Alerts12.2.25

The H-1B Holiday Rush Towards H-1B Enforcement

Visa

Highlights
  • The U.S. Department of Labor (DOL)’s new “Project Firewall” significantly intensifies H-1B enforcement, enabling expanded audits, interagency data sharing, stricter penalties (including debarment), and increased scrutiny of patterns like offsite placements, wage discrepancies, and inconsistent job information.
  • Employers face a heightened year-end compliance push, as the initiative places renewed focus on documentation, accurate filings, and monitoring of third-party placements, with the DOL publishing an H-1B Compliance Assistance Toolkit to guide expectations.
  • Proactive, collaborative compliance is now essential, and employers are urged to conduct regular audits, strengthen internal processes, and work closely with immigration counsel ahead of the FY 2027 H-1B registration season.

With the holidays just around the corner, Project Firewall, a new enforcement initiative launched by the DOL, will ensure H-1B compliance does not take any time off.

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