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ISCR Case 22-02129 — CASE

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ISCR Case 22-02129

A decided public DOHA case, shown for research — not advice or a prediction.

Case Profile
Decision Date2/11/2026
Statusdenied
LevelAPPEAL
TypeSTANDARD ISCR
Related decisionSee the hearing decision (Case 22-02129) →
Participants
Judge: Moira D. Modzelewski, Allison Marie, Jennifer I. Goldstein
Government Counsel: Andrea M. Corrales
Case Summary
The applicant in ISCR Case No. 22-02129 sought a security clearance from the Department of Defense (DoD), which was denied based on concerns under Guideline B (Foreign Influence) and Guideline E (Personal Conduct). The Statement of Reasons (SOR) indicated that the applicant had familial and social ties to individuals in China, including an uncle, an aunt, and four friends, and alleged that she failed to disclose these associations during interviews with U.S. government agencies. Additionally, the SOR noted that she did not report assistance from a Chinese contact in transferring approximately $350,000 from China to the United States.
The administrative judge found that the applicant admitted to having these connections but denied any intent to conceal them. She argued that her actions were influenced by personal circumstances, specifically the death of her father in 2015. However, the judge determined that her failure to disclose these relationships and the significant financial transaction indicated a lack of judgment and trustworthiness. The judge concluded that the applicant's foreign influence and personal conduct were unmitigated, affirming the denial of her security clearance. The appeal board upheld this decision, stating that the judge had adequately considered the evidence and provided a rational basis for the conclusions reached.
Guidelines Evaluated
- Guideline BForeign Influence · Against Applicant
- Guideline EPersonal Conduct · Against Applicant
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Case Headnote

ISCR Case No. 22-02129

Feb 11, 2026· Hon. Moira D. Modzelewski· appeal

Summary

An applicant, represented by counsel, was denied a security clearance due to concerns under Guideline B (Foreign Influence) and Guideline E (Personal Conduct). The denial stemmed from the applicant's failure to disclose significant foreign associations and financial transactions.

Specifically, the applicant did not disclose family and friends residing in China. Furthermore, the applicant intentionally concealed financial transactions totaling approximately $350,000, which were transferred from China to the U.S.

Despite the consideration of mitigating conditions AG ¶ 8(a), AG ¶ 8(b), AG ¶ 8(c), and AG ¶ 17(c), the judges found these unpersuasive. Ultimately, no mitigating factors were found sufficient to support granting a security clearance, leading to the denial of the appeal.

Conditions Referenced

Disqualifying

Guideline BraisedForeign Influence
Guideline EraisedPersonal Conduct

Mitigating

AG ¶ 8(a)rejectedNature of Relationships with Foreign PersonsThe judge found the relationships significant enough to warrant concealment.
AG ¶ 8(b)rejectedConflict of InterestThe applicant's concealment indicated a potential conflict of interest.
AG ¶ 8(c)rejectedCasual and Infrequent ContactThe applicant's relationships were deemed significant and not casual.
AG ¶ 17(c)rejectedMinor Offense or Unique CircumstancesThe applicant's repeated falsifications were not limited to a unique time period.

Key Rule Quoted

“Any doubt concerning personnel being considered for national security eligibility will be resolved in favor of the national security.”
— AG ¶ 2(b)

Procedural Posture

SOR issuedJun 6, 2024
Answer filed—
Hearing held—
Decision dateFeb 11, 2026Decision affirmed on appeal.

Cite For

Failure to Disclose Foreign Associations Under Guideline B
Intentional Concealment of Financial Transactions Under Guideline E
Standards for Evaluating Mitigating Conditions in Security Clearance Cases

Editorial summary generated for research. Not legal advice; not a prediction. Verify against the full decision before relying on any quoted language.

Appeal at a glance· Full written decision

Affirmed

The appeal involved a denial of security clearance based on foreign influence and personal conduct concerns. The applicant argued that the Judge failed to properly weigh evidence and apply mitigating factors. The Board affirmed the decision, finding no harmful error in the Judge's analysis.

Appealed bythe applicant

Applicant representationAttorney

Judge belowWilford H. Ross — denied the clearance

Decided ona hearing

Guidelines belowGuideline BGuideline E

What the Board reviewed

Judge mis-weighed or ignored evidence — raised by the applicantRejected
Applicant argued that the Judge failed to give proper weight to record evidence and applicable mitigating factors.
Mitigation wrongly applied / not applied — raised by the applicantRejected
Applicant contended that the Judge failed to properly analyze evidence in support of mitigating conditions.

Why the Board ruled this way

The Board found that the Judge properly considered all relevant issues and applied the mitigating conditions appropriately, affirming the denial of the security clearance.

Standard of review applied

Harmful-error gatekeeperSubstantial-evidence reviewArbitrary-and-capricious reviewProcedural complianceNo de-novo re-decisionNo new evidence on appealDeference to the judge’s credibility calls

Appeal Board panel

Moira Modzelewski — Chair
Allison Marie
Jennifer Goldstein

Descriptive structured reading of this decided, public Appeal Board decision — what the case says, not a prediction or advice.

Full decision

The complete, official text — footnotes and signatures included — is in the original PDF.