ICE Is Suddenly At The Door: How Retailers, Hospitals, And Hotels Can Survive The Surprise Visitor

Imagine a typical morning at your retail store, hospital, or hotel—customers are arriving, staff are busy, and suddenly, federal agents from ICE appear at your front desk. The surprise is real, but panic does not have to be. Unannounced inspections conducted by Immigration and Customs Enforcement (ICE) inspectors have been occurring for years, but in recent months, ICE has ramped up inspection visits across the service sector, targeting I-9 compliance and employment records. These visits are not always dramatic raids; more often, they are routine checks that can escalate if your team is not prepared.

Preparing your staff and documents and maintaining a culture of compliance that keeps your business out of the headlines is key to calmly responding to these situations. Whether you are in retail, healthcare, or hospitality, read on for steps to protect your organization—and your people—when ICE comes knocking.

ICE Inspections Versus ICE Raids

What is an ICE Audit?

In May 2025, Department of Homeland Security agents visited over 100 restaurants in the Washington, D.C. area. An ICE audit is an examination conducted by government officials to assess an employer's adherence to employment eligibility laws, including the verification of Form I-9. Officials from the Department of Homeland Security (DHS), Department of Justice (DOJ), and Department of Labor (DOL) are authorized to inspect Form I-9 records. Neither your consent nor a search warrant is required, however, employers must be provided with a written “Notice of Inspection” at least three days before the audit. Some companies, when faced with this scenario waive the three day period without realizing they have a choice not to. The inspection can occur at a U.S. Immigration and Customs Enforcement field office or onsite at the employer's location. Employers must be ready to provide electronic and physical records as requested.

What is Form I-9?

Form I-9, known as Employment Eligibility Verification, is a mandatory document that all U.S. employers must complete. It is used to verify the identity and employment authorization of every individual hired in the United States, whether they are U.S. citizens or foreign nationals.

What is an ICE Raid or Search?

ICE raids differ from audits as they are unexpected and can significantly disrupt business operations. These raids focus on identifying unauthorized workers or investigating suspected illegal hiring practices. During a raid or more specifically, a search, ICE agents arrive without prior notice, secure the premises, and monitor all entry and exit points with the aim of locating, detaining, and arresting unauthorized workers.

ICE Raids New Flagship Electric Vehicle Battery Plant in Georgia

On September 5, 2025, the heart of Georgia’s industrial corridor was rocked by a massive federal immigration raid at Hyundai’s co-owned sprawling mega plant. In a scene reminiscent of past enforcement sweeps, agents arrested a significant number of workers, most reportedly South Korean nationals—sending shockwaves through the automotive sector and beyond. The raid marks one of the largest workplace enforcement actions in recent U.S. history, raising urgent questions for manufacturers, suppliers, and HR departments nationwide. This raid was an enforcement action authorized by a judicial search warrant authorized by a federal judge.

The events at the Georgia plant serve as a stark reminder that a single morning can upend not only a company’s operations, but also the lives of hundreds of workers and the stability of an entire region. What started as an ordinary workday rapidly transformed into a significant turning point when federal agents arrived, leaving an impact that resonated well beyond the confines of the factory floor.

But the story does not end at the plant gates. This raid signals a new era of enforcement, where high-profile employers across the country must reckon with the reality that immigration compliance is no longer a back-office issue, but at their front door.

Increased ICE Enforcement Goes Hand-in-Hand With National Guard Federalization

Increased ICE enforcement activity at retailers, hotels, and hospitals has occurred whenever and wherever the federal government has federalized National Guard troops and deployed them. For example, in Washington D.C., immediately following the deployment of the D.C. National Guard on the streets of the Nation’s Capital, ICE enforcement activities were initiated at grocery stores, retail stores and hospitals frequented by immigrant populations. Similar enforcement increases have occurred in Los Angeles, Chicago, Portland and other cities that have attracted federal enforcement attention. We are advising organizations and businesses regarding ICE enforcement for companies, with a focus on those operating nationally and those with offices in Washington D.C., Los Angeles, and Chicago. If you have operations in geographies hosting federalized National Guard troops, you should anticipate an increased likelihood of ICE enforcement activities that may include your company or organization.

Hearing about the recent ICE activities, companies are left to ask:

Are we prepared for a knock at our own door?

Preparation for ICE Inspections and ICE Raids:

Retail stores, hospitals, and hotels—businesses that usually hire large numbers of essential, front line employees—have increasingly found themselves on the front lines of immigration enforcement as ICE agents conduct inspection visits. These I-9 visits, sometimes mistaken for raids, are typically focused on reviewing employment eligibility documentation, most notably Form I-9s, and supporting identity records. During an I-9 inspection, agents may request a wide array of documents, including I-9 audit trails, E-Verify confirmations, payroll records, company ownership details, and staffing vendor information. Businesses are generally given a Notice of Inspection, triggering a 72-hour window to gather and present the required materials.

Prior to an ICE Inspection or enforcement action, employers should also:

• Have legal counsel establish or review robust compliance policies.
• Train employees on what to do before, during and after an ICE enforcement action to enable them to be prepared and composed.
• Designate and train a “visit manager,” and train frontline staff—especially receptionists and security—on how to respond calmly and professionally, and who to contact at the company at any given time. The importance of this step cannot be over-emphasized.
• Have legal counsel that is knowledgeable regarding ICE enforcement on standby, and all required documents should be organized and preserved, ideally offsite.
• Maintain organized records, separating I-9 records from other personnel records.

• Ensure all levels of employees understand their rights and responsibilities, and set up in advance a communications team to be ready to manage public messaging if headlines arise.

Responding to ICE Inspections and ICE Raids

• The specific steps hospitals, hotels, and retailers should take before, during and after ICE inspections or enforcement actions will vary depending on factors including the type of business, the location of your business, the physical layout of your premises, and the parts of your business that are open to the public.
• Generally speaking, ICE enforcement activities cannot take place in areas of your business where you have a reasonable expectation of privacy without a judicial warrant.^[1] But there are nuances involved in, for example, designating areas as “private” or “not open to the public” that can enhance the protection of your business and employees in the event of an enforcement action that should be tailored to your particular circumstances.
• ICE does not have carte blanch access to non-public areas without a judicial warrant unless you consent. ICE also has no right to be left alone in a private space or office while inspecting your employment records, unless ICE is conducting a court-authorized search warrant and that warrant identifies locations (i.e., the business office) that are likely to contain business records.^[2]
• Training managers on what to do before, during and after an ICE raid is both necessary and easy, but again, should be tailored to each business to be effective and conducted by knowledgeable counsel or experienced security personnel.

Conclusion: Prepare. Train. Respond. Repeat.

This alert offers a glimpse into the various measures a company can implement to prepare for an ICE visit, including the crucial step of preparing and reassuring your frontline employees that a plan of action is established. But know that if ICE visits, the reaction does not have to be one of chaos or crisis. Instead, it can be a composed response demonstrating preparation, teamwork, compliance, and resilience.