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ISCR Case 16-01311.h1 — CASE

ISCR Case 16-01311.h1granted

Case Headnote

ISCR Case No. 16-01311.h1

grantedJul 20, 2017· Hon. Juan J. Rivera· hearing

Summary

A 54-year-old naturalized U.S. citizen, originally from Iraq and working as a linguist, was granted a security clearance despite concerns under Guideline B (Foreign Influence). Disqualifying conditions were raised regarding the applicant's family members and property interests in Iraq.

However, the judge found that these concerns were mitigated by several factors. The applicant demonstrated a long track record of loyalty to the United States, including service under enemy fire, and had developed deep, long-lasting bonds within the U.S. This was further supported by endorsements from U.S. military officers.

The applicant also credibly testified that he would resolve any potential conflict of interest in favor of the United States. Based on these mitigating conditions, the security clearance was granted.

Why the Applicant Prevailed

The applicant demonstrated a long track record of loyalty to the United States despite threats from foreign entities.
He has developed deep and long-lasting bonds in the United States, supported by endorsements from U.S. military officers.
The applicant credibly testified that he would resolve any potential conflict of interest in favor of the United States.

Conditions Referenced

Disqualifying

AG ¶ 7(a)raisedContact with Foreign Family Members
AG ¶ 7(b)raisedConnections Creating Potential Conflict of Interest
AG ¶ 7(f)raisedSubstantial Financial Interests in a Foreign Country

Mitigating

AG ¶ 8(a)appliedNature of Relationships with Foreign Persons Unlikely to Create Conflict
AG ¶ 8(b)appliedMinimal Conflict of Interest Due to Strong U.S. Ties

Key Rule Quoted

“An individual is not automatically disqualified from holding a security clearance because they have connections and contacts in a foreign country.”

Procedural Posture

SOR issuedSep 18, 2016
Answer filedNov 26, 2016
Hearing heldMar 8, 2017Applicant requested expedited hearing after returning from overseas.
Decision dateJul 20, 2017

Cite For

Mitigation of Foreign Influence Concerns Under Guideline B
Importance of Demonstrated Loyalty to the U.S. in Security Clearance Cases
Consideration of Familial Ties in Foreign Influence Assessments

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: Decision on RecordDecided: granted

The judge found that the applicant mitigated foreign influence security concerns related to family members, a bank account, and property interests in Iraq. The applicant's strong allegiance to the United States, supported by his military service and deep ties in the U.S., led to the granting of his 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: Naturalized U.S. Citizen · U.S. Spouse or Partner · 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–1.m	13 sub-charges — specific text not stated in this decision (for the applicant).	For Applicant	Unspecified Foreign Relationship Immediate Family	— HEIGHTENED RISK		—	—	—

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.

Decision text, by section

DEFENSE OFFICE OF HEARINGS AND APPEALS

HEARING

APPEARANCES

DEPARTMENT OF DEFENSE DEFENSE OFFICE OF HEARINGS AND APPEALS

In the matter of: ) ) ) ISCR Case No. 16-01311 ) ) Applicant for Security Clearance

For Government: Robert J. Kilmartin, Esq., Department Counsel For Applicant: Thomas J. Fields III, Personal Representative.

07/20/2017 __________

STATEMENT OF CASE

__________

RIVERA, Juan J., Administrative Judge:

Applicant mitigated foreign influence security concerns raised by family members, a bank account, and property interests in Iraq. His past behavior clearly demonstrates he can resolve any potential conflict of interest in favor of the United States. His undivided allegiance to the United States is corroborated by his dependability and performance while under enemy fire and facing grievous harm. U.S. military officers who served with him in Iraq endorse his eligibility for a security clearance. Additionally, he has developed deep and long-lasting bonds in the United States. Clearance is granted.

