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Section 274A(b) of the Immigration and Nationality Act imposes an obligation on employers to verify that their employees are legally authorized to work in the United States. 8 U.S.C. § 1324a(b). Regulations designate the Employment Eligibility Verification Form (“1-9 Form”) for this purpose, 8 C.F.R. § 274a.2(a)(2), and employers must retain these forms and provide them for inspection upon three days’ notice. 8 C.F.R. § 274a.2(b)(2)(ii). This case arises out of the results of one such inspection in which Immigration and Customs Enforcement (“ICE”) discovered violations of the verification requirements of § 1324a(b).

Ketchikan Drywall Services, Inc. (“KDS”) petitions for review from the summary decision of an Administrative Law Judge (“ALJ”) in favor of ICE on 225 out of 271 alleged violations of § 1324a(b) and the resulting civil penalty of $173,250.00. KDS argues that it substantially complied with the requirements of the statute, that the ALJ improperly refused to consider certain documents, and that the penalty was improperly calculated. We have jurisdiction under 8 U.S.C. § 1324a(e)(8) and deny the petition.

I.

KDS is a drywall installation company incorporated in…