Last year, I had several clients who were preparing for Government employment in the field of Artificial Intelligence policy or safety. The positions they were interested in required national security clearances. They were all native-born U.S. citizens, who had chosen to attend the University of Oxford. When they contacted me, most of them had only recently returned to the U.S. or were still in the United Kingdom (UK). All of them had been in the UK for the past four to five years. Like most clearance applicants, they had no idea that they could be refused a national security clearance simply because they were recently outside the US for a significant period of time.
This type of situation is addressed in Security Executive Agent Directive 4 (SEAD 4), “National Security Adjudicative Guidelines” (NSAG), at Appendix C: Exceptions—specifically “Deviations.”
Deviation (D): Eligibility granted or continued despite either a significant gap in coverage or scope of the investigation. “Significant gap” for this purpose means either complete lack of coverage for a period of six months or longer within the most recent five years investigated or the lack of one or more relevant investigative scope components (e.g., employment checks, financial review, or a subject interview) in its entirety.
The Oxford students mentioned above represent extreme cases where a deviation would be needed to receive a security clearance. Unfortunately, it’s doubtful a U.S. department or agency would grant a deviation for a complete lack of coverage that encompassed the better part of the past five years. More common situations involve students who recently participated in yearlong study abroad programs and individuals returning from long-term overseas assignments with global/transnational companies or two-year Peace Corps assignments. The requirement for a deviation also applies to applicants whose background investigations lack coverage for one or more significant investigative scope components. For example, this can occur when a recent past employer, residential neighborhood, or school no longer exists (e.g., destroyed in a natural disaster and not reestablished).
Security clearances are not granted based solely on the absence of unmitigated derogatory information regarding an applicant’s conduct and character. There must be an affirmative determination, based on an investigation of a sufficient period of an applicant’s life, that eligibility is clearly consistent with the interests of national security. Except on U.S. military bases overseas, U.S. security clearance investigators cannot conduct background investigations in foreign countries. However, in some allied countries limited checks can be done by U.S. embassy personnel through liaison with foreign government agencies. The records of the International Criminal Police Organization (INTERPOL) can also be check through the US National Central Bureau.
There are other investigative workarounds to compensate for lack of coverage (period and scope), and security clearance applicants can help facilitate the workarounds. Say, you’ve been in a foreign country for a while and plan on seeking employment that requires a security clearance as soon as you return to the U.S. You should maintain or reestablish contact with U.S. citizens with whom you had contact in the foreign country and who are now or will soon be back in the U.S. When you apply for a clearance, you should use the “Optional Comment” text field in the appropriate section of the electronic version (eApp) of the Standard Form 86 (SF86), “Questionnaire for National Security Positions,” and provide complete contact information for each associate. You should also explain the nature, frequency, and period of time you had contact with each of these associates in the foreign country. Former work associates can be added to an Optional Comment in the SF86 section for “Employment Activity.” Former school associates can be added to an Optional Comment in the “Where You Went to School” section. Former roommates and neighbors can be added to an Optional Comment in the section for “Where You Have Lived.” Others, who were social contacts, can be added to an Optional Comment in the section for “People Who Know You Well.” You should add as many people as needed, who in aggregate can provide as much time coverage as possible for each foreign venue (e.g., work, school, residence). The same applies to places in the U.S. where you lived, worked, or went to school that no longer exist.
It’s slightly easier for younger people and people who are/were assigned to U.S. military installations abroad. Even though the SEAD 4 paragraph on deviations says a “significant gap . . . within the most recent five years,” the actual period of investigative coverage for an applicant less than 20 years old is two years. For those between 20 and 23 years of age, the period of coverage only extends back to their 18th birthday. As mentioned earlier, U.S. investigators can conduct background investigations on U.S. military installations in foreign countries. Periodically, the Defense Counterintelligence and Security Agency will send investigators overseas on temporary duty to major US military installations for several weeks at a time to conduct security clearance investigations.
If you are planning on going to a foreign country for work or school and anticipate applying for a security clearance soon after you return, in addition to the U.S. citizens you meet in the foreign country, try to maintain close and continuing contact with your friends and relatives in the U.S., while you’re overseas. In a pinch these people can be interviewed to collaterally verify your activities. I’ve never seen a background investigation report that included a telephone interview of a reference living in a foreign country. However, in the recent past reference interviews and Subject Interviews have often been conducted by voice and video calls. This practice continues today, but on a more limited basis. A reference interview of a U.S. citizen living overseas might be an option investigators can use to verify your activity in a foreign country.
In addition to the possible need for a deviation from investigative standards, living overseas for an extended period may raise security clearance eligibility concerns under NSAG Guidelines B (Foreign Influence), C (Foreign Preference), and L (Outside Activities).
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