As immigration policies evolve, camps employing international staff must stay informed and prepared. This update outlines new United States Citizenship and Immigration Services (USCIS) registration requirements for Canadian citizens and provides essential guidance on Form I-9 compliance, ICE audits, and creating a safe, legally sound workplace for all employees.
New Registration Requirements
As of April 11, 2025, USCIS has implemented a new registration requirement affecting Canadian citizens who plan to stay in the United States for more than 30 days.
Who Needs to Register?
There are various groups of foreign nationals who are required to register; however, if a foreign national has applied for a visa (and they were 14 years or older at the time they applied) through a consular application, and that individual has since been admitted to the United States with a Form I-94 Arrival/Departure document, they are already considered to be registered. Notably, Canadians are visa exempt and so may be required to register if they traveled by land and were not issued an I-94. The registration requirement applies if a foreign national will be in the US for 30 days or longer during any single visit.
Considerations for Camps as an Employer
Form I-9 Introduction and Basics
Form used by employers in the US to verify the identify and employment eligibility of individuals they hire.
Understanding an Immigration and Customs Enforcement vs. an I-9 Audit
An I-9 audit is a formal review of an employer’s records to ensure compliance with federal hiring laws and must come with 3-days’ advance notice. In contrast, an ICE raid is an unannounced enforcement action where agents enter a workplace to detain individuals suspected of being in the US unlawfully. Audits target paperwork compliance; raids target people.
- ICE raids require a judicial warrant
- I-9 audits require notice of inspection
How to Prepare for an I-9 Audit
- Conduct an Internal I-9 Audit with assistance of immigration counsel (failure to properly conduct an internal I-9 Audit may result in liability should an employer be subject to an I-9 Audit by a government agency)
- Organize your records
- Train your staff to understand retention and procedures for Form I-9
- Do not discriminate
- Prepare to respond within three (3) business days if ICE issues a Notice of Inspection
How to Prepare for a Possible ICE Raid
- Identify a greeter
- Identify an ICE visit manager
- Cooperate and remind the enforcement agents you are cooperating
Supporting Campers and Families
- Know your rights in the workplace
- Know your rights in public vs. at home
Best Practices and Long-Term Readiness
- Create space for staff to learn about possible Customs and Immigration Enforcement activities to share:
- Camp’s Customs and Immigration Enforcement response policy
- Reiterate the visit manager’s role and ability to consent to activities
- Treat Customs and Immigration Enforcement employees like another external visitor
- Ensure foreign national staff and campers are prepared before travel and consider where they are traveling to, if at all.
- Consider a “Don’t Ask, Don’t Tell" policy
- Such as: Camp values its employees and is committed to maintaining a safe, respectful, and inclusive workplace. While all employees have valid I-9 forms on file, Camp does not provide immigration-related support or advice, including for family members. For any immigration concerns, employees should consult a trusted immigration attorney and avoid discussing personal immigration matters at work.
Long-Term Readiness
- Review camp policies annually: Update plans based on current legal guidance.
- Build relationships with immigration attorneys: Ensure someone is on call for urgent legal support.
- Advocate for safe spaces: Collaborate with other youth-serving organizations to protect vulnerable communities.
ICE Operations: FAQs to Help Camps Prepare
Resources
- ACA Recorded Webinar: Navigating Immigration Enforcement Operations (ICE) and Exchange Visitor Visas (J-1) This Summer
- National Immigrant Justice Center
- United We Dream
- American Immigration Lawyers Association
Special thanks to Ken Robinson and Sarah Charlton of Ice Miller LLP for their May 13, 2025, presentation on these important issues.
Photo credit: Sundry Photography / iStock Editorial / Getty Images Plus
The views and opinions expressed by contributors are their own and do not necessarily reflect the views of the American Camp Association or ACA employees.
