From Benefits to Badges: The New Face of USCIS
When Congress dismantled Immigration and Naturalization Services (“the INS”) after 9/11, it made a deliberate choice: separate “benefits” from “enforcement.”
CBP was tasked with border inspections,
ICE was assigned to interior enforcement,
USCIS was designed to adjudicate applications for visas, green cards, and naturalization.
That separation was intentional. USCIS was meant to be a service agency — a place where families, businesses, and individuals could apply for lawful immigration benefits without fearing the very same office was also an enforcement arm. Starting October 6, 2025, that picture begins to change.
W.A.T.C.H.
The help employers, HR teams, and business leaders keep track of these changes, we’ve organized the key takeaways into a simple framework: WATCH.
Why it Matters
A New Movement
Takeaways for Business
Compliance Steps
Horizon: What Comes Next
Each piece represents a part of the bigger picture – and together, they show how the face of USCIS is changing and what that means for those who rely on it.
Why It Matters
This development doesn’t exist in isolation. It is part of a larger trend reshaping immigration enforcement.
ICE Expansion: DHS is actively hiring to expand ICE’s footprint.
USCIS Retooling: With its new agents, USCIS is shifting away from a purely service-first mission.
Judicial Signals: Recent court rulings have widened discretion for immigration enforcement actions, raising the stakes for individuals and employers.
Together, these movements suggest a structural shift: immigration benefits and enforcement are no longer neatly separated.
A New Movement
Think of the immigration system like a watch. For years, the face displayed USCIS as a benefits agency, while the gears of enforcement turned separately in ICE and CBP. Now, DHS has rewired those gears: USCIS will deploy its own cadre of federal “special agents” (1,811 officers), with powers to:
Carry firearms
Execute search and arrest warrants
Arrest and detain individuals
Release on bond or other conditions
The watch still keeps time — but the face looks different. What was once purely a benefits agency now shows the hands of enforcement as well.
Takeaways for Business
Employers, HR teams, and compliance officers should take note.
Worksite audits may involve in-person inspections with armed agents, not just desk reviews.
Filing errors could create risks beyond simple denials.
Employees — both citizens and noncitizens — may experience greater scrutiny in certain industries and workplaces.
For businesses, this means immigration compliance is no longer just paperwork. It has become part of a broader enforcement environment.
Compliance Steps
Companies will need to be more proactive than ever to keep pace with these changes:
Review compliance procedures to ensure accuracy and completeness.
Document employment and sponsorship processes meticulously.
Train HR and managers on what to do if enforcement arrives on-site.
Seek professional legal guidance to anticipate risks before they arise.
Horizon: What Comes Next?
The immigration system has always required balance — service on one side, security on the other. With USCIS’s new enforcement authority, this is shifting. Businesses, families, and individuals will need to watch more closely as the gears of immigration policy turn.
The watch is still running — but its face has changed.
Further Information & Guidance
If you’re an individual or employer with questions about these new developments, contact us for further information.
