As a reminder for all employers considering sponsoring an employee via the H-1B Visa Program, the U.S. Department of Labor (DOL) has launched Project Firewall, an enforcement initiative designed to strengthen oversight and prevent misuse of the H-1B process.

What is Project Firewall? Project Firewall shifts enforcement from complaint-based investigations to proactive audits. For the first time, the Secretary of Labor can personally certify investigations based on “reasonable cause,” even without a formal complaint.

• The program focuses on wage compliance, proper recruitment practices, and accurate documentation.

Why It Matters: Employers across industries rely on H-1B talent, but under Project Firewall, compliance will be aggressively enforced.

• Violations can lead to back wage payments, civil penalties, public disclosure, and even debarment from the H-1B program.

• Multiple agencies will collaborate with the DOL to ensure compliance (including USCIS, DOJ, EEOC, and DHS).

Key Risks for Employers:

• Financial: New supplemental fees and potential penalties.
• Operational: Loss of access to global talent if debarred.
• Reputational: Publicized violations can harm credibility.

Action Steps to Stay Compliant:

• Monitor Updates: Stay informed on regulatory changes and DOL guidance.
• Communicate with H-1B Staff: Keep employees aware of new rules and implications.
• Verify Wage Compliance: Pay the higher of the prevailing wage or actual company wage.
• Maintain Accurate Records: Keep complete Public Access Files, certified LCAs, and proof of notice postings.
• Engage Legal Counsel: Work with immigration attorneys to review records and develop compliance strategies.

For additional information:

• DOL Press Release (09/19/2025) – Project Firewall

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