ClearanceJobs reported last month on the Japanese government’s recent move to establish an industrial security clearance system in line with the United States and other G-7 allies. As it turns out, our partners in Toyko aren’t the only ones behind the curve on protecting their defense industrial base from spying. Prompted in large part by increasing espionage threats from China and Russia, Ireland is also moving to establish a vetting system for industry and shore-up how it protects sensitive information.

The Irish Times highlighted in March how “[t]here is currently no system for non-government officials to get official security clearance in Ireland.” Nor, for that matter does the country possess a “statutory security clearance system” to formally classify sensitive information based on the level of damage that would result to Irish national security from disclosure.

The focus of new legislative efforts in this area “will be on ensuring the confidentiality of EU Classified Information (EUCI), as required by EU law.” But it remained unclear as recently as March if the protections were to extend to domestic classified information, and little has been publicly reported about the issue since.

The revelations about Japan and Ireland – both advanced democracies and U.S. allies – are surprising in 2023. The U.S., by comparison, has maintained a robust system of industrial security clearances and information classification since the 1950’s. We’ve had a federal agency dedicated to overseeing both since 1972, when the Defense Investigative Service – the predecessor of the Defense Security Service and now-Defense Counterintelligence and Security Agency – was established.

Yet characterizing either foreign country as complacent or naïve ignores cultural differences that undoubtedly also played a role in being late to the party. Much like Japan, where trust plays an outsized role in society, Ireland runs on collegiality, kindness, and decency. Visiting feels in some respects like stepping into the fictional Mayberry from the old “Andy Griffith Show.” You’ll perhaps never meet kinder, more welcoming people, and I hope that never changes.

On the other hand, events in Japan and Ireland provide an illuminating look inside modern diplomacy; specifically, the challenges in marshaling a united front against threats to global security. U.S. counter-espionage efforts only go so far when, for example, export-controlled technologies are shared with allied countries that lack the means to adequately protect them from sophisticated adversaries.

It seems that at least Japan and Ireland are waking up to this problem. But the belated efforts to shore up defenses against an increasingly aggressive China and Russia raise questions about whether the fox is already in the hen house – and how many other allied nations are similarly vulnerable.



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. 


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Sean M. Bigley retired from the practice of law in 2023, after a decade representing clients in the security clearance process. He was previously an investigator for the Defense Counterintelligence and Security Agency (then-U.S. Office of Personnel Management) and served from 2020-2024 as a presidentially-appointed member of the National Security Education Board. For security clearance assistance, readers may wish to consider Attorney John Berry, who is available to advise and represent clients in all phases of the security clearance process, including pre-application counseling, denials, revocations, and appeals. Mr. Berry can be found at