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ICE Investigation Results in Over $8 Million in Fines for Colorado Businesses

By Desiree Sullivan posted 05-14-2025 08:11 AM

  

With the change in presidential administration in January, there was anticipation that Form I-9 compliance would be a key focus by U.S. Immigration and Customs Enforcement (ICE).  This has further come to light after ICE’s recent decision to impose over $8 million in fines after an investigation revealed at least 143 unauthorized workers across three janitorial companies. ICE’s press release noted the following regarding the companies that were fined:  

  • CCS Denver, Inc. – Fined $6.19 million after a 100% substantive violation rate and evidence of knowingly hiring and employing at least 87 unauthorized workers. 

  • PBC Commercial Cleaning Systems, Inc. – Fined $1.6 million for a 74% violation rate and a pattern of knowingly employing at least 12 unauthorized workers. 

  • Green Management Denver – Fined $270,195 after a 100% violation rate and identification of 44 unauthorized employees. 

These are the highest fines since the change in administration. The fines emphasize the focus that ICE will have on enforcing compliance with work authorization laws.  

Takeaways for Employers 

Employers must be aware of their requirements under federal law to make sure they are employing individuals who are authorized to work. The primary way that this is ensured and enforced is through Form I-9. Penalties regarding Form I-9 include the following:  

  • Uncorrected I-9 violations can result in civil penalties of up to $2,861 per Form I-9. 

  • Knowingly employing an unauthorized alien can range from $716 per individual for a first offense to $28,619 per individual for a third or greater offense.  

  • Engaging in a pattern or practice of knowingly hiring or continuing to employ unauthorized aliens can result in criminal penalties.  

If the Department of Homeland Security (DHS) finds that there is a failure to comply with Form I-9 requirements, it will consider the following to determine the amount of the penalty:  

  • The size of your business 

  • Your good faith 

  • The seriousness of the violation 

  • Whether the individual was an unauthorized alien 

  • The history of your previous violations, if any 

Learn how to help ensure I-9 compliance in this Employers Council article, whitepaper, and upcoming webinar. If you have questions or concerns, please contact us at info@employerscouncil.org. 

Desiree Sullivan is an attorney for Employers Council. 

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