One of the more insidious byproducts of the COVID-19 pandemic is a significant increase in internet gambling addictions caused by working from home and social isolation. Gambling addictions may not present the same type of outwardly visible signs as alcohol or drug addictions, but the security clearance implications can be just as severe.
3 Ways Gambling Gets Notices by Security Officials
The issue typically comes to the attention of security officials in one of three ways. First, the SF-86 form asks if the applicant has “EVER” experienced any financial problems due to gambling. An affirmative answer to that question then results in a request for additional details about the problem gambling and likely investigation by the government.
Second, clearance holders who are not completing a personnel security questionnaire are required by government policy to self-report certain financial anomalies. Holders of a Secret clearance are called to report bankruptcies or delinquency on any debt over 120 days – both of which can be implicated by gambling addictions. Holders of Top Secret clearances are required to more broadly report any “financial anomalies,” including, in pertinent part, winnings of more than $10,000.
The third and least desirable scenario for clearance holders is when the government discovers the addiction on their own – either by a trail of financial delinquencies on the individual’s credit report (which can now be more quickly flagged though the Continuous Evaluation program), suspicious activity reports (SAR’s) filed by gambling platform operators in compliance with federal law, or, in rare case, the reporting of the issue by a cleared third party as required by Security Executive Agent Directive 3’s “Reportable Actions by Others” section (sometimes called the “rat” provision). Each of these scenarios can add integrity concerns on top of the addiction issue itself.
One Common Theme for Gambling Issues
Regardless of how the government comes to learn of the problem, there is one commonality: by that time, it is often too late for the clearance holder to sufficiently mitigate security concerns. Like other addictions, demonstrating that problem gambling is under control frequently requires that the clearance holder show a track record of engaging in an accountability program (e.g., Gambler’s Anonymous) and/or therapy. It likely also requires significant efforts to resolve the debt that has inevitably accrued – itself a security issue due to the heightened susceptibility to bribery or other illegal activity it may be perceived as creating.
This can be done by engaging a reputable credit counseling service, establishing a budget, negotiating payment plans with creditors, and taking other steps to get one’s financial house in order. These things take time; but security clearance revocations can occur swiftly, and at some agencies the process for appeal unfolds in a matter of just months.
Don’t Wait to Address Issues
All of this is to say that clearance holders who find themselves caught in a spiral of problem gambling should start addressing the issue now instead of waiting for the government to force their hand. It is the addiction itself that constitutes the potentially disqualifying condition under the National Adjudicative Guidelines for Security Clearances – not the act of seeking help for it. Seeking professional help in some form is all but a requirement for mitigating the issue.
This article is intended as general information only and should not be construed as legal advice. Although the information is believed to be accurate as of the publication date, no guarantee or warranty is offered or implied. Laws and government policies are subject to change, and the information provided herein may not provide a complete or current analysis of the topic or other pertinent considerations. Consult an attorney regarding your specific situation.
