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H1B

DOL Project Firewall Expands H-1B Enforcement with 175+ Investigations

Since September 2025, Project Firewall has led to at least 175 H-1B investigations with secretary-certified cases. Focus areas include wage underpayment, worker displacement, misrepresented worksites and questionable LCA filings. Interagency data-sharing with DOJ, EEOC and USCIS raises audit risks. Possible penalties include fines, back wages and debarment. Employers should review LCAs and remote-work records; affected workers may receive back pay or face immigration consequences.

Last updated: November 7, 2025 10:34 pm
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Key takeaways
Department of Labor opened at least 175 active H-1B investigations under Project Firewall since September 2025.
Secretary Lori Chavez-DeRemer is personally certifying certain cases where there is “reasonable cause” of violations.
Investigations target wage underpayment, U.S. worker displacement, misrepresented worksites and questionable LCA filings.

The U.S. Department of Labor has opened at least 175 ongoing investigations into potential abuses of the H-1B visa program, part of a stepped-up enforcement push known as Project Firewall that began in September 2025. The effort targets employers suspected of breaking H-1B rules, with the stated aim of protecting American jobs while still allowing companies to hire foreign workers in specialty roles when truly needed. Officials say the investigations are active nationwide and will continue as the initiative expands.

What Project Firewall changes

DOL Project Firewall Expands H-1B Enforcement with 175+ Investigations
DOL Project Firewall Expands H-1B Enforcement with 175+ Investigations

Project Firewall marks a shift in both tone and tools. For the first time, the Secretary of Labor, Lori Chavez-DeRemer, is personally certifying certain cases where the department believes there is “reasonable cause” to suspect violations. That secretary-certified process gives senior-level backing to deeper probes and signals tougher oversight of companies that rely on H-1B workers.

While the department has long enforced wage and posting rules tied to H-1B hiring, the direct certification by the Secretary underscores the priority placed on these cases under the current policy push.

Key concerns being investigated

Investigators are focusing on several familiar issues in the H-1B space:

  • Wage underpayment
  • Displacement of U.S. workers
  • Questionable filings of labor condition applications (LCAs)

They are reviewing situations where job duties or worksite locations appear misrepresented, including arrangements that involve offsite or remote assignments. According to analysis by VisaVerge.com, the scope of these H-1B visa investigations is expected to widen as more tips arrive and as agencies share data across systems.

Interagency coordination

Project Firewall broadens the DOL’s coordination with other federal agencies:

  • Working with the Department of Justice’s Civil Rights Division
  • Coordinating with the Equal Employment Opportunity Commission (EEOC)
  • Sharing information with U.S. Citizenship and Immigration Services (USCIS)

Data-sharing and joint case reviews can reveal patterns of fraud, discrimination, or evasion. Officials can compare visa filings to payroll and worksite records, increasing the chance that inconsistencies trigger interviews, audits, or formal findings.

Project Firewall: H‑1B Enforcement Timeline
Key milestones and actions since the launch in September 2025
SEP 2025
🛡️

Project Firewall Launched

Policy change

The U.S. Department of Labor (DOL) launches an enhanced H‑1B enforcement initiative to protect U.S. jobs while preserving specialty hiring where needed.

SEP 2025
📝

Secretary Case Certification Begins

Enforcement tool

Secretary Lori Chavez‑DeRemer personally certifies select cases with “reasonable cause,” enabling deeper probes and signaling tougher oversight.

SEP 2025
💵

$100,000 One‑Time Fee on New H‑1B Petitions

Fee change

A presidential proclamation adds a $100,000 one‑time fee intended to tighten oversight and raise costs for high‑volume filers.

SEP 2025–PRESENT
🔎

175+ Active H‑1B Investigations

Enforcement

DOL opens at least 175 investigations nationwide targeting wage underpayment, U.S. worker displacement, misrepresented worksites, and questionable LCA filings.

SEP 2025–PRESENT
🤝

Interagency Coordination Intensifies

Coordination

DOL coordinates with DOJ’s Civil Rights Division, the EEOC, and USCIS to compare filings with payroll and worksite records, surfacing inconsistencies.

SEP 2025–PRESENT
📌

Focus on Remote/Hybrid Posting & Wage Location

Compliance focus

Employers must post LCAs at all relevant locations (client sites and qualifying home offices), keep records of job/location changes, and ensure wages match the actual worksite.

SEP 2025–PRESENT
📂

Expanded Document Requests and Audits

Audit

Investigators request payroll records, LCA postings, and assignment/worksite details. Mismatches with visa filings can trigger formal charges; layered vendors face closer scrutiny.

NOW
✅

Employer Action Checklist

Guidance

Audit LCAs, verify wage levels, update job descriptions, document remote/hybrid worksites, and ensure records are producible on short notice.

COMING MONTHS
📣

Expected Case Outcomes

Outcomes

Likely results include settlements, back‑wage payments to workers, and public debarment notices. No formal end date announced for the first wave of cases.

ONGOING
👥

Impact on H‑1B Workers

Informational

Enforcement may secure back wages for underpaid workers. If assignments end or employers are debarred, some workers could face status decisions. DOJ/EEOC coordination also targets discrimination.

