DATE: October 29, 2007
In Re:
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SSN: -----------------
Applicant for Security Clearance
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ISCR Case No. 07-00426
DECISION OF ADMINISTRATIVE JUDGE
BARRY M. SAX
APPEARANCES
FOR GOVERNMENT
Jennifer I. Goldstein, Esquire, Department Counsel
FOR APPLICANT
Pro Se
SYNOPSIS
Applicant is a highly educated 43 year old Programmer Analyst who was born in Jordan in
1964, and met her future American-born husband while here for a college program in 1992. She
moved here, married, and completed her MBA in 1995.  She became a U.S. citizen in 2002. She has
renounced her Jordanian citizenship and surrendered her expired Jordanian passport.  Her elderly
mother and sisters are still citizens and residents of Jordan. He closet ties are with her mother.  She
has no other emotional, financial, or other ties to Jordan. Her ties to the U.S. are both deep and
strong.  She credibly avers prompt reporting of any inappropriate contacts regardless of the source.
Mitigation has been established. Clearance is granted. 
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STATEMENT OF THE CASE
 
On July 11, 20075, the Defense Office of Hearings and Appeals (DOHA), pursuant to
Executive Order 10865 and Department of Defense Directive 5220.6 (Directive), dated January 2,
1992, as amended, issued a Statement of Reasons (SOR) to the Applicant. The SOR detailed reasons
why DOHA could not make the preliminary affirmative finding required under the Directive that it
is clearly consistent with the national interest to grant or continue a security clearance for the
Applicant. The SOR recommended referral to an Administrative Judge to conduct proceedings and
determine whether a clearance should be granted, denied or revoked. 
On July 25, 2007, Applicant responded to the allegations set forth in the SOR, and elected
to have a decision made by a DOHA Administrative Judge after a hearing. The case was assigned
to me on September 11, 2007. A Notice of Hearing was issued on September 20, 2007, setting the
hearing for October 4, 2007. The Government introduced four (4) exhibits (Government’s Exhibits
(GX) 1 - 4). The Government also introduced seven (7) Official Notice documents (ON I-VII).
Applicant testified, and introduced four (4
/ exhibits. (Applicant’s Exhibits (AX) A - E). Applicant also introduced four post hearing exhibits
(AX F-I) and a series of Official Notice documents (App ON I, and 1A - 1.S). Some of the
Applicant’s offered Official Notice documents do not qualify as such and, although not admitted as
such, have been considered as hearsay documents that provide some insight, but have not influenced
the outcome of this decision. The transcript was received on October, 2007. 
FINDINGS OF FACT 
Applicant is a 42-year-old Programmer/Analyst for a defense contractor. The SOR contains
seven (7) allegations under Guideline B (Foreign Influence) and two (2) allegations under Guideline
C (Foreign Preference). Applicant admits all allegations, which are accepted and incorporated herein
as Findings of Fact.  1
After considering the totality of the evidence, I make the following additional FINDINGS
OF FACT as to the status of each SOR allegation. 
Guideline B (Foreign Influence) 
1.a. - Applicant’s 69 year old mother is a citizen and resident of Jordan. 
1.b., 1.c., 1.e., and 1.f. - Applicant’s sisters are citizens and residents of Jordan. 
1.g.- Applicant traveled to Jordan from December 26, 2000 to January 8, 2001, at which time
she was not yet a U.S. citizen. 
1.h. - Applicant traveled to Jordan from December 26, 2003 to January 8, 2004, during which
period she was a U.S. citizen. She used the Jordanian passport in 2003 for "convenience" and to
avoid having to obtain a Jordanian visa (GX 2). She visited Jordan once more in 2007, with her
husband. This time she had some Jordanian money and purchased a visa to use with her U.S.
passport (Tr at 83). 
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Guideline C (Foreign Preference) 
2.a. - Applicant held dual U.S.-Jordanian citizenship, by virtue of her birth in that country
to Jordanian citizens.  She has renounced her Jordanian citizenship by letter to the Embassy of
Jordan in Washington, D.C. (Tr at 83-85, AX F, G, and H). 
2.b. - Applicant used her Jordanian passport to travel to Jordan after becoming a U.S. citizen
on August 15, 2002 and receiving a U.S. passport on August 23, 2002, as detailed in paragraph 1.h.,
above. On the latter occasion she attempted to use her U.S. passport, but was told by Jordanian
authorities at the airport that she would need a visa that could be paid for only in Jordanian money.
She did not have any and it was available only in another section of the airport. Her elderly
mother was waiting for her, so she decided to avoid any problem or delays by using her Jordanian
passport. Under these circumstances, I find no suggestion that she acted out of any preference for
Jordan over the United States. She has used her U.S. passport for all other travel.  The passport
expired in October 2005 and has not been renewed. She destroyed the Jordanian passport in the
presence of the Facility Security Officer at her employing company (AX F and I). 
Her mother and sisters are in good financial condition and do not need any help from
Applicant. None of them are connected with the Jordanian government and Applicant does not
believe they are in position to be exploited in such a way as to force Applicant to choose between
them and the U.S. as to security related matters. 
