CALJ Invites Amicus Briefs on Date of Assessment for INA §274A Violations

In connection with a remand from the Chief Administrative Hearing Officer (CAHO), the Chief Administrative Law Judge (CALJ) invites amicus briefs on the question of when an employer is liable for INA §274A violations that occurred after 11/2/15, what date of assessment should be used to calculate the inflation-adjusted penalty ranges. See 28 CFR §85.5; 28 CFR §68.52(c)(8); 28 CFR §85.1. Briefs are due by 8/10/23.