ISCR Case No. 24-01100

______________ ______________ DEPARTMENT OF DEFENSE DEFENSE OFFICE OF HEARINGS AND APPEALS In the matter of: Applicant for Security Clearance ) ) ) ) ) ISCR Case No. 24-01100 Appearances For Government: Sakeena Farhath, Esq., Department Counsel For Applicant: Pro se 11/13/2025

BLAZEWICK, Robert B., Chief Administrative Judge: Applicant did not provide sufficient evidence to mitigate the security concerns under Guideline B (Foreign Influence). The security concerns under Guideline C (Foreign Preference) and Guideline E (Personal Conduct) are mitigated. Eligibility for access to classified information is denied. Statement of the Case Applicant submitted a security clearance application (SCA) on April 28, 2023, in connection with his employment in the defense industry. On September 25, 2024, the Department of Defense (DOD) issued a Statement of Reasons (SOR) to Applicant detailing security concerns under Guidelines C, B, and E. Applicant responded to the SOR on November 27, 2024 (Answer) and requested a decision on the written record in lieu of a hearing. Department Counsel submitted the Government’s written case on February 26, 2025. A complete copy of the file of relevant material (FORM), including Items 1-4, was provided to Applicant, who was afforded an opportunity to file objections and submit material to refute, extenuate, or mitigate the security concerns. Applicant received the FORM on March 6, 2025, and he did not respond. The case was forwarded to the DOHA Hearing Office for assignment to an

administrative judge on April 22, 2025, and assigned on May 30, 2025. The Government exhibits included in the FORM are admitted in evidence without objection. The Government also requested I take administrative notice of certain facts relating to the Hashemite Kingdom of Jordan. Department Counsel provided a four-page summary of facts, supported by five Government references pertaining to Jordan, identified as Administrative Notice (AN) I. The documents provide elaboration and context for the summary. I take administrative notice of the facts included in the U.S. Government reports. They are limited to matters not subject to reasonable dispute. They are set out in the Findings of Fact.

Briefly, the Guideline C SOR allegations concern Applicant’s alleged past use of his Jordanian passport in lieu of his United States (U.S.) passport to enter and exit the U.S. on three oc

casions, as well as intended future use, and his statement that he has divided loyalties (SOR ¶¶ 1.a, 1.b). The Guideline B allegations concern his Jordanian parents and sister (SOR ¶¶ 2.a, 2.b) and a cross-allegation of the Guideline C allegations (SOR ¶ 2.c). The Guideline E allegations concern Applicant’s alleged failure to disclose use and purchase of marijuana on his SCA (SOR ¶ 3.a, 3.b). In his SOR Response, Applicant admitted all of the SOR allegations (¶¶ 1.a-1.b, 2.a-2.b, and 3.a-3.b, and the cross-allegation at SOR ¶ 2.c), with some brief additional comments. His SOR admissions are incorporated into the findings of fact. After a thorough and careful review of the pleadings and exhibits submitted, I make the following additional findings of fact. Applicant is 27 years old. He was born in the United Arab Emirates as a Jordanian citizen. He first entered the U.S. in January 2015 at age 17 but returned to Jordan in February 2015 to finish high school. After graduation, he returned to the U.S. in July 2015 and enrolled in a U.S. community college the following month. He received a bachelor’s degree in 2021 from a U.S. university. He has never married and does not have children. He became a naturalized U.S. citizen on December 13, 2021. He has been employed with a defense contractor as an engineer since January 2023. This is his first clearance application. (Item 3) Guideline C As of the date of his SCA, Applicant possessed a Jordanian passport issued on June 3, 2019, with an expiration date of June 2, 2024. He traveled to Jordan on that passport from July 2019 to August 2019; June 2021 to July 2021; and August 2022 to October 2022. He was issued a U.S. passport on January 20, 2022, shortly after becoming a U.S citizen. (Item 3) When discussing his two passports during his September 2023 subject interview with a government investigator (SI), Applicant stated that he obtained his Jordanian

