If ICE cannot kill you, it will bury you in debt, so deep it will be hard to climb up from it. And the only way out may be deportation.

For the estimated 350,000 undocumented Filipinos in the US, that debt sentence may arrive in a mass-mailed Notice of Violation Order like the junk mail that piles up in your mailbox together with the credit card offers and pizza coupons — except this envelope contains fines running into the millions.

The Department of Homeland Security (DHS) has reportedly mass-mailed roughly 103,000 of these notices since January 2025, totaling some $84 billion in assessed penalties, at a statutory rate of $998 for every day a person remains in the US after a final removal order. 

Fines per individual often reach $1.8 million, the maximum amount allowed under the five-year federal statute of limitations for civil fines and penalties. As of July 16, DHS has reportedly collected approximately $1.2 million in payments.

Ignore the notice, and your wages can be garnished, your tax refunds seized, and you can be reported to credit bureaus that can quietly wreck a person’s financial life long before any court ever weighs in. 

DHS can also confiscate savings and personal property — homes included — to satisfy the debt. According to The New York Times, a Togo national who was fined $1.3 million had her $10,662 tax refund — she filed jointly with her husband, a US citizen and active-duty service member raising their four US-born children — seized by the government.

Some Pinoy “TNTs” (undocumented) are already self-deporting themselves after receiving this notice of civil monetary penalty rather than continue fighting their case, according to San Francisco-based immigration lawyer Lou Tancinco.

“Others, however, are choosing to fight for their right to remain by filing appeals and invoking their constitutional and statutory protections,” Tancinco said.

Capricious rule-making

Those fighting back are pinning their hopes on Maria L. v. Noem, a federal class action suit filed in the US District Court for the District of Massachusetts by a coalition of legal advocacy groups — the Legal Aid Society, Public Justice, the NYU Immigrant Rights Clinic, the Free Migration Project, and Covington & Burling LLP.

The suit challenges a June 2025 rule that fast-tracked these penalty assessments while stripping away internal appeal rights and cutting response time in half, arguing the mass-fining campaign violates the Eighth Amendment’s ban on excessive fines, the Fifth Amendment’s guarantee of due process, and federal administrative law barring arbitrary and capricious rule-making. 

Tancinco said the fine only holds if someone willfully fail or refuse to depart, and that can be challenged if they were checking in regularly with ICE, physically unable to leave due to illness, pursuing a pending legal path to stay, had filed a motion to reopen, were incarcerated, or had since been granted relief on a U or T visa given to crime victims and trafficking survivors who cooperate with law enforcement.

You can hide, but you can’t run

To receive one of these letters, a person must already have a final removal order or a voluntary departure order on file.

A TNT is not an NPA. A New People’s Army (NPA) cadre survives on having no fixed residence — No Permanent Address (NPA). But a Tago Ng Tago (TNT), though always hiding, is just a mass-mailed Notice of Violation Order away from being found, meaning DHS has an “A-file” with their name, biographic history, and the address of record from their day in immigration court, however many years ago that was.

Where that address has gone stale, DHS can still trace them through the US Postal Service’s national change-of-address database, DMV, and, for a window of several months last year, an unprecedented data-sharing agreement between the IRS and ICE that let agents submit 1.28 million names for cross-verification against tax returns, a pipeline that yielded roughly 47,000 confirmed matches before federal courts intervened and found the arrangement likely unlawful. 

The people receiving these bills, in other words, are not phantoms who slipped through the cracks of American bureaucracy. They are found not because the system finally caught up to them, but because it never really lost track of them at all.

“Paano ko babayaran ’to?,” a Filipino caregiver asked after she was fined $998,000, accrued over nearly three years since a removal order she claims she barely remembers receiving. Her debt is ticking up $998 a day, and could reach $1.8 million if she doesn’t get a reprieve to adjust her status or leave.

She said even if she works her lifetime changing adult diapers and administering medication, the fact that she is paid flat rates well under minimum wage for round-the-clock, on-call labor, the math would never work in her favor. 

“The intended effect of these civil penalty notices appears to be fear – pressuring recipients into making the decision to leave and return to the Philippines,” Tancinco said.

If you leave, you can get barred from reentering the US for 10 years, leaving loved ones for those in mixed-status families, or those living with US citizens.

“It’s hard to give general advice here, since every case is different. It may be worth consulting an immigration attorney to determine whether to stay in the US – or return to the Philippines to live peacefully without fear,” Tancinco said. – Rappler.com

Oscar Quiambao is a former reporter of the The Philippine Daily Inquirer who now lives in San Francisco.