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ISCR Case 23-02606 — CASE

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ISCR Case 23-02606

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

Case Profile
Decision Date3/9/2026
Statusgranted
LevelHEARING
TypeSTANDARD ISCR
Participants
Judge: Erin C. Hogan
Government Counsel: Daniel P. O'Reilley
Applicant's Counsel: Samir Nakleh
Case Summary
The applicant in this case was a 29-year-old employee of a Department of Defense (DOD) contractor, who had previously worked for another DOD contractor and held a security clearance since 2020. The Statement of Reasons (SOR) issued by the DOD raised concerns under Guideline B (foreign influence), primarily due to the applicant's dual citizenship with Libya and the dual citizenship of his immediate family members, including his parents and siblings. The SOR also noted the applicant's travel to Libya in July 2024 to visit his parents.
During the proceedings, the applicant admitted to the allegations in the SOR but provided context regarding his family's situation. He emphasized that he had never exercised his Libyan citizenship, held no foreign investments, and maintained all his financial accounts in the United States. The applicant's family members, while dual citizens, were not involved in Libyan politics or government, and he had limited communication with relatives in Libya due to language barriers. He also highlighted his employer's awareness of his dual citizenship and their support for his security clearance application.
The administrative judge ruled in favor of the applicant, concluding that he had sufficiently mitigated the foreign influence concerns. The judge noted the applicant's strong ties to the United States, including his education, employment, and lack of foreign affiliations or investments. The judge found that the applicant's family connections to Libya did not pose a significant risk to national security, leading to the decision to grant him eligibility for access to classified information.
Guidelines Evaluated
- Guideline BForeign Influence · For Applicant
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Case Headnote

ISCR Case No. 23-02606

grantedMar 9, 2026· Hon. Erin C. Hogan· hearing

Summary

A 29-year-old Department of Defense contractor was granted a security clearance despite concerns under Guideline B (Foreign Influence) related to his dual U.S. and Libyan citizenship. The Statement of Reasons noted that the applicant, his two brothers, three sisters, father, and mother all hold dual citizenship with the United States and Libya. Additionally, the applicant and one brother traveled to Libya in July 2024 to visit their parents, who were residing there at the time.

Disqualifying conditions under Guideline B were raised, specifically concerning foreign preference and foreign connections that could create a conflict of interest or foreign influence. However, the administrative judge applied several mitigating conditions. The applicant demonstrated that he has never exercised his Libyan citizenship, consistently using a U.S. passport for all travel.

Furthermore, all immediate family members are U.S. citizens residing in the United States, which was found to diminish the likelihood of divided allegiance. The applicant also disclosed his travel to Libya to his employer and received approval prior to his trip. These factors, demonstrating strong ties to the U.S. and a commitment to national interests, outweighed the potential risks, leading to the granting of the security clearance.

Why the Applicant Prevailed

The applicant has never exercised his Libyan citizenship and uses a U.S. passport for travel.
All immediate family members are U.S. citizens residing in the U.S., diminishing the likelihood of divided allegiance.
The applicant disclosed his travel to Libya to his employer and received approval before traveling.

Conditions Referenced

Disqualifying

AG ¶ 7(a)raisedContact with Foreign Family Members
AG ¶ 7(b)raisedConnections to Foreign Persons

Mitigating

AG ¶ 8(a)appliedNature of Relationships with Foreign Persons
AG ¶ 8(b)appliedMinimal Conflict of Interest
AG ¶ 8(c)appliedCasual and Infrequent Contact with Foreign Citizens

Key Rule Quoted

“The protection of the national security is the paramount consideration.”

Procedural Posture

SOR issuedJan 14, 2025
Answer filedFeb 12, 2025
Hearing heldJan 6, 2026via Microsoft Teams
Decision dateMar 9, 2026

Cite For

Mitigation of Foreign Influence Concerns Under Guideline B
Importance of U.S. Citizenship and Residency in Evaluating Foreign Influence
Consideration of the Whole-person Concept in Security Clearance Decisions

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: granted

The judge found that the applicant's foreign ties, including dual citizenship of his family members in Libya, were mitigated by his strong connections to the United States. The applicant admitted to the allegations but demonstrated a commitment to his U.S. citizenship and did not exercise his Libyan citizenship. The decision was granted, indicating that the applicant's foreign influence concerns were resolved favorably.

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: Naturalized U.S. Citizen · U.S. Home or Property · U.S. Career or Business · U.S. Financial Assets Predominant · Intent to Remain in U.S.

¶	Allegation	Finding	Relationship	Country	Response	Disqualifying (¶7)	Mitigating applied (¶8)	Mitigation
1.a	Applicant’s two brothers are dual citizens of the United States and Libya.	For Applicant	Sibling in Foreign Country Immediate Family	Libya HEIGHTENED RISK	Admitted	—	(a) relationships such that a conflict between foreign and U.S. interests is unlikely	Claimed Deep U.S. Ties
1.b	His three sisters are dual citizens of the United States and Libya.	For Applicant	Sibling in Foreign Country Immediate Family	Libya HEIGHTENED RISK	Admitted	—	(a) relationships such that a conflict between foreign and U.S. interests is unlikely	Claimed Deep U.S. Ties
1.c	His father is a dual citizen of the United States and Libya.	For Applicant	Parent in Foreign Country Immediate Family	Libya HEIGHTENED RISK	Admitted	—	(a) relationships such that a conflict between foreign and U.S. interests is unlikely	Claimed Deep U.S. Ties
1.d	His mother is a dual citizen of the United States and Libya.	For Applicant	Parent in Foreign Country Immediate Family	Libya HEIGHTENED RISK	Admitted	—	(a) relationships such that a conflict between foreign and U.S. interests is unlikely	Claimed Deep U.S. Ties
1.e	He and one of his brothers traveled to Libya in July 2024 to visit their mother and father who were residing in Libya at that time.	For Applicant	Unspecified Foreign Relationship Other	Libya HEIGHTENED RISK	Admitted	—	(a) relationships such that a conflict between foreign and U.S. interests is unlikely	Claimed Deep U.S. Ties

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

Full decision

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