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March 27, 2009

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The inside sources in DC that I know tell me that Obama wants to focus on human traffickers particularly those who traffick women for sexual purposes (mostly East European) but the rank and file DHS want to focus on raids...and there may be some defiance.

Jack - I just wrote a book on employer compliance that comes out in a few weeks and can tell you after deep, deep research during the two years I worked on the manuscript that I-9 audits can be extremely effective in catching bad actors. In fact, a great deal of the evidence used in the indictments in the typical criminal case is gathered during an I-9 review. Criminal cases can still be pursued very effectively against employers using this technique rather than going the high drama route of the work site raid. I think the raids are more about ICE wanting to show it's got control over the situation. I-9 audits just don't produce the same level of response from the media and the public even though they're pretty darn effective if conducted by people who know what they're doing.

'I would urge the Administration to publicly state that raids are on hold'

Please consider what message this would send to worst-of-the-worst abusers like Agriprocessors: abuse human beings with impunity.

Administrative tactics and I-9 audits don't catch the Agriprocessors of the world in the vast array of sordid activities they engage in. That requires a surprise inspection so if raids are taken off the table, abuse is condoned.

As a general principle, Greg, isn't it foolish to announce to lawbreakers of any sort that a particular form of law enforcement is 'on hold'? Even if 'a moratorium is believed to be in operation' why not let bad actors worry (at least a little) about being caught in the act via raid?

Why are work-site raids bad? Any good reason except it's bad for business? I mean the treatment of the actual workers should probably be better but I thought the idea was to punish the employers and not the workers.

Wont be surprised. The ICE office out there probably dont recognize Obama as President as that state went heavily for the GOP!

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