DOL Launches “Project Firewall” to Enforce H-1B Compliance

The U.S. Department of Labor (DOL) has announced Project Firewall, a new enforcement initiative aimed at protecting American workers and holding employers accountable for H-1B visa misuse.

Key Highlights:

• Secretary-Certified Investigations: For the first time in DOL history, the Secretary of Labor will personally certify the initiation of H-1B investigations when there is “reasonable cause” to suspect non-compliance.

• Enforcement Scope: Employers found in violation could face back wage collections, civil money penalties, and even temporary bans from using the H-1B program.

• Agency Partnerships: Project Firewall will coordinate across multiple agencies—including DOJ’s Civil Rights Division, the EEOC, and USCIS—to share information and combat discrimination.

• Compliance Focus: The Wage and Hour Division, Employment and Training Administration, and Office of Immigration Policy will jointly lead the initiative.

What’s Unclear:

• DOL has not specified what criteria or metrics will trigger a Secretary-certified investigation.

• The definition of “reasonable cause” remains broad, leaving uncertainty for employers on how investigations may begin.

Why It Matters:

This is a historic expansion of H-1B oversight. Employers using the H-1B program should expect heightened scrutiny and ensure strict compliance with wage, recruitment, and documentation requirements.

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👉 PERM Takeaway: While this initiative is focused on H-1B, it underscores a broader federal push for accountability in immigration programs. Employers navigating the PERM labor certification process should anticipate closer DOL oversight, keep meticulous records, and partner with experienced compliance teams to avoid costly setbacks.