The raid was massive: roadblocks, a boat fishing people out of a sewage pond, workers hiding in air ducts. Agents asked every worker for identifying information before clearing some to leave and detaining the rest. It was the largest single-site enforcement action in Homeland Security history.
Hyundai has said that some arrested were not its direct employees but contractors or subcontractors. Still, construction of the $5.5 billion facility is now halted. South Korea dispatched diplomats. Lawsuits will almost certainly follow.
Trump's border czar, Tom Homan, told CNN's Jake Tapper that there will be similar raids at other businesses. "The short answer is yes, we're going to do more work site enforcement operations."
Which begs the question—what should employers do now to prepare? Here are 5 thoughts.
🔹 Run internal I-9 audits. Pull your files and check for accuracy. Fix mistakes proactively (within the law) before regulators come knocking. If you don't have a process for ongoing I-9 compliance, build one now. It's better to confirm who is, or not, legal to work before ICE arrives, not while they are lining up and detaining your workers.
🔹 Audit your contractors, and subcontractors. Don't assume they're following the rules. Require documentation, review onboarding practices, and insist on proof of compliance. If they can't show you how they complete I-9s or use E-Verify, that's a problem.
🔹 Strengthen your contracts. Build in clear obligations to comply with immigration and employment laws. Require indemnification if violations are discovered. Add audit rights so you can check for yourself rather than taking their word.
🔹 Train your team. A raid is chaotic. Your managers need to know what to do: who to call, how to handle agent requests, and how to protect your business without obstructing lawful enforcement. This training includes your receptionist and anyone else who will be the first to greet the agents on their arrival.
🔹 Have a response plan. Think of it like a fire drill. If ICE or DOL walked in today, could you gather all I-9s quickly? Could you explain your contractor relationships? Could you show that you vet subs before they set foot on your job site?
The Hyundai raid is a wake-up call. Immigration enforcement at worksites is real, and when it happens, the headlines don't distinguish between "direct" and "subcontracted" employees. They only see your company's name.
The time to prepare is now—before your business is the next test case.