Statement of the Case

Applicant submitted a security clearance application (SCA) on December 26, 2014. After reviewing it and the information gathered during a background investigation, the Department of Defense (DOD) on September 18, 2016, issued him a Statement of Reasons (SOR) alleging security concerns under Guideline B (foreign influence). Applicant answered the SOR on November 26, 2016, and requested a hearing before an administrative judge from the Defense Office of Hearings and Appeals (DOHA). The case was assigned to me on February 28, 2017. The DOHA issued a notice of hearing on March 6, 2017, scheduling a hearing for March 8, 2017. At the hearing, the Government offered six exhibits (GE 1 through 6). GE 5 (discovery letter) and GE 6 (administrative notice request) were marked and made part of the record, but they are not evidence. Applicant testified and submitted exhibits (AE) 1 through 4. All exhibits were admitted without objection. DOHA received the hearing transcript (Tr.) on March 20, 2017.

Procedural Issue

Applicant was deployed overseas working for a federal contractor, and Department Counsel had difficulty communicating with him to schedule his hearing. On about February 28, 2017, Applicant returned to the United States and requested an expedited hearing. At hearing, Applicant stated he had sufficient time to prepare, was ready to proceed, and affirmatively waived his right to 15-days advanced notice of his hearing. (Appellate Exhibit 1; Tr. 12-14)

Department Counsel requested I take administrative notice of facts concerning Iraq. (GE 6) There were no objections, and I took administrative notice as requested. The noted facts are incorporated in my findings of fact.

FINDINGS OF FACT

Applicant admitted all the SOR factual allegations. His admissions to the SOR and at his hearing are incorporated herein as findings of fact. After a thorough review of the record evidence, including his testimony and demeanor while testifying, I make the following additional findings of fact:

Applicant is a 54-year-old linguist, translator, and consultant. He has worked for U.S. forces and federal contractors on and off since 2007. Applicant was hired by his current employer and clearance sponsor in November 2013. As of his hearing, he was in the middle of his third deployment to Iraq in support of U.S. interests. He received an interim secret clearance in April 2016, which was withdrawn in September 2016 because of the security concerns alleged in the SOR.

Applicant was born, raised, and educated in Iraq. He was drafted into the Iraqi army in 1987, where he served until the expiration of this term of service in 1991. The highest rank he held was corporal. At age 44, in 2007, he immigrated to the United States pursuant to a special immigrant visa issued to him because of his job as an interpreter for U.S. forces in Iraq. He became a naturalized U.S. citizen in 2013.

Applicant married his wife in 1989 in Iraq. She immigrated to the United States with Applicant and she is now a naturalized U.S. citizen. They own a home in the United States. They have four children, all of whom were born in Iraq. The SOR alleged that Applicant’s 26-year-old daughter was a dual citizen of Iraq and the United States (naturalized), and that she is employed by a Middle East Country’s Embassy or Consulate in the United States. Although Applicant admitted the SOR allegation, at hearing he testified that his daughter is only a U.S. citizen. He submitted a letter from his daughter explaining that she is employed by the Middle East Country’s Cultural Mission to the United States. She claimed she does not work for the Middle East Country’s Embassy or the Consulate. (AE 4) His 23-year-old son is a U.S. resident and a green card holder. His 19-year-old son and 16-year-old daughter are both naturalized U.S. citizens living in the United States.

Applicant’s parents (deceased), siblings, extended family members, wife, and her family members were born, raised, and educated in Iraq. The following are citizens and residents of Iraq:

1. His 66-year-old mother-in-law;

2. His 58-year-old brother who is currently employed by the Iraqi Ministry of Industry. Applicant testified his brother does not work directly for the Ministry of Industry, but for a company under the control of the Ministry. He explained that in Iraq the government controls almost every business. Applicant testified this brother applied for assistance to immigrate to the United States;

3. His 56-year-old sister;

4. His 44-year-old brother who is working for the Iraqi National Police. Applicant testified he does not get along with this brother and they have not been in contact for many years. He believes his brother applied for assistance to immigrate to the United States. Applicant testified he only remains in contact with his older brother living in Iraq;

