Summary
A 61-year-old U.S. citizen and accountant was granted a security clearance despite concerns under Guideline B (Foreign Influence). The Statement of Reasons cited his ongoing contact with a Ukrainian national, a former translator, and her family, including her sister and brother-in-law. Additionally, the applicant held substantial financial interests in Germany, specifically a bank account with over $730,000 and a home valued at approximately $190,000. The U.S. State Department's advisory against travel to separatist-controlled areas of Ukraine, where U.S. citizens have faced detention, was also noted.
Disqualifying conditions under AG ¶ 7(a) and AG ¶ 7(f) were raised. However, the applicant mitigated these concerns by providing detailed disclosures of his foreign contacts, assets, and work history, satisfying AG ¶ 8(a) and AG ¶ 8(f).
The judge determined that the applicant's friendships with Ukrainian nationals were unlikely to create a conflict of interest between U.S. and foreign interests. Furthermore, his significant German assets were acquired through his professional career and were not deemed likely to lead to foreign influence. Consequently, the security clearance was granted.
Why the Applicant Prevailed
- The applicant disclosed detailed information about his foreign contacts and financial interests, demonstrating transparency.
- His friendships with Ukrainian nationals were not likely to place him in a position of conflict between U.S. and foreign interests.
- The applicant's substantial German-based assets were accumulated in the normal course of his professional life and are unlikely to result in foreign influence.
Conditions Referenced
- AG ¶ 7(a)raisedContact with Foreign NationalsThe applicant maintains close relationships with individuals who are residents and citizens of Ukraine.
- AG ¶ 7(f)raisedSubstantial Financial InterestsThe applicant has substantial financial assets in Germany that could subject him to foreign inducement.
- AG ¶ 8(a)appliedNature of RelationshipsThe applicant's friends are not involved in activities that would create a conflict of interest.
- AG ¶ 8(f)appliedRoutine Nature of Foreign InterestsThe applicant's financial interests in Germany are maintained as a convenience and are unlikely to result in a conflict.
Key Rule Quoted
“[F]oreign contacts and interests, including . . . financial and property interests, are a national security concern if they result in a divided allegiance [or] . . . 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.”
Procedural Posture
- SOR issuedMar 25, 2016
- Answer filed—Applicant requested a decision on the written record.
- Hearing held—Decision made based on written record.
- Decision dateOct 31, 2017
Cite For
- Mitigation of Foreign Influence Concerns Under Guideline B
- Importance of Full Disclosure of Foreign Contacts and Financial Interests
- Consideration of the Whole-person Concept in Security Clearance Decisions.