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Report to the Chairman, Committee on Education and Labor, House of 
Representatives: 

United States Government Accountability Office: 

GAO: 

September 2010: 

H-2B Visa Program: 

Closed Civil and Criminal Cases Illustrate Instances of H-2B Workers 
Being Targets of Fraud and Abuse: 

GAO-10-1053: 

GAO Highlights: 

Highlights of GAO-10-1053, a report to the Chairman, Committee on 
Education and Labor, House of Representatives. 

Why GAO Did This Study: 

The H-2B visa program assists U.S. employers anticipating a shortage 
of domestic nonagricultural workers by permitting them to hire 
nonimmigrant foreign workers temporarily. The program is overseen by 
several agencies, including the Department of Labor (Labor), the 
Department of Homeland Security’s United States Citizenship and 
Immigration Services (USCIS), and the Department of State. Employers 
often hire labor recruiters or other intermediaries to assist with the 
process of obtaining labor certifications and finding foreign workers. 
GAO was asked to determine if there were examples of recruiters and 
employers engaging in illegal or fraudulent activity within the H-2B 
visa program. 

GAO reviewed recent closed civil and criminal court cases involving H-
2B workers, obtained data from Labor and USCIS on H-2B visas issued in 
fiscal years 2008 and 2009 and in first 6 months of fiscal year 2010, 
and interviewed advocacy groups that represent H-2B workers in 
litigation. In addition, GAO made undercover calls and site visits to 
recruiters, posing as H-2B employers and foreign H-2B workers and 
asked a series of questions related to legal requirements of the 
program. GAO also visited several H-2B housing and work site 
locations. Case studies and results of tests and site visits cannot be 
projected to the entire population of H-2B employers and recruiters. 

What GAO Found: 

GAO reviewed 10 closed cases over the last 5 years that involved H-2B 
employers and recruiters that violated various labor laws or settled 
allegations of violations outside of court. These 10 cases involved 
diverse employers in different industries with employees in 29 states 
with violations in areas such as employers failing to pay promised 
wages, overtime, or both; employers charging H-2B workers exorbitant 
fees; and employers and recruiters submitting fraudulent documentation 
to government officials. For example, in one case H-2B workers became 
indebted to their employer through a series of arbitrary charges. The 
employer then forced workers to take second jobs at local fast food 
restaurants to pay these debts. The table below provides a summary of 
cases where H-2B workers rights were violated. 

Table: Cases of Fraud and Abuse within the H-2B Program: 

Industry, location: Hotel - South Dakota; 
Details: 
* Hotel owners forced H-2B workers to work in substandard conditions, 
confiscated workers’ passports, and threatened workers that they would 
be sent home in a “box” if they disobeyed orders. 
* In 2008, the couple was found guilty on nine counts, including 
conspiracy, holding people in peonage, making false statements, and 
visa fraud. 

Industry, location: Construction and foreign contract labor firm - 
Louisiana; 
Details: 
* Workers from India paid at least $20,000 for H-2B visas to enter the 
United States but were never employed by the construction company.
* The construction company owner pled guilty to conspiracy, and the 
other conspirators were found guilty of 1 count of conspiracy, 14 
counts of encouraging and inducing illegal immigration, and 1 count of 
money laundering. 

Industry, location: Labor broker, hospitality employers, and 
immigration attorney - Virginia; 
Details: 
* Conspirators fraudulently obtained H-2B certification from Labor for 
over 3,800 individuals, leased workers to undisclosed businesses not 
listed on the visa petitions, defrauded the government of $7.4 million 
in payroll taxes never remitted to the Internal Revenue Service.
* The conspirators pled guilty to charges including conspiracy, visa 
fraud, and tax evasion charges that were linked to an international 
organized crime ring. 

Source: GAO analysis of court files. 