Applicant has consistently and credibly averred that "fact that my mother and sisters are
outside the U.S. does in no way affect my maturity or loyalty. I firmly believe in work ethics, trust,
and responsibility. I take my job seriously and I will not, and didn’t at any time, let my relationship
with family or friends to interfere with my judgment or duties" (Response to SOR). 
"I state that while my mother is my tie to Jordan, my ties to the United States are numerous.
They include my country, my family, my friends, my work, our financial assets, retirements, pension,
and social security benefits. I consider myself to be fortunate and proud to be a citizen of this country
and as loyal as an American born citizen" (AX F). 
Her husband is a university professor. They own a condominium deeded to them by the
university. He was present at the hearing. Other than her family, she has no friends in Jordan. 
Her Project Manager and other colleagues praise her as reliable, professional, dedicated, of
high character, security conscious in handling classified information, a "strict follower" of "company
security policies,” and "excited about becoming a U.S. citizen." Her father-in-law, who held a "Q"
clearance for many years, avers that "her primary loyalty is, and would, be to the United States.” 
POLICIES 
Viewed in an overall context, under E2.2.3.of the Directive, the ultimate determination of
whether the granting or continuing of eligibility for a security clearance is clearly consistent with the
interests of national security must be an overall common sense determination based upon careful
consideration of the following, each of which is to be evaluated in the context of the whole person.
Explained further below (emphasis added): 
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The Whole Person Concept: Under E2.2.1., the DoD adjudicative process is an examination
of a sufficient period of a person's life to make an affirmative determination that the person is
eligible for a security clearance. Eligibility for access to classified information is predicated upon
the individual meeting these personnel security guidelines. The adjudicative process is the careful
weighing of a number of variables known as the whole person concept. Available, reliable
information about the person, past and present, favorable and unfavorable, should be considered in
reaching a determination. 
In evaluating the relevance of an individual's conduct, the adjudicator should consider the
following factors: 1. The nature, extent, and seriousness of the conduct; 2. The circumstances
surrounding the conduct, to include knowledgeable participation; 3. The frequency and recency of
the conduct; 4. The individual's age and maturity at the time of the conduct; 5. The voluntariness of
participation; 6. The presence or absence of rehabilitation and other pertinent behavioral changes;
The motivation for the conduct; 8. The potential for pressure, coercion, exploitation, or duress; and
9. The likelihood of continuation or recurrence. 
CONCLUSIONS 
Applicant is a 42-year-old "Programmer Analyst." (Tr at 55). Born in Jordan in December
1964, she worked for the Ministry of Tourism in 1982-1983 as a typist. She first came to the U.S.
in 1992 to attend a six-month program. During that period, she met her future husband, a native-born
U.S. citizen. She began thinking about emigrating to the United States and arrived in 1995, at which
time they were married (Tr at 57, 86). She received a MBA in 1997, and became a naturalized U.S.
citizen in August 2002 (Tr at 58). She has telephone contact with her family in Jordan every two or
three months and visits them in Jordan every two or three years. She and her husband have a
"household net worth" of about $1.4 million (GX 2) 
Foreign Influence - The concern is that "Foreign contacts and interests maybe a security
concern if the individual has divided loyalties or foreign financial interests, may be manipulated or
induced to help a foreign person, group, organization, or government in a way that is not in U.S.
interests, or is vulnerable to pressure or coercion by any foreign interest. Adjudication under this
Guideline can and should consider the identity of the foreign country in which the foreign contact
or financial interest is located , including but not limited to such considerations as whether the
foreign country is known to target U.S. citizens to obtain protected information and/or is associated
with a risk of terrorism. 
The concern stated in the SOR relates to (1) Applicant’s mother and sisters being citizens and
residents of Jordan, and (2) her travel to Jordan twice between December 2000 and January 2004,
primarily to visit her elderly mother. This information was originally provided by Applicant in her
security clearance application of December 15, 2005, and expanded upon in her answers to
interrogatories of April 16, 2007. On both these occasions and at the October 4, 2007 hearing, she
displayed no reticence in describing her feelings about her mother. At the same time, she was
impressive in expressing her feelings about her family and life in America and her dedication to this
country, as has been corroborated by her career in service to the national defense effort. 
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Disqualifying Condition(s) (DC) 
8. (a) contact with a foreign family member, business or professional associate, friend, or
other person who is a citizen of or resident in a foreign country if that contact creates a heightened
risk of foreign exploitation, inducement, pressure, or coercion. None other apply. 
Mitigating Conditions(s) (MC). Applicable are: 
8.(a) the nature of th relationships with foreign persons, the country in which these persons
are located, or the positions or activities of those persons in that country are such that it is unlikely
the individual will be placed in a position of having to choose between the interests of a foreign
individual, group, organization, or government and the United States; and 
8.(b) there is no conflict of interest, either because the individual’s sense of loyalty or
obligation to the foreign person, group, government, or country is so minimal, or the individual has
such deep and long-standing relationships and loyalties in the United States, that the individual can
be expected to resolve any conflict of interest in favor of th United States. 
