From Worksite To Wire Fraud: A Compliance Wake-Up Call

Michigan Couple Arrested in Large-Scale Immigration Scheme

In November of 2025, the U.S. Attorney's Office for the Western District of New York announced charges by criminal complaint against a Michigan couple accused of orchestrating a multi-state scheme involving the employment of unauthorized workers, generating approximately $74 million in customer revenue. This case underscores how immigration violations can escalate into criminal liability, including money laundering and conspiracy charges, and offers important compliance lessons for employers. It also serves as a reminder of the increasing cooperation between agencies.

What Happened

According to the U.S. Attorney's Office, the couple operated Orduna Plumbing Inc., employing more than 250 individuals between 2022 and 2024, only six of whom were legally authorized to work in the U.S. Business operations spanned Michigan, New York, North Carolina, and Ohio. Moises Orduna-Rios, President, and Raquel Orduna-Rios, Treasurer and Secretary, were charged by criminal complaint with conspiracy, transporting and harboring unauthorized aliens for commercial advantage or private financial gain, and conspiracy to bring in, harbor, and transport unauthorized aliens.

Federal agents arrested 23 undocumented workers in multiple cities where Orduna Plumbing Inc. operated and uncovered evidence of an ongoing criminal conspiracy. The scheme generated an estimated $74 million in revenue from January 2022 to August 2025, with payments funneled through multiple bank accounts controlled by the defendants.

Why It Matters

This case illustrates how immigration compliance failures can trigger cascading risks leading to criminal prosecution. Just as important, this case underscores that immigration enforcement is not limited to worksite arrests or individual removal actions. Prosecutors are increasingly pursuing employers and company officers where the government alleges a pattern of unlawful hiring tied to profit, expansion, or operational strategy. The investigation also illustrates how coordination across agencies can accelerate exposure, immigration enforcement, federal investigators, and prosecutors can combine resources, share information, and develop parallel financial and immigration theories in the same case.

Because these matters can quickly move from civil compliance issues to criminal and financial exposure, employers should treat immigration controls as part of their broader risk and compliance program.

Practical Takeaways

Although this case represents an extreme example of using unauthorized workers for financial gain, employers should take proactive steps to ensure compliance:

• Conduct I-9 Audits. While not required by law, employers should periodically review Forms I-9 to ensure ongoing compliance with federal immigration requirements. Employers should consider conducting a review in conjunction with counsel. A well-structured audit begins with defining its purpose and scope, deciding whether to review all forms or a sample, and avoiding any appearance of discrimination or retaliation. Employers should also be looking at electronically created Forms I-9 in order to ensure vendor systems meet the regulatory requirements. Employers should apply consistent standards when addressing deficiencies. Corrections must be made properly, and explanations should be attached for any changes. Employers should also consider the operational challenges associated with audits as they would reveal action items that could affect the workforce, including identification of identity and fraud issues.
• Strengthen Employment Eligibility and Onboarding Checks. A strong onboarding process is your first line of defense. Consider best practices including using E-Verify, training HR teams to recognize fraudulent documents as well as uncommon acceptable documents, and standardizing procedures for collecting and storing work authorization records. Ensure all Form I-9 sections are completed accurately and on time, and never accept photocopies (unless in the virtual I-9 context) or incomplete documentation. Where applicable consider badging processes to ensure identity is verified onsite.
• Add Vendor/Subcontractor Guardrails (for employers and staffing firms). Whether you are the worksite employer or the staffing provider, use contracts and procedures that clearly allocate responsibility for I-9 completion/retention, reverification, and cooperation in the event of an investigation (including audit rights and documentation standards). This helps reduce "willful blindness" risk and limits downstream exposure if an investigation expands across the labor supply chain.
• Have a Government Inquiry Response Plan. Because these cases can involve coordinated activity across agencies, and expand into financial and conspiracy theories, employers should have a designated response team (HR, in-house/legal, and where appropriate white-collar counsel), a protocol for subpoenas/warrants/agent visits, and a document preservation plan to avoid missteps that can compound liability. This is especially important given the recent surfacing of the DHS memo asserting officers may enter a person's residence to execute a removal arrest based on an administrative Form I-205, an approach likely to be litigated, but one that underscores why employers must know how to respond when agents present non-judicial paperwork
• Implement Training. Educate managers, supervisors, and HR personnel on immigration compliance obligations, fraud awareness, anti-discrimination rules, and proper handling of Form I-9.

Matters like these—where immigration compliance issues can quickly escalate into criminal, financial, and multi‑agency exposure—sit at the intersection of two of Seyfarth's core strengths. Our Immigration Compliance and Enforcement team partners closely with our White Collar Defense & Investigations team to deliver integrated guidance across the full spectrum of risk. Together, we help clients strengthen compliance programs, respond to government inquiries, and navigate parallel civil and criminal investigations. This coordinated approach ensures employers receive comprehensive, practical support aligned with both compliance obligations and enforcement realities. If you have questions or need assistance, please feel free to reach out to our teams.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.