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Project Firewall

Project Firewall, sometimes referred to as Operation Firewall in public discussions, is an enforcement initiative launched by the U.S. Department of Labor (DOL) on September 19, 2025, aimed at protecting American workers by cracking down on fraud and abuse in the H-1B visa program. "Firewall" refers to three distinct government initiatives. A 2025 Department of Labor (DOL) enforcement initiative focused on H-1B visa employer compliance. A long-standing U.S. Immigration and Customs Enforcement (ICE) operation started in 2005 targeting bulk cash smuggling. The Secret Service Operation Firewall began in July 2003 as an investigation into access device fraud.

On September 19, 2025, the Department of Labor (DOL) announced the launch of "Operation Firewall" as a broad initiative aimed at H-1B employer compliance. This operation involved expanding the DOL Secretary's authority to independently initiate investigations into H-1B employers without a formal complaint. DOL would increase coordination with other agencies, including U.S. Citizenship and Immigration Services (USCIS), the Department of Justice (DOJ), and the Equal Employment Opportunity Commission (EEOC), focusing on strict enforcement of existing H-1B regulations, such as ensuring proper Labor Condition Application (LCA) notices are posted and public access files (PAFs) are complete and timely.

In a span of just days, the Trump administration unveiled three major policy initiatives targeting the H-1B visa program—and together, they left many in the global talent mobility and immigration community , employers, law firms, and workers wondering what might come next.

First came the headline: a $100,000 H-1B visa fee for large employers. Announced via presidential proclamation, the proposal sparked immediate backlash and a wave of legal challenges. Second, the Department of Homeland Security published a proposed rule to prioritize H-1B cap selection based on wage levels, This wage-based lottery reform could significantly reduce access for entry-level roles and early-career professionals, especially international graduates of US universities. Third, and most consequential, the Department of Labor (DOL) launched a directive known as Firewall, a broad enforcement initiative aimed at H-1B employer compliance.

The program focused on ensuring that employers prioritize hiring qualified U.S. workers for high-skilled jobs before turning to foreign labor, aligning with broader efforts to safeguard wages, job opportunities, and the "American Dream" for domestic talent. Key Objectives

• Prioritize American Workers: Employers must demonstrate efforts to hire qualified Americans first, preventing the displacement of U.S. talent by lower-wage foreign workers.
• Combat Fraud and Abuse: Root out misuse of H-1B visas, such as undercutting wages or bypassing local hiring, particularly in tech and high-skilled sectors.
• Protect Wages and Rights: Ensure fair pay and working conditions for both U.S. and H-1B workers, addressing concerns like outsourcing and corporate exploitation.

DOL conducts targeted investigations into employers suspected of non-compliance, marking the first time the Secretary of Labor personally certifies such probes when reasonable cause exists. This includes sharing information and coordinating with federal partners like the Department of Justice's Civil Rights Division, the Equal Employment Opportunity Commission (EEOC), and U.S. Citizenship and Immigration Services (USCIS). Actions include adits, compliance assistance, and potential criminal referrals for severe violations. Resources for reporting issues include a toll-free hotline (1-866-4-US-WAGE). Within the DOL, the initiative was led by the Office of Immigration Policy, Employment and Training Administration (ETA), and Wage and Hour Division (WHD).

Employers found in violation face recovery of back wages owed to affected workers and debarment from the H-1B program for a set period, barring future participation. This could extend to broader implications like discrimination charges or USCIS petition denials. As of late October 2025, the DOL ramped up awareness through a social media ad campaign, including a video posted on October 30 highlighting how H-1B abuse has "stolen the American Dream" from young U.S. workers, with visuals of laid-off Americans and calls for accountability. The ad accuses corporations of exploiting the program, noting that 72% of H-1B visas go to workers from India, and promises stricter enforcement under "America First" policies. Public discourse on X (formerly Twitter) has been mixed: Supporters praise it as overdue reform against outsourcing giants like Infosys. Critics argue it's a "do-nothing platitude" or insufficient, merely signaling action without real change, especially amid ongoing layoffs and foreign hiring preferences. Some tie it to broader issues like federal overreach or preferential hiring for foreign labor in government roles.

U.S. Secretary of Labor Lori Chavez-DeRemer stated: “The Trump Administration is standing by our commitment to end practices that leave Americans in the dust. As we reestablish economic dominance, we must protect our most valuable resource: the American worker. Launching Project Firewall will help us ensure no employers are abusing H-1B visas at the expense of our workforce.”

Firewal Disambiguation

The term "firewall" originated in the 18th-19th centuries from architecture and engineering, referring to fire-resistant walls in buildings to contain fires. It derives from "fire" (destructive flames) + "wall" (barrier), with early uses in German "Brandmauer" (brand = fire, mauer = wall) influencing English by the 1760s. In computing, it was metaphorically adopted in the late 1980s (first documented around 1988 in networking papers) to describe digital barriers that "contain" cyber threats, much like physical ones stop fire spread. This analogy highlights containment and separation.

A cyber firewall is a security system in computer networks that acts as a barrier between trusted internal networks and untrusted external ones, like the internet. It monitors, filters, and blocks unauthorized traffic based on rules, preventing threats such as hackers, malware, or data breaches. Types include hardware (e.g., dedicated devices), software (e.g., on operating systems like Windows Firewall), or cloud-based solutions.

