The Department of Labor (DOL) launched Project Firewall in September 2025. The move is part of a larger effort imposing increased government oversight of the H-1B program. Whether Project Firewall’s introduces permanent change is unclear.

Key Enforcement Features

Project Firewall enables the following:

• The DOL opening cases without complaint.
• Data sharing among the DOL, U.S. Citizenship and Immigration Services (USCIS), the Department of Justice (DOJ), and Equal Employment Opportunity Commission (EEOC) for unified compliance actions.
• Enhanced audits on prevailing wage accuracy, Labor Condition Application (LCA) worksite compliance, and third-party placement integrity.
• Wage orders, civil fines, or debarment from visa programs for employers found in violation.
• Cross-referrals to DOJ or EEOC for discrimination or civil rights violations.
• Unannounced site visits and record audits by the DOL or Fraud Detection and National Security Directorate (FDNS).
• Classifying employers based on likelihood of violation. Factors marking employers as ‘high risk’ include:
  • Misclassified worksites.
  • Emote work inconsistencies.
  • Layoffs followed by H-1B hires, and wage underpayments as ‘high-risk’ indicators.
  • LCA mismatches between approved and actual work locations.
  • Improper wage levels or incomplete Public Access Files.
  • Contractor redeployment without new LCAs or amendments.

Recommended Employer Actions

Taking the following actions gives employers the highest chance of not violating the provisions established by Project Firewall:

• Conduct internal audits of all H-1B cases.
• Verify LCA postings, wage documentation, and worksite accuracy.
• Establish audit and site-visit procedures. Afterwards, train HR and recruiters on these procedures.
• Diversify workforce planning by aggressively recruiting U.S. hires and foreign workers with alternative visas.

How Our Firm Can Help

For consulting firms, proactive compliance and expert legal guidance are now mission critical. We help employers with an immigration firewall through:

• Identifying exposure in LCAs, Public Access Files, and placement contracts before the DOL does.
• Preparing for DOL Investigations, site visits, and audits.
• Informing employers of enforcement trends through our newsletters and real time news postings.
• Managing DOL investigations, negotiating settlements, and defending against debarment.

As always, Immigration USA actively monitors ongoing U.S. immigration news. If you have questions about any U.S. immigration related issue, contact us. Working with an experienced attorney ensures you get the right advice based on the most recent laws. In an ever-evolving immigration policy landscape, we’re with you every step of the way.