Guideline C (Foreign Preference), the stated concerns are her "dual citizenship" with Jordan
ane her use of the Jordanian passport in 2003/2004, as discussed above under Findings of Fact,
above. The security concern occurs when an individual acts in such a way as to indicate a preference
for a foreign country over the United States, then he or she may be prone to provide information or
make decisions that are harmful to the interests of the United States. 
2.a - Applicant’s Jordanian citizenship was the result of her birth in Jordanian parents. She
retained her Jordanian citizenship because she did not know it would be a problem. When she
learned that was the case, she promptly renounced that citizenship by letter to the Jordanian Embassy
along with her cut up Jordanian passport. 
2.b. - Her Jordanian passport was obtained before she became a U.S. citizen and therefore
cannot be considered an act of preference for Jordan over the United States. Her use of the Jordanian
passport on the one occasion cited in the SOR occurred after she tried to use her U.S. passport and
out of concern for her elderly mother waiting for her elsewhere at the airport. She has recently
renounced her Jordanian citizenship by letter to the Jordanian Embassy and attaching the Jordanian
passport she cut up in front of her company’s facility security officer. Under these circumstances her
conduct did not indicate any preference for Jordan over the United States. The record does not reflect
any conduct indicating a preference for Jordan. 
I understand the Government’s concern with the mother and sisters in Jordan being at risk
of being pressured to use whatever influence they may have on Applicant to act against U.S. security
interests. However, the real concern in Guideline B and C cases is that a person seeking or
possessing a clearance might respond to such pressure by acting improperly and against U.S.
interests.
Disqualifying Conditions 
10.(a) - exercise of any right, privilege, or obligation of foreign citizenship after becoming
a U.S. citizen or through the foreign citizenship of a family member: 
10(a)(1) Possession of a foreign passport. None other apply; 
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Mitigating Conditions 
11.(a) dual citizenship is based solely on parents’ citizenship or birth in a foreign country;
11.(b) the individual has expressed a willingness to renounce dual citizenship [and has
actually done so]. 
11.( e) the passport has been destroyed, surrendered to the cognizant security authority, or
otherwise invalidated. 
I have carefully considered the Government’s exhibits and Official Notice documents. I
understand the risks incurred by Applicant’s family members being citizens and residents of Jordan.
This nation has traditionally been friendly to the United States, and is not cited in Official Notice
documents as being active in espionage or the gathering of sensitive information. At the same time,
there are terrorist elements in Jordan that are a threat to foreigners, including U.S. citizens. I have
taken this reality into account in my evaluation and risk analysis. 
The Government’s evidence comes down to the presence in Jordan of her mother and sisters,
a situation about which she can do little or nothing.  Their status is not her choice. At the same time,
those relationships have survived for many years with Applicant living and working in the U.S., with
no apparent security problems. 
While the lack of past problems does not mean there will be no problems in the future, it is
a positive factor that must be considered along with all other relevant information. Applicant
understands her security obligations and promises to act appropriately. Such promises of future
conduct may not be considered, by themselves, to be substantial evidence, they are augmented by
Applicants long career in America’s defense effort and the solidly positive opinions of those who
have known her over so any years. 
Applicant has a solid record of maturity, integrity, and service to her adopted country.
Despite the risks that may exist solely because of her family members in Jordan, nothing in the
record suggests that Applicant would even hesitate before doing the right thing, to instinctively
protect U.S. security interests. Under the specific facts and circumstances in this case, I conclude that
adequate mitigation of the risk has been shown. 
Finally, in a recent case, the Appeal Board rejected the Government’s contention that the
Administrative Judge’s "whole person analysis" was unsustainable (ISCR Case No. 04-06564 (May
30, 2006). The Appeal Board found that the Administrative Judge had restated some of the Guideline
B mitigating factors and presented a reasonable explanation for her decision, given the relevant
factors in this case, making the favorable decision was sustainable. 
After a careful study of the Appeal Board decision, and the underlying decision of the
Administrative Judge, I conclude the facts and circumstances are substantially similar to those in the
present case as a rationale for the granting of a DoD security clearance.
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FORMAL FINDINGS 
Formal Findings as required by Section 3, Paragraph 7 of Enclosure 1 of the Directive are
hereby rendered as follows: 
Guideline B (Foreign Influence) 
Subparagraph 1.a.             For the Applicant
Subparagraph 1.b. For the Applicant
Subparagraph 1.c.             For the Applicant
Subparagraph 1.d. For the Applicant
Subparagraph 1.e.             For the Applicant
Subparagraph 1.f.. For the Applicant
Guideline C (Foreign Preference) For the Applicant
Subparagraph 2.a.             For the Applicant
Subparagraph 2.b. For the Applicant
DECISION
In light of all the circumstances presented by the record in this case, it is clearly consistent
with the national interest to grant or continue a security clearance for Applicant. 
BARRY M. SAX 
ADMINISTRATIVE JUDGE