Project Firewall To Focus on H1 Compliance

There have been reports of site visits targeting certain metropolitan areas. All employers should assume that a site visit is possible, regardless of location or company size.

The U.S. Department of Labor recently announced the launching of Project Firewall, an H-1B initiative focusing on enforcement and compliance. The DOL’s announcement declared that “[t]he department, including the Wage and Hour Division, will use all available tools to hold employers accountable when they abuse the H-1B visa process to hire foreign workers instead of qualified U.S. workers.”

A central feature of Project Firewall is an expected rise in both random and targeted worksite inspections. These visits are designed to verify that employers are adhering to the terms of approved H1B petitions and their associated Labor Condition Applications (LCAs). Advance preparation remains the most effective way to reduce risk during a site visit. Noncompliance can lead to petition denials or revocations, civil penalties, and, in serious cases, debarment from participation in immigration programs.

Site visits would most likely be done by either the DOL or USCIS. In a DOL visit, employers could expect an audit of wage and payroll records, the Public Access File (PAF), and compliance with all four LCA attestations. With USCIS, a visit may be more likely to focus on verifying the employee’s job duties, salary, work location, and qualifications against the approved petition, and confirming the existence and nature of the employer’s business. These visits can happen unannounced, so it is best to be pre- pared ahead of time for the possibility of an audit.

Efforts to denaturalize foreign-born citizens

The Trump administration is dramatically expand- ing an effort to revoke U.S. citizenship for foreign-born Americans. Over the past several months, USCIS has been sending experts to its offices around the country or reas- signing staff members to focus on whether some citizens processed through those offices could now be denaturalized. The effort is part of the overall push by Homeland Security to drastically curtail immigration. The goal of emphasizing naturalized citizens is to supply the office of immigration litigation with 100 to 200 possible cases per month, one of the people familiar with the plans said. The Justice Department has already told attorneys to focus on denaturalization cases, and it has offered possible case examples, from “individuals who pose a risk to national security” or who have engaged in war crimes or torture to people who have committed Medicaid or Medicare fraud or have otherwise defrauded the government. There is also a broad catch-all provision that refers to “any other cases . . . that the division determines to be sufficiently important to pursue.”

Foreign-born Americans were generally stripped of citizenship only if they were found to have committed fraud during their application processes. In past decades, those cases focused on former Nazis who fled to the U.S. after World War II under false pretenses. Both Democratic and Republican administrations have sought to increase investigations, but it’s still rare for a reason, a former USCIS official said. The denaturalization process is lengthy and time-consuming, and there is a high legal bar. Even if the administration makes the push to investigate someone with the aim to denaturalize, it could take years, and a subsequent deportation would take even longer.

Visa Bulletin for March 2026 is available on our website. Please go to http://www.khabar.com/magazine/ immigration/

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