[End of table] 

GAO personnel found that most recruiters they called or visited posing 
as prospective H-2B employers and workers did not encourage our 
undercover agents to violate program rules. Of the 18 recruiters in 
multiple states we contacted, 15 appropriately did not offer any 
advice on violating H-2B program rules. However, during three calls, H-
2B recruiters did provide suggestions on how to circumvent program 
rules, such as providing “good excuses” to help “weed out” prospective 
U.S. workers or recouping costs through “off-the-book” transactions to 
avoid restrictions on pay deductions. Additionally, GAO found that H-
2B workers contacted during the site visits to their housing locations 
were generally pleased with their living and working conditions. 
However, at one location the H-2B workers were afraid to speak with 
outside individuals for fear of retaliation from their employer. 

View GAO-10-1053 or key components. For more information, contact 
Gregory Kutz at (202) 512-6722 or kutzg@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

Court Cases Reveal Unfair Wages, Excessive Fees, and Fraudulent 
Documentation in the H-2B Program: 

In Undercover Tests, Most Recruiters Did Not Encourage H-2B Visa Fraud 
but Some Offered to Help Violate Laws and Regulations: 

Appendix I: Scope and Methodology: 

Table: 

Table 1: Summary of Court Cases: 

[End of section] 

United States Government Accountability Office:
Washington, DC 20548: 

September 30, 2010: 

The Honorable George Miller: 
Chairman: 
Committee on Education and Labor: 
House of Representatives: 

Dear Mr. Chairman: 

With the United States continuing to attract tens of thousands of 
foreign nationals each year who seek legal employment, the H-2B visa 
program is intended to benefit both American employers and foreign 
workers. Employers anticipating a shortage of American nonagricultural 
workers may hire nonimmigrant foreign workers[Footnote 1] to fill 
temporary labor needs though the H-2B visa program. Employers often 
hire labor recruiters[Footnote 2] or other intermediaries to help find 
foreign workers and obtain the required labor certifications. The 
workers come from a diverse set of countries and work in a range of 
industries, most often construction, landscaping, manufacturing, 
hospitality service, and food processing. Several federal agencies 
oversee the program, including the Department of Labor (Labor), the 
Department of Homeland Security's United States Citizenship and 
Immigration Services (USCIS), and the Department of State (State). 

Several recent convictions have shown that some employers and 
recruiters may be abusing the foreign workers in the program. In 
addition, some employers may violate program rules by subverting 
program regulations requiring that employers first attempt to hire 
U.S. workers. You asked us to determine if there were examples of 
recruiters and employers that were engaging in illegal or fraudulent 
activity within the H-2B visa program. Specifically, we (1) reviewed 
recent closed civil and criminal court cases of fraudulent, illegal, 
and abusive activity by recruiters and employers participating in the 
H-2B program and (2) conducted undercover tests of employer and 
recruiter practices. 

To identify court cases of recent fraud and abuse within the H-2B 
program, we researched court documentation involving violations of the 
H-2B program in the last 5 years that resulted in a criminal 
conviction, civil or administrative liability, or significant 
financial settlement. We reviewed a nonrepresentative selection of 10 
closed cases, from leads provided by advocacy groups and our own 
research, associated with workers employed in 29 states and various 
industries to illustrate the types of abuse and fraud that occurred in 
the H-2B program, but we cannot generalize these findings to the 
program. 

To examine methods used by H-2B employers and recruiters, we reviewed 
recent civil and criminal cases involving H-2B workers; obtained data 
from Labor and USCIS on H-2B visas issued in fiscal years 2008 and 
2009 and in the first 6 months of fiscal year 2010; and interviewed 
advocacy groups that represent H-2B workers in litigation. We 
conducted undercover calls to 18 U.S.-based H-2B recruiters and 
staffing agencies. These recruiters were selected from leads provided 
by advocacy groups and our own research. Using scenarios based on 
recent court cases and program requirements, we posed as potential 
employers and foreign workers to assess whether selected recruiters 
would advocate violating program laws and regulations. We also made 
undercover site visits to two selected recruiters that we had 
previously contacted by phone. Finally, we conducted site visits of H- 
2B worker housing locations to identify instances of substandard 
housing accommodations or other forms of abuse and the mistreatment of 
H-2B workers. These sites were selected from leads provided by 
advocacy groups and our own research. Case studies, site visits, and 
results of proactive testing cannot be projected to the entire 
population of H-2B employers and recruiters. 

