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ISCR Case 13-01151.h1 — CASE

ISCR Case 13-01151.h1granted

Case Headnote

ISCR Case No. 13-01151.h1

grantedApr 22, 2014· Hon. Noreen A. Lynch· hearing

Summary

A naturalized U.S. citizen, originally from Nigeria, was granted a security clearance after an assessment under Guideline B (Foreign Influence) and Guideline C (Foreign Preference). Initial concerns arose due to the applicant having three brothers and one sister who are citizens and residents of Nigeria. The applicant maintains regular, though infrequent, contact with these siblings, including a visit to Nigeria in 2012 for a brother's wedding.

To mitigate these concerns, the applicant renounced his Nigerian citizenship and surrendered his Nigerian passport, demonstrating a clear commitment to the United States. The applicant also established strong ties to the U.S. through his family and professional life.

The judge determined that the applicant's foreign family ties did not pose a significant risk of coercion or conflict of interest, noting that the family members in Nigeria were not involved with the Nigerian government. Consequently, the security clearance was granted.

Why the Applicant Prevailed

The applicant renounced his Nigerian citizenship and surrendered his Nigerian passport, mitigating foreign preference concerns.
The applicant demonstrated strong ties to the U.S. through his family and professional commitments, reducing the risk of foreign influence.
The applicant's family members in Nigeria are not involved with the government and do not pose a significant risk of coercion.

Conditions Referenced

Disqualifying

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

Mitigating

AG ¶ 8(a)appliedNature of Relationships with Foreign Persons
AG ¶ 8(b)appliedMinimal Conflict of Interest

Key Rule Quoted

“Eligibility for a security clearance is predicated upon the applicant meeting the criteria contained in the AG.”
— Executive Order 10865, Safeguarding Classified Information within Industry § 2 (Feb. 20, 1960), as amended.

Procedural Posture

SOR issuedDec 30, 2013
Answer filed—Timely response to SOR.
Hearing heldApr 10, 2014
Decision dateApr 22, 2014

Cite For

Mitigation of Foreign Influence Concerns Under Guideline B
Surrender of Foreign Citizenship as a Factor in Security Clearance Decisions
Consideration of Family Ties in Security Clearance Evaluations

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's foreign influence concerns were mitigated by his strong ties to the United States, including his naturalization as a U.S. citizen and the absence of financial interests in Nigeria. The applicant's family ties in Nigeria were acknowledged, but the judge concluded that these did not create a heightened risk of foreign exploitation or coercion, resulting in a decision to grant the 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. Children · U.S. Home or Property · U.S. Career or Business

¶	Allegation	Finding	Relationship	Country	Response	Disqualifying (¶7)	Mitigating applied (¶8)	Mitigation
2.a	Applicant has three brothers and one sister who are citizens and residents of Nigeria. They were never involved with the Nigerian government. Applicant speaks to his sister about four times a year. Applicant speaks to one of his brothers on the phone three times a year. Applicant communicates with another brother who has also visited the United States several times. He speaks to him on the phone once every three months. Applicant speaks to his third brother several times a year. Applicant traveled to Nigeria in 2012 for this brother’s wedding and saw his family.	For Applicant	Sibling in Foreign Country Immediate Family	Nigeria HEIGHTENED RISK	Denied	(a) contact with a foreign family member/associate/friend creating a heightened risk of exploitation (b) connections creating a potential conflict of interest	(b) deep/longstanding U.S. loyalties; conflict resolves in favor of the U.S.	Credited Deep U.S. Ties Documented Foreign Assets Divested

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 C (Foreign Preference) · descriptive summary of a decided case

Posture: Decision on RecordDecided: granted

The judge found that the allegations under Guideline C (Foreign Preference) were withdrawn by the government, as the applicant had surrendered his Nigerian passport and renounced his Nigerian citizenship. Therefore, there were no foreign preference concerns that affected the applicant's eligibility for a security clearance.

