Trump Administration Restricts Entry of New H-1B Workers and Launches Project Firewall Enforcement Initiative

On September 19, 2025, President Trump signed an executive order restricting the entry of certain H-1B nonimmigrant workers into the United States.¹ This action introduced a $100,000 payment requirement to accompany or supplement H-1B petitions. A supplemental fact sheet provided further details.²

We have been closely monitoring developments and guidance surrounding this proclamation to assess its potential impact on visa status and travel plans. As of September 21, 2025, the administration clarified that the proclamation applies prospectively — only to petitions not yet filed. Based on this guidance, we are optimistic that current H-1B visa holders will not be affected regarding status, international travel, and future visa processing.

In parallel, the U.S. Department of Labor has launched Project Firewall, a new enforcement initiative targeting H-1B program compliance.³

This effort aims to:

• Protect American workers by ensuring employers prioritize qualified U.S. citizens.
• Hold employers accountable for misuse of the H-1B visa process.
• Conduct Secretary-certified investigations — a first in the department’s history.

Violations may result in:

• Recovery of back wages
• Civil penalties
• Debarment from future H-1B usage

Project Firewall will be led by the Department’s Office of Immigration Policy, Employment and Training Administration, and Wage and Hour Division, in collaboration with the DOJ Civil Rights Division, EEOC, and USCIS.

Therefore, while the proclamation from Friday does not seem to affect current H-1B visa holders, there will be increased enforcement. We recommend that employers audit their H-1B filings to ensure strict compliance with job title, description, and workplace.

AGG remains available to support you through these developments and will continue to provide timely updates as new guidance emerges. If you have questions about how these changes may affect your status or petition strategy, please reach out to AGG Global Mobility attorneys Teri Simmons, Stephen Pocalyko, Dorothea Hockel, or Matt Ohm.

[1] See Executive Order (Sept. 19, 2025), available here.

[2] See Fact Sheet: President Donald J. Trump Suspends the Entry of Certain Alien Nonimmigrant Workers (Sept. 19, 2025), available here.

[3] See U.S. Department of Labor news release (Sept. 19, 2025), available here.

 Authors:

Teri Simmons 
Email: teri.simmons@agg.com;

Stephen Pocalyko 
Email: Stephen.pocalyko@agg.com;

Dorothea Hockel
Email: dorothea.hockel@agg.com;

Matt Ohm 
Email: matt.ohm@agg.com