We conducted the work for this investigation from April 2010 through 
September 2010 in accordance with the standards prescribed by the 
Council of Inspectors General for Integrity and Efficiency. Additional 
details on our scope and methodology are included in appendix I. 

Background: 

The Immigration and Nationality Act allows foreign nationals to enter 
the United States to perform temporary labor if unemployed individuals 
capable of performing the work cannot be found in the United States. 
Labor and USCIS are responsible for reviewing employers' applications 
for H-2B workers, and State is responsible for issuing visas to 
workers. Under the program, employers in industries with a onetime 
occurrence, peak load, seasonal, or intermittent needs can supplement 
their domestic workforces with H-2B workers. The temporary work must 
be for full-time employment and the employer's need for the workers 
must generally be less than a year. The H-2B classification may be 
extended for qualifying employment in 1-year increments up to a total 
of 3 years. Up to 66,000 H-2B visas can be issued each fiscal year. 

Prospective H-2B employers must apply to Labor for a temporary labor 
certification attesting that American workers capable of performing 
the work are not available and that the employment of foreign workers 
will not adversely affect the wages and working conditions of 
similarly employed American workers. The H-2B program requires the 
employer to attest to Labor that it will offer a wage that equals or 
exceeds the highest of the prevailing wage, the applicable federal 
minimum wage, the state minimum wage, or the local minimum wage to the 
H-2B worker. The employer also must agree to offer terms and working 
conditions typical to U.S. workers in the same geographical area; 
[Footnote 3] not use H-2B workers to replace striking workers; comply 
with all federal, state, and local labor, health, and safety laws; and 
detail and clarify all paycheck deductions in the job offer and ensure 
that all deductions are reasonable. The employer must also not place 
any workers outside the area listed on the Labor application without 
first obtaining a new certification and must notify Labor and USCIS if 
an H-2B worker quits before the end of the term of employment. In 
addition, the employer agrees to forbid any recruiter from seeking or 
receiving payment from H-2B workers, except for costs that are the 
responsibility of the worker.[Footnote 4] Moreover, the employer 
agrees not to seek or receive payment of any kind from the H-2B 
workers related to labor certification. 

Court Cases Reveal Unfair Wages, Excessive Fees, and Fraudulent 
Documentation in the H-2B Program: 

The 10 cases that we reviewed demonstrate fraud and abuse committed by 
recruiters and employers participating in the H-2B visa program and 
operating in 29 states. Though the cases include a diverse group of 
employers in different industries, our review of these 10 cases showed 
violations in areas such as unfair wages for employees, excessive fees 
charged to employees, and fraudulent documentation submitted to 
federal agencies to circumvent program rules. 

Employers failed to pay the prevailing hourly wage or overtime. In 6 
of the 10 cases we reviewed, there were allegations that employers did 
not pay their H-2B employees the established hourly wage, overtime, or 
both. For example, a carnival operator in New York paid employees by 
the week regardless of the number of hours worked. Working up to 80 
hours a week, the employees averaged less than $5.00 an hour--far less 
than the $8.00 to $12.20 promised. In another case, H-2B employees 
alleged that an Arkansas-based forestry corporation did not pay 
overtime wages despite work weeks regularly exceeding 40 hours. 

Employers charged H-2B workers excessive fees. In 6 of the 10 cases we 
reviewed, employers charged their H-2B workers fees that were for the 
benefit of the employer or charged excessive fees that brought 
employees' wages below the hourly federal minimum wage. These charges 
included visa processing fees far above actual costs, rent in 
overcrowded apartments that drastically exceeded market value, and 
transportation charges subject to arbitrary "late fees." Workers left 
the United States in greater debt than when they arrived. In one case, 
these fees reduced employees' paychecks to as little as $48 for a 2- 
week period. A total of 4 of these cases resulted in a criminal 
conviction, including civil or administrative liability, and the 
remaining 2 cases resulted in a significant financial settlement. 