Important / Policy / Fee Enforcement / Pending Approvals / Outcomes Informational / Coordination

Possible penalties and enforcement focus

The penalties under review are not new, but the department is putting more weight behind them:

  • Civil fines
  • Orders to pay back wages
  • Debarment from filing new H-1B petitions for a set period

Back pay is central in wage cases, and debarment can significantly limit a company’s future hiring plans. The department intends to test compliance in areas that have drawn criticism in past years, including:

  • Proper wage levels
  • Accurate job descriptions
  • Timely posting of LCAs at all relevant worksites (including remote and hybrid locations)

Officials emphasize employer responsibility to account for remote and hybrid worksites as work patterns have shifted across many sectors.

How investigations proceed and what documents may be requested

Investigators have authority to request:

  • Payroll records
  • LCA postings
  • Assignment details showing actual work locations

If documents do not match the facts submitted during visa filings, they can form the basis for formal charges. Employers using layers of vendors or staffing firms may face closer scrutiny—particularly when the true worksite or supervision structure is unclear. This is why accurate LCAs and transparent job descriptions are critical.

⚠️ Important
Misrepresenting job duties or worksite locations can trigger secretary-certified investigations and debarment. Ensure all filings reflect true conditions and maintain transparent records.

Impact on H-1B workers

H-1B visa holders may be directly affected by the probes in several ways:

  • Enforcement can help foreign workers who were underpaid by pushing employers to provide back wages.
  • If a company faces debarment or ends assignments during an investigation, some H-1B workers could face difficult choices about their immigration status and next steps.

The department’s coordination with the DOJ and EEOC is also aimed, in part, at spotting discrimination during investigations.

Remote work and posting requirements

The department stresses that employers must:

  • Ensure LCA postings are made at all relevant locations, including client sites and home offices where required
  • Keep clear records of any changes to job locations and duties
  • Confirm wage levels match actual work locations when roles shift

VisaVerge.com reports many employers are reviewing internal checklists and compliance procedures under Project Firewall to reduce audit risk.

Broader policy implications and reactions

Project Firewall reflects a broader policy theme of closer oversight:

  • Backers say the H-1B visa remains a legal path for companies that can’t find qualified domestic candidates, but it must not erode wages or displace U.S. workers.
  • Critics will likely view the investigations as a needed correction after years of complaints about wage tiers and loopholes.
  • Business groups may argue that sweeping probes and higher costs could slow hiring and projects, especially in industries that depend on specialized talent.

The department notes the initiative coincided with a presidential proclamation that added a $100,000 one-time fee on new H-1B petitions, intended to tighten oversight and raise costs for high-volume filers. The combination of higher fees, secretary-certified cases, and expanded audits signals that compliance stakes have grown.

Where to find baseline rules

For a federal overview of H-1B specialty occupations and program conditions, see the USCIS: H-1B Specialty Occupations guidance on wage obligations and petition procedures:

  • USCIS: H-1B Specialty Occupations

Reading that background alongside actions announced since September 2025 shows enforcement shifting from guidance to deeper field checks.

Likely outcomes and near-term steps

As Project Firewall cases progress, likely outcomes include:

  • Settlements
  • Payments to workers (back wages)
  • Public notices when companies are debarred

The department has not released a timeline for concluding the first wave of cases; formal decisions may take months. In the meantime:

  • Employers are urged to review job descriptions, confirm worksite addresses, and ensure records are producible on short notice.
  • Workers who believe they were underpaid or misled should expect investigators to look for patterns across related complaints, not just isolated reports.

The launch of Project Firewall in September 2025, paired with the at least 175 active investigations, sets a tougher baseline for the H-1B program. Federal officials are seeking stronger proof that H-1B hiring meets legal standards, that wages match promises, and that foreign hiring is used when truly needed — not as a shortcut at the expense of U.S. workers.

Frequently Asked Questions

Q1
What is Project Firewall and when did it start?
Project Firewall is the Department of Labor’s enhanced enforcement initiative targeting H-1B abuses. It began in September 2025 and has at least 175 active investigations nationwide.

Q2
Which issues are investigators focusing on under Project Firewall?
Investigators prioritize wage underpayment, displacement of U.S. workers, questionable LCA filings and misrepresented worksites, including offsite or remote assignments.

Q3
How might these investigations affect employers and what should they do now?
Employers may face fines, back wages or debarment. They should immediately audit LCAs, verify wage levels, update job descriptions and document remote/hybrid work locations.

Q4
What options do H-1B workers have if they were underpaid or misled?
Workers should preserve payroll records, LCA postings and assignment documents, report concerns to investigators or seek legal advice; they may be eligible for back wages if violations are found.

VisaVerge.com
Learn Today
H-1B → A U.S. nonimmigrant visa for foreign workers in specialty occupations requiring specialized knowledge or a degree.
LCA (Labor Condition Application) → A form employers file attesting to wage levels and worksite postings required for H-1B petitions.
Debarment → A penalty preventing an employer from filing new H-1B petitions for a set period due to violations.
Back wages → Payment ordered to compensate workers for wages they were underpaid during the period of violation.

This Article in a Nutshell

Project Firewall, launched September 2025, has prompted at least 175 DOL investigations into alleged H-1B abuses. Secretary Lori Chavez-DeRemer is certifying cases, signaling stricter enforcement focused on wage underpayment, displacement of U.S. workers, misrepresented worksites and dubious LCA filings. The DOL is coordinating with DOJ, EEOC and USCIS to cross-check payroll, filings and locations. Penalties may include fines, back wages and debarment. Employers should audit LCAs, job descriptions and remote-work records; workers may gain back wages or face status uncertainty.

— VisaVerge.com
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