Site visits, wage audits and per-violation fines are all climbing. For in-house counsel at companies sponsoring dozens or hundreds of employees, waiting for HR to escalate is no longer a strategy.

It usually starts with a forwarded email. A USCIS officer arrived unannounced to ask about an H-1B employee's job duties. A Department of Labor audit letter landed. A buyer's diligence team wants to know why the target's I-9s don't reconcile.

For many general counsel, that email is their first close look at the company's immigration program. People Ops runs it day to day, often alongside an outside firm. Legal owns the consequences. As programs grow and enforcement intensifies, that gap is where companies get hurt.

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