The Defense Office of Hearing and Appeals (DOHA) Board adjudicates industrial security clearance cases for contractor personnel doing classified work for all DoD components.  The board has held 477 hearings this year for appeals on adverse security clearance determinations or eligibility for placement into public trust positions.  The majority of final decisions were upheld by the board, an indication that adjudicators are getting it right when they review all of the relevant information and make the initial determination.  Analysis of the types of issues resulting in adverse determination shows that financial considerations, personal conduct, and foreign influence concerns outnumber all of the other issues combined.  Below is a breakdown of the types of issues presented (note- some cases had multiple issues):

Adjudicative Guideline Number of Cases
Guideline A: Allegiance to the U.S 0
Guideline B: Foreign Influence 88
Guideline C: Foreign Preference 20
Guideline D: Sexual Behavior 14
Guideline E: Personal Conduct 131
Guideline F: Financial Considerations 295
Guideline G: Alcohol Consumption 19
Guideline H: Drug Involvement 37
Guideline I: Psychological Conditions 3
Guideline J: Criminal Conduct 41
Handling Protected Information 7
Guideline L: Outside Activities 0
Guideline M: Use of IT Systems, 4


If one were to dig deeper into the top three concerns that resulted in denial of eligibility for a security clearance, the findings would not be surprising.  The economic downturn, bad investment decisions, and life events such as divorce and medical emergencies all contributed to the substantial increase in financial concerns.  However, there were many cases where individuals simply overextended themselves or displayed poor financial responsibility.  As these cases showed, those that took responsibility for their debts and initiated proactive steps to resolve their financial delinquencies were able to mitigate the concerns.  Personal conduct issues mostly involved dishonesty or lack of candor in not disclosing required information, which is difficult to mitigate, especially when it is for a reinvestigation and the individuals were briefed on the requirements.  The number of cases involving foreign influence concerns has increased dramatically, mainly due to the number of foreign born naturalized citizens being used to support Warfighters.  These individuals still have close relatives in their home country that may be used to exert undue influence.

With the increased scrutiny by politicians and the media on security clearance processes and procedures as a result of recent high profile events involving contractors Aaron Alexis and Edward Snowden, behavior that may have been previously overlooked is now being taken more seriously.  There is now an emphasis on reporting and sharing information.  Those that intend on applying for or retaining a security clearance should ensure that they provide full disclosure and are proactive in taking steps to mitigate any concerns prior to the initiation of an investigation.

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Marko Hakamaa served in various military police positions with the United States Army worldwide for 22 years before retiring in 2006 as a Master Sergeant. Afterwards, he transitioned into the civilian workforce as a contractor background investigator for the Office of Personnel Management (OPM) before entering civil service as a Security Specialist in 2009.