passport for travel purposes, specifically because using a Jordanian passport allows him to travel to Jordan without applying for a visa. (In fact, this Jordanian passport was issued at a time when he was not yet a U.S. citizen.) The summary of the interview states, “[h]e intends to continue to use a Jordan passport to enter and exit the US for the same reason.” He stated that he would not surrender his Jordanian passport as a condition of employment or for his clearance unless it was required, and he had a guarantee his employment would be protected. He intends to renew his Jordanian passport. (Item 4) Applicant’s most recent Jordanian passport, issued in 2019, expired in June 2024, as noted above. In August 2024, in response to interrogatories, he stated he will renew the passport if he needs it for some reason. He also provided a full copy of his expired Jordanian passport, which reflects trips to Jordan in 2019, 2021, and 2022. It also has U.S. “Admitted” stamps corresponding to his return trips in 2019 and 2021, but there are no U.S. stamps corresponding to the 2022 trip. (Item 4) In his Answer, Applicant admitted SOR ¶ 1.a, stating “I will use the Jordanian passport if it makes my trip easier. I will use the U.S. passport if it makes my trip easier.” It is unclear if this statement means he has renewed his Jordanian passport since his August 2024 response to interrogatories, or if he is speaking hypothetically. There is no documentary evidence of a current Jordanian passport in the record. (Answer) Applicant also told the interviewer that “[h]e does not have allegiance to one country over the other because he views them as equal. He has no conflicts between allegiances.” He stated that, apart from possessing and using a Jordanian passport, he does not have any rights, privileges, benefits of, or obligations to, Jordan. He maintains dual citizenship because he has no reason to renounce his Jordanian citizenship, nor is he willing to. If his employer required it, he would renounce his Jordanian citizenship, provided he was given a contract ensuring his employment was protected. (Item 4) Guideline B Applicant’s mother is a Jordanian citizen who resides in the U.S. as a legal permanent resident. He reported her legal permanent resident card expiration date was January 23, 2025. The record is silent as to whether her permanent residency was renewed or if there have been any changes in her immigration status since the expiration date. Applicant lives with his mother, and they have daily in-person and telephonic contact. She has never been employed. (Items 3, 4) On his SCA and in his SI, Applicant reported his father as a Jordanian citizen who resides in the U.S. as a legal permanent resident. Applicant reported his father’s legal permanent resident card expiration date as March 31, 2025. In his response to interrogatories, Applicant listed his father as a dual U.S./Jordanian citizen without providing any further information pertaining to his father’s change in immigration status. Applicant lives with his father and reported daily in-person and telephonic contact with him in his SCA and SI, but in his response to interrogatories, he stated he has weekly

telephonic contact with his father. Applicant’s father works for a cellular phone service company. (Items 3, 4) On his SCA and in his SI, Applicant listed his three brothers as two U.S. citizens and one dual U.S./Jordanian citizen and reported that all three lived with Applicant, where he had daily contact with them. In his response to interrogatories, Applicant clarified that all three brothers are dual U.S./Jordanian citizens and listed two of the brothers as living in a different town than the rest of the family, with weekly in-person contact instead of daily. It appears that the third brother still lives with Applicant, but it is unclear from the information he provided. (Items 3, 4) Applicant’s sister is a Jordanian citizen living as a lawful permanent resident with Applicant in the U.S., where they have daily in-person contact. Her lawful permanent resident card expires in May 2033. She previously worked as a teacher in Jordan but does not currently work. (Items 3, 4) Applicant reported in his response to interrogatories that none of his relatives have ties to a foreign military or government. He also listed a friend with dual U.S./Jordanian citizenship who lives in the same town as Applicant, with no ties to a foreign military or government. Applicant reported that he does not have any financial assets, interests, or obligations in any foreign country. (Item 4) Applicant listed only two personal references, including one relative, on his 2023 SCA, when he was asked to list three non-relatives. (Item 3). When he was asked about this during his SI, Applicant stated he had no one else to list under that section. According to the interviewer, “[Applicant] refused [to provide two additional references] because he does not want anyone he knows to be bothered by the government because of him.” Applicant told the interviewer he was fine with being considered uncooperative for his response. (Item 4) Guideline E On Applicant’s 2023 SCA, when asked whether he had used any illegal drugs or controlled substances in the last seven years, he answered “no.” When asked whether he had illegally purchased any drug or controlled substance in the last seven years, he answered, “no.” (Item 3) In his SI, however, Applicant volunteered that he has used and purchased marijuana. His first use was in 2017 or 2018, and his most recent use was January 2022. He estimated his total use as three to four times during the reported timeframe. He purchased it once from a dispensary and once from an individual. He chose to purchase and use marijuana out of curiosity. He told the investigator his drug use was purposely omitted on the SCA “because he was afraid of being fired from [his employer] if it was disclosed to the company.” (Item 4)

