When ICE Knocks: The New Playbook for I-9 Audits, Raids, and Worksite Defense in 2026

Daniel Brown, Partner | Fragomen, Del Rey, Bernsen & Loewy LLP

Daniel Brown is a Partner in the Washington, D.C. office of Fragomen, Del Rey, Bernsen & Loewy LLP and Chief Executive Officer of Fragomen WorkRight U.S. I-9, the firm’s I-9 employee verification technology platform. A senior member of Fragomen’s Government Strategies and Compliance Group, Daniel is widely regarded as one of the country’s foremost authorities on I-9 and E-Verify compliance, bringing a rare blend of senior government experience and private-sector insight to the most complex challenges in employment-based immigration. He counsels Fortune 500 companies through high-stakes government audits, advises private equity firms on immigration-related due diligence in connection with acquisitions, and helps fast-growing startups build smart, compliant immigration programs from day one — making him a trusted, go-to resource for practical and strategic counsel on internal investigations, enforcement defense, and nuanced immigration matters.

• Education & Credentials

Daniel earned his Juris Doctor from the University of Southern California’s Gould School of Law in 1996. He holds a Master of Accountancy from DePaul University, conferred in 1993, and a Bachelor of Arts from the University of Chicago, completed in 1989. This unusual combination of legal, financial, and policy training underpins the analytical rigor he brings to compliance program design, regulatory engagement, and the technology-enabled solutions he leads at WorkRight U.S.

• Recognition & Leadership

Daniel’s standing in the immigration compliance bar is reflected in his appointment as Chief Executive Officer of Fragomen WorkRight U.S. I-9 in June 2025, where he now oversees both the firm’s I-9 service center technology and the legal services that power its end-to-end employment verification offering. Firm leadership has described his command of both the regulatory and practical dimensions of employment verification as unparalleled, positioning him to guide clients through an era of intensifying enforcement and shifting government requirements. As a co-author of the American Bar Association’s Immigration Compliance and Best Practices — a definitive resource for immigration practitioners, in-house counsel, and senior human resources professionals — Daniel has helped shape the field’s understanding of effective compliance program design, employer liability, and enforcement risk.

• Professional Involvement

Daniel is a recognized thought leader who is frequently called upon by national media, including Bloomberg Law, HR Dive, and the ABA Journal, to comment on developments in Immigration and Customs Enforcement guidance, employer penalty exposure, and the practical realities facing companies under audit. He has been an active speaker on the leading stages of the employment-based immigration field, including the American Immigration Lawyers Association Annual Conference and the SHRM Employment Law and Legislative Conference, where he has led discussions on preparing clients for I-9 audits and investigations, navigating Form I-9 with confidence, and engaging effectively in the politics of programs such as E-Verify. He continues to advise administrations and policymakers on electronic I-9 regulations, drawing on his earlier government service to bridge the gap between regulatory intent and operational practice.

• Experience

Daniel joined Fragomen in 2012, following a partnership at Berry Appleman & Leiden LLP and earlier service as an attorney at Paul Hastings LLP. His career is distinguished by significant senior service in the federal government, where, between 2003 and 2006, he held key roles within the Department of Homeland Security as Deputy Associate General Counsel for Immigration and as Director of the Office of Policy and Planning at U.S. Immigration and Customs Enforcement, also serving as Counselor to the Assistant Secretary. From that vantage point, he helped shape the policy frameworks that today govern employer obligations in employment eligibility verification. In private practice, his counsel spans the full lifecycle of immigration compliance — from program design, training, and internal audits to defense in government investigations and enforcement actions before ICE, the Department of Justice, and other agencies. As CEO of Fragomen WorkRight U.S. I-9, he now leads the strategic direction of the firm’s compliance technology platform, ensuring that its solutions remain robust, adaptable, and responsive to the real-world needs of employers nationwide.

Daniel N. Ramirez, Partner | Monty & Ramirez LLP

Daniel “Danny” Ramirez is a Partner at Monty & Ramirez LLP and a Board Certified Labor and Employment attorney who strategically represents public and private employers in labor, employment, and immigration matters. With a practice that spans complex litigation, government investigations, and proactive compliance counseling, Danny is known for an aggressive yet client-centric approach that delivers swift, cost-effective resolutions. He regularly guides employers through high-stakes ICE raids, Form I-9 audits, and sensitive HR matters, and his client roster includes numerous McDonald’s and Walgreens franchises, the Metropolitan Transit Authority of Harris County, Lone Star College, Houston Community College, and a broad range of privately held companies of every size.

