By: Bruce E. Buchanan, Sebelist Buchanan Law

In an interesting development, five New York-based 7-Eleven franchises have joined IMAGE (ICE Mutual Agreement between Government and Employers), a U.S. Immigration and Customs Enforcement (ICE) employment compliance program, that allows private industry to partner with ICE to reduce unauthorized employment. The five corporations, each individually owning one 7-Eleven franchise are: FYN Management, Inc.; HYN, Inc.; YN 1, Inc.; 5th Avenue Wali, Inc.; and ZHSG, Inc. Yousaf Naseer is the President of all five corporations. Four of the locations are on Long Island and one is located in Manhattan.

I note this is interesting because in January 2018, ICE served Notices of Inspection/subpoenas on 98 7-Eleven franchises throughout the United States. By becoming IMAGE members, it appears these franchisees are trying to protect themselves from ICE making them targets. Of course, by being an IMAGE member, the franchisees are opening the door to ICE auditing their I-9 forms.

ICE established the IMAGE program in 2006 to work toward a legal work force. However, ICE has been able to sign up very few employers over the past 12 years. The numbers are so few that ICE issues a press release for every company becoming an IMAGE member. To qualify for IMAGE certification, a company must perform the following requirements: undergo a Form I-9 audit conducted by ICE; conduct self-assessments of their hiring practices to uncover vulnerabilities that could be exploited by illegal aliens; enroll in E-Verify; and many more requirements.

If you want to know more information on issues related to IMAGE and employer immigration compliance, I recommend you read The I-9 and E-Verify Handbook, a book I co-authored with Greg Siskind, and available at