Few things say “rolling in cash” quite like driving a luxury vehicle that retails for north of $100,000. And yet, there was the subject of my background investigation – who I knew was making about $70,000 annually from having previously reviewed his employment file – pulling up to our investigative interview in one circa 2010.

It raised my eyebrows, to say the least, so I casually asked how much the lease was on such a beauty. To my surprise, he wasn’t leasing; he owned it. The next surprise came just a half-beat later. If I thought that was a nice car, he quipped with only a hint of humor, I should see what he had in his garage.

At this point in my nascent counter-intelligence career, it seemed that all signs pointed to nefarious activity. “You make $70,000 per year”, I blurted out. “How are you paying for these cars?”

Much to my chagrin, he wasn’t taking money from the Chinese or the Russians, nor was he selling drugs on the side – all possibilities that admittedly ran through my cynical mind. It was something much more innocuous, which his references later confirmed, and which I should have assumed given his ostentatious display of wealth: a recent inheritance.

Large Inheritance Can Change a Lifestyle

Personally, I would have put that money toward paying off my mortgage or retiring early, as both options sound significantly more attractive than a flashy ride. In this case, however, the gentleman’s priorities differed, and that was okay. As long as the funds were from a legitimate, legal source – and were being used for a legitimate, legal purpose – which they were, the details weren’t particularly relevant to his eligibility to maintain a security clearance.

But imagine a different scenario: one that involves a more subtle display of extravagance, like an expensive Rolex, and a cleared colleague making a modest salary. There may have been an inheritance or even lottery winnings, for that matter, but you don’t want to pry. Do you report the unexplained affluence to security officials or simply stay out of it?

Subtle Evidence of Affluence Can Raise Eyebrows

Most people I know, including most security clearance holders, select the latter. “Its none of my business” or “why get involved” are refrains I hear commonly. And while I certainly understand that sentiment, some of the most damaging espionage activity in U.S. history – for example, notorious CIA mole Aldrich Ames – yielded subtle evidence of unexplained affluence that a diligent cleared colleague probably noticed at some point but chalked up to imagined circumstances because they didn’t want to rock the boat.

In fact, federal policy quietly enacted in 2017 now requires you to do just that. Complying with an obligation known as Security Executive Agent Directive (SEAD)-3 means reporting to security officials a cleared colleague who exhibits signs of unexplained affluence. The only question is what would a reasonable person consider unexplained affluence?

Self-Report Inheritance to Avoid Suspicion

The answer is that it’s all relative. A Rolex, to use the prior example, might be a perfectly reasonable extravagance for someone making $150,000 annually, but for someone making $50,000 annually, perhaps it raises questions. There is a spectrum of reasonableness that runs from negligence to alarmism; the exercise of common sense is supposed to be somewhere in the middle.

For those on the other side of the equation – the beneficiary of an inheritance or the lottery winner – keep in mind that unexplained affluence poses just as much of a security risk as living beyond one’s means. It is wise under such circumstances to proactively self-report the influx of newfound wealth to personnel security officials before you find yourself the subject of unnecessary suspicions.

 

 

This article is intended as general information only and should not be construed as legal advice. Consult an attorney regarding your specific situation.

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Security Clearance Attorney Sean M. Bigley represents clients worldwide in security clearance denials and revocations. He is a former investigator for the U.S. Office of Personnel Management. For more information, please visit www.bigleylaw.com