On September 19, 2025, the U.S. Department of Labor (DOL) announced the launch of Project Firewall, a new H-1B enforcement initiative. The program is designed to safeguard U.S. workers by strengthening employer compliance, increasing oversight, and coordinating with other federal agencies.
Key Changes
- Secretary-certified investigations: For the first time, the Secretary of Labor will personally certify the initiation of H-1B employer investigations when there is reasonable cause to believe noncompliance exists.
- Stronger enforcement tools: Investigations may result in back wage collection for affected workers, civil monetary penalties, and/or debarment from the H-1B program.
- Interagency coordination: The DOL will collaborate with the Department of Justice, the Equal Employment Opportunity Commission, and U.S. Citizenship and Immigration Services to address discrimination and strengthen enforcement.
What This Means for Employers
- Increased compliance scrutiny: Employers should expect enhanced oversight of their H-1B practices, including possible Secretary-certified investigations.
- Financial and operational risks: Violations could result in repayment of back wages, civil penalties, and potential suspension from the H-1B program.
- Agency collaboration: Federal agencies will share information and coordinate investigations, which may broaden the scope of enforcement actions.
- Proactive compliance recommended: Employers should review their H-1B policies, recordkeeping, and hiring practices to ensure alignment with DOL requirements.
We recommend that employers review their H-1B programs with counsel to minimize compliance risks under this initiative.
For assistance with H1B and DOL compliance under these new rules, please contact our office.
We Are Here to Help
If you would like assistance evaluating your company’s H-1B compliance practices — including review of petitions, wage obligations, or risk of investigation under Project Firewall — please contact the KLF immigration professional with whom you normally work or call us on our main line at (212) 495-9245 or email us at info@klugfirm.com.
Disclaimer: This Client Alert is for general informational purposes only; it does not constitute legal advice. Actual application of laws and policies may vary based on your specific facts.