so HR's job is to have a trained, designated point person and a pre-set protocol in place before ICE ever shows up, not to improvise under pressure.

Key notes

Designate a specific point person (with a trained alternate) who is the only one authorized to interact with ICE, and train frontline staff to say, "I don't have the authority to let you in, let me get someone who does."
Learn to distinguish a judicial warrant (signed by a judge, court name, allows compelled entry to specific named areas) from an administrative warrant (a DHS form with no legal authority to enter private space without consent).
Properly mark and enforce private versus public areas with signage (e.g., "Employee access only") since ICE can enter any space you treat as open to the public, and whatever you allow a stranger to do, you're effectively allowing law enforcement to do.

The contrarian takeThe intuitive assumption that securing or gating a facility to lock out ICE is universally the right move gets challenged here. The speakers stress this is purely a business risk decision, not a legal or moral obligation, and that in some cases, like a judicial warrant or a visa sponsor situation, providing information or access is actually required or advisable.

Take this back Monday

Do this for your team

Designate and train one point person (plus a backup) as the only staff authorized to interact with ICE, and script frontline staff to defer to them.

Say this in your next leadership meeting

Most ICE encounters are administrative warrants with no legal authority to enter — our real gap isn't the law, it's not having a trained point person and protocol ready before they show up.

Watch out for

Letting intimidated frontline staff (receptionists, security guards) wave ICE in just because agents look authoritative or claim to have a warrant, without verifying it.
Assuming an administrative warrant grants ICE legal authority to enter, search, or seize — it does not, unless the company consents.
Failing to secure or clearly mark private versus public areas, which effectively invites ICE into spaces the company didn't intend to open.

Fun fact · David Jones

David Jones' immigration practice stretches into export-control law, handling ITAR and EAR compliance and citizenship-status discrimination cases alongside DHS, DOJ, and State Department matters.

If this landed, see these

↳ Go deeperNavigating the Wild Habitat of Workforce RegulationsSets the point-person protocol inside the wider 2026 wave of regulatory volatility.⇄ The counterpointWhen Employee Relations Isn't Enough: A CLEAR Framework for Protected Class InvestigationsArgues high-stakes situations need far more structure than one trained point person.✦ The unexpected oneEmotional Intelligence Is a System Skill That Makes Work WorkSame fix, different crisis: design the system instead of relying on one person.