In his response to interrogatories, Applicant listed his first date of use and purchase of marijuana as 2017, last date of use and purchase as January 2022, and he stated he used it a total of six times and purchased twice. He stated he does not intend to use or purchase marijuana in the future. He stated he has not made any changes in his personal or professional life that would be indicative of a change of lifestyle away from his past drug usage. In his Answer, Applicant stated he used marijuana two or three times. (Item 4, Answer) The Hashemite Kingdom of Jordan The Hashemite Kingdom of Jordan (Jordan) is a relatively stable country, but it lies in a region rife with instability and high tensions. Because of this, the threat of terrorism is high, with the U.S. Department of State currently issuing a Level 2 travel advisory (exercise increased caution) for Jordan and a Level 4 travel advisory (do not travel) for Jordan’s border with Syria and Iraq, refugee camps, and several other areas. Jordan is regularly threatened with transnational and indigenous terrorist groups conducting or supporting attacks in Jordan, particularly along its borders with Syria and Iraq. Terrorists may also target U.S. and Western citizens and interests, with possible targets such as tourist sites, hotels, restaurants, malls, and similar “soft” targets. Jordan has actively worked to prevent terrorist attacks and counter violent extremism; it is one of the largest recipients of U.S. military aid in the region; it cooperates with the U.S. on several issues including counterterrorism; and it has Major Non-NATO Ally status with the U.S. Jordan faces several significant human rights issues such as torture, arbitrary arrest and detention, gender-based violence and violence against LGBTQ+ persons, and restrictions on freedom of the press, expression, assembly, and association. The government has taken some steps to investigate and prosecute those who committed human rights abuses, but government impunity for such abuses remains widespread.

This case is adjudicated under Executive Order (EO) 10865, Safeguarding Classified Information within Industry (February 20, 1960), as amended; DOD Directive 5220.6, Defense Industrial Personnel Security Clearance Review Program (January 2, 1992), as amended (Directive); and the adjudicative guidelines (AG) implemented by the DOD on June 8, 2017. “[N]o one has a ‘right’ to a security clearance.” Department of the Navy v. Egan, 484 U.S. 518, 528 (1988). As Commander in Chief, the President has the authority to “control access to information bearing on national security and to determine whether an individual is sufficiently trustworthy to have access to such information.” Id. at 527. The President has authorized the Secretary of Defense or his designee to grant applicants eligibility for access to classified information “only upon a finding that it is clearly consistent with the national interest to do so.” EO 10865 § 2.

Eligibility for a security clearance is predicated upon the applicant meeting the criteria contained in the adjudicative guidelines. These guidelines are not inflexible rules of law. Instead, recognizing the complexities of human behavior, an administrative judge applies these guidelines in conjunction with an evaluation of the whole person. An administrative judge’s overarching adjudicative goal is a fair, impartial, and commonsense decision. An administrative judge must consider all available and reliable information about the person, past and present, favorable and unfavorable. The Government reposes a high degree of trust and confidence in persons with access to classified information. This relationship transcends normal duty hours and endures throughout off-duty hours. Decisions include, by necessity, consideration of the possible risk that the applicant may deliberately or inadvertently fail to safeguard classified information. Such decisions entail a certain degree of legally permissible extrapolation about potential, rather than actual, risk of compromise of classified information. Clearance decisions must be made “in terms of the national interest and shall in no sense be a determination as to the loyalty of the applicant concerned.” EO 10865 § 7. Thus, a decision to deny a security clearance is merely an indication the applicant has not met the strict guidelines the President and the Secretary of Defense have established for issuing a clearance. Initially, the Government must establish, by substantial evidence, conditions in the personal or professional history of the applicant that may disqualify the applicant from being eligible for access to classified information. The Government has the burden of establishing controverted facts alleged in the SOR. See Egan at 531. “Substantial evidence” is “more than a scintilla but less than a preponderance.” See v. Washington Metro. Area Transit Auth., 36 F.3d 375, 380 (4th Cir. 1994). The guidelines presume a nexus or rational connection between proven conduct under any of the criteria listed therein and an applicant’s security suitability. See ISCR Case No. 15-01253 at 3 (App. Bd. Apr. 20, 2016). Once the Government establishes a disqualifying condition by substantial evidence, the burden shifts to the applicant to rebut, explain, extenuate, or mitigate the facts. Directive ¶ E3.1.15. An applicant has the burden of proving a mitigating condition, and the burden of disproving it never shifts to the Government. See ISCR Case No. 02- 31154 at 5 (App. Bd. Sep. 22, 2005). An applicant “has the ultimate burden of demonstrating that it is clearly consistent with the national interest to grant or continue his security clearance.” ISCR Case No. 01­ 20700 at 3 (App. Bd. Dec. 19, 2002). “[S]ecurity clearance determinations should err, if they must, on the side of denials.” Egan at 531.