5. Five sisters-in-law and two of his sisters-in-law’s spouses. One of whom served in the Iraqi military; and

6. He also has a friend who is a citizen and resident of Libya. Applicant explained that they became friends when Applicant worked in Libya for five years. His friend was the bus driver who drove them to work. He claimed his last contact with the Libyan was in 2007. (Tr. 33)

Applicant has two brothers, 52 and a 49, both of whom are U.S. green card holders and U.S. residents. The 49-year-old brother served in the Iraqi army from 1985 to 2003. He also has a 48-year-old brother who is a resident of Denmark where he owns a business; a 46-year-old brother who is a U.S. resident; and a 36-year-old brother (disabled and unemployed) who is a U.S. resident.

Applicant owns a share of real estate in Iraq with an estimated value of $90,000. He and his siblings inherited the property when his father passed in 2005. He also owns a bank account with an estimated value of $88,000, and real estate (his home in Iraq) with an estimated value of $560,000. Applicant purchased his home in Iraq in 2002, when he returned from working in the oil fields in Libya. In 2005, Applicant was working as a translator/interpreter for U.S. forces in Iraq. The Iraqi militia identified him as a traitor and Applicant and his family had to leave his house twice under death threats and attacks. He immigrated to the United States because of the death threats in 2007. Applicant’s oldest brother is living in his house currently.

A government background investigator interviewed Applicant in 2015 concerning his bank account and properties in Iraq. He was made aware of the security concerns his financial and proprietary assets in Iraq raised. Applicant promised that he would close the bank account and dispose of the Iraqi properties. (GE 4) However, as of his hearing, Applicant still had his financial and property interests in Iraq. Applicant testified he could not sell his Iraqi property or close the bank account without giving a power of attorney to his older brother or appearing in person to do the transactions. Applicant implied he was afraid of returning to Iraq to sell the properties or close the bank account, and that he was concerned about giving a power or attorney to his older brother.

Applicant did not fully understand the security concerns raised by his financial and property interests in Iraq. He believed that because he has worked for U.S. forces since 2005 and is now a U.S. citizen, his financial and property interests in Iraq would not be a concern. (Tr. 50-52)

Applicant testified he does not need the money in the bank account, or the anticipated proceeds of the sale of his real estate properties in Iraq. Applicant submitted a U.S. bank account showing he has about $230,000 in savings and $7,500 in a checking account. (AE 3) He paid $140,000 cash for a home in the United States when he returned from his deployment to Iraq in 2009. (Tr. 56)

Applicant credibly testified that neither he, nor his wife or children, intend to return to live in Iraq. He and his family are very happy to be living in the United States and they enjoy the peace and quality of life they have in the United States. While working for U.S. forces in Iraq, Applicant came under weapons fire (mortar, rifle, rifle propelled grenades (RPGs)) numerous times, had grenades thrown at his home, and was the victim of an improvised explosive devise attack. Applicant credibly testified that he would resolve any possible conflict of interest in favor of the United States.

At his hearing, Applicant presented the testimony of one witness, submitted eight reference letters, and four certificates of appreciation. The witness was a U.S. forces’ team leader in Iraq. His mission was to conduct raids throughout Baghdad, and Applicant was his interpreter. He trusted Applicant and allowed him to carry weapons for self-defense. While working with U.S. forces, Applicant was engaged in numerous firefights with Iraqi insurgents and was exposed to grave danger. His references included mostly U.S. officers in charge of teams deployed to Iraq. The gist of their testimony is that Applicant demonstrated exceptional skills and ability as an interpreter. He proved to be extremely valuable to the U.S. forces and gained the trust and confidence of his references. Most of the references endorsed Applicant’s eligibility for a security clearance. (AE 1)

I take administrative notice of the following facts concerning the Iraqi government: Iraq faces many challenges fueled by sectarian and ethnic divisions. Numerous terrorist groups and elements hostile to the United States remain active in Iraq. The Islamic State of Iraq and the Levant (ISIL) controls a significant part of Iraqi territory, though Iraqi forces, with the assistance of the United States, have seen successes recently and most of the territory previously held by ISIL has been retaken. Threats of kidnapping and violence are high, and the Department of State warns U.S. citizens that all but essential travel to Iraq should be avoided. Within areas under ISIL control, the Iraqi government has little or no ability to exercise control and ensure public safety. Although the government of lraq have made significant progress in its campaign to retake occupied territory from ISIL, there remains a security vacuum in parts of Iraq.

