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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 Date12/2/2025
Statusdenied
LevelHEARING
TypeSTANDARD ISCR
Related decisionSee the appeal decision (Case 22-02129) →
Participants
Judge: Wilford H. Ross
Government Counsel: Aubrey M. De Angelis
Applicant's Counsel: Nekeisha Campbell
Case Summary
The applicant in this case was a 43-year-old senior analyst employed by a defense contractor, with prior military service in the Army and experience in the intelligence field. The Department of Defense issued a Statement of Reasons (SOR) citing security concerns under Guidelines E (Personal Conduct) and B (Foreign Influence). The core allegations included poor judgment and untrustworthiness due to her foreign contacts and financial dealings with individuals in China, which raised concerns about divided allegiance and potential coercion.
The applicant admitted to some allegations, including her foreign financial transactions and certain aspects of her personal conduct, but denied others, claiming misunderstandings or lack of close relationships with the individuals involved. She explained that she had used a friend in China to facilitate a currency transfer due to restrictive policies, and admitted to lying during interviews with federal agencies about her foreign contacts and the nature of her interactions with Chinese operatives. Despite her explanations, the administrative judge found that the applicant's actions demonstrated a lack of candor and reliability.
The administrative judge ruled against the applicant, concluding that she had not sufficiently mitigated the security concerns under the relevant guidelines. The judge emphasized the applicant's repeated dishonesty during interviews and the potential risks posed by her foreign connections, ultimately denying her eligibility for access to classified information.
Guidelines Evaluated
- Guideline BForeign Influence · Against Applicant
- Guideline EPersonal Conduct · Against Applicant
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Case Headnote

ISCR Case No. 22-02129

deniedDec 2, 2025· Hon. Wilford H. Ross· hearing

Summary

A 43-year-old defense contractor and former military intelligence professional was denied a security clearance under Guidelines B (Foreign Influence) and E (Personal Conduct). The denial stemmed from allegations that the applicant possessed foreign contacts and interests that could pose a national security concern and potentially lead to divided allegiance. Specifically, the applicant failed to report foreign contacts during travel to China.

Furthermore, the applicant was found to have engaged in conduct demonstrating poor judgment, untrustworthiness, or unreliability. This included lying during multiple interviews with federal investigators about her foreign contacts and financial transactions. The judge determined that the applicant's foreign relationships and financial dealings created a heightened risk of foreign exploitation and manipulation.

Ultimately, the applicant's lack of candor and questionable judgment regarding these matters undermined her trustworthiness, leading to the denial of her security clearance.

Why the Applicant Was Denied

The applicant lied during multiple interviews with federal investigators about her foreign contacts and financial transactions.
The applicant's foreign relationships and financial dealings created a heightened risk of foreign exploitation and manipulation.
The applicant's conduct demonstrated a lack of candor and questionable judgment, undermining her trustworthiness.

Conditions Referenced

Disqualifying

AG ¶ 6(a)raisedContact with Foreign Family Members or Associates
AG ¶ 6(b)raisedConnections to Foreign Persons Creating Potential Conflict of Interest
AG ¶ 6(c)raisedFailure to Report Foreign Contacts
AG ¶ 7(a)appliedContact with Foreign Persons Creating Risk of Exploitation
AG ¶ 7(b)appliedConnections to Foreign Persons Creating Potential Conflict of Interest
AG ¶ 7(c)appliedFailure to Report Foreign Contacts

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 filedJul 25, 2024
Hearing heldJul 8, 2025Hearing was scheduled as planned.
Decision dateDec 2, 2025Decision delayed due to federal government shutdown.

Cite For

Denial of Clearance Due to Lack of Candor Under Guideline E
Foreign Influence Concerns Under Guideline B
Impact of Dishonesty on Security Clearance Eligibility

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

Standardized Decision Profile

SEAD-4 Guideline B (Foreign Influence) · descriptive summary of a decided case

Posture: HearingDecided: denied

The judge found against the applicant on all allegations related to foreign influence, determining that her foreign contacts and interests posed a national security concern and could lead to divided allegiance. The applicant's failure to report foreign contacts during her travel to China further contributed to the negative findings, resulting in a denied security clearance.

Country conditions:the decision took administrative notice of official facts about the foreign country (the Government’s country submission).

U.S. ties the decision noted: U.S. Military or Government Service

¶	Allegation	Finding	Relationship	Country	Response	Disqualifying (¶7)	Mitigating applied (¶8)	Mitigation
2.a	Applicant has foreign contacts and interests that may be a national security concern.	Against Applicant	Unspecified Foreign Relationship Other	— HEIGHTENED RISK	Admitted	—	—	—
2.b	Applicant's foreign contacts may result in divided allegiance.	Against Applicant	Unspecified Foreign Relationship Other	— HEIGHTENED RISK	Admitted	—	—	—
2.c	Applicant failed to report foreign contacts during her travel to China.	Against Applicant	Unspecified Foreign Relationship Other	China HEIGHTENED RISK	Denied	—	—	—

Descriptive standardized rendering of a decided public case (Guideline B). The verbatim source decision is shown in full below.

Standardized Decision Profile

SEAD-4 Guideline E (Personal Conduct) · descriptive summary of a decided case

Posture: HearingDecided: denied

The judge found against the applicant on the personal conduct allegations, determining that her actions demonstrated poor judgment and untrustworthiness. The applicant admitted to some allegations but denied others, particularly regarding her honesty during interviews about foreign contacts. Ultimately, the judge concluded that the applicant's conduct did not mitigate the concerns raised.

¶	Allegation	Finding	Conduct	Concealed Issue	Response	Disqualifying (¶16)	Mitigating applied (¶17)	Mitigation
1.a	Applicant is ineligible for clearance because she has engaged in conduct that shows poor judgment, untrustworthiness, or unreliability.	Against Applicant	Questionable Judgment General	—	Admitted	—	—	—
1.b	Applicant lied during interviews with federal investigators about her foreign contacts.	Against Applicant	Lack of Candor in InterviewFOUND DELIBERATE	Foreign Contacts or Interests	Denied	(a) deliberate omission, concealment, or falsification on a security form	—	—

Descriptive standardized rendering of a decided public case (Guideline E). The verbatim source decision is shown in full below.

Full decision

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