Project Firewall: DOL’s New H-1B Enforcement Initiative

On September 19, 2025, the U.S. Department of Labor (DOL) rolled out Project Firewall. It is a bold new enforcement initiative designed to crack down on fraud, wage abuse, and misuse of the H-1B visa program.

This comes right on the heels of the Presidential Proclamation imposing a $100,000 filing fee on new H-1B petitions. Together, these moves make one thing crystal clear: the federal government is getting serious about reshaping the H-1B landscape and putting U.S. workers first.

What Is Project Firewall?

For the first time in the history of the H-1B program, we’re seeing enforcement at this level of visibility and coordination:

• Direct Oversight – The Secretary of Labor will personally sign off on all H-1B investigations.

• Interagency Teamwork – DOL will now share data and coordinate enforcement with USCIS, DOJ, and EEOC.

• Real Consequences – Violators could face hefty back wage orders, steep civil fines, and even debarment from the H-1B program.

Why Employers Should Pay Attention

The compliance bar just got higher. Employers need to be ready for:

• More investigations into Labor Condition Applications (LCAs).

• Increased scrutiny of wages, job duties, and worksites.

• Stronger penalties for non-compliance.

• Cross-agency enforcement, meaning issues may not stop with the DOL.

In short: if you’re cutting corners on H-1B compliance, Project Firewall will likely find you.

VKM Guidance for Employers

This is the moment to get ahead of enforcement. Employers should:

• Double-check LCA postings and maintain complete public access files.

• Audit wage and hour practices for H-1B employees.

• Ensure job descriptions align with specialty occupation rules.

• Get proactive legal advice to minimize risks before investigators come knocking.

FAQ: Project Firewall & H-1B Compliance

Does Project Firewall change the petition process?
No. Filing procedures stay the same but oversight and enforcement have dramatically increased.

Who can be investigated?
Any employer with H-1B workers. If there’s suspicion of fraud, wage violations, or abuse, you’re on the radar.

What penalties are possible?
Back wages, civil fines, and debarment from the H-1B program.

How does this connect to the $100,000 H-1B filing fee?
The Proclamation sets a higher financial threshold for new petitions. Project Firewall enforces compliance obligations already in place. Together, they reshape how H-1B is used in the U.S.

👉 Bottom line: If you employ H-1B workers, now is the time to tighten compliance. Project Firewall is here, and enforcement is no longer business as usual.