There are 12 steps all employers should take in 2012 to comply with the multitude of immigration laws and to avoid monetary and criminal penalties. These steps include: conduct an annual I-9 audit; incorporate immigration policies in handbooks; audit H-1B public access files; properly withdraw H-1Bs; implement hiring practices that avoid discrimination claims; and abide by E-verify. Someone other than the person responsible for completing I-9s should conduct the I-9 audit to avoid repeating the same errors. The remaining steps include: do not ignore SSN No Match letters; implement export control practices; avoid taking a hands-off approach; avoid passing immigration fees onto employees; utilize contract employees properly; and budget time and expenditures for immigration.