Employers and recruiters submitted fraudulent documentation. In 8 of 
the 10 cases we reviewed, employers were alleged to have submitted 
fraudulent documentation to Labor, USCIS, and State to either exploit 
their H-2B employees or hire more employees than needed. Employers and 
recruiters misclassified employee duties on Labor certification 
applications to pay lower prevailing wages; used shell companies to 
file fraudulent labor certification applications for unneeded 
employees, then leased the additional employees to businesses not on 
the visa petitions; and preferentially hired H-2B employees over 
American workers in violation of federal law. A total of 5 of these 
cases resulted in a criminal conviction, including civil or 
administrative liability, and the remaining 3 cases resulted in a 
significant financial settlement. 

There is no law or program requirement that prohibits companies from 
being awarded federal contracts even if they have been found to have 
violated H-2B immigration laws. Several of these employers continued 
to receive H-2B certifications and money from federal contracts while 
in litigation, after reaching a settlement as a result of litigation, 
or after being found guilty of various charges. 

Table 1 summarizes the 10 cases in which H-2B employers and recruiters 
committed visa fraud or exploited their H-2B workers. 

Table 1: Summary of Court Cases: 

Case: 1; 
Location: Arizona, Delaware, Maryland, New Jersey, New York, 
Pennsylvania, and Virginia; 
Defendants: Temporary employment recruiting agency; 
Case details: 
* The agency conspired with client businesses to return employed 
illegal aliens to native countries, and then fraudulently obtain H-2B 
visas to bring the employees back; 
* The agency submitted falsified documents to Labor, State, and USCIS 
using names from a Mexico phone book and fictitious biographical 
information to serve as placeholders, so that additional H-2B visas 
were on hand in case client businesses needed to hire additional alien 
workers; 
* The agency coached the employees to lie to U.S. immigration 
officials during visa application interviews and about their previous 
presence in the United States; 
* Federal criminal suit was filed in 2009; 
Outcome: 
* In 2009, all parties involved (the owner, his wife, his sister, and 
an unrelated office manager) pled guilty. The owner's sister was 
sentenced to 3 years of probation, 200 hours of community service a 
year for 3 years, and a $50,000 fine. The office manager and the 
owner's wife received 5 years of probation. Additionally, his wife 
received 200 hours of community service a year for 5 years and a 
$2,000 fine, while the office manager received 250 hours of community 
service a year for 5 years and a $20,000 fine. The owner passed away 
while awaiting sentencing. 

Case: 2; 
Location: New York; 
Defendants: Carnival operator; 
Case details: 
* In 2008, New York's Office of Attorney General (OAG) began to 
investigate this company after receiving complaints from H-2B workers 
about wages and substandard housing. The OAG alleged that the company: 
* discriminated against 54 Mexican H-2B employees by not paying the 
salary promised; 
* housed employees in overcrowded, cockroach-and bedbug-infested 
trailers with unsanitary restrooms; 
* did not provide safety equipment or proper attire; 
* verbally harassed employees; and; 
* paid $275 to $350 a week regardless of hours (employees earned an 
average of $5.00 an hour but were promised $8.00 an hour and $12.20 an 
hour for overtime); 
Outcome: 
* In 2009, the carnival operator settled with the OAG and did not 
admit liability, but agreed to pay $325,000 in restitution and damages 
to the employees; 
* The employer agreed to submit to an independent monitor to ensure, 
among other things, compliance with minimum wage and overtime law and 
provide equal treatment and sanitary housing to employees. 

