On January 20, 2025, President Trump signed an executive order declaring a national emergency at the southern border of the United States and allowing for the use of federal funding for border security and the deployment of armed resources to the region. The following day, the Department of Homeland Security issued a directive rescinding policies that limited enforcement in sensitive locations such as churches, schools and hospitals.
Since this directive was implemented, employers should be prepared to handle ICE immigration enforcement actions or inspections at these locations as ICE raids, which target undocumented employees are not announced in advance. Businesses, schools, employees, and students must be ready and well prepared to address immigration actions by ICE during the foreseeable future.
Preparing requires designating a key representative, such as HR, legal counsel or a senior administrator, to interact with ICE officers and training front-line staff to direct officers to the representative. Employers should be prepared with written response plans and should be aware of their rights—and the rights of their employees.