U.S. Launches “Project Firewall” to Step Up H-1B Visa Enforcement

What Happened?

On September 19, 2025, the U.S. Department of Labor (DOL) announced the launch of Project Firewall, a sweeping enforcement initiative aimed at protecting American workers from abuses of the H-1B program.

“Launching Project Firewall will help us ensure no employers are abusing H-1B visas at the expense of our workforce,” Secretary of Labor Lori Chavez-DeRemer said in a statement. “By rooting out fraud and abuse, the Department of Labor and our federal partners will ensure that highly skilled jobs go to Americans first.”

The move comes amid growing political pressure to tighten oversight of high-skilled immigration. While the launch coincided with President Trump’s proclamation imposing a $100,000 H-1B application fee, the DOL has not confirmed whether the two actions are directly connected or part of a coordinated rollout.

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What Is Project Firewall?

Project Firewall reinforces the DOL’s compliance oversight role in the H-1B program. It enables the following procedures:

• Secretary-certified investigations: For the first time, the Secretary of Labor will personally approve investigations where there is “reasonable cause” to believe an employer violated H-1B rules.
• Types of violations investigated:
  • Wage underpayment or wage theft
  • Displacement of U.S. workers by H-1B hires
  • Fraudulent labor condition applications
  • Misrepresentation of job duties or worksite locations
• Penalties: Employers may face civil fines, payment of back wages to workers, and temporary bans on filing future H-1B petitions.
• Cross-agency coordination: DOL will share data with the Department of Justice, Equal Employment Opportunity Commission, and U.S. Citizenship and Immigration Services (USCIS).

Why Now?

H-1B enforcement has long been a political flashpoint. Under both Republican and Democratic administrations, the DOL has investigated companies accused of exploiting the program. For context, the DOL’s Wage and Hour Division recovered more than $274 million in back wages for over 163,000 workers across all industries in 2023, demonstrating the scope of wage violations nationwide.

For the first time, the secretary of labor will personally sign off on investigations into suspected H-1B violations, an expansion of the department’s role in overseeing the program

Compliance Checklist for Employers

Employers should act now to reduce the risk of being targeted under Project Firewall:

• Ensure labor condition applications (LCAs) are accurate and updated
• Pay H-1B workers the higher of the the prevailing wage or actual wage for the position and location
• Keep documentation of worksite locations and job duties
• Avoid displacement of U.S. workers in similar roles
• Maintain audit-ready records for all H-1B employees

Red Flags That Could Trigger an Investigation

• Sudden layoffs of U.S. workers followed by new H-1B hires
• Significant differences between posted wages and actual pay
• Assigning H-1B workers to client sites not listed on the LCA
• Complaints filed by employees or whistleblowers

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What H-1B Workers Can Do

If you’re currently on an H-1B visa, you may feel vulnerable to how your employer responds to these new rules. Steps you can take:

• Know your rights: You are entitled to be paid the wage listed on your LCA.
• Keep records: Save pay stubs, offer letters, and worksite assignment details.
• Seek help if needed: The Wage and Hour Division operates a toll-free line (1-866-487-9243) for workers to report violations.
• Stay updated: Enforcement may increase processing delays or employer hesitancy to sponsor new visas.