The State Department warns that anti-U.S. sectarian militias may also threaten U.S. citizens and western companies throughout Iraq. Kidnappings and attacks by means of improvised explosive devices (IED) occur frequently in many areas of the country, including Baghdad. Methods of attack have included explosively formed penetrators, magnetic IEDs placed on vehicles, human and vehicle-borne IEDs, mines placed on or concealed near roads, mortars and rockets, and shootings using various direct fire weapons. Such attacks often take place in public venues such as cafes and markets. The U.S. government considers the potential personal security threats to U.S. government personnel in Iraq to be serious enough to require them to live and work under strict security guidelines. All U.S. Government employees under the authority of the U.S. Chief of Mission must follow strict safety and security procedures when traveling outside the Embassy and Consulates. In its annual human rights report, the U.S. Department of State reported that ISIL committed the overwhelming number of serious human rights abuses, including attacks against civilians, especially Shia but also Sunnis who opposed ISIL, members of other religious and ethnic minorities, women, and children. ISIL members committed acts of violence on a·mass scale, including killing by suicide bombings, improvised explosive devices, execution-style shootings, public beheadings, and other forms of executions. Sectarian hostility, widespread corruption, and lack of transparency at all levels of government and society weakened the Iraqi government's authority arid worsened effective human rights protections.

POLICIES

The SOR was issued under Executive Order (Exec. Or.) 10865, Safeguarding Classified Information Within Industry (February 20, 1960), as amended; DOD Directive 5220.6, Defense Industrial Personnel Security Clearance Review Program (Directive) (January 2, 1992), as amended; and the Adjudicative Guidelines for Determining Eligibility for Access to Classified Information (AG), implemented by the DOD on September 1, 2006. The case will be decided under Security Executive Agent Directive (SEAD) 4, National Security Adjudicative Guidelines (AG), effective 8 June 2017.

Eligibility for access to classified information may be granted “only upon a finding that it is clearly consistent with the national interest to do so.” Exec. Or. 10865, § 2. The U.S. Supreme Court has recognized the substantial discretion of the Executive Branch in regulating access to information pertaining to national security, emphasizing that “no one has a ‘right’ to a security clearance.” Department of the Navy v. Egan, 484 U.S. 518, 528 (1988).

The AG list disqualifying and mitigating conditions for evaluating a person’s suitability for access to classified information. Any one disqualifying or mitigating condition is not, by itself, conclusive. However, the AG should be followed where a case can be measured against them, as they represent policy guidance governing access to classified information. Each decision must reflect a fair, impartial, and commonsense consideration of the whole person and the factors listed in SEAD 4, App. A ¶¶ 2(d) and 2(f). All available, reliable information about the person, past and present, favorable and unfavorable, must be considered.

Security clearance decisions resolve whether it is clearly consistent with the national interest to grant or continue an applicant’s security clearance. The Government must prove, by substantial evidence, controverted facts alleged in the SOR. If it does, the burden shifts to the applicant to rebut, explain, extenuate, or mitigate the facts. The applicant bears the heavy burden of demonstrating that it is clearly consistent with the national interest to grant or continue his or her security clearance.

Persons with access to classified information enter into a fiduciary relationship with the Government based on trust and confidence. Thus, the Government has a compelling interest in ensuring each applicant possesses the requisite judgment, reliability, and trustworthiness of those who must protect national interest as their own. The “clearly consistent with the national interest” standard compels resolution of any reasonable doubt about an applicant’s suitability for access in favor of the Government. “[S]ecurity clearance determinations should err, if they must, on the side of denials.” Egan, 484 U.S. at 531; SEAD 4, ¶ E(4); SEAD 4, App. A, ¶¶ 1(d) and 2(b). Clearance decisions are not a determination of the loyalty of the applicant concerned. They are merely an indication that the applicant has or has not met the strict guidelines the Government has established for issuing a clearance.

