Dark Mode
On July 21st 2025, Acting ICE Director Todd Lyons delivered a stark declaration on CBS’s Face the Nation: the agency will arrest any individual found in the country without authorization, regardless of criminal history, and simultaneously pursue employers who hire undocumented workers.
Lyons explained that ICE’s previously more restrictive “aperture” for targeting noncitizens has been fully opened. This means that agents will no longer limit arrests to those with criminal records; instead, any individual encountered during operations who lacks legal status is now subject to detainment.
Expanded Goals and Resources
The agency is backed by a massive budget increase—from about $8 billion to $28 billion annually—which supports intensified worksite raids, sanctuary‑city enforcement, and a renewed push to meet President Trump’s goal of 1 million removals per year.
Employer Accountability
ICE is also signaling stronger action against American companies employing unauthorized workers—using criminal warrants and investigations to hold businesses accountable for labor exploitation. Recent worksite raids in industries like meatpacking, agriculture, hospitality, and cannabis cultivation have resulted in hundreds of worker arrests, though employers are still seldom charged.
Tactics and Controversy
Mask-wearing agents remain part of ICE’s approach. Director Lyons—while personally uneasy—defends masks as a necessary protection amid a reported 800‑830 percent increase in attacks on ICE personnel. Critics argue masks threaten transparency and enable impersonation. Meanwhile, ICE has admitted it’s using Medicaid data to locate undocumented individuals—a move raising privacy and legal concerns.
Implications for Clients
1. Undocumented individuals
If found during an ICE operation, even noncriminal immigrants may now face arrest and deportation. Lyons’ remarks confirm a deliberate policy shift with no carve-out for low-level or civil-status-based cases.
2. Employers
Companies using undocumented labor are receiving increased scrutiny. ICE is actively pursuing criminal charges under labor exploitation and harboring laws. Employers should now immediately:
• Audit hiring and I‑9/E‑Verify compliance
• Retain immigration counsel before facing ICE subpoenas or warrants
• Prepare for potential large-scale workplace enforcement
ICE’s current objectives reflect a dramatic escalation—unlocking resources to arrest anyone without status while targeting businesses that hire them. This dual enforcement mandate marks a decisive shift in immigration policy. At Spar & Bernstein, we stand ready to provide proactive legal counsel to both individuals and employers facing these emerging challenges.
Learn how our experienced attorneys can help you navigate this intensified enforcement environment.