¶	Allegation	Finding	Type	Response	Disqualifying (¶10)	Mitigating applied (¶11)	Mitigation
1	WITHDRAWN	Withdrawn	Unspecified Foreign Preference	Unknown	—	—	—

Descriptive standardized rendering of a decided public case (Guideline C). 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. 13-01151 ) ) Applicant for Security Clearance

For Government: Gina L. Marine, Esq., Department Counsel For Applicant: Bradley P. Moss, Esq.

04/22/2014 ______________

STATEMENT OF CASE

______________

LYNCH, Noreen A., Administrative Judge:

This case involves security concerns raised under Guideline B (Foreign Influence) and Guideline C (Foreign Preference). Eligibility for access to classified information is granted.

Statement of the Case

Applicant submitted a security clearance application on August 8, 2012. On December 30, 2013, the Department of Defense (DOD) issued a Statement of Reasons (SOR) detailing the basis for its preliminary decision to deny his application, citing security concerns under Guideline C and Guideline B. DOD acted under Executive Order 10865, Safeguarding Classified Information within Industry (February 20, 1960), as amended; Department of Defense Directive 5220.6, Defense Industrial Personnel Security Clearance Review Program (January 2, 1992), as amended (Directive); and the adjudicative guidelines (AG) implemented on September 1, 2006.

Applicant timely answered the SOR, and requested a hearing before an administrative judge. The case was assigned to me on March 24, 2014. A notice of hearing was issued on March 26, 2014, scheduling the hearing for April 10, 2014. Government Exhibits (GX) 1 and 2 were admitted in evidence without objection. Applicant testified, and presented two witnesses. Applicant submitted Applicant Exhibits (AX) A through C at the hearing. I kept the record open for Applicant to submit an additional exhibit, and he timely submitted a document which was marked as AX D. DOHA received the transcript (Tr.) on April 18, 2014.

Administrative Notice

Department Counsel requested that I take administrative notice of relevant facts about Nigeria. The request and supporting documents are attached to the record as HX. Applicant did not object to documents. (Tr. 12) I took administrative notice as requested by Department Counsel. The facts administratively noticed are set out below in my findings of fact.

FINDINGS OF FACT

In his answer to the SOR, Applicant denied the factual allegations in the SOR under Guideline B (Foreign Influence) and Guideline C (Foreign Preference) and offered explanations. He provided additional information to support his case. His answers are incorporated in my findings of fact.

Applicant is a native of Nigeria. He received his undergraduate degree (engineering) in Nigeria. He left Nigeria in 2002 to study in the United Kingdom. Applicant obtained a master’s degree from a London University in 2006. He came to the United States in 2006 to marry. He has worked as an information technology trainer for approximately eight years. (Tr. 67) His professional life in the United States has been in engineering and information technology working as a contractor for the federal government. He has been with his current employer since March 2014. Applicant has not held a security clearance, but he has worked with sensitive information in his work. Applicant became a naturalized U.S. citizen in May 2009. (GX 1) He renounced his Nigerian citizenship and surrendered his Nigerian passport in April 2014. (AX C) He holds a U.S. passport.

Applicant is married and has one son. His wife is a U.S. citizen by birth. Her parents are U.S. citizens. (Tr. 30) Applicant’s wife’s siblings are U.S. citizens and reside in the United States. (Tr. 59) None of her family members have any connection with the Government in Nigeria.

Applicant’s father died in 2007. (Tr. 54) His mother is a citizen and resident of Nigeria. However, she was granted a visa to reside in the United States as a permanent resident. (AX D) The expected date of her arrival is May 2014, and she plans to remain in the United States to live with Applicant and his family. Applicant’s mother contacts him every two weeks. She inquires about her grandson.

Applicant has three brothers and one sister who are citizens and residents of Nigeria. They were never involved with the Nigerian government. His sister is a small business owner. (Tr. 73) Applicant speaks to his sister about four times a year. (Tr. 74) Applicant’s sister does not know anything about Applicant’s work.

One of Applicant’s brothers (A) is a banker who has visited the United States. (Tr.75) Applicant speaks to this brother on the phone three times a year. He is not aware of Applicant’s work.

