Trump Transition Picks Likely to Impact Immigration Enforcement

President-elect Trump tapped Tom Homan as Immigration Czar in an effort to accelerate immigration enforcement. Homan’s appointment is part of a broader effort, alongside several other nominations, to prioritize the southern border and stem illegal immigration.

Homan ran Immigration and Customs Enforcement in an acting capacity in the first Trump Administration from 2017 to 2018, where he took a hard line on deportations. Prior, he ran the agency’s enforcement and removal operations under President Obama from 2013 to 2017. 

Workplace raids: Homan announced a return of “workplace immigration raids” sparking concern for employers in the poultry, agriculture, construction, hospitality and service industries. 

• Raids last ramped up in 2008 under the Bush administration and again in 2019 during Trump’s initial term. 

• Employers should review their employment verification processes and compliance in anticipation of greater enforcement in 2025.

Trump also selected Stephen Miller as his deputy chief of staff for policy and homeland security advisor and Governor Kristi Noem, as Secretary of the Department of Homeland Security. Both are known as an immigration hawks.

• Miller was the architect of the immigration polices in Trump’s first term, and since has been challenging DEI-related policies as president of America First Legal. 

• The combined nomination and appointments of Governor Noem, Tom Homan, and Stephen Miller reinforce the President-elect’s focus on immigration as a top priority.

The bottom line: Access to labor will likely be constrained by the revival of previous Trump administration policies that prohibited the entry of certain asylum-seekers and persons who potentially pose a health risk. If pursued again, such policies could grind immigration operations to a halt due to the complexity of implementation.