Case: 3; 
Location: South Dakota; 
Defendants: Hotel; 
Case details: 
* The employer forced nine employees to work in substandard conditions 
and placed them in servitude[A] at their hotel; 
* The employer offered employees $6.05 an hour but actually paid $3.00 
per room and required that each room be cleaned for an hour; 
* The employer did not pay overtime; 
* The employer charged nine employees $1,200 each in visa processing 
fees, despite actual fees totaling $1,200 for all nine workers; 
* The employer charged seven employees $1,050 a month for an apartment 
they shared, though it normally rented for $375; 
* The employer forced employees to pay arbitrary charges, leading them 
to take second jobs at local fast food restaurants to pay these debts; 
* The employer isolated the workers from the community and threatened 
physical abuse; 
* The employer confiscated the employees' passports and threatened 
deportation in a "box" if they disobeyed orders; 
* Federal criminal suit was filed in 2007; 
Outcome: 
* In 2008, the couple who owned the hotel was found guilty on nine 
counts, including conspiracy, holding people in peonage,[B] making 
false statements, and visa fraud; 
* The husband was sentenced to 50 months in jail, while his wife 
received 36 months in jail. Each received a $15,000 fine. 

Case: 4; 
Location: Virginia; 
Defendants: Landscaping company; 
Case details: 
* A labor union filed a complaint with the Department of Justice 
alleging that the employer discriminated against U.S. workers by 
preferentially hiring H-2B employees in violation of federal law; 
* The company obtained certifications for over 2,500 H-2B workers from 
Labor since 2007; 
Outcome: 
* A settlement agreement was reached on May 11, 2010, in which the 
employer did not admit liability but agreed to modify its hiring 
policy and personnel practices and provide full back pay of $11,173 to 
a U.S. citizen who was denied a job. 

Case: 5; 
Location: Arkansas; 
Defendants: Forestry company; 
Case details: 
* A class action was filed against the company alleging violations of 
the Fair Labor Standards Act and Migrant and Seasonal Agricultural 
Worker Protection Act. The plaintiffs alleged that the company: 
* failed to pay over 2,200 workers the prevailing wage or overtime for 
6 years by exploiting their inability to speak English and their lack 
of understanding U.S. laws; 
* forced 7-day work weeks and frequent overtime without breaks; 
* violated the Migrant and Seasonal Agricultural Worker Protection Act 
by failing to reimburse the workers for expenses they incurred and 
making unlawful withholdings and deductions from wages; and; 
* forced workers to move to another work site but deducted living 
expenses from their paychecks for both locations; 
Outcome: 
* During litigation, the company was held in contempt of court three 
times for intimidating workers who expressed interest in joining the 
lawsuit; 
* The company entered into a settlement agreement in which it did not 
admit liability but agreed to pay $2.75 million in February 2010 after 
workers sued to recover unreimbursed expenses for obtaining H-2B visas; 
* The company continues to receive active labor certifications from 
Labor to recruit H-2B workers since the settlement; 
* The company obtained certifications for over 1,900 H-2B workers from 
Labor since 2007; 
* The company received over $200,000 from federal contracts during 
litigation. 

Case: 6; 
Location: Louisiana; 
Defendants: Construction company and foreign contract labor firm; 
Case details: 
* The company obtained $1.8 million from a fraudulent H-2B visa 
conspiracy to bring 87 Indian nationals into the United States 
illegally; 
* The company submitted fraudulent H-2B documentation to federal 
agencies allegedly seeking workers from India; 
* The company charged at least $20,000 for H-2B visas but never 
employed the Indian nationals; 
* Representatives of the firm traveled to India to assist the Indian 
nationals with the application process and corresponded with the U.S. 
Consulate on behalf of the workers; 
* These conspirators were indicted on federal criminal charges in 2008; 
Outcome: 
* In 2009, the construction company owner pled guilty to conspiracy 
and was sentenced 3 years probation and 6 months home confinement; 
* In 2009, the other conspirators were found guilty of 1 count of 
conspiracy, 14 counts of encouraging and inducing illegal immigration, 
and 1 count of money laundering and sentenced to 41 months 
imprisonment. 

