by Chris Musillo

The US Immigration and Customs Enforcement (ICE) has recently announced an increase in Form I-9 enforcement. Form I-9 completion and retention is often problematic for companies who place workers at third-party worksites because the Form I-9 documents must be seen in person by the employer or the employer’s representative. The April 2013 update to the US government’s M-274, Handbook for Employers, reconfirmed the best practice for Form I-9 completion in these difficult situations.


In these instances, the best practice is for the employer to specially designate someone to personally review the documents and complete Form I-9, Section 2, Employer or Authorized Representative Review and Verification. Ideally this person should be a Notary Public, although the rule allows anyone acting on the employer’s behalf, such as another employee at the worksite.

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