DATE:  December 20, 2007
In Re:
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SSN: -----------
Applicant for Security Clearance
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ISCR Case No. 07-04860
DECISION OF ADMINISTRATIVE JUDGE
THOMAS M. CREAN
APPEARANCES
FOR GOVERNMENT
Francisco Mendez, Esq., Department Counsel
FOR APPLICANT
Joseph P. Drennan, Esquire
SYNOPSIS
Applicant is an information technology specialist for a defense contractor.  He has a mother
and siblings residing in Jordan, Saudi Arabia, and the United Arab Emirates.  He destroyed his
Jordanian passport before a cognizant security official.  He mitigated security concerns for his family
members in Jordan, Saudi Arabia, and the United Arab Emirates.  Clearance is granted.
STATEMENT OF THE CASE
On August 14, 2007, the Defense Office of Hearings and Appeals (DOHA) issued a
2
Statement of Reasons (SOR) detailing the basis for its decision to deny a security clearance for
Applicant.  The action was taken under Executive Order 10865, Safeguarding Classified Information
within Industry (February 20, 1990), as amended, and Department of Defense Directive 5220.6,
Defense Industrial Personnel Security Clearance Review Program (January 2, 1992), as amended
(Directive).  The new adjudicative guidelines, promulgated by the President on December 29, 2005,
and effective in the Department of Defense on September 1, 2006, will be used to adjudicate this
case.  Applicant acknowledged receipt of the SOR on August 20, 2007.  The SOR alleges security
concerns under Guideline B (Foreign Influence), and Guideline C (Foreign Preference) of the
Directive.
Applicant answered the SOR in writing on September 4, 