After an I-9 audit, the United States Immigration and Customs Enforcement (ICE) found that none of the company's I-9 forms were completed within three business days after the start date of employment as required by the Immigration and Nationality Act. Instead, all 54 of the company's I-9s were completed and signed after management received ICE's audit notification. The company argued that it had substantively complied with the I-9 requirements by retaining all the identifying documents on file, allowing it to prove that all employees were legally permitted to work in the country. ICE disagreed, pointing to federal regulations that expressly indicate the mere copying and retaining of identifying documents does not relieve an employer from its I-9 obligations. ICE issued Buffalo Transportation a civil penalty of over $109,000. Upon review, an Administrative Law Judge reduced the amount to $75,000 after considering the size of the employer and the absence of bad faith. …