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Worksite Enforcement

Funds obtained from HSI investigation presented to Michigan State Police and Huron County Sheriff's Office

HSI presents checks to local and state officials for their assistance in a worksite investigation.
HSI presents checks to local and state officials for their assistance in a worksite investigation.
CARO, Mich. — U.S. Immigration and Customs Enforcement's (ICE) Homeland Security Investigations (HSI) has presented the Michigan State Police (MSP) and Huron County Sheriff's Office (HCSO) with funds obtained from a criminal investigation. The funds were shared with HSI's law enforcement partners for their assistance in the investigation – and successful prosecution – of a mid-Michigan dairy farm that was staffed almost exclusively with illegal aliens.

"HSI is proud to recognize the key role that our equally important county and state law enforcement partners played in bringing this significant worksite enforcement investigation to a successful resolution," said William Hayes, acting special agent in charge of HSI Detroit. "These funds will allow the Michigan State Police and the Huron County Sheriff's Office to continue the excellent work they do in the community."

"The Michigan State Police at its core is a service organization. We have a long history of providing the highest quality of law enforcement services and public safety throughout Michigan," said First Lieutenant Mitch Krugielki of MSP. "We recognize that this investigation was a direct result of the cooperative efforts of all agencies involved. The Michigan State Police will continue to strive to work cooperatively with law enforcement partners in an effort to make our communities a safer place to live."

"The Huron County Sheriff's Office is a small rural department with limited resources, some of which were used to assist with the HSI investigation into Aquila Farms," said Huron County Sheriff Kelly J. Hanson. "The asset forfeiture funds being awarded will help us to recover some of our investment by allowing us to update equipment, training facilities, and community safety programs that may have not been possible due to budgetary constraints."

The funds constitute a portion of the money obtained when the owners and the business itself, Aquila Farms LLC, were ordered to pay fines and payments in lieu of forfeiture of more than $2.7 million. The funds were distributed in accordance with HSI's asset-forfeiture program that applies to assets obtained as proceeds or instrumentalities of criminal activity. MSP and HCSO received ceremonial checks in the amounts of $250,652.09 and $35,807.44, respectively in a ceremony at MSP's Caro post. Both agencies have already received payments.

The case first made headlines in May 2007 when HSI special agents executed search warrants at the farm as part of the investigation that resulted in the administrative arrests of dozens of illegal aliens.

MSP's involvement began in early 2007, when they provided the lead to HSI Detroit of suspected illegal activity at the farm. After HSI initiated an investigation, MSP and the sheriff's office assisted in executing federal search and arrest warrants at the business owners' home and at the farm on three separate occasions.

The owners were sentenced Nov. 8, 2011, to three years of probation and ordered to pay fines totaling $234,000 after pleading guilty to hiring illegal aliens and aiding and abetting each other to do so.

The company also pleaded guilty to harboring illegal aliens for commercial advantage or private financial gain. For this offense, the company was sentenced to probation for five years, ordered to pay a fine of $500,000, and required to make payments totaling $2 million in lieu of forfeiture.

The investigation revealed that the Bad Axe, Mich., dairy operation employed 78 different illegal aliens from approximately 2000 through 2007, which constituted almost 75 percent of its workforce over that time period. The company also failed to conduct the necessary inquiries to determine the employment eligibility of their work force, as required by federal immigration laws.

HSI worksite investigations

Effective worksite enforcement plays an important role in the fight against illegal immigration. HSI has developed a comprehensive worksite enforcement strategy that promotes national security, protects critical infrastructure and targets employers who violate employment laws or engage in abuse or exploitation of workers.

An effective worksite enforcement strategy must address both employers who knowingly hire illegal workers, as well as the workers themselves. In worksite cases, HSI investigators adhere to high investigative standards, including the following:

  • HSI will look for evidence of the mistreatment of workers, along with evidence of trafficking, smuggling, harboring, visa fraud, identification document fraud, money laundering and other such criminal conduct; and
  • HSI will obtain indictments, criminal arrests or search warrants, or a commitment from a U.S. attorney's office to prosecute the targeted employer before arresting employees for civil immigration violations at a worksite.

HSI also works with the private sector to educate employers about their responsibilities to hire only authorized workers and how to accurately verify employment eligibility, through such tools as ICE's Mutual Agreement between Government and Employers (IMAGE) program.

IMAGE program

Undocumented workers create vulnerabilities in today's marketplace by presenting false documents to gain employment, completing applications for fraudulent benefits and stealing identities of legal United States workers. To combat this, ICE initiated the IMAGE program in 2006. As part of the IMAGE program, ICE provides employers with education and training on proper hiring procedures, including use of employment screening tools such as E-Verify. IMAGE certified employers also undergo an audit of their I-9 forms to ensure current employees are eligible to work in the United States.

Employers that are certified with ICE through the IMAGE program pledge to maintain a secure and stable workforce and curtail the employment of unauthorized workers through outreach and education. ICE recently revamped IMAGE, simplifying program requirements.


All IMAGE members must participate in the U.S. Department of Homeland Security (DHS) E-Verify employment eligibility verification program. Through this program, employers can verify that newly hired employees are eligible to work in the United States. This Internet-based system is available throughout the nation and is free to employers. It provides an automated link to the Social Security Administration database and DHS immigration records.