New regulations on Social Security No-Match letters

Immigrations & Customs Enforcement (ICE) just published new final regulations related to employer obligations when receiving "no-match letters" from the Social Security Administration. The real issue here is, of course, not social security taxes. The real issue is the employer's obligation to determine whether it is only employing persons lawfully entitled to work in the United States - i.e. I-9 compliance.

Basically, the regulations provide a safe-harbor for employers. The employer will be protected from sanctions, if it exercises due diligence to promptly re-verify an employee's information and does not otherwise know that the employee lacks work authorization.

More to follow, once I have digested the full set of regulations.