ANALYSIS

Guideline B, Foreign Influence

The foreign influence security concern is explained at 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 allegiance. 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.1

An individual is not automatically disqualified from holding a security clearance because they have connections and contacts in a foreign country. Instead, in assessing an individual’s potential vulnerability to foreign influence, an administrative judge must take into account the foreign government involved; the intelligence-gathering history of that government; the country’s human rights record; and other pertinent factors.2

The United States and Iraq are allies in the war against ISIL. However, the serious security threat posed by these terrorists and other elements hostile to the United States must be taken into account in assessing the security concerns raised by Applicant’s familial connections and other interests in Iraq. Applicant’s relationship to these foreign relatives, coupled with the facts administratively noticed, raise a heightened security concern.

In assessing the security concern raised by Applicant’s foreign contacts and interests, I have considered the following disqualifying and mitigating conditions:

AG ¶ 7(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;

AG ¶ 7(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;

AG ¶ 7(f): substantial business, financial, or property interests in a foreign country, or in any foreign owned or foreign-operated business that could subject the individual to a heightened risk of foreign influence or exploitation or personal conflict of interest;

AG ¶ 8(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 U.S.;

AG ¶ 8(b): there is no conflict of interest, either because the individual’s sense of loyalty or obligation to the foreign person, group, government, or country is so minimal, or the individual has such deep and longstanding relationships and loyalties in the U.S., that the individual can be expected to resolve any conflict of interest in favor of the U.S. interest; and

AG ¶ 8(f): the value or routine nature of the foreign business, financial, or property interests is such that they are unlikely to result in a conflict and could not be used effectively to influence, manipulate, or pressure the individual.

An individual with family members and other connections in a foreign country faces a high, but not insurmountable hurdle in mitigating security concerns raised by such foreign ties. An applicant is not required “to sever all ties with a foreign country before he or she can be granted access to classified information.”3 However, what factor or combination of factors will mitigate security concerns raised by an applicant with family members in a foreign country is not easily identifiable or quantifiable.4

In the present case, Applicant has three siblings, his mother-in-law, five sisters- in-law (and two of their husbands) and financial and property interests in Iraq. (His remaining close family members live in the United States or in countries where they are not subject to possible coercion or harm.) Notwithstanding, Applicant has a long track record of resolving potential conflicts of interest raised by his relatives in Iraq and his fiduciary responsibilities to the United States in favor of U.S. interests. Since 2005, in the face of death threats to him and his family, and attacks on his home in Iraq, Applicant repeatedly faced down those threats and maintained his loyalty and fiduciary obligations to the United States.

These threats were not only just leveled against Applicant but also his wife and children in Iraq. Applicant, with the encouragement of his family and his U.S. forces’ friends, remained loyal to the United States, reported the threats, and continued his work and responsibilities to the United States. Applicant abandoned his home in Iraq and immigrated to the United States because of the threats and attacks on his family in 2007. Notwithstanding, he has continued to serve the U.S. forces on other Iraq missions and would like to continue working for U.S. forces in the future.

Applicant’s testimony that he would report any attempted coercion or threats, and that he would resolve any potential conflict in favor of the United States, is fully supported by his long and distinguished track record of doing so. His undivided allegiance to the United States is corroborated by his dependability and performance while under enemy fire and facing grievous harm. U.S. military officers who served with him in Iraq endorse his eligibility for a security clearance.5 Additionally, Applicant has developed deep and long-lasting bonds in the United States, as evidenced by the reference letters and his witness’ testimony.

