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www.IndependentRetailer.com COVER STORY Immigration
Compliance continued from page 92
but be sure to complete Sec- tion 3 of the I-9 with the date of rehire, and updating with the new work authorizing document, as necessary. 7) Understand the
line
between verifi cation and dis- crimination, and encourage consistent and lawful I-9 prac- tices throughout the company. Remember that there are civil and criminal penalties for fail- ure to comply with employment verifi cation requirements and for discrimination. 8) Maintain completed and
signed I-9 forms in a separate fi le throughout the entire time the individual is employed with the company, and for one year from the date of termination or for three years from the date of hire, whichever comes later. 9) Self-audit I-9 fi les at least
annually, and immediately after major hiring. 10) Be sure store managers
know who to contact within the company if a Notice of Inspec- tion is received. Companies will generally have only three days to produce the request- ed documents, so time is of the essence. By establishing thorough in-
house immigration compliance policies and practices, perform- ing spot checks of existing I-9 Employment Eligibility Verifi - cation fi les; training personnel responsible for I-9 procedures, and developing a basic plan
for handling government in- spections, savvy retailers can position themselves to take advantage of better economic times to come, free of the con- cerns of being caught in an enforcement quagmire. Julie Wade is an immigration
attorney in the Dallas offi ce of Gardere Wynne Sewell LLP. Her practice focuses on business and family immigration, including I-9 compliance, employment visas for professional workers, and per- manent residency proceedings, and she is a frequent speaker and author on business immigra- tion topics. She can be reached at
jwade@gardere.com. ■
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