I-9 & PAF Compliance Audit Services

I-9 and Public Access File (PAF) audits are internal reviews designed to ensure an organization’s employment eligibility verification records comply with federal immigration regulations. In the current regulatory climate, these audits serve as a critical risk-management tool for employers maintaining a workforce of foreign nationals.

Technical errors in I-9 and Public Access Files (PAFs) often sit unnoticed in our internal systems, creating HR “Silent Liabilities” that remain hidden until they trigger significant fines during a government audit. With federal enforcement increasing, proactive auditing is the only way to identify these risks and correct errors before a Notice of Inspection (NOI) arrives from ICE or Homeland Security Investigations (HSI).

Launched on September 19, 2025, Project Firewall represents a historic escalation in how the Department of Labor (DOL) monitors immigration compliance for H-1B compliance. This initiative marks a definitive shift from a complaint-driven system to a proactive, aggressive enforcement model, similar to tactics across the board for all immigration-related matters under the Department of Homeland Security. In this new regulatory climate, a “reactive” compliance strategy is no longer a viable defense. Below are some of the key features of Project Firewall: 

• Secretary-Certified Investigative Authority: The Secretary of Labor has activated a previously dormant statutory authority to personally initiate H-1B investigations. 
• Multi-Agency “Task Force” Audits:  A coordinated interagency enforcement initiative, which involves  DOL’s Wage and Hour Division – sharing information and working closely with other federal agencies;  the Department of Justice’s Civil Rights Division; the Equal Employment Opportunity Commission (EEOC), and U.S. Citizenship and Immigration Services (USCIS)—to identify patterns of noncompliance and discrimination and to pursue coordinated enforcement actions. 
• Zero-Tolerance Focus: Investigations are now triggered proactively based on DOL’s own reasonable cause indicators—such as wage inconsistencies, high ratios of H-1B workers to U.S. workers, or discrepancies between payroll records and visa filings.
•  Expanded Scope and Scrutiny: Practical enforcement priorities include areas that historically have drawn scrutiny and can now trigger deeper examination:
• Wage Integrity: Strict scrutiny of Labor Condition Application (LCA) wage level designations and actual pay. 
• Illegal “Benching”: Immediate penalties for failure to pay H-1B workers during non-productive periods.

U.S. Worker Protections: Intensive audits of recruitment records to identify any perceived bias against domestic candidates.

• I-9 Paperwork Violations: Civil fines assessed per form for technical or substantive errors, which can escalate rapidly across a workforce.
• H-1B Wage and Compliance Violations: Exposure to back wages, civil penalties, and heightened scrutiny of employer practices.
• Program Debarment: Temporary or long-term bans on sponsoring foreign national employees, including potential loss of eligibility for federal contracts and grants.

FGI Audit Services
The risk of an unannounced audit is at an all-time high. Fakhoury Global Immigration (FGI) provides specialized compliance audits designed to “audit-proof” your files using the same criteria employed by federal investigators.

• Documentation & Lifecycle Integrity: Comprehensive analysis of I-9 and Public Access Files to resolve technical errors and manage secure retention protocols.
• Modern Workforce Compliance: Alignment of hybrid verification processes with 2026 standards and preparation for unannounced FDNS site visits.

Strategic Risk Mitigation: Actionable roadmaps to correct administrative discrepancies and ensure non-discriminatory hiring ahead of the H-1B Cap season.

Even one mistake can trigger significant fines. Federal authorities increasingly view unintentional non-compliance as a failure of due diligence rather than a valid defense. 

Don’t wait for a Notice of Inspection. Audit-proof your files today.