The Secret Service "Operation Firewall" had taken a lead role in the emerging area of cyber crime and, through a nationwide network of 15 electronic crimes task forces, established working partnerships in both the law enforcement and business communities to address such issues as protection of critical infrastructure, internet intrusions and associated fraud.

Operation Firewall began in July 2003 as an investigation into access device fraud. The case evolved into a highly technical, transnational investigation involving global credit card fraud and identity theft over the internet. During the course of the investigation, computer underground criminal groups were identified as Shadowcrew, Carderplanet and Darkprofits. The criminal organizations operated websites used to traffic counterfeit credit cards and false identification information and documents. These websites not only shared information on how to commit fraud, but also provided a forum by which to purchase such information and tools.

These groups are highly organized international criminal enterprises that use websites to promote and facilitate a wide variety of criminal activities including electronic theft of personal identifying information, credit card and debit card fraud, and the production and sale of false identification documents. After initial contact via the internet, the suspects exchanged stolen information and counterfeit documents such as credit cards, driver’s licenses, domestic and foreign passports and birth certificates.

Beginning in early 2004, data obtained through court authorized intercepts revealed internal communications, transactions and practices of the previously identified groups and other criminal organizations. The amount of information gathered during the investigation is approximately two terabytes – the equivalent of an entire university’s academic library.

The assistance of international law enforcement – particularly the United Kingdom’s National Hi-Tech Crimes Unit, the Vancouver (British Columbia, Canada) Police Department’s Financial Crimes Section, the Royal Canadian Mounted Police and Europol – has been and will continue to be critical to the success of Operation Firewall. In addition, specific support was provided by Secretary General Boiko Borisov of Bulgaria as well as police agencies in Belarus, Poland, Sweden, the Netherlands and Ukraine and the U.S. Department of State.

The ICE "Operation Firewall" was a separate, long-running operation led by ICE (under the Department of Homeland Security) and Homeland Security Investigations (HSI). The bulk cash smuggling (BCS) initiative, Operation Firewall, began in August of 2005. This operation was a joint strategy, utilizing the historical interdiction expertise of U.S. Customs and Border Protection (CBP) in conjunction with the historical investigative expertise of ICE to address the BCS vulnerability. This enforcement operation has addressed various smuggling techniques, including commercial and private passenger vehicles, commercial air cargo shipments, commercial airline passengers and pedestrians transiting the U.S. border. ICE and CBP conducted “Firewall” training operations with law enforcement partners in Mexico. During this training, ICE and CBP, utilizing their historical expertise, provided hands-on training to our law enforcement partners on passenger analysis and investigative techniques proven effective in the United States. Investigations of seizures that occurred in Mexico have resulted in the dismantling of significant Colombian organizations based in Mexico.

“Firewall” operations in Mexico alone resulted in the seizure of more than $37 million. Mexican authorities seized $760,000 in U.S. currency destined for Costa Rica. Costa Rican officials advised that the funds were 14 directed to an individual who heads a major alien smuggling organization.This alien smuggling organization is involved in providing fraudulent passports and paperwork used to obtain U.S. visas that can be exploited by terrorists or other criminal organizations that intend to do harm. In 2006, ICE expanded its foreign “Firewall” operations to include Panama, Colombia and the Philippines. Since then, all foreign Operation Firewall activity has accumulated a total of $44 million in seized U.S. currency.

This currency had been successfully smuggled out of the U.S. and was intercepted en route to criminal organizations.These seizures are attributed to the training ICE and CBP jointly provided abroad. Since its inception, Operation Firewall resulted in the seizure of more than $82 million in U.S. currency both domestically and abroad, as well as negotiable instruments and the arrest of 225 individuals.

The DHS-led Operation Firewall was a comprehensive law enforcement operation targeting criminal organizations involved in the smuggling of large quantities of US currency. The Obama Administration on March 24, 2009 announced the Administration’s comprehensive response to the situation along the border with Mexico. US Immigration and Customs Enforcement (ICE) is the largest investigative agency in the Department of Homeland Security. ICE is charged with enforcing a wide array of laws, including those related to financial crime, trade fraud, counterfeiting, cash smuggling and others.

In recent years, the smuggling of bulk currency has become a preferred method for drug dealers and other criminals to move illicit proceeds across our borders. Congress criminalized the act of smuggling large amounts of cash as part of the USA PATRIOT Act. Specifically, Title 31 U.S.C. 5332-Bulk Cash Smuggling makes it a crime to smuggle or attempt to smuggle over $10,000 in currency or monetary instruments into or out of the United States, with the specific intent to evade the U.S. currency-reporting requirements codified in 31 U.S.C. 5316.

ICE took a leading role in combating bulk cash smuggling, teaming in 2005 with U.S. Customs and Border Protection (CBP) to launch Operation Firewall, a comprehensive law enforcement operation targeting criminal organizations involved in the smuggling of large quantities of U.S. currency.

Operation Firewall targeted the full array of methods used to smuggle bulk cash, including commercial and private passenger vehicles, commercial airline shipments and passengers, and pedestrians crossing U.S. borders with Mexico and Canada. ICE and CBP partner to combat cash smuggling at U.S. ports-of-entry. In the U.S. interior, ICE works with state and local partners to identify and intercept smuggled bulk cash shipments being transported along domestic interstate highways.