• 954

Timely and consistent I-9 compliance which is frequently referenced to on this blog and multiple other immigration resources, acquired new significance for a small staffing company in Minnesota. Upon receipt of a Notice of Inspection (NOI) requiring to present all of its I-9 forms for current and former employees, the business turned over a number of I-9 forms to ICE within the allotted three day period. However, the company subsequently discovered additional I-9 forms in its files and delivered them to ICE on two separate dates outside the three day compliance period. The government determined that the I-9 forms were not presented in a timely fashion and penalized the company by $500 to $600 fine for each belatedly presented form. The overall penalty assessed for the failure to prepare or timely present I-9 forms was set at $185,000. The company was additionally fined for the I-9 Forms deficiencies with the total penalties demanded by the government in excess of $275,000. The company’s error with the timing of I-9 files delivery to the government appears to stem from the I-9 forms upkeep practices – i.e., the files were split between several corporate locations. Better (and safer) practice is to maintain all I-9 files at the company’s headquarters.