Applicant communicates with his brother (B) who has also visited the United States several times. He speaks to him on the phone once every three months. (Tr. 76) His brother works for an auditing firm. He has no involvement with the Nigerian government. (Tr.78)

Applicant’s third brother (C) who lives in Nigeria has never visited the United States. He is a banker. Applicant speaks to his brother several times a year. Applicant travelled to Nigeria in 2012 for this brother’s wedding and saw his family. (Tr. 81) Applicant has no other relatives in Nigeria. He has siblings who live in the United Kingdom. He stated that his family does not know the specifics of his work. (Tr. 85) They do not know about Applicant’s current employer.

Applicant and his wife own a home in the United States. They both earn professional incomes that total approximately $180,000. They do not have any financial interest or property in Nigeria. Applicant has not been in the Nigerian military. He has never voted in any Nigerian elections.

Applicant explained at the hearing that he came to the United States to marry and to establish a career. His professional career includes teaching at a community college. He has roots in the United States both professionally and personally. Applicant has worked with various federal agencies. His wife and son are U.S. citizens. He has not held a clearance, but has been involved with sensitive information, providing service to the U.S. Government through his work with sensitive research. Applicant was credible when he explained that if in the unlikely situation that there would be pressure on him or his family, he would immediately contact his facility security officer.

Applicant expressed his love for the United States. He contributes to the community in various ways. He has a strong commitment to public service, and volunteers in the church ministry. He is a law-abiding citizen. He and his wife own a home and have another property in the United States. He has no financial ties to Nigeria.

Applicant submitted a letter of recommendation (sworn declaration) from the Chief Executive Officer (CEO) and Facility Security Officer (FSO) of a contracting company with whom he worked. The CEO has known Applicant since July 2012. She describes Applicant as a person of integrity, strong character, and extraordinary knowledge. (AX A) The CEO has held a clearance for a number of years, and is familiar with the security concerns. A friend from Applicant’s church who has known him for about five years describes him as a man of integrity and moral character. Applicant is a church elder who possesses character and works diligently to help the church community. (Tr. 24) Applicant’s friend knows the reason for the security concerns at issue, and holds a security clearance. The friend has met Applicant’s mother and his siblings when they visited the United States for the birth of Applicant’s son. (Tr. 28) She recommends Applicant highly for a security clearance.

Applicant’s wife testified that she met Applicant while studying in England. She has known him since 2004. She is also a member of the same church. Applicant’s wife testified that Applicant’s mother visited the United States in 2011 for the birth of their son. She also confirmed that Applicant’s mother has a visa and plans to live in the United States.

Another colleague, who has known Applicant since 2007, describes him as a reliable person. (AX B) She has a security clearance and is familiar with the SOR allegations. She has no reservations endorsing Applicant as a person who works with sensitive or classified information.

Applicant possessed a Nigerian passport that he used to travel to Nigeria in April 2012 for a wedding. He used the Nigerian passport for convenience so that he did not have to get a visa. He further explained that he told investigators and his FSO that he was willing to surrender the passport and to renounce his Nigerian citizenship. At the hearing, the Government withdrew the security concerns under Foreign Preference, as Applicant has surrendered his Nigerian passport. (AX C)

Administrative Notice

I take administrative notice of the following facts. Nigeria is a federal republic in western Africa. It gained its independence from Britain in 1960. Since then it has faced intermittent political turmoil and economic crisis. There is conflict along ethnic and geographical lines, and there have been military coups and long military-imposed transition programs rather than civilian rule. Since its independence the military has ruled Nigeria for approximately 28 of the 51 years.

Nigeria is Africa’s most populous country, and there is pervasive poverty. Ethnic and religious clashes are common. The dominant ethnic group in the northern two-thirds of the country is Hausa-Fulani, most of whom are Muslims, and the Yoruba people, about half of whom are Christian and half Muslim, predominate the Southwest. Nigeria pursues a policy of developing military production capabilities. Before the lifting of sanctions by many Western nations, Nigeria turned to China, Russia, North Korea, and India for the purchase of military equipment and training.

The United States is Nigeria’s largest trading partner. Oil imports from Nigeria to the United States account for 11 percent of U.S. oil imports. The United States is the largest foreign investor in Nigeria, and U.S. investment is mostly in mining and petroleum.