• Education & Credentials

Danny earned his Juris Doctor from The University of Texas School of Law in 2002, where he served as Articles Editor of The Review of Litigation and Associate Editor of the Texas Hispanic Journal of Law and Policy. He completed his Bachelor of Arts at The University of Texas at El Paso in 1998. He is Board Certified in Labor and Employment Law by the Texas Board of Legal Specialization — a distinction held by only a small percentage of attorneys in the state — and he practices fluently in both English and Spanish. Danny is admitted to practice before the State Courts of Texas, the United States Court of Appeals for the Fifth Circuit, and the United States District Courts for the Southern, Northern, Western, and Eastern Districts of Texas.

• Recognition & Leadership

Danny’s work has earned consistent recognition from the legal community’s most respected rating organizations. He holds an AV Preeminent rating from Martindale-Hubbell, has been named a Super Lawyer by Texas Super Lawyers every year since 2014, and has been recognized by Best Lawyers® since 2023. Earlier in his career, he was named a Texas Rising Star in Employment and Labor Law by Texas Super Lawyers and Texas Monthly in 2010, 2011 (a front-cover feature), 2012, and 2013. The Hispanic Bar Association of Houston honored him with its President’s Award in both 2011 and 2012, and The University of Texas School of Law presented him with its Peregrinus Consul Award in 2002. For his work on behalf of military families, Danny received a Certificate of Special U.S. Congressional Recognition in 1999, and his service in uniform was honored with U.S. Naval Reserves Meritorious Medals in 1996 and 1999. In leadership, he has served as Chairman of the Harris County Sheriff’s Civil Service Commission, as President of the Hispanic Bar Association of Houston, and currently serves as a Commissioner of the City of Houston Civil Service Commission.

• Professional Involvement

Danny is actively engaged in the legal profession and civic life of his community. He is a member of the National Association of College and University Attorneys and the Labor and Employment Section of the Houston Bar Association, and he remains deeply involved with the Hispanic Bar Association of Houston, where he previously served as President, President-Elect, and Treasurer, and continues to serve on the Board of Directors. He has been a member of the National Hispanic Bar Association since 2009. Beyond the bar, Danny served as Chairman of the Harris County Sheriff’s Civil Service Commission from 2013 to 2015 and previously as a Commissioner, served on the City of Houston Civil Service Commission from 2018 to 2021, and is a graduate of the Leadership Houston Class of 2011–2012. A frequent and sought-after speaker, Danny presents in both English and Spanish to audiences ranging from HR Houston, the State Bar of Texas, and the SHRM Gulf Coast Symposium to the Texas Restaurant Association, NAMWOLF, the National Employment Law Council, and the BSCAI HR Summit, covering topics that include FLSA compliance, I-9 audits, ICE enforcement, discrimination in the remote workplace, and union-related matters.

• Experience

Danny defends employers across the full spectrum of workplace disputes — wage and hour collective actions, Title VII discrimination, sexual harassment, ADEA claims, workers’ compensation retaliation, non-subscriber cases, non-compete enforcement, and NLRB matters — in state and federal courts, arbitration, and on appeal. His litigation record includes a successful jury verdict in a disability and gender discrimination case, summary judgment victories in age and gender discrimination matters, and the management of complex multi-million-dollar federal whistleblower (qui tam) litigation from inception through dismissal on behalf of a public employer. On the compliance side, he represents employers during ICE enforcement raids and Notices of Inspection, manages EEOC charges, and resolves Department of Labor investigations carrying potential million-dollar exposure. He has implemented immigration compliance initiatives tied to AUSA non-prosecution agreements and routinely conducts Form I-9 audits and training to eliminate liability and identity-fraud risk. He also drafts the employment policies, arbitration agreements, and non-competition and confidentiality provisions that allow his clients to avoid disputes before they arise. Before launching his legal career, Danny served in the U.S. Navy and Reserves from 1993 to 2001 as a second-generation Navy service member, and worked as a Military and Veterans Caseworker in the District Office of Congressman Silvestre Reyes from 1995 to 1998. He clerked for the Honorable David Briones of the U.S. District Court for the Western District of Texas during the summer of 1999. He maintains primary practice locations in Houston and Dallas, Texas.

SESSION 1 – Assessing I-9 Compliance Risks in the Face of Expanding ICE Enforcement | 1:00pm – 2:00pm

With ICE I-9 enforcement intensifying, this session equips practitioners to evaluate employer compliance risks, conduct internal audits, strengthen verification policies, navigate the new DHS Fact Sheet implications, and address heightened E-Verify oversight from federal and state authorities.

BREAK | 2:00pm – 2:10pm

SESSION 2 – From Audits to Arrests: How ICE Enforcement is Escalating in 2026 | 2:10pm – 3:10pm

This session examines escalating ICE enforcement in 2026, recapping recent raids and forecasting targeted arrests, warrants, and seizures. Learn how SSA mismatches and IRS anomalies trigger investigations, plus practical steps employers can take to reduce exposure.