In today’s manufacturing environment, even highly compliant employers can find themselves navigating unexpected visits from U.S. Immigration and Customs Enforcement (ICE).
While it’s critical for leaders to be fluent in employee rights and what the laws say about warrants and resistance, manufacturers must move beyond the framework of “know your rights” and focus on how to lead during uncertainty.
It’s important to know how to professionally and empathetically manage these encounters so that operations can continue, relationships with employees remain strong and risk is minimized.
That means crafting a plan that not only ensures legal compliance, but also demonstrates compassion and control in moments that can be highly emotional for employees.
Leaders should tackle this head on—not passively or reactively—because hoping an ICE visit never happens is not a strategy.
It’s Not Just About Compliance—It’s About People
One reality often overlooked in ICE preparedness discussions is that immigration enforcement affects more than just legal status: It impacts your workforce culture. Even if all of your employees are fully authorized to work, many may have close family members, housemates or friends who are undocumented.
For these employees, an unannounced ICE visit is not simply a procedural inconvenience—it’s a deeply personal and stressful event. The fear of detention, deportation or familial separation can introduce serious anxiety into your workplace, even if no legal risk exists within your own walls.
Leaders must recognize that this fear is real and valid—and must account for it in training, preparation and real-time response.
A Leadership-Based Framework for ICE Preparedness
Manufacturing leaders can and should be proactive. Here are several best practices that focus not just on legal compliance but also on operational continuity, employee trust and long-term resilience.
1. Prepare with walkthroughs or tabletop exercises
While the idea of formal ICE “drills” may sound thorough, they’re often too disruptive or too performative to be practical in a manufacturing environment. A more effective and realistic approach is to conduct tabletop exercises or onsite walkthroughs with key leaders—whichever is best suited to your team and facility.
These simulations allow your management team to walk through ICE scenarios in detail: Who speaks to the agents? Who reviews the warrant? How is the workforce informed, if at all? What happens if someone panics or runs?
Discussing these steps in a controlled setting enables your team to identify gaps, clarify roles and practice calm, coordinated responses without interrupting operations or causing unnecessary fear among employees.
2. Designate and empower the right responders
Assign specific team members—preferably bilingual and ideally from HR, compliance or senior operations—who are trained not only in what rights to assert but how to engage law enforcement respectfully. These individuals should be practiced in how to:
- Politely request to review warrants.
- Clearly articulate areas marked “private.”
- Communicate calmly with both agents and employees.
- These responders are not “resisters”—they are a bridge between ICE and your operation.
3. Prepare documentation thoughtfully
One of the most stressful parts of an ICE visit is the question of documentation. While you are not legally required to produce I-9s on the spot, being able to retrieve and present them promptly—after verifying warrant requirements—can go a long way toward expediting the visit and reducing scrutiny.
Consult your legal team in advance on:
- Whether to voluntarily produce documentation during a visit.
- How quickly you’re required to provide I-9s upon written notice.
- What to say and what not to say if questioned about specific employees.
A readiness mindset helps you control the narrative rather than react to it.
4. Coach Employees on Thoughtful Responses
Yes, employees have the right to remain silent. But that doesn’t mean silence is always the best path. An employee who is authorized to work and understands their rights might reasonably choose to answer questions calmly and professionally. That decision should be theirs—but it should be an informed one, not driven by fear.
Use team meetings or safety huddles to walk through potential scenarios. Make it clear that no one is required to speak—but that there are professional ways to engage if they choose to. For example, if an ICE agent approaches an employee on the shop floor and asks, “Can I see your ID?”, the employee might respond, “I’m not sure I’m required to provide that. I’d prefer to speak with our company representative—can I direct you to them?” This kind of calm, respectful response helps de-escalate the situation and redirects the interaction to the designated point of contact.
Likewise, if an agent asks an employee about a coworker—such as, “Is Carlos working today?” or “Do you know where Maria lives?”—a thoughtful response might be, “I’m not comfortable answering questions about someone else. I think our HR department can help you better.” This protects coworkers’ privacy and steers the interaction toward someone trained to respond.
Employees should feel empowered to choose whether or not to speak, while also understanding the potential implications of either option. The goal is not to script every answer, but to instill confidence and clarity in how to respond professionally and lawfully.
5. Address the emotional and cultural impact
Manufacturers who view ICE encounters strictly through a legal lens miss the bigger picture. Many employees—especially those in immigrant communities—experience ICE visits as traumatic, regardless of their own legal standing. A family member’s arrest or deportation can ripple through your workforce, affecting focus, morale and mental health.
Make space to acknowledge this reality. Encourage managers and team leads to be emotionally present and trained in how to respond with empathy—not just policy. Offer resources through your EAP or local nonprofits that assist with immigration-related concerns. Most importantly, create an environment where employees feel safe sharing concerns without fear of retaliation or exposure.
6. Define success differently
A successful ICE visit is not one where every right is asserted with maximum resistance. It’s one where:
- No one was unnecessarily detained.
- Business disruption was minimal.
- Relationships with employees remained intact.
- No additional scrutiny or penalties were introduced.
This doesn’t mean rolling over. It means navigating the event like any other operational challenge: with preparation, professionalism and poise.
7. Document Thoroughly but Discretely
You should document everything about an ICE visit: badge numbers, the number of agents, items requested or seized and how your team responded. If allowed under state law, video recordings can also help. If your facility has security cameras, now is the time to ensure they are fully operational and that footage is accessible. This can serve as an objective record of the encounter.
But documentation should not feel like surveillance. Train designated staff to take notes discretely and professionally, not as an act of provocation. That tone matters.
8. Strengthen compliance now—not later
If your last internal I-9 audit was more than a year ago, it's time to revisit it. Fixing errors or missing information now reduces the risk of violations if ICE audits your records. Consider working with a compliance consultant who can audit without the bias of internal familiarity.
Also, be sure to update your internal procedures so that new hires are onboarded with complete documentation and that those forms are easy to retrieve if needed.
Final Thought: Lead with Trust, Not Fear
ICE visits are serious business. But manufacturers who do not knowingly employ unauthorized workers should feel confident—not threatened—by compliance. The key is preparation rooted in respect: for the law, for your workforce and for the human experience behind every badge check.
When your team knows what to do, who to look to and how to carry themselves, your facility won’t just be legally prepared—it will be operationally resilient and culturally strong. You’ll demonstrate to your workforce that leadership isn’t just about compliance; it’s about care, clarity and the courage to lead through uncertainty with integrity and empathy.
