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Department of Labor Launches “Project Firewall”: What Employers Need to Know

On September 19, 2025, the U.S. Department of Labor (DOL) announced a new enforcement initiative called Project Firewall, targeting compliance in the H-1B program. The initiative aims to strengthen protections for U.S. workers while holding H-1B employers accountable for violations.

Below is an overview of what Project Firewall means, why it matters, and what employers should be doing now, especially during the current government shutdown.

What Is Project Firewall?

Project Firewall is a DOL-led enforcement program designed to:

• Ensure employers prioritize qualified U.S. workers before hiring H-1B workers
• Hold H-1B employers accountable for misusing the program
• Increase oversight and enforcement when there is reason to believe an employer is not complying with H-1B program rules

Under this initiative, the Secretary of Labor can directly certify investigations into employers when there is reasonable cause to suspect violations.

The program also strengthens interagency coordination, bringing together:

• USCIS
• Department of Justice (DOJ)Equal Employment Opportunity Commission (EEOC)
• Department of Homeland Security (DHS)
• Department of Homeland Security (DHS)

These agencies may now share data and insights, making enforcement more coordinated and robust.

What Project Firewall Means for Employers

Employers who violate H-1B regulations may face significant consequences, including:

• Back wage assessments
• Civil monetary penalties
• Temporary debarment from participating in the H-1B program

With increased data sharing across federal agencies, employers should expect broader and more proactive compliance reviews.

Why Project Firewall Matters

This initiative reflects a much stricter approach to H-1B oversight. Employers should take this as a reminder to:

• Review their use of the H-1B program
• Ensure job postings, recruitment, wages, and worksite practices comply with DOL requirements
• Maintain complete and accurate records

Being proactive now can prevent costly penalties later.

Government Shutdown Reminder: A Key Window for Employer Compliance

Because the federal government is currently shut down, the DOL is inactive until funding is restored. This unexpected downtime provides employers with a valuable chance to address internal compliance needs.

Now is an ideal time to:

• Review and update Public Access Files for H-1B workers
• Conduct internal I-9 and E-Verify audits
• Assess broader compliance with employment-based immigration obligations

Preparing now ensures employers are ready when DOL operations resume—and strengthens compliance ahead of any future Project Firewall investigations.

Need help navigating these updates?

Project Firewall raises the stakes for H-1B employers, and staying compliant is more important than ever. Our team can help you review your current practices, strengthen your documentation, and prepare for increased government oversight.
Set up a consultation with the Law Office of Jacqueline Lentini, LLC by calling 630-262-1435 or emailing jacki@lentinivisas.com