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ICE Mutual Agreement Between Government and Employers

Your Workforce Compliance Partner

U.S. Immigration and Customs Enforcement (ICE) is responsible for enforcing the nation’s immigration and customs laws. One known vulnerability is the presence of undocumented workers who have secured jobs by fraudulent means, including presentation of false documents, completion of fraudulent benefit applications and theft of identities. To combat unlawful employment and reduce vulnerabilities that help illegal aliens gain such employment, the ICE Mutual Agreement between Government and Employers (IMAGE) program was initiated in 2007. The goal is to assist employers in targeted sectors to develop a more secure and stable workforce and to enhance fraudulent document awareness through education and training.

IMAGE Program

By voluntarily participating in the IMAGE program, companies can reduce unauthorized employment and the use of fraudulent identity documents. As part of IMAGE, ICE and U.S. Citizenship and Immigration Services (USCIS) will provide education and training on proper hiring procedures, fraudulent document detection, use of the E-Verify employment eligibility verification program and anti-discrimination procedures. Employers seeking to participate in IMAGE must agree to:

  • Complete a self-assessment questionnaire;
  • Enroll in E-Verify;
  • Enroll in the Social Security Number Verification Service;
  • Adhere to IMAGE Best Employment Practices;
  • Undergo an I-9 audit conducted by ICE; and
  • Review and sign an official IMAGE partnership agreement with ICE.

Upon enrollment and commitment to DHS’s best hiring practices, program participants will be deemed “IMAGE Certified” – a distinction DHS believes will become an industry standard. The results of the IMAGE program and participation in IMAGE by partners in industry will serve to guide DHS in shaping future worksite enforcement policy and legislation.

IMAGE members participate in DHS’s E-Verify employment eligibility verification program, administered by USCIS. Through this program, employers can verify that newly hired employees are eligible to work in the United States. This Internet-based system is available in all 50 states and is free to employers. It provides an automated link to the Social Security Administration database and DHS immigration records. To sign up for participation, visit the registration Web site

Associate Membership

In June 2008, ICE initiated an “associate member” category in the IMAGE program for employers seeking to join the program but who would prefer a two year period of time in order to complete all requirements for full IMAGE membership. Under associate IMAGE membership, employers can implement the best practices and begin to take advantage of the benefits of membership while deferring the I-9 audit and annual report requirement for up to two years.

Trade Association Membership

A parallel membership opportunity since the inception of IMAGE, trade associations can become "endorsee" partners by signing an endorsement agreement stating that they support and highly recommend the use of the IMAGE "Best Employment Practices" by their members.  The above-mentioned process for business entities is not required for association partnerships.

Best Hiring Practices

Use the E-Verify employment eligibility verification program for all hiring.
Establish an internal training program, with annual updates, on how to manage completion of Form I-9 (Employee Eligibility Verification Form), how to detect fraudulent use of documents in the I-9 process, and how to use E-Verify.
Permit the I-9 and E-Verify process to be conducted only by individuals who have received this training – and include a secondary review as part of each employee’s verification to minimize the potential for a single individual to subvert the process.
Arrange for annual I-9 audits by an external auditing firm or a trained employee not otherwise involved in the I-9 and electronic verification process.
Establish a self-reporting procedure for reporting to ICE any violations or discovered deficiencies.
Establish a protocol for responding to no-match letters received from the Social Security Administration.
Establish a tip line for employees to report activity relating to the employment of unauthorized aliens, and a protocol for responding to employee tips.
Establish and maintain safeguards against use of the verification process for unlawful discrimination.
Establish a protocol for assessing the adherence to the “best practices” guidelines by the company’s contractors/subcontractors.
Submit an annual report to ICE to track results and assess the effect of participation in the IMAGE program.

For more information on the IMAGE Program, please visit the IMAGE FAQ page. You may request an information packet via the IMAGE Information Packet Request form.

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