ICE Revamps IMAGE Program to Encourage Participation

IMAGE (ICE Mutual Agreement between Government and Employers) is an Immigration and Customs Enforcement (ICE) program that partners with employers to improve compliance with U.S. immigration laws. The IMAGE group within ICE has the responsibility to grow the employer membership in IMAGE.

In the past, requirements for participation were a burden to employers and so employers simply weren’t interested. Those employers “encouraged” to join as a direct result of an ICE enforcement audit of Form I-9s were among the few participants.

The requirements to become an IMAGE member have been softened. ICE is headed a new direction – toning down the number of workplace raids that seek out illegal workers instead, utilizing outreach programs that train and educate employers on Form I-9 compliance.

IMAGE will be hosting free forms around the county this summer and fall. Employers interested in learning more about being an IMAGE member should attend one of these free forums. Employers will receive an in-depth look at how to identify fraudulent documents.

IMAGE Forum Schedule:

July 26 – Seattle
August 11 – Dallas

August 23 – Atlanta

September 1 – Denver

September 8 – Phoenix

September 20 – New York City

September 29 – San Diego


The IMAGE website

Employers wishing to participate as an IMAGE member must agree to:

  • Complete the IMAGE application
  • Enroll in E-Verify within 60 days
  • Establish a written hiring and employment verification policy (including an internal, annual Form I-9 audit)
  • Submit to a Form I-9 inspection
  • Review and sign the IMAGE partnership agreement with ICE

Enrollment brings certification for employers – a distinction DHS believes will become an industry standard. IMAGE Certified employers, however, are not offered safe harbor for participating in the program. IMAGE certification does not eliminate fines and punishment or prosecution for employing unauthorized workers. However, ICE is limiting fines as a result of an IMAGE participant’s Form I-9 inspection to the lowest applicable rate. IMAGE is designed to be an outreach program that trains and educations, not to get employers turned in during the inspection.

Employers should consider participation in IMAGE as part of any comprehensive corporate compliance program.

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