Overview

• Project Firewall is now active as a DOL initiative to police employer compliance in the H‑1B program, with probes personally certified by the labor secretary.
• DOL components will coordinate with the DOJ Civil Rights Division, the EEOC, and USCIS, increasing the likelihood of parallel civil inquiries and possible criminal referrals.
• Expected tactics, based on prior practice, include surprise site visits, record audits, and scrutiny of job classifications, wages, worksites, and Public Access Files.
• Consequences for violations can include repayment of back wages, civil monetary penalties, and temporary debarment from the H‑1B program, alongside whistleblower retaliation risks.
• Advisers say stricter enforcement could slow sponsorships and push firms to emphasize U.S. hires, with some reports tying the effort to a proposed $100,000 fee per new H‑1B petition.