I considered that the value of Applicant’s financial and property interests in Iraq are higher than his financial and property interests in the United States. Because of the security clearance process, Applicant now understands the importance of the security concerns raised by his financial and property interests in Iraq. I believe he will work to divest himself from those interests. Regardless, Applicant’s past behavior demonstrates his ability to resolve any potential conflict of interest in favor of the United States even under enemy fire and facing grievous harm. As he explained, he abandoned the properties and bank account twice before under death threats. He would be happy to sell the properties and bring the proceeds to the United States. He just needs the time to do so. Accordingly, after a complete and thorough review of the record evidence, and while remaining mindful of my duty to resolve any unmitigated doubt in favor of protecting national security, I find that Applicant mitigated the security concerns raised by his connections to and contact with his family in Iraq and his financial and property interests in Iraq.

WHOLE PERSON CONCEPT

I considered the potentially disqualifying and mitigating conditions in light of all the facts and circumstances surrounding this case, and under the whole-person concept. SEAD 4, App. A, ¶¶ 2(a), 2(d) and 2(f). I have incorporated my comments under Guideline B in my whole-person analysis. Some of these factors were addressed under that guideline, but some warrant additional comment.

Applicant is a 54-year-old employee of a federal contractor. He has worked for U.S. forces in Iraq on and off since 2005. He established an excellent reputation for his knowledge, cultural expertise, and linguistic abilities. He is considered to have exceptional skills and abilities as an interpreter.

Moreover, Applicant is considered to be a highly trusted employee, who is reliable, dependable, and a loyal American. He accompanied U.S. forces on numerous military missions where he risked his life and fought the enemy shoulder to shoulder with his U.S. forces’ companions and friends. His references, U.S. military officers who served with him in Iraq, endorsed his eligibility for a security clearance without reservations.

FORMAL FINDINGS

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 B: FOR APPLICANT

Subparagraphs 1.a - 1.m: For Applicant

CONCLUSION

In light of all the circumstances presented by the record in this case, it is clearly consistent with the national security interests of the United States to grant eligibility for a security clearance to Applicant. Clearance is granted.

____________________________ JUAN J. RIVERA Administrative Judge

FOOTNOTES

1 ISCR Case No. 09-07565 at 3 (App. Bd. Jul. 12, 2012) (“As the Supreme Court stated in Egan, a clearance adjudication may be based not only upon conduct but also upon circumstances unrelated to conduct, such as the foreign residence of an applicant’s close relatives.”) (internal citation omitted).

2 ISCR Case No. 05-03250 at 4 (App. Bd. Apr. 6, 2007) (setting forth factors an administrative judge must consider in foreign influence cases). 3 ISCR Case No. 07-13739 at 4 (App. Bd. Nov. 12, 2008).

4 ISCR Case No. 11-12202 at 5 (App. Bd. Jun. 23, 2014). 5 ISCR Case No. 07-00034 at 2 (App. Bd. Feb. 5, 2008) (“Generally, an Applicant’s statements, by themselves, as to what he would do in the face of threats by a foreign government or entity are entitled to little weight. On the other hand, an applicant’s proven record of action in defense of the U.S. is very important and can lead to a favorable result for an applicant in a Guideline B case. In this case, Applicant has served the U.S. military as a translator in dangerous circumstances in Afghanistan and has risked his life to protect American personnel there.) See also ISCR Case No. 05-03846 at 6 (App. Bd. Nov. 14, 2006) (“As a general rule, Judges are not required to assign an applicant’s prior history of complying with security procedures and regulations significant probative value for purposes of refuting, mitigating, or extenuating the security concerns raised by the applicant’s more immediate disqualifying conduct or circumstances. However, the Board has recognized an exception to that general rule in Guideline B cases, where the applicant has established by credible, independent evidence that his compliance with security procedures and regulations occurred in the context of dangerous, high-risk circumstances in which the applicant had made a significant contribution to the national security. The presence of such circumstances can give credibility to an applicant’s assertion that he can be relied upon to recognize, resist, and report a foreign power’s attempts at coercion or exploitation.”) (internal citations omitted).