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ICE reversed hospitality enforcement shields and ramped up to 12,000+ annual I-9 audits. Nevada employers face increased raid risk. Prepare now with mobile verification.
September 30, 2025
All Employers
The Department of Homeland Security reversed June 2025 guidance that limited Immigration and Customs Enforcement raids on farms, hotels, restaurants, and food processing plants. ICE field office directors received updated instructions in September 2025 directing agents to resume worksite enforcement operations at hospitality and restaurant businesses across the United States, eliminating the temporary "safe spaces" that had briefly protected these industries from immigration inspections.
This policy reversal directly impacts Nevada's hospitality-dependent economy, where casinos, hotels, and restaurants employ tens of thousands of workers across Las Vegas, Henderson, and North Las Vegas. DHS spokesperson Tricia McLaughlin confirmed ICE will continue making arrests at worksites, emphasizing "there will be no safe spaces for industries that harbor violent criminals or intentionally undermine ICE's efforts."
ICE has ramped up I-9 compliance audits to 12,000–15,000 Notices of Inspection (NOIs) per year, returning to enforcement levels last seen in fiscal years 2018–2019 when ICE conducted 6,450 audits annually. This represents a four-fold increase from the 3,000–3,500 audits averaged during the Bush and Obama administrations. Nevada employers—particularly in hospitality, healthcare, staffing, and pharmaceutical sectors—face elevated audit risk as ICE prioritizes industries with high worker volume and turnover rates.
Key Enforcement Statistics:
Nevada Governor Joe Lombardo signed a September 2025 memorandum of understanding with the U.S. Department of Justice to enhance state cooperation with ICE enforcement operations, ending Nevada's prior "sanctuary jurisdiction" designation. The agreement allocates $430,000 in FEMA State Homeland Security Grant funds to upgrade Washoe County Jail with ICE holding cells and co-located office space, signaling increased ICE presence and operational capacity in Nevada.
ICE Enforcement and Removal Operations (ERO) initiates worksite investigations based on several triggering factors. Understanding these risk indicators helps Nevada employers assess their audit exposure and implement preventive compliance measures.
High-Risk Indicators for ICE Audits:
1. Conduct Internal I-9 Audits Immediately
Review all current and recently terminated employee Forms I-9 to identify and correct technical violations before ICE inspection. Common errors include missing signatures, incorrect completion dates, incomplete Section 2 entries, failure to use current form versions, and inadequate List A/B/C document copies. Document all corrections with dated explanations and supervisor signatures. Retention requirement: 3 years after hire or 1 year after termination, whichever is later.
2. Designate ICE Response Team and Legal Counsel
Identify HR personnel, facility managers, and legal counsel authorized to interact with ICE agents during inspections or raids. Train staff on proper procedures for verifying ICE credentials, requesting search warrants, documenting agent actions, and protecting employee rights. Develop written protocols for business continuity, employee communication, media inquiries, and staffing contingencies during enforcement actions.
3. Use Mobile I-9 Authorized Representatives
Lake Mead Mobile Notary provides on-site I-9 Section 2 verification services throughout Las Vegas, Henderson, and Clark County for multi-location employers, remote workers, and HR-constrained organizations. Same-day mobile service ensures compliant document examination and Form I-9 completion within federal 3-day deadlines, reducing paperwork violation exposure and demonstrating good-faith compliance effort during ICE audits.
4. Implement E-Verify (Strategic for High-Risk Industries)
Nevada does not mandate E-Verify for private employers except state contractors, but voluntary enrollment provides significant audit protection benefits. E-Verify employers receive access to the Alternative Procedure for remote I-9 verification via live video, reducing authorized representative costs and geographic barriers. E-Verify participation also signals proactive compliance posture and may reduce penalty severity if violations are discovered during ICE inspection.
5. Train All Staff on ICE Raid Protocols
Employees should understand their rights and employer obligations during ICE enforcement actions. Key training points: employees are not required to answer questions about immigration status, ICE must present valid warrants to enter non-public areas, employees have the right to remain silent and contact an attorney, and employers must produce Forms I-9 within 3 business days of receiving Notice of Inspection. Post employee rights notices in English and Spanish in break rooms and common areas.
Nevada imposes no additional I-9 requirements beyond federal compliance and does not mandate E-Verify usage for private employers. However, the September 2025 MOU between Governor Lombardo and DOJ creates enhanced ICE operational capacity in Nevada, particularly in Northern Nevada (Washoe County) where upgraded detention facilities will accelerate processing of detained workers. Summerlin, Downtown Las Vegas, Green Valley, and Enterprise employers in hospitality, gaming, and service industries face particularly elevated enforcement risk given Las Vegas Strip concentration of high-volume, high-turnover businesses.
Book mobile I-9 verification services: https://lakemeadmobilenotary.com/book or call/text (702) 748-7444.
This content is for informational purposes only and does not constitute legal advice. Employers should consult immigration counsel for compliance guidance specific to their circumstances.
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