1. Current Immigration Enforcement Climate
Since January of 2025, the immigration enforcement climate has changed very quickly and in dramatic ways. Immigration has been and remains a hot topic and priority focus of the Trump Administration.
Starting on the very first day of his Administration, President Trump began issuing Executive Orders about immigrants and immigration;1 and since January 2025, U.S. Immigration Customs and Enforcement (ICE) interactions have surged as ICE hired over 12,000 new agents and expanded its headcount to over 22,0002 after Congress passed (and President Trump signed) the One Big Beautiful Bill Act (OB3) on on July 4, 2025 that provided $75 billion(over four years) in funding for ICE, including $45 billion (over four years) to be used to detain immigrants, 3 and resulted in ICE becoming the highest-funded U. S. law enforcement agency.4
On June 9, 2026, Congress passed the Secure America Act, which funds ICE and U.S. Customs and Border Protection (CBP) with $69.5 billion dollars through September 30, 2029 (nearly an entire fiscal year of Trump’s successor’s first term after the 2028 election). This funding is in addition to the $170 billion dollars that was allocated for immigration and border enforcement in OB3, which also lasts through September 30, 2029.
With this surge, DHS hiring practices and training standards have changed in ways that have considerably heightened the risks of violence and the disregard for protocols that protect civil rights.5
Enforcement by ICE has become more frequent, more intense, and more violent.6 ICE agents are no longer trained in the manner they used to be, the minimum age for ICE agents is now 18 instead of 21,7 and ICE agents often conceal their identities with masks, plain clothes, and unmarked vehicles.8 According to a January 2026 report published by the American Immigration Council,9 in January 2025, there were approximately 40,000 people held in immigration detention. By the end of December 2025, that number had grown to more than 68,000 people (an almost 75% increase).10 Statistics show that 2025 was the deadliest year for individuals in ICE custody since 2004,11 and outside of ICE detention settings, there have been numerous deaths and injuries resulting from ICE interactions.
These heightened risks are especially challenging for nonprofits that serve children and families, as schools and daycare centers, food pantries and community centers, and social service organizations have increasingly become targets for immigrant enforcement.12 Even organizations with religious purposes and places of worship are targets.13
In the face of this escalated risk, nonprofits — especially those in more urban areas and those serving vulnerable populations — are discovering that they must revisit how they’ve been preparing for interactions with ICE agents.
By understanding the current enforcement landscape and the heightened risks that could impact your nonprofit, preparing a response plan in advance, and shoring up your organization’s I-9 and other compliance efforts, you can help your nonprofit mitigate risk while continuing to focus on the critical work of serving its mission.
- See e.g., Executive Order 14159 “Protecting the American People Against Invasion” (January 20, 2025) [so-called “sanctuary jurisdictions” will not receive access to federal funds]; Executive Order 14160 “Protecting the Meaning and Value of American Citizenship” (January 20, 2025) [challenges birthright citizenship]; Executive Order 14163 “Realigning the United States Refugee Admissions Program” (January 20, 2025) [suspension of the Refugee Admissions Program]; Executive Order 14165 “Securing Our Borders” (January 20, 2025) [physical wall, prevention of entry, detention, removal]; and Executive Order 14218 “Ending Taxpayer Subsidization of Open Borders” (February 19, 2025) [eligibility for federally funded programs].
- See https://www.dhs.gov/news/2026/01/03/ice-announces-historic-120-manpower-increase-thanks-recruitment-campaign-brought
- See https://www.brennancenter.org/our-work/research-reports/how-ices-budget-boom-changing-immigration-detention
- See https://www.npr.org/2026/01/21/nx-s1-5674887/ice-budget-funding-congress-trump
- See https://www.brookings.edu/articles/ice-expansion-has-outpaced-accountability-what-are-the-remedies/; https://www.cnn.com/2026/02/27/us/ice-deportation-officers-training-agents-invs; https://www.theguardian.com/us-news/2026/feb/26/trump-ice-hiring-surge
- See https://www.americanimmigrationcouncil.org/blog/ice-expanding-detention-system/ and https://www.americanimmigrationcouncil.org/fact-sheet/ice-cbp-legal-analysis/
- See https://apnews.com/article/ice-immigration-trump-mass-deportations-border-249268f025baa6920fb4370e8e297049
- See https://www.pbs.org/newshour/show/rise-of-ice-agents-wearing-masks-creates-opportunity-for-imposters-to-conduct-crimes and https://www.npr.org/2025/10/28/nx-s1-5587653/trump-administration-relying-on-unmarked-vehicles-in-immigration-enforcement
- https://www.americanimmigrationcouncil.org/wp-content/uploads/2026/01/immigration-detention-report.pdf
- Ibid.
- https://www.theguardian.com/us-news/ng-t interactive/2026/jan/04/ice-2025-deaths-timeline
- See https://www.nj.com/cumberland/2026/01/ice-detained-people-waiting-at-a-food-pantry-salvation-army-says.html and https://www.pbs.org/newshour/show/they-are-circling-our-schools-superintendent-says-after-5-year-old-detained-by-ice
- See e.g., https://www.wunc.org/2026-01-22/anti-ice-protest-at-minnesota-church-leads-to-3-arrests-but-no-charges-for-a-journalist; https://news.bloomberglaw.com/litigation/ice-blocked-from-immigration-raids-near-some-houses-of-worship