Case: 7; 
Location: Virginia; 
Defendants: Labor broker, hospitality employers, and immigration 
attorney; 
Case details: 
* The conspiracy fraudulently obtained H-2B certification from Labor 
for over 3,800 individuals; 
* The conspirators obtained certifications for more workers than 
needed, leasing the additional workers to undisclosed hotels or 
businesses not listed on the visa petitions; 
* The conspirators generated over $35 million in gross income by 
establishing a permanent foreign labor pool for jobs normally filled 
by Americans; 
* The conspirators defrauded the government of $7.4 million in payroll 
taxes never remitted to the Internal Revenue Service; 
* The businesses charged H-2B workers exorbitant fees for visa-related 
services and excessive rent for unsanitary, overcrowded houses; 
* The conspiracy started in 2003 and was terminated in 2009 when 
federal criminal charges were filed; 
Outcome: 
* Nineteen suspects pled guilty to several charges including 
conspiracy, visa fraud, and tax evasion charges that were linked to an 
international organized crime ring; 
* Some individuals convicted in the conspiracy received probation, 
home confinement with electronic monitoring, or federal prison 
sentences; 
* Suspects were sentenced from October 2009 through February 2010. 

Case: 8; 
Location: Florida; 
Defendants: Hospitality labor broker; 
Case details: 
* Company representatives posed as executives from other legitimate 
businesses to fraudulently obtain H-2B certifications from Labor; 
* The company coerced workers to sign contracts agreeing to lower pay 
than originally promised; 
* The company charged up to 16 workers rent to live together in a two-
bedroom house; 
* The company paid as little as $48 for 2 weeks of work because of 
excessive paycheck deductions, including fees for not cleaning housing 
accommodations and arriving late for transportation to work sites; 
* Investigative documents indicate that the conspiracy started in 1999 
and continued until 2007, when federal criminal charges were filed; 
Outcome: 
* The court referred to the treatment of these workers as "legal 
slavery"; 
* All four executive officers received federal prison sentences and 
joint $1 million dollar asset forfeiture; 
* Final sentencing for defendants occurred in 2008. 

Case: 9; 
Location: Pennsylvania; 
Defendants: Landscaping company and labor broker; 
Case details: 
* A federal civil suit was filed in 2007 alleging that the company did 
the following: 
* Requested more H-2B workers than needed to lease them to other 
businesses via a recruitment firm at a premium rate; 
* Misclassified employee duties on Labor certification applications to 
pay lower wages to H-2B workers; 
* Required foreign workers to pay preemployment bonds guaranteeing 
that they would work for the entire season or forfeit the bond to 
company, in order to secure H-2B positions. Workers stated that the 
bonds were not refunded after terms of employment ended; 
* Forced workers to pay excessive rent to live in employer-owned, 
substandard housing; and; 
* Fired workers who complained or threatened the company with breach 
of contract; 
Outcome: 
* In 2009, the court approved a settlement that required the employer 
to pay H-2B workers over $20,000 and submit documentation verifying 
adherence to Fair Labor Standards Act and H-2B regulations in future 
employment practices. 

Case: 10; 
Location: Colorado, Connecticut, Delaware, Indiana, Maryland, 
Massachusetts, Minnesota, Missouri, New Jersey, New York, Ohio, 
Pennsylvania, Texas, Virginia, and Wisconsin; 
Defendants: Landscaping company; 
Case details: 
* A federal class action civil suit was filed in 2005, representing H-
2B workers employed by the company from 2002 to 2005; 
* The plaintiffs alleged that the employer made excessive deductions 
from paychecks, often resulting in workers receiving less than minimum 
wage; 
* H-2B workers sought relief under the Fair Labor Standards Act for 
minimum wage and overtime violations, breach of contract, and wrongful 
termination; 
Outcome: 
* The company paid a $600,000 settlement to workers in 2008, the 
largest amount at that time; 
* In 2008, the court ruled that H-2B travel costs, visa expenses, and 
employee fees primarily benefited the employer and could not be 
deducted from paychecks; 
* Since 2008, the firm has been awarded over $35,000 in federal 
contracts, and has applied for certifications for over 8,000 employees. 

