Initiated in July of 2006 and administered by Immigration and Customs Enforcement (ICE), IMAGE is a voluntary partnership between ICE and private sector employers. IMAGE, or "ICE Mutual Agreement between Government and Employers," is a program in which employers self-police their hiring practices and share pertinent information with ICE. As part of the program, employers must agree to receive training, oversight and direction from ICE as to its hiring practices and policies. IMAGE participants must also join E-Verify, the automated employment verification system. According to the ICE, IMAGE was developed as an initiative to ensure employer self-compliance and prevent or reduce any hiring or retention of unauthorized workers.
Although IMAGE does not promise 100% accuracy in preventing unauthorized employment, ICE touts the program as enhancing fraudulent document awareness through education and training. While IMAGE participation may be a mitigating factor in the determination of any civil penalty for hiring of unauthorized workers, IMAGE does not provide any safe harbor for employers. For the majority of employers who have not signed onto IMAGE, best practices to ensure compliance with immigration laws is to ensure proper completion of I-9 forms for every employee hired on or after November 6, 1986.
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