Nigeria has provided strong diplomatic support to U.S. Government counter- terrorism efforts. An estimated one million Nigerians and Nigerian-Americans live, study, and work in the United States, and another 25,000 Americans live and work in Nigeria.

The U.S. Department of State Travel Warning recommends avoiding travel to certain areas of Nigeria due to the risk of kidnapping, robbery, and other armed attacks. In 2010, the U.S. Embassy issued a warning informing government personnel to defer travel to states experiencing violence in the aftermath of the presidential election. There have been more frequent attacks in Nigeria’s northern states. In 2009, there were numerous warnings regarding the threat of violence and potential attacks against U.S. citizens and in the vicinity of the U.S. Consulate General.

The Nigerian government’s human rights record is poor, and the government at all levels continues to commit serious human rights abuses, to include: extrajudicial killings and impunity of abuses by security forces, torture, arbitrary arrest, and judicial corruption. In addition, police raid homes without warrants, and security forces have beaten, detained, and harassed journalists. Nigerian police and other law enforcement do not always inform the U.S. Embassy or Consulate immediately of the arrest or detention of a U.S. citizen.

POLICIES

“[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.” Exec. Or. 10865, Safeguarding Classified Information within Industry § 2 (Feb. 20, 1960), as amended.

Eligibility for a security clearance is predicated upon the applicant meeting the criteria contained in the AG. 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, 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 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.” See Exec. Or. 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, 484 U.S. 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. 92-1106 at 3, 1993 WL 545051 at *3 (App. Bd. Oct. 7, 1993).

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, 484 U.S. at 531; see AG ¶ 2(b).

ANALYSIS

Guideline B, Foreign Influence

The security concern under this guideline is set out in AG ¶ 6:

Foreign contacts and interests may be a security concern if the individual has divided loyalties or foreign financial interests, may be manipulated or induced to help a foreign person, group, organization, or government in a way that is not in U.S. interests, or is vulnerable to pressure or coercion by any foreign interest. Adjudication under this Guideline can and should consider the identity of the foreign country in which the foreign contact or financial interest is located, including, but not limited to, such considerations as whether the foreign country is known to target United States citizens to obtain protected information and/or is associated with a risk of terrorism.

Two disqualifying conditions under this guideline are relevant to this case. First, a disqualifying condition may be raised by “contact 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(a). Second, a disqualifying condition may be raised by “connections to a foreign person, group, government, or country that create a potential conflict of interest between the individual’s obligation to protect sensitive information or technology and the individual’s desire to help a foreign person, group, or country by providing that information.” AG ¶ 7(b).

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).

Furthermore, “even friendly nations can have profound disagreements with the United States over matters they view as important to their vital interests or national security.” ISCR Case No. 00-0317, 2002 DOHA LEXIS 83 at **15-16 (App. Bd. Mar. 29, 2002). Finally, friendly nations have engaged in espionage against the United States, especially in the economic, scientific, and technical fields. Nevertheless, the nature of a nation’s government, its relationship with the United States, and its human rights record 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, a family member is associated with or dependent upon the government, or the country is known to conduct intelligence operations against the United States. In considering the nature of the government, an administrative judge must also consider any terrorist activity in the country at issue. See generally ISCR Case No. 02-26130 at 3 (App. Bd. Dec. 7, 2006) (reversing decision to grant clearance where administrative judge did not consider terrorist activity in area where family members resided).

Applicant has lived and worked in the United States since 2006. He is a naturalized U.S. citizen. Applicant’s child is a U.S. citizen. His wife is a U.S. citizen by birth. He holds a U.S. passport and has renounced his Nigerian citizenship. (AX)

Applicant’s three brothers and a sister live in Nigeria. He speaks to his siblings several times a year. He has emailed one brother. His mother is a citizen and resident of Nigeria. However, she is coming to the United States to live. A[T]here is a rebuttable presumption that a person has ties of affection for, or obligation to, the immediate family members of the person's spouse.@ ISCR Case No. 01-03120, 2002 DOHA LEXIS 94 at * 8 (App. Bd. Feb. 20, 2002). Applicant has not rebutted this presumption. After considering the totality of Applicant’s family ties to Nigeria as well as each individual tie, I conclude that Applicant’s family ties are sufficient to raise an issue of a heightened risk of foreign exploitation, inducement, manipulation, pressure, or coercion. Applicant speaks to his brother once or twice a year on the phone. He saw his brother in 2012. Based on all these circumstances, I conclude that AG ¶¶ 7(a) and, (b) are raised.

