Damian Conforti, Brent Pohlman, and Frank Custode from our Employment and Criminal Defense Practice Groups, were featured in a Hotel Dive article titled “How Hotels Can Prepare for ICE Raids,” where they shared vital insights for hotel owners and managers navigating the growing risks of immigration enforcement in the hospitality industry. As federal authorities increase their focus on workplace compliance, it’s more important than ever for hotel operators to understand their legal rights and responsibilities.
With a workforce that often includes immigrant labor, hotels are particularly vulnerable to unannounced visits from Immigration and Customs Enforcement (ICE). As enforcement ramps up, hotel operators must be proactive, not reactive, in ensuring legal compliance and protecting both their businesses and employees.
Employment Documentation and Training
One of the most critical steps hotels can take is ensuring that all Form I-9 records are accurate, complete, and readily available. These forms verify each employee’s identity and authorization to work in the U.S., and failure to maintain proper documentation can lead to steep fines, even if there was no intent to violate the law. Routine internal audits can help identify and correct errors before ICE does.
Just as important as documentation is staff preparedness. Hotel managers and HR professionals should be trained to handle enforcement actions professionally and lawfully. Our attorneys strongly recommend designating a single point of contact—often someone from HR or legal—to engage with ICE agents if they arrive. Front desk and security staff should be briefed on basic protocols and instructed not to grant agents unrestricted access.
What to Do During an ICE Visit
If ICE agents visit the property, the business should ask to see identification and request any legal documentation, such as a judicial warrant. The attorneys note that agents are not permitted to access non-public areas without appropriate authorization. Businesses are encouraged to contact legal counsel immediately to help guide the response and ensure that all actions taken are compliant with applicable laws.
As our attorneys emphasize in the article, being prepared is not just about compliance—it’s about keeping your business running smoothly. Proactive audits, clear procedures, and knowledgeable staff can make all the difference in how your hotel weathers an enforcement action.
To read the full article, visit Hotel Dive.
For legal guidance, contact our Labor and Employment and White Collar and Criminal Defense Practice Groups at Mandelbaum Barrett PC.