URGENT COMPLIANCE ALERT: DOL Suspends Cognizant’s PERM Filings — Is Your H-1B/PERM Program Audit-Ready?.

BREAKING: H-1B AND PERM ENFORCEMENT HAS ENTERED A NEW PHASE

Dear Client, We are writing to every employer we represent because the enforcement landscape has changed, and the cost of being unprepared has never been higher.

WHAT HAS HAPPENED:

1. In July 2026, the U.S. Department of Labor’s Inspector General announced the administration’s first major investigation into alleged H-1B and PERM fraud, working with the White House Fraud Task Force. Dozens of subpoenas have already been issued to employers and labor brokers, and the Inspector General has said publicly that more are coming.
2. On September 8, 2026, the Inspector General announced that Cognizant’s PERM filings are suspended pending the outcome of that investigation. Cloudera’s PERM filings were suspended the same day, and H-1B processing for both companies was reported halted. One of the largest sponsors in the country currently cannot file new PERM applications for its employees. No charges have been filed, but the business disruption is immediate.
3. FDNS site visits, DOL Wage and Hour investigations, and LCA/Public Access File audits are all part of the same enforcement push. These are no longer limited to small or obscure employers.

• Back wages owed to every affected H-1B worker, often going back years.
• Civil money penalties assessed per violation.
• Debarment from filing H-1B, PERM, and other petitions for one to three years or longer.
• Suspension of pending filings while an investigation runs.
• Revocation of approved petitions and loss of key employees.
• Referral for criminal investigation in cases involving misrepresentation.

WHERE EMPLOYERS FAIL MOST OFTEN:

• LCA notices that were never actually posted, or posted at the wrong location, with no proof of posting
• Public Access Files that are missing, incomplete, or not created within one business day of LCA filing
• Employees working at a location, in a role, or at a wage different from what the petition states, with no amended petition filed
• Benching, unpaid gaps, or wages below the required wage
• End-client managers and H-1B employees who give inconsistent answers to an FDNS officer
• PERM recruitment files and audit files that cannot be produced within the 30-day audit response window
• Missing or stale contracts, SOWs, and end-client letters for third-party placements
• I-9 files with errors that surface during the same visit

Receiving instructions by email is not compliance. The government looks at what is actually in your files and what your people actually say on the day an officer walks in.

WHAT WE ARE ASKING YOU TO DO NOW:

Please contact our office this week to schedule a review of your immigration compliance program. The review covers:

• A public access file audit for every active LCA
• LCA posting verification and worksite reconciliation for each H-1B employee
• Wage, payroll, and job duty reconciliation against each approved petition
• PERM recruitment and audit file review, including retention for five years
• FDNS site visit protocol and training for front desk staff, HR, managers, and H-1B employees
• Third-party placement documentation review
• A written corrective action plan, prepared under attorney-client privilege

Problems we find and fix before the government arrives are correctable. Problems the government finds first are violations. To schedule your review, reply to this email or call our office. We are prioritizing employers in the order requests are received.

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