Security concerns under this guideline can be mitigated by showing that “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(a).

Security concerns under this guideline can be mitigated by showing “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.” AG ¶ 8(b).

Applicant maintains a relationship with his mother, brothers and sister who live in Nigeria. He stays with his brother when he visits Nigeria. I find AG ¶ 8(c) does not apply because his familial relationships in Nigeria are more than casual.

The United States maintains close relations with Nigeria. There are problems with threats in Nigeria and its human rights record is poor. The risk of coercion, persuasion, or duress is significantly greater if the foreign country has an authoritarian government, a family member is associated with or dependent upon the government or the country is known to conduct intelligence operations against the United States.

Applicant was born in Nigeria but chose the United States as his home country. His son is in the United States. He has been a citizen of the United States since 2009. He has built a career in the United States. He has no assets in Nigeria. There is no indication that Applicant’s relatives are in positions or are involved in activities that would place Applicant in a position of having to choose between his family and the interests of the United States. There is no indication that Nigeria targets or exploits its own citizens to obtain intelligence. Based on Nigeria’s relationship to the United States, it is unlikely that intelligence officials would attempt to pressure Applicant’s relatives in Nigeria to gather valuable or classified information from the United States through Applicant. It is highly unlikely, considering Nigeria’s relationship with the United States and Applicant’s close ties to the United States, that he would choose his family in Nigeria over his life and children in the United States. I find mitigating AG 8(a) and 8(b) apply.

WHOLE PERSON CONCEPT

Under 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(a):

(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.

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. I have incorporated my comments under Guideline B in my whole-person analysis. Some of the factors in AG ¶ 2(a) were addressed under that guideline, but some warrant additional comment.

Applicant is a naturalized U.S. citizen who has lived in the United States since 2006. He, his U.S. born wife, and his son reside in the United States. He was candid, sincere, and credible at the hearing. Applicant’s home is in the United States. Applicant has been successful in the information technology field. His current employer recommends him for his professionalism and integrity.

Applicant chose to leave his home and pursue his career in the United States. He is firmly entrenched in the United States. All of his assets are located in the United States. Although Applicant has some familial ties to Nigeria, I am convinced that he will resolve any conflicts in favor of the United States.

There is no evidence any of the individuals at issue are involved with, or under scrutiny, by interests antithetical to the United States. His family members in Nigeria do not know the specifics of his work.

Regarding Applicant’s life in the United States, he is an American citizen, with a stable family, social, and professional life. His life is focused here. He is admired by his peers. He is active in his church and volunteers in the community. There is no evidence indicating that he may be manipulated or induced to help a foreign power or interest. He credibly stated he would report any attempts to influence him to security. In light of these facts and the country at issue, I find that Applicant successfully mitigated foreign influence concerns. After weighing the disqualifying and mitigating conditions under Guideline B, and evaluating all the evidence in the context of the whole person, I conclude Applicant has mitigated the security concerns based on foreign influence. Accordingly, I conclude he has carried his burden of showing that it is clearly consistent with the national interest to grant him eligibility for access to classified information.

FORMAL FINDINGS

I make the following formal findings on the allegation in the SOR:

Paragraph 1, Guideline C (Foreign Preference): WITHDRAWN

Paragraph 2, Guideline B (Foreign Influence): FOR APPLICANT

Subparagraph 2.a: For Applicant

CONCLUSION

I conclude that it is clearly consistent with the national interest to grant Applicant eligibility for a security clearance. Eligibility for access to classified information is granted.

Noreen A. Lynch Administrative Judge