Summary
The applicant, a 69-year-old dual national of Finland and the U.S., sought a security clearance but was denied due to significant foreign influence and preference concerns. The applicant maintained close relationships with Finnish citizens, held substantial financial interests in Finland, and exercised his Finnish citizenship by voting in elections. The judge concluded that these connections raised security concerns that were not sufficiently mitigated.
Under Guideline B (Foreign Influence) and Guideline C (Foreign Preference), the Statement of Reasons alleged the following: Applicant admits that his sister is a citizen and resident of Finland. She is retired from working with an 'oil company.' He communicates with her through social media on a weekly basis, and physically speaks to her 'maybe four times a year.' (1.a). Applicant admits that his one brother is a citizen and resident of Finland. 'He is employed . . . [by] a Swedish industrial manufacturer.' His communications with this brother are similar to that with his sister, noted above (1.b). Applicant admits that his other brother is a citizen of Finland, but is a resident of France. He 'runs a business with a business partner.' This second brother's business is 'in industrial equipment used by the pharmaceutical industry.' Applicant has little contact with this brother, 'maybe once in two years.' (1.c). Applicant admits that he has a very close female friend who is a citizen of Finland, but who resides with Applicant much of the time in the United States. 'She's a correspondent for a Finnish newspaper.' They are romantically involved, and they also co-own an apartment in Finland valued at about $357,000 (1.d). Applicant has been an Honorary Counsel for Finland from about January of 2019 to the present. 'It's completely pro bono. . . . no budget, no money, no payment.' He dedicates 'two or three hours per month,' to this honorary service to the Finnish government (1.e). Applicant denies that he maintains a Finnish bank account with a value of over $800,000. He avers that its value varies between $10,000~$50,000 (1.f). Applicant denies that he maintains bank accounts and business interests, with his three children, in Finland valued at nearly $2,000,000. He avers that the bank accounts are about $30,000, and the business investment about $700,000 (1.g). Applicant denies that he maintains joint bank accounts with an individual and with two businesses in Finland, in the Netherlands, and in England. He is, in fact, CEO and co-owner of a U.S. business worth between $6,000,000 and $20,000,000 (1.h). Applicant admits that he co-owns investments in Finland valued at about $2,750. This amount is diminutive in light of Applicant's other foreign assets (1.i). As a dual-national, Applicant voted in the Finnish Presidential election in about January of 2018 (2.a). Applicant will receive a monthly pension of about $2,283 from Finland upon his retirement (2.b).
The judge denied the clearance. The government raised disqualifying conditions AG ¶ 7(a), AG ¶ 7(b), AG ¶ 7(e), AG ¶ 10(a), AG ¶ 10(d)(1). The decision turned on the following: The applicant's dual nationality and close ties to Finland raised significant security concerns under both foreign influence and preference guidelines; The applicant admitted to maintaining substantial financial interests in Finland, including co-ownership of property and investments, which created a potential conflict of interest; The applicant exercised his Finnish citizenship by voting in a foreign election, indicating a preference for Finland over the U.S.
Why the Applicant Was Denied
- The applicant's dual nationality and close ties to Finland raised significant security concerns under both foreign influence and preference guidelines.
- The applicant admitted to maintaining substantial financial interests in Finland, including co-ownership of property and investments, which created a potential conflict of interest.
- The applicant exercised his Finnish citizenship by voting in a foreign election, indicating a preference for Finland over the U.S.
Conditions Referenced
- AG ¶ 7(a)raisedContact with Foreign Family Members
- AG ¶ 7(b)raisedConnections to Foreign Persons Creating Potential Conflict of Interest
- AG ¶ 7(e)raisedSubstantial Business Interests in a Foreign Country
- AG ¶ 10(a)raisedAcquiring Citizenship in Another Country
- AG ¶ 10(d)(1)raisedParticipation in Foreign Activities
Key Rule Quoted
“The protection of the national security is the paramount consideration.”
Procedural Posture
- SOR issuedJun 4, 2021
- Answer filedJul 13, 2021
- Hearing heldJun 2, 2022
- Decision dateOct 5, 2022
Cite For
- Security Concerns Related to Dual Nationality Under Guideline B and C
- Impact of Foreign Financial Interests on Security Clearance Eligibility
- The Significance of Exercising Foreign Citizenship Rights in Security Clearance Determinations