Source: GAO analysis of court records, federal contract data, and 
Labor data. 

[A] A condition of compulsory service in which the victim is compelled 
to perform labor or services against the victim's will for the benefit 
of another person through, among other things, the use of force, 
threats of force, restraint, or use or threat of coercion through law 
or the legal process. 

[B] A condition in which the victim is forced to perform labor against 
the victim's will to pay off a debt. 

[End of table] 

In Undercover Tests, Most Recruiters Did Not Encourage H-2B Visa Fraud 
but Some Offered to Help Violate Laws and Regulations: 

Of the 18 recruiters in multiple states we contacted, 15 H-2B 
recruiters did not encourage our undercover agents posing as 
prospective H-2B employers and employees to violate H-2B program 
rules. Most recruiters told our fictitious employers that they would 
have to pay H-2B employees the appropriate prevailing wage, as well as 
advertise job openings in local markets before seeking H-2B 
certifications. Most recruiters also informed our fictitious employers 
that they would not be able to profit from fees charged to H-2B 
employees for expenses such as rent or travel. In addition, one 
recruiter correctly told our fictitious prospective H-2B employee that 
she would have to return to her home country before applying for H-2B 
worker status. 

However, in three cases recruiters offered advice on violating or 
evading program rules. A Texas recruiter suggested that we discourage 
American workers from accepting our landscaping job openings by having 
applicants run around the shop carrying a 50-pound bag to determine 
they were fit for the work. The recruiter also suggested conducting 
interviews before 7 a.m. and requiring drug testing prior to the 
interview as means to "weed out" qualified American applicants. In 
addition, the recruiter suggested that our current American landscape 
workers be fired "for cause" or induced to quit months before filing a 
petition for H-2B workers to avoid arousing suspicion by Labor. 
Furthermore, the recruiter made comments about recouping employer 
costs through "off-the-book" transactions for rent to avoid caps on 
payroll deductions. A recruiter in New York offered to provide "good 
excuses" to help "weed out" prospective U.S. workers who applied for 
our housekeeping jobs. 

We also found that recruiters we visited did not offer our undercover 
agents assistance in violating the rules of the H-2B program. A 
recruiter in Kentucky told us that it usually petitions Labor for more 
workers than needed in case the employer has to hire one or two U.S. 
workers. This allows the employer to still be able to obtain the 
amount of H-2B workers it was seeking. However, the recruiter 
suggested that interest in these positions is usually limited because 
of low wages. Additionally, the recruiter suggested that U.S. workers 
would only apply for our jobs so that they could continue to receive 
unemployment benefits. We selected two recruiters located in Texas and 
New York that we had contacted during our undercover phone calls, 
posed as prospective H-2B employers willing to pay a retainer fee, and 
sought their assistance to help us obtain H-2B workers and violate the 
rules of the program. These recruiters refused to offer assistance in 
violating the program rules or to accept our retainer fee. 

Our site visits to H-2B employee housing revealed that most of the 
workers we spoke with felt they had adequate housing, pay, and working 
conditions, though we did find some occurrences that were suspicious. 
H-2B employees at a circus in West Virginia with prior allegations of 
wage abuse and exorbitant recruitment fees stated that their employer 
provided adequate meals, transportation, and living accommodations 
that were not deducted from their salaries. The accommodations 
consisted of 6 to 7 employees living in one travel trailer. When our 
undercover agents asked to enter the trailer, the workers were adamant 
that no one was allowed inside without their employer's consent. We 
also visited known housing locations for H-2B seafood processing 
employees in North Carolina. The employees told our investigators that 
they were afraid to speak with outside individuals for fear of 
retaliation from the employer. One employee said that another employee 
had recently been fired and sent back to their home country for 
reporting a burglary at their housing location to the police. Again, 
we were not allowed inside the employees' housing. 

