By Sang M. Shin 

On Thursday, September 4, 2025, a large-scale immigration enforcement operation took place at the construction site of a Hyundai and LG Energy Solution battery plant in Ellabell, Georgia. This site, adjacent to Hyundai’s electric vehicle manufacturing facility, is one of the state’s largest and most high-profile industrial projects, employing approximately 1,400 people and expected to create thousands more jobs in the coming years.

Details of the Raid

The operation was led by agents from U.S. Immigration and Customs Enforcement (ICE), Homeland Security Investigations (HSI), and several other federal agencies, including the FBI, DEA, ATF, and the Georgia State Patrol. The agencies executed a judicial search warrant as part of an investigation into alleged unlawful employment practices and other serious federal violations.

The raid resulted in the arrest of approximately 475 individuals, most of whom were South Korean nationals. This marks the largest single-site enforcement operation in HSI history and is a significant example of the Trump administration’s ongoing crackdown on immigration violations at workplaces across the United States.

Ensuring Compliance and Readiness

The unprecedented multi-agency worksite operation carried out at the Hyundai–LG Energy Solution battery plant construction site offers a stark reminder that U.S. immigration and labor regulators are intensifying scrutiny of large, high-profile projects—particularly those that rely on significant numbers of foreign national workers. With 475 arrests (predominantly South Korean nationals) and an immediate work stoppage, the raid stands as the largest single-site action in HSI history and signals that enforcement priorities remain firmly fixed on the intersection of immigration, national security, and critical-infrastructure investment.

Although the facts surrounding the warrant and the underlying allegations have yet to be fleshed out, several lessons emerge. First, federal investigators will not hesitate to converge on a jobsite—regardless of a project’s economic significance—if they suspect unauthorized employment, misclassification, visa fraud, or other federal crimes. Second, immigration enforcement actions ripple far beyond the worksite: construction schedules derail, contractual milestones are missed, insurance and finance covenants are triggered, and diplomatic relations become strained. Third, leadership teams that wait for an ICE audit or an HSI raid to evaluate their compliance programs could expose shareholders and stakeholders to avoidable civil liabilities, criminal exposure, and reputational damage.

Doing things the right way is no longer a best practice; it is an operational necessity. U.S. law imposes strict liability on employers that knowingly—or through constructive knowledge—employ unauthorized workers. Contractors, subcontractors, and staffing agencies are equally vulnerable under joint-employment and agency theories, meaning that a single weak link in a project’s labor supply chain can place the entire enterprise in jeopardy.

Foreign companies investing in the United States must therefore embed immigration compliance into every stage of the project lifecycle. Before ground is broken, master services agreements should address adequate immigration compliance procedures. When working with foreign nationals, confirm that their visa category (e.g., H-2B, H-1B, L-1, E-2, B-1 in lieu of H-1B) matches the actual job duties and that any third-country nationals have obtained proper work authorization. On the back end, exit procedures should preserve evidence demonstrating continuous good-faith compliance.

Because the legal landscape evolves rapidly, proactive engagement with immigration counsel is critical. Counsel can identify overlooked red flags and create privilege-protected remedial action plans. They can also prepare incident-response protocols so that, in the event of a visit from ICE, HSI, or another government agency, personnel know how to preserve documents, manage interviews, and minimize operational disruption. Compliance training should extend beyond human-resources staff to site supervisors, security personnel, and executive leadership, each of whom may be approached by agents executing a warrant.

The Hyundai–LG incident likewise illustrates that enforcement actions carry geopolitical consequences. Host governments may lodge diplomatic protests, while shareholders question whether aggressive U.S. enforcement chills foreign direct investment. Companies that demonstrate a rigorously documented compliance posture may be better positioned to obtain favorable consideration under prosecutorial guidelines that weigh corporate culture and remedial efforts.

The Ellabell raid is a powerful reminder that doing things the right way—before federal agents arrive—protects projects, profits, and people. By investing in robust, auditable immigration-compliance frameworks today, foreign companies can safeguard their U.S. operations, shield themselves from liability, and sustain the trust of regulators, employees, and the communities in which they operate.

If you or your company are involved in large-scale projects, either as a vendor or prime contractor, or even if your company is the project owner, and you employ foreign nationals, it is crucial to review your compliance with U.S. immigration and labor laws. Consult with an immigration attorney to ensure all workers have proper authorization and to prepare for potential audits or enforcement actions. Staying informed and proactive is the best way to protect your interests and those of your employees.