Guideline C, Foreign Preference

The security concern for foreign preference is set out in AG ¶ 9: When an individual acts in such a way as to indicate a preference for a foreign country over the United States, then he or she may provide information or make decisions that are harmful to the interests of the United States. Foreign involvement raises concerns about an individual’s judgment, reliability, and trustworthiness when it is in conflict with U.S. national interests or when the individual acts to conceal it. By itself; the fact that a U.S. citizen is also a citizen of another country is not disqualifying without an objective showing of such conflict or attempt at concealment. The same is true for a U.S. citizen’s exercise of any right or privilege of foreign citizenship and any action to acquire or obtain recognition of a foreign citizenship. The guideline notes several conditions that could raise security concerns under AG ¶ 10. The following disqualifying condition is potentially applicable in this case: (c) failure to use a U.S. passport when entering or exiting the U.S. As drafted, SOR ¶ 1.a really concerns two separate issues: 1) Applicant’s prior use of his Jordanian passport; and 2) his stated future intention to do so. These are taken in turn. With regard to the first issue, the evidence does not establish the allegation. Applicant was not a U.S. citizen in 2019 or June to July of 2021. He was not issued a U.S. passport until January 2022, shortly after becoming a U.S. citizen. Despite Applicant’s “admission” to SOR ¶ 1.a, there are no security concerns about his use of his Jordanian passport to enter or exit the United States in 2019 and 2021, since he was not yet a U.S. citizen with a U.S. passport. This leaves only his August to October 2022 trip to Jordan. As to this trip, it is significant that Applicant’s Jordanian passport does not include a U.S. admission stamp like his prior two trips did. Although not conclusive evidence that he entered the U.S. with his U.S. passport, it likewise is not enough to prove that he used his Jordanian passport to enter the U.S. in 2022. Thus, no Guideline C security concern is established for any of Applicant’s trips to Jordan. AG ¶ 10(c) does not apply. This leaves only the portion of SOR ¶ 1.a concerning Applicant’s future intentions. It is important to note that the record is unclear at best as to whether Applicant even has a current Jordanian passport, as there is no documentary record of this. Here, the Government seems to be relying on Applicant’s SI statement that he intends to use his Jordanian passport to enter and exit the U.S. “for the same reason” that he uses the Jordanian one to enter and exit Jordan, i.e., the ability to travel without a visa. This statement essentially makes no logical sense, particularly in light of Applicant’s Answer stating “I will use the Jordanian passport if it makes my trip easier. I will use the U.S. passport if it makes my trip easier.” It is common knowledge that entering and exiting a

country is easiest for that country’s citizens. Using a different passport to enter and exit a country in which one is a citizen could very likely raise suspicion and potentially lead to questioning by the authorities, causing unnecessary delays and scrutiny. Given Applicant’s stated goal of smooth travel, his SI statement is almost certainly either a typo or a misunderstanding. SOR ¶ 1.a is found for Applicant. With regard to SOR ¶ 1.b, the allegation fails to raise a disqualifying condition, and it does not constitute conduct discussed in the security concern under Guideline C. Nowhere in the evidence does Applicant express a preference for Jordan over the United States, nor is there evidence that he has taken actions indicating a preference for Jordan over the United States, such as those listed in AG ¶ 10. The fact that Applicant has expressed divided loyalties between the United States and Jordan that he cannot resolve is perhaps better addressed under Guideline B, since those divided loyalties are perhaps the essence of a Guideline B security concern. This will be addressed further in discussing the cross-allegation at SOR ¶ 2.c, below. But as for Guideline C, I conclude that no disqualifying conditions are established. SOR ¶ 1.b is found for Applicant. Guideline B, Foreign Influence The security concern for foreign influence is set out in AG ¶ 6: Foreign contacts and interests, including, but not limited to, business, financial, and property interests, are a national security concern if they result in divided al

