I-9 Remediation: Building your Path to Compliance

READY, SET, REMEDIATE

Presenters:• Nici Kersey, Bose, McKinney & Evans LLP and

Kersey Immigration Compliance, LLC• Rita Ziman, Bank of the West• Scott Willett, LawLogix

AGENDA

§ Initial Poll§How to Audit I-9§ Identifying I-9 Procedures§Building a Remediation Strategy§Real Life Example of Remediation

October 29, 2020

CRASH COURSE IN I-9 AUDITINGOUTLINE CURRENT PROCESS

§ Who/When are I-9’s created?

§ Where are your I-9s stored?

§ Who will be involved in the audit?

§ Does company have a purge policy? Is it being enforced?

§ How are re-verification dates being tracked?

§ How are reminders created today?

CRASH COURSE IN I-9 AUDITING

§ Variety of auditing practices

§ Identify missing I-9s

§ Identify if employees are missing re-verifications

§ Identify missing documents

§ What if the employee is terminated?

§ Common errors found in Section 1 ,2 and 3

How to Audit I-9’s

I-9 Audit Checklist will be provided following the

presentation

BUILDING YOUR REMEDIATION STRATEGY§ Create a game plan§ Identify your team – time, people, and tech!§ Train your team§ Categorize the errors§ Prioritize remediation efforts§ Correction best practices

I-9 REMEDIATION PLAYBOOKHOW TO MAINTAIN COMPLIANCE IN THE FUTURE?

§ Monthly or quarterly audits§ Annual or biannual training§ Consistent audit practices

REAL WORLD REMEDIATION: BANK OF THE WEST§ Prioritizing the I-9

Project § Who has been

involved?

§ Collecting all I-9 records

§ Where are they?

§ Do you have paper and electronic

§ Did you acquire a company?

§ Remediation Strategy

§ Communication Plan(s)

§ Phased Approach

§ How are corrections being applied?

§ Practical Advice!!!

SUMMARY

§ Ensure policy and procedures are being followed

§ Locate and centralize all I-9’s§ Train, Train, Train§ Think about timing§ Have the right people§ Keep it up!

ON DEMAND

QUESTIONS?