As agreed with your office, unless you publicly announce the contents 
of this report earlier, we plan no further distribution until 30 days 
from the report date. At that time, we will send copies to interested 
congressional committees, the Secretary of Labor, the Secretary of 
Homeland Security, and other interested parties. The report also will 
be available at no charge on the GAO Web site at [hyperlink, 
http://www.gao.gov]. 

If you or your staff have any questions about this report, please 
contact me at (202) 512-6722 or kutzg@gao.gov. Contact points for our 
Offices of Congressional Relations and Public Affairs may be found on 
the last page of this report. 

Sincerely yours, 

Signed by: 

Gregory D. Kutz: 
Managing Director Forensic Audits and Special Investigations: 

[End of section] 

Appendix I: Scope and Methodology: 

To identify court cases of illegal or fraudulent activity within the H-
2B visa program, we researched court documentation involving 
violations of the H-2B program in the last 5 years that resulted in a 
criminal conviction, civil or administrative liability, or significant 
financial settlement. To illustrate cases of fraudulent, illegal, and 
abusive activity in the H-2B program, we identified 10 closed cases 
for detailed audit and investigation. The 10 cases were selected from 
leads provided by advocacy groups and our own research based on 
criteria that provided indications of fraud and abuse. For example, to 
investigate methods used by H-2B employers and recruiters, we reviewed 
recent civil and criminal cases involving H-2B workers; obtained data 
from the Department of Labor (Labor)[Footnote 5] and the Department of 
Homeland Security's United States Citizenship and Immigration Services 
[Footnote 6] on H-2B visas issued; and interviewed representatives of 
advocacy groups that represent H-2B workers in litigation. The cases 
were associated with workers employed in 29 states and various 
industries to illustrate a broad range of abuse or fraud occurring in 
the H-2B program. 

To illustrate potential fraudulent recruiting methods utilized by H-2B 
recruiters, we conducted undercover calls to 18 U.S.-based H-2B 
recruiters and staffing agencies. These recruiters were selected from 
leads provided by advocacy groups and our own research. Using 
scenarios based on recent court cases and program requirements, we 
posed as potential employers and foreign workers to assess whether 
selected recruiters would advocate violating program laws and 
regulations. We also made undercover site visits to two selected 
recruiters that we had previously contacted by phone call. 

To identify potential instances of abuse, we conducted site visits of 
H-2B worker housing locations to identify instances of substandard 
housing accommodations or other forms of exploitation and the 
mistreatment of H-2B workers. These locations were selected from leads 
provided by advocacy groups and our own research. Case studies, site 
visits, and results of proactive testing cannot be projected to the 
entire population of H-2B employers and recruiters. 

We conducted the work for this investigation from April 2010 through 
September 2010 in accordance with the standards prescribed by the 
Council of Inspectors General for Integrity and Efficiency. 

[End of section] 

Footnotes: 

[1] An H-2B worker is defined as a foreign nonimmigrant worker 
employed by a U.S. employer to perform temporary nonagricultural labor 
or services. 8 U.S.C § 1101(a)(15)(H)(ii)(b). 

[2] A recruiter is an individual or company hired by U.S. businesses 
to identify and hire foreign workers for employment under the H-2B 
visa program. 

[3] H-2B workers are covered by the Fair Labor Standards Act (FLSA). 
FLSA establishes minimum wage, overtime pay, recordkeeping, and youth 
employment standards affecting employees in the private sector and in 
federal, state, and local governments. 

[4] According to Labor regulations, acceptable fees that are the 
responsibility of H-2B workers include passport or visa fees or 
reimbursement for the lesser of the actual cost or fair market value 
of transportation abroad. 

[5] Total number of records extracted may be understated because of 
the variation of each employer or representative name entered into the 
Labor database. 

[6] The data cover fiscal years 2008 and 2009 and the first 6 months 
of fiscal year 2010. 

[End of table] 

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