Milford, Massachusetts, a town with more than 1,500 employees, has become the first U.S. municipality to partner with Immigration and Customs Enforcement’s (ICE) IMAGE (ICE Mutual Agreement between Government and Employers) program, an employment compliance initiative founded in 2006. According to the IMAGE program, members voluntarily submit to a Form I-9 audit, enroll in E-Verify, and receive training about proper hiring practices. Members also pledge to create a written hiring and employment eligibility verification policy, including an annual Form I-9 audit, and sign a formal partnership agreement that emphasizes employers’ commitment to maintaining a secure workforce and curtailing the hiring of undocumented immigrants.

Although critics contend that the IMAGE program preemptively invites government scrutiny, employers who partner with ICE also receive important benefits, such as reputational credibility and a greater likelihood of government leniency in the event of an enforcement action.