legiance. They may also be a national security concern if they create circumstances in which the individual may be manipulated or induced to help a foreign person, group, organization, or government in a way inconsistent with U.S. interests or otherwise made vulnerable to pressure or coercion by any foreign interest. Assessment of foreign contacts and interests should consider the country in which the foreign contact or interest is located, including, but not limited to, considerations such as whether it is known to target U.S. citizens to obtain classified or sensitive information or is associated with a risk of terrorism. The guideline notes several conditions that could raise security concerns under AG ¶ 7. The following are potentially applicable in this case: (a) contact, regardless of method, with a foreign family member, business or professional associate, friend, or other person who is a citizen of or resident in a foreign country if that contact creates a heightened risk of foreign exploitation, inducement, manipulation, pressure, or coercion; (b) connections to a foreign person, group, government, or country that create a potential conflict of interest between the individual’s obligation to

protect classified or sensitive information or technology and the individual’s desire to help a foreign person, group, or country by providing that information or technology; and (e) shared living quarters with a person or persons, regardless of citizenship status, if that relationship creates a heightened risk of foreign inducement, manipulation, pressure, or coercion. Guideline B is not limited to countries hostile to the United States. “The United States has a compelling interest in protecting and safeguarding classified information from any person, organization, or country that is not authorized to have access to it, regardless of whether that person, organization, or country has interests inimical to those of the United States.” ISCR Case No. 02-11570 at 5 (App. Bd. May 19, 2004). Nevertheless, the nature of a nation’s government and its relationship with the United States are relevant in assessing the likelihood that an applicant’s family members are vulnerable to government coercion. The risk of coercion, persuasion, or duress is significantly greater if the foreign country has an authoritarian government, or if a family member is associated with or dependent upon the government. An administrative judge must also consider any terrorist activity in the country at issue. AG ¶ 7(a) requires substantial evidence of a “heightened risk.” The “heightened risk” required to raise one of these disqualifying conditions is a relatively low standard. “Heightened risk” denotes a risk greater than the normal risk inherent in having a family member living under a foreign government. See, e.g., ISCR Case No. 12-05839 at 4 (App. Bd. Jul. 11, 2013). Applicant’s family connections and the risk of terrorism in Jordan are sufficient to establish a “heightened risk.” AG ¶¶ 7(a), 7(b), and 7(e) apply to SOR ¶¶ 2.a and 2.b. SOR ¶ 2.c is found for Applicant with regard to the cross-allegation of SOR ¶ 1.a (passport use) for the reasons discussed above under Guideline C. However, AG ¶¶ 7(a), 7(b), and 7(e) apply to SOR ¶ 2.c with regard to the cross-allegation of SOR ¶ 1.b (divided loyalties). The first sentence of the general concern of Guideline B specifically refers to divided allegiance: “Foreign contacts and interests, including, but not limited to, business, financial, and property interests, are a national security concern if they result in divided allegiance.” (AG ¶ 6, emphasis added) The issue of divided or dual allegiance goes to the heart of the Guideline B concern, since such a statement places Applicant’s allegiances at issue by definition, and the listed disqualifying conditions all contemplate a scenario involving a conflict of interest. AG ¶ 8 provides conditions that could mitigate security concerns. The following are potentially applicable: (a) the nature of the relationships with foreign persons, the country in which these persons are located, or the positions or activities of those persons in that country are such that it is unlikely the individual will be placed in a

position of having to choose between the interests of a foreign individual, group, organization, or government and the interests of the United States; (b) there is no conflict of interest, either because the individual’s sense of loyalty or obligation to the foreign person, or allegiance to the group, government, or country is so minimal, or the individual has such deep and longstanding relationships and l oyalties in the United States, that the individual can be expected to resolve any conflict of interest in favor of the U.S. interests; and (c) contact or communication with foreign citizens is so casual or infrequent that there is little likelihood that it could create a risk of foreign influence or exploitation. Applicant’s contacts with his parents and sister are not minimal, casual, or infrequent, given that they live together and have daily contact. As discussed above, Applicant feels an equal sense of loyalty to the U.S. and to Jordan. The record contains thin evidence regarding his ties to the U.S., and it is concerning that he was either unable or unwilling to provide non-relative references on his SCA and in his SI, preferring to be considered uncooperative for his response. Given these facts, the evidence does not support the conclusion that Applicant can be expected to resolve any conflict of interest in favor of the U.S. interest. With that in mind, although all three alleged family members lawfully reside in the U.S., given the evidence of a “heightened risk” with regard to Jordan, his closeness to his family, his lack of known ties to the U.S., and his divided allegiance, Applicant is already in a position of potentially having to choose between the interests of a foreign individual, group, organization, or government and the interests of the United States. None of the mitigating conditions are established. Guideline E, Personal Conduct The security concern for personal conduct is set out in AG ¶ 15: Conduct involving questionable judgment, lack of candor, dishonesty, or unwillingness to comply with rules and regulations can raise questions about an individual’s reliability, trustworthiness, and ability to protect classified or sensitive information. Of special interest is any failure to cooperate or provide truthful and candid answers during national security investigative or adjudicative processes. The guideline notes several conditions that could raise security concerns under AG ¶ 16. The following is potentially applicable in this case: (a) deliberate omission, concealment, or falsification of relevant facts from any personnel security questionnaire, personal history statement, or similar form used to conduct investigations, determine employment qualifications,

