Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 05 DECEMBER 2025

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

Barnes & Thornburg LLP
Explore more from Barnes & Thornburg LLP

The U.S. Department of Labor (DOL)'s new "Project Firewall" significantly intensifies H-1B enforcement, enabling expanded audits...

United StatesImmigration
Sarah J. Hawk
Sarah J. Hawk
Alexa Zambory
Alexa Zambory
Author LinkedIn connections

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.

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

October 2026 Visa Bulletin Advances EB-5 Filing Date For Mainland China By 4 Years

The U.S. Department of State has released the October 2026 Visa Bulletin, marking the start of fiscal year 2027 with significant changes to employment-based immigrant visa categories. How will the advancement of priority dates, particularly the substantial four-year leap for mainland China-born EB-5 investors in the Dates for Filing chart, impact eligible applicants seeking adjustment of status benefits?
GlobalImmigration
Greenberg Traurig
Greenberg Traurig
Article

DHS Proposes $70,000 And $30,000 Fees For F-1 Optional Practical Training

The Department of Homeland Security has proposed a controversial new rule requiring SEVP-certified schools to pay substantial fees—$70,000 for a student's first Optional Practical Training recommendation and $30,000 for each subsequent OPT application, including STEM extensions. With only a 30-day comment period and potential annual costs reaching up to $16.5 billion across nearly 2,500 affected institutions, the proposed regulation is expected to face significant legal challenges if finalized.
United StatesImmigration
Duane Morris LLP
Duane Morris LLP
Article

DHS Continues Work Authorization For Ukrainian, Sudanese TPS Beneficiaries; I-9 Guidance Remains Unclear

The Department of Homeland Security has not issued formal determinations for Temporary Protected Status designations for Ukraine and Sudan despite the October 19, 2026 expiration date, creating uncertainty for employers navigating Form I-9 compliance and employment authorization documentation. USCIS states that affected individuals retain TPS protections and work authorization, but has not updated operational guidance to explain how employers should document continued employment eligibility or handle
United StatesImmigration
Greenberg Traurig
Greenberg Traurig
Article

OFAC Broadens Cuba Sanctions And Restricts Payments And Travel

The U.S. Treasury Department's Office of Foreign Assets Control has implemented sweeping changes to Cuba sanctions, introducing a new regulatory framework that extends restrictions beyond U.S. persons to foreign entities and financial institutions. These measures eliminate key banking authorizations, expand transaction prohibitions to include intermediary payments, and significantly narrow travel permissions, creating new compliance challenges for businesses operating in or through Cuba-related channels.
United StatesGovernment, Public Sector
Barnes & Thornburg LLP
Barnes & Thornburg LLP
Article

IEEPA Tariff Refunds: Critical Developments, Phase III Delays, And Action Steps For Importers

U.S. Customs and Border Protection has begun processing IEEPA tariff refunds through its CAPE system, but Phase III covering finally liquidated entries faces delays and requires court orders. With the Department of Justice appealing the universal refund order and class certification pending, importers with finally liquidated entries may need to file individual lawsuits at the Court of International Trade to preserve their claims before statutory deadlines expire.
United StatesInternational Law
Barnes & Thornburg LLP
Barnes & Thornburg LLP
Article

California Passes AB-1883 Targeting AI Workplace Surveillance Of Employees’ Emotional State And Neural Data

On Aug. 30, AB-1883 received final legislative approval and now heads to California Governor Gavin Newsom for signature or veto. If enacted, AB-1883 would prohibit employers from using workplace surveillance tools that rely on artificial intelligence (AI) to recognize, infer, or predict an employee’s emotional state, or to collect “neural data.”
United StatesEmployment and HR
Barnes & Thornburg LLP
Barnes & Thornburg LLP
Article

Time To Update The Handbook And The Training Deck: Three New California Laws Affecting Employment Policies And Training

California Governor Newsom has signed three bills that will require California employers to revisit their written policies and their training programs. On the policy side, SB 1149 widens who counts as a “family member” for bereavement leave. On the training side, AB 1803 adds an anti-hate speech component to mandatory harassment prevention training starting Jan. 1, 2028.
United StatesEmployment and HR
Barnes & Thornburg LLP
Barnes & Thornburg LLP
Article

Russia Sanctions And Tariffs: What Businesses Need To Know About The Graham Act

President Trump has signed the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026, introducing sweeping new tariffs of up to 100% on countries purchasing Russian energy and up to 500% on Russian-origin goods. The legislation also codifies existing executive order sanctions into statute, requiring congressional action to lift restrictions and creating mandatory secondary sanctions on foreign financial institutions transacting with designated Russian banks. Companies face immediate compliance challenge
RussiaInternational Law
Barnes & Thornburg LLP
Barnes & Thornburg LLP
Article

New York State Minimum Wage Increase Halted For 2027; Governor Proposes March Hike

New York's minimum wage will hold steady at current rates through early 2027, but Governor Hochul has proposed legislation that would tie future increases to inflation beginning March 1, 2027. Home care workers will see immediate wage increases to $19-$20 per hour starting January 1, 2027, while standard minimum wages remain at $16-$17 depending on location. Employers across the state should prepare now for potential legislative changes that could affect payroll systems and compensation structures.
United StatesEmployment and HR
Barnes & Thornburg LLP
Barnes & Thornburg LLP