Outside activities (Guideline L of the adjudicative criteria) refers to jobs or relationships occurring outside of the United States and involving relationships with foreign countries, persons and businesses. With the internet, social media, and global connectivity, there are many opportunities to meet other like-minded business people. The world is getting smaller, and opportunities to connect are increasing. Forming businesses with foreign people and companies can create new jobs, products, and services. T These opportunities come with a cost to those who might seek a government security clearance. Let’s look at a few examples:

Earning half of your income from a foreign-based country

An applicant is the president and CEO of a company incorporated in Singapore. Key management employees and decision makers are foreign citizens and almost half of his income is from the company. He spends time overseas, with foreign citizens, and other foreign companies related to his business.

His ability to safeguard classified and sensitive information could be influenced by his business interests, foreign relationships, or financial portfolio. Pressure from his outside activities could cause him to disclose classified or sensitive information to unauthorized persons through coercion or exploitation. The applicant was denied a security clearance in favor of the national security. Remember, the government will always err on the side of protecting its own interests. When a person has more than a half-interest and significant relationships in a foreign country, there is cause for concern.

Hail Britannia

The applicant is the president of an American subsidiary of a British-based company that does business with the Department of Defense. Prior to the promotion, he was an employee at the same foreign company. He has a substantial financial stake with the company by virtue of his high valued stock. Because of his employment in the foreign organization and serving as a representative of the foreign country, his clearance was denied. His high position in the company, share of stocks, and possible relationships with foreign partners could cause him to be vulnerable to coercion or exploitation.

End the Foreign Relationship, Mitigate the Risk

An applicant worked as vice president of business development for a wholly-owned subsidiary of an Israeli company. In his position, he marketed computer hardware and software to U.S. companies. He was hired for the job after meeting the owner at a trade show, but had very infrequent interaction with the owner.

The applicant has not worked for the company in a few years. Also he no longer has ties with the company neither by positions, finances, relationships, or shares. His relationship and interaction with his former employer and employees is infrequent, if ever. The applicant has mitigated concerns raised by Guideline L by completely separation himself from the business. This demonstrated separation has greatly reduced the likelihood of any potential security incident and therefore he was granted a security clearance.

Outside activities where U.S. persons enjoy foreign positions, relationships, and financial benefits can be rewarding, but do come with a cost.  Security clearance applicants should demonstrate that they are not bringing additional risk to classified or sensitive information through their outside activities. The concern for Guideline L is that certain types of outside employment or activities is a security concern if it poses a conflict of interest with an individual’s security responsibilities, and could create an increased risk of unauthorized disclosure of classified or sensitive information. Often, the only way to mitigate the potential concern is by severing ties with those foreign entities, particularly financial ones.

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Jeffrey W. Bennett is a security consultant with SFPC, SAPPC, ISOC, ISP certifications. He maintains a security blog and newsletter and is the author of many security books including DoD Security Clearance and Contracts Guidebook-What Cleared Contractors Need to Know About Their Need to Know, The Insider’s Guide to Security Clearances, and books on security certification. Visit his website www.redbikepublishing.com for more information.