award benefits or status, determine security clearance eligibility or trustworthiness, or award fiduciary responsibilities. Applicant admitted that he purposed omitted his drug use and purchase on the SCA because he was afraid it would affect his employment. AG ¶ 16(a) is established. AG ¶ 17 provides conditions that could mitigate personal conduct security concerns. The following mitigating conditions potentially apply in Applicant’s case: (a) the individual made prompt, good-faith efforts to correct the omission, concealment, or falsification before being confronted with the facts; and (c) the offense is so minor, or so much time has passed, or the behavior is so infrequent, or it happened under such unique circumstances that it is unlikely to recur and does not cast doubt on the individual’s reliability, trustworthiness, or good judgment. Applicant volunteered his drug use and purchase at the SI and admitted that he intentionally omitted that information. I also considered that Applicant is relatively young, with no military or government background, and this was his first security clearance application. The omission is not minor but given that he provided the information unprompted at his interview, and over two years have passed, I find that this concern has been mitigated. AG ¶¶ 17(a) and 17(c) apply.

Under AG ¶ 2(c), the ultimate determination of whether to grant eligibility for a security clearance must be an overall commonsense judgment based upon careful consideration of the guidelines and the whole-person concept. In applying the whole- person concept, an administrative judge must evaluate an applicant’s eligibility for a security clearance by considering the totality of the applicant’s conduct and all relevant circumstances. An administrative judge should consider the nine adjudicative process factors listed at AG ¶ 2(d): (1) the nature, extent, and seriousness of the conduct; (2) the circumstances surrounding the conduct, to include knowledgeable participation; (3) the frequency and recency of the conduct; (4) the individual’s age and maturity at the time of the conduct; (5) the extent to which participation is voluntary; (6) the presence or absence of rehabilitation and other permanent behavioral changes; (7) the motivation for the conduct; (8) the potential for pressure, coercion, exploitation, or duress; and (9) the likelihood of continuation or recurrence. I have incorporated my comments under Guideline B in my whole-person analysis and applied the adjudicative factors in AG ¶ 2(d). Because Applicant requested a

________________________ determination on the record without a hearing, I had no opportunity to evaluate his credibility and sincerity based on demeanor. See ISCR Case No. 01-12350 at 3-4 (App. Bd. Jul. 23, 2003). “Once a concern arises regarding an applicant’s security clearance eligibility, there is a strong presumption against the grant or maintenance of a security clearance.” ISCR Case No. 09-01652 at 3 (App. Bd. Aug. 8, 2011), citing Dorfmont v. Brown, 913 F.2d 1399, 1401 (9th Cir. 1990), cert. denied, 4999 U.S. 905 (1991). Applicant has not overcome this presumption. After weighing the disqualifying and mitigating conditions under Guideline B and ev

aluating all the evidence in the c ontext of the whole person, I conclude Applicant has not mitigated the security concerns raised by the foreign influence allegations.

Formal findings for or against Applicant on the allegations set forth in the SOR, as required by section E3.1.25 of Enclosure 3 of the Directive, are: Paragraph 1, Guideline C ( Foreign Preference): FOR APPLICANT Subparagraphs 1.a-1.b: For Applicant Paragraph 2, Guideline B (Foreign Influence): AGAINST APPLICANT Subparagraphs 2.a-2.b: Against Applicant Subparagraph 2.c: For Applicant with regard to SOR ¶ 1.a; Against Applicant with regard to SOR ¶ 1.b

Paragraph 3, Guideline E (Personal Conduct) FOR APPLICANT Subparagraphs 3.a-b: For Applicant

I conclude that it is not clearly consistent with the interests of national security to grant Applicant eligibility for access to classified information. Clearance is denied. Robert B. Blazewick Chief Administrative Judge