September 19, 2025, the U.S. Department of Labor (DOL) announced Project Firewall, a sweeping initiative to strengthen oversight of the H-1B visa program.

Under this new framework:

The Secretary of Labor can personally certify investigations when there’s “reasonable cause” to suspect noncompliance.
DOL will partner more closely with USCIS, DOJ, EEOC, and other agencies, coordinating findings and enforcement actions.
Audits will become more frequent and proactive, initiated even without a formal complaint.

In short: this marks a shift from reactive enforcement to active, preventive oversight.

Why It Matters Now for Employers

1. Stiffer Penalties for Noncompliance

Employers found in violation of H-1B program rules may face:

Civil monetary fines

In other words: even relatively small missteps in paperwork, wage disparities, or posting rules could trigger serious consequences.

2. $100,000 Fee on New Petitions

Simultaneous with Project Firewall, a Presidential Proclamation now mandates a $100,000 supplemental payment for new H-1B petitions filed after September 21, 2025 (though not for existing visas or renewals).

This fee is aimed at deterring misuse of the visa program.

3. Higher Risk of Cross-Agency Scrutiny

Because DOL is sharing data and coordinating with other federal offices, employers may face multi-agency audits — e.g. USCIS immigration reviews, DOJ civil rights probes, or EEOC discrimination checks.

4. Focused on Wage & Documentation Compliance

Project Firewall places particular emphasis on:

What Employers (Especially in Travel / Aviation B2B) Must Do

Conduct an Internal Compliance Audit

Review all your H-1B files, especially:

Implement Standardized Practices

Train HR, Managers & Compliance Teams

Everyone handling visa or overseas hiring must:

Prepare for Government Inquiries

Revisit Business Strategy

Takeaway for B2B Travel & Aviation Stakeholders

Though Project Firewall is focused on the U.S. H-1B visa domain, its ripple effects influence global talent sourcing, vendor contracts, and compliance risk frameworks—especially in travel, aviation, and related services.

If your company depends (even indirectly) on H-1B–sponsored staff (e.g. IT teams, analytics, customer support, contract staff in aviation tech), now is the moment to get ahead. A proactive compliance posture not only minimizes exposure to hefty penalties, but also helps maintain operational trust with clients, vendors, and regulators.

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