Case Explained: From Worksite To Wire Fraud: A Compliance Wake-Up Call – White Collar Crime, Anti-Corruption & Fraud – Legal Perspective

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.