For years, ICE focused almost exclusively on the criminal prosecution of employers. Now, as ICE shifts its focus back to civil fines, it's time to dust off OCAHO procedures and case law and review new ICE guidance related to fine assessments to prepare to defend our employer clients against civil penalties. In lieu of criminal prosecution, ICE is also resolving corporate criminal investigations through the use of Non-Prosecution and Deferred Prosecution Agreements ("NPAs" and "DPAs"). The speakers will review OCAHO procedures and leading case law and discuss the nuts and bolts of high profile NPA agreements (Walmart, IFCO and Pilgrim's Pride Corporation).
Josie Gonzalez (DL),
Jeff Joseph,
Richard A. Gump Jr.,
Jay T. Jorgensen,
Ellen K. Thomas