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Iowa Dairy Farmer Indicted for IRCA Violations—Paid $250k in Sanctions And Will Spend Three Months i

Updated: Aug 1, 2022

As the result of an investigation by U.S. Immigration and Customs Enforcement (ICE), Michael Millenkamp, a dairy farmer in Earlville, Iowa, was convicted of harboring (employing undocumented workers), a violation of immigration compliance under IRCA and RICO.

Millenkamp was sentenced to serve three months in federal prison. He was also ordered to pay a fine of $5,000, forfeit $245,000 to the United States, and serve a term of 3 years supervised probation.

In order to not receive the full jail time (possibly a decade), Millenkamp signed a plea agreement which required him to comply with immigration regulations related to employment, and will also be required to make at least two presentations at annual conventions sponsored by local cattle and dairy farmers associations regarding his indictment.

What’s Different Here?

We regularly report on employers being in hot water with I-9 compliance, but the result of this case is strikingly different than what we have seen in the past. Since the publication of the 2009 Worksite Enforcement Memo, ICE continues to target "employers, owners, CEOs, managers, supervisors, and others in the management structure of a company." Seeking civil and criminal penalties has become the new norm nationwide, in cases from Washington to New York. However, requiring Mr. Millenkamp to make various public presentations indicates that ICE is looking for new ways to warn employers that the government has placed noncompliant business directly in their crosshairs.

What Can Employers and Managers Do to Protect Themselves?

Depending on the size of a business, bringing a company into full compliance with employment eligibility verification laws can be an difficult task, but it is an investment that will pay huge dividends. Compliance is the only sure defense against not only enormous fines but also the risk of forfeiting your entire business and years of profits to the government—or jail.

The best way to put your company in compliance is to begin training your hiring personnel on the correct way to complete a Form I-9. Additionally, at least one person should be trained as an immigration compliance officer so that the company has at least one person informed and implementing the plans, policies, and procedures for immigration compliance for the company.

You can start training your personnel at

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