ICE Enforcement & Employer Compliance in the OBBBA Era: Strategic Response, I-9 Defense, and Workforce Risk Management

Timothy D’Arduini | Klasko Immigration Law Partners, LLP

Tim is Partner-in-Charge of the Klasko Immigration Law Partners’ Washington, DC office and a leader on the worksite compliance team. He advises multinational clients on a range of employment eligibility verification issues, immigration-related fraud investigations, worksite enforcement actions, and global right-to-work requirements. He develops protocols and policies and oversees internal audits of employer protocols that help mitigate risk. Tim also defends companies subject to administrative subpoenas, as well as in worksite enforcement actions (i.e., “raids”), including matters involving potential civil and criminal liability to employers. Tim integrates proactive compliance practices to help clients avoid penalties and maintain operational integrity. Known for his strategic and pragmatic approach, he partners with employers across industries to create sustainable compliance frameworks that support business objectives while meeting complex regulatory requirements.

• Education & Credentials

Tim earned his J.D. from Rutgers Law School, where he was the senior managing editor of the law review and a member of the Order of the Coif. He holds a B.S. from Georgetown University and is admitted to practice law in New Jersey and Washington, D.C.

• Recognition & Leadership

He is ranked as “Up and Coming” by Chambers USA® (2022–present) and was named a “Rising Star” by The Legal 500 U.S. (2019–2021). Tim serves on the AILA DC ICE Liaison Committee (2025–2026) and the AILA Verification and Documentation Liaison Committee (2024–2026).

• Professional Involvement

Tim is a frequent lecturer on I-9 compliance and worksite enforcement for organizations like AILA and the Smithsonian Institution. He also advises civic organizations on developing immigration programs to attract foreign talent and revitalize local communities.

• Experience

As Partner-in-Charge of the Washington, D.C. office, Tim manages global mobility programs for Fortune 500 companies in the technology, defense, and financial sectors. He has successfully defended clients during ICE raids, conducted multimillion-dollar internal audits, and advised on the immigration impact of complex mergers and acquisitions.

Taylor Gibson | Klasko Immigration Law Partners, LLP

Taylor Gibson is an Associate in Klasko Immigration Law Partners’ Washington, D.C. office and an integral member of Klasko’s worksite compliance and corporate immigration team. She counsels employers on developing and implementing Form I-9 compliance programs, conducting internal audits, and addressing immigration-related anti-discrimination and enforcement risks under federal immigration regulations. Taylor works with multinational corporations and organizations of all sizes to develop policies and training that strengthen worksite compliance frameworks and mitigate risk. She assists clients in navigating complex enforcement dynamics and supports audits, internal reviews, and corrective action to maintain regulatory alignment. Her practice also encompasses guidance on global immigration programs, workforce mobility compliance, and proactive protocols designed to help employers stay ahead of enforcement trends. Known for her thoughtful analysis and practical solutions, Taylor partners with human resources and legal teams to integrate sustainable compliance practices that support business goals while ensuring adherence to evolving regulatory requirements.

• Education & Credentials

Taylor earned her J.D., cum laude, from the American University Washington College of Law, where she served as a student attorney for the Immigrant Justice Clinic. She graduated magna cum laude from Providence College with a B.A. in Political Science and Spanish and is admitted to practice law in Maryland.

• Recognition & Leadership

She was honored as a Spotlighted Volunteer by the D.C. Bar Pro Bono Center in June 2025. An active member of the American Immigration Lawyers Association (AILA), Taylor participates in professional initiatives such as the AILA D.C. book club and is recognized for her frequent contributions to legal alerts on federal immigration policy.

• Professional Involvement

Taylor is a frequent author on emerging immigration issues, including EEOC guidance, USCIS fee proclamations, and birthright citizenship litigation. She leverages her background as a former Legislative Counsel in the U.S. Senate to advise clients on engaging with Congress, the White House, and federal agencies to advance their compliance and talent goals.

• Experience

Taylor has extensive experience in both the private and public sectors, having served as an Attorney Advisor in the Immigration Court through the DOJ Honors Program and as Legislative Counsel to two U.S. Senators. She specializes in Form I-9 audits, workplace investigations, and securing complex visas such as O-1s for executives, L-1s for multinational managers, and E-2 investor visas.

Nick Lowrey | Klasko Immigration Law Partners, LLP

Nick Lowrey is an associate with Klasko Immigration Law Partners in the firm’s Washington, D.C. office and a key member of the worksite compliance team. He advises employers of all sizes and industries on comprehensive employment eligibility and worksite compliance matters, including large-scale Form I-9 audits, suspect document assessments, immigration-related fraud issues, and anti-discrimination policies. Nick helps clients design compliance policies and protocols tailored to their operations, conducts strategic training, and offers routine consultations on unique I-9 and worksite compliance questions. His work emphasizes proactive risk mitigation and the integration of sustainable compliance practices that align with evolving regulatory requirements. Known for his creative problem-solving and commitment to superior client service, Nick partners with employers to assess existing programs, strengthen internal controls, and navigate worksite enforcement dynamics. By focusing on practical yet robust compliance frameworks, he supports clients in avoiding costly penalties and maintaining operational integrity.

