Sponsorship of Foreign Workers Under Heightened DOL Scrutiny

Avoiding Compliance Pitfalls in Securing Permanent Foreign Labor Certification

Recording of a 90-minute CLE webinar with Q&A

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Conducted on Thursday, September 11, 2008

Course Materials


The U.S. Department of Labor (DOL) has increased its scrutiny of law firms and corporations involved in the sponsoring of foreign workers for permanent residence in recent months, resulting in the unprecedented audit of a firm’s labor certification applications and a software company’s debarment.

The heightened DOL scrutiny is likely to cause companies to back away from their efforts to recruit foreign workers. The DOL is expected to continue to pursue enforcement actions.

Listen as our panel of immigration law attorneys offers perspectives on the current enforcement environment, provides practical guidance for complying with current laws in order to protect businesses from penalties and offers best practices for responding to a DOL audit.



  1. Current enforcement efforts
    1. Audit of Fragomen, Del Rey, Bernsen & Loewy’s labor certification applications
    2. Supervised recruitment of Cohen & Grigsby’s labor certification applications
    3. Debarment of software company
  2. Complying with DOL’s PERM Program requirements
    1. DOL Guidance Bulletin of June 13, 2008
    2. Position and search requirements — “business necessity” standard
    3. Documentation
    4. Timing considerations
    5. Legal fees and advertising costs
  3. Best practices for responding to a DOL audit


The panel will review these and other key questions:

  • What current enforcement efforts are underway to ensure that U.S. workers are given priority over foreign workers when companies recruit for positions?
  • What are some best practices to ensure effective compliance with federal and state immigration laws when sponsoring foreign workers?
  • How should companies targeted for audit respond to the Department of Labor?


Denyse Sabagh
Denyse Sabagh
Duane Morris

She heads the firm's Immigration Practice, helping corporate clients manage inbound and outbound employment...  |  Read More

William A. (Bill) Stock
William A. (Bill) Stock

Klasko Law

He has practiced immigration law exclusively since 1993, representing multinational corporations and their employees....  |  Read More

Robert H. Cohen
Robert H. Cohen
Porter Wright

He has extensive experience in all aspects of business immigration procedures. He is former chair of the Ohio Chapter...  |  Read More

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