• Education & Credentials

Nick earned his J.D. from the University of California, Irvine School of Law and his B.A. from the University of California, Santa Cruz. He is admitted to practice law in California and the District of Columbia.

• Recognition & Leadership

He has been recognized as a “Rising Star” by Super Lawyers and has held leadership roles within the American Immigration Lawyers Association (AILA). Nick is frequently called upon to provide expert analysis on complex regulatory changes and federal immigration policy shifts.

• Professional Involvement

Nick is a prolific author and speaker on corporate immigration topics, including H-1B compliance, Department of Labor audits, and the impact of presidential proclamations. He actively engages with industry stakeholders to develop best practices for managing large-scale foreign national populations.

• Experience

As an Associate at the firm, Nick specializes in employment-based immigration, advising multinational corporations and high-growth startups on visa strategy and worksite compliance. His expertise includes navigating PERM labor certifications, immigrant visa processing, and defending employers against complex government audits and investigations.

I. Framework of Government Actions (ICE/HSI) | 1:00pm – 1:15pm

This section breaks down specific federal actions including the Notice of Inspection (NOI), Notice of Suspect Documents (NSD), and Notice of Intent to Fine (NIF). Counsel must understand these triggers to effectively prepare clients for OCAHO litigation and potential criminal prosecution. Mastering these responses helps mitigate the collateral consequences and enforcement actions that follow a government raid or audit.

II. I-9 Compliance Strategies | 1:15pm – 1:30pm

The panel offers practical tips to mitigate the risk of hiring unauthorized workers through written I-9 policies and internal training programs. Strategies include using electronic I-9 storage, maintaining document copies, and establishing protocols to respond to constructive knowledge. These procedures are designed to avoid discrimination while utilizing external law firm audits to ensure attorney-client privilege.

III. Reception & Security Protocols for Site Visits | 1:30pm – 1:45pm

Preparing the frontlines is critical to managing an employer’s engagement with ICE during an unannounced doorstep arrival or workplace raid. This topic outlines proactive compliance strategies and the exact escalation protocols required between legal, HR, and business leadership. Ensuring staff know how to handle site visits prevents unauthorized access and protects the organization’s legal interests during high-pressure events.

IV. Employment-Based Sponsorship and Workforce Planning | 1:45pm – 2:00pm

Despite heightened enforcement, sponsoring foreign nationals can provide a competitive advantage through robust business continuity planning. The discussion focuses on sponsorship strategy considerations and future-looking perspectives on how to navigate the current regulatory landscape. Counsel will learn to advise employers on balancing the costs of sponsorship with the necessity of maintaining a stable, legally authorized workforce.

Break | 2:00pm – 2:10pm

V. Stakeholder Management | 2:10pm – 2:30pm

Effective counsel must keep internal and external clients informed using issue-spotting frameworks that bridge immigration, employment, and compliance disciplines. This includes preparing client alerts, internal guidance, and navigating the ethical considerations and scope-of-practice awareness unique to this field. Coordination ensures all departments from payroll to HR remain aligned with shifting federal and state enforcement regimes.

VI. OBBBA and the Modern Employer | 2:30pm – 2:40pm

This program provides a foundational understanding of how the One Big Beautiful Bill Act (OBBBA) reshapes obligations across immigration, benefits, and tax reporting. Early-career professionals will gain a practice-ready framework to manage the intersection of these three pillars in a post-OBBBA world. The session clarifies the evolving roles of federal agencies like the DOL, IRS, DHS, and ICE under the new law.

VII. Immigration Enforcement After OBBBA | 2:40pm – 2:50pm

The OBBBA has significantly increased immigration petition fees and ICE funding, leading to aggressive new enforcement priorities and audit frequencies. Attorneys will examine the implications for I-9 compliance, sponsorship decisions, and workforce continuity in light of expanded federal and state-level regimes. This section helps counsel anticipate where the next wave of government scrutiny will hit a client’s labor force.

VIII. Employer-Provided Benefits Under OBBBA | 2:50pm – 3:00pm

Legislative changes have expanded dependent care FSA limits, employer-provided childcare credits, and modified paid family and medical leave credits. Understanding the interaction between these OBBBA provisions and existing laws like ERISA and the ACA is vital for compliance and dispute risk. Counsel will learn to advise on the strategic implementation of these benefits to minimize litigation exposure.

IX. Employment Tax Changes and Reporting Obligations | 3:00pm – 3:05pm

New mandates include overtime premium deductions under the FLSA and separate deductions for tipped workers, alongside increased reporting requirements. Coordination between payroll, HR, and tax functions is now mandatory to avoid costly federal penalties and audits. This topic focuses on identifying the specific reporting triggers that could lead to institutional liability and financial damages.

X. Putting It All Together: Practice-Ready Frameworks | 3:05pm – 3:10pm

The program concludes with a comprehensive issue-spotting checklist for advising employer-clients across immigration, benefits, and tax disciplines. Participants will learn to prepare high-value internal memos, litigation support materials, and client alerts while respecting ethical boundaries. This framework ensures that attorneys can add immediate value by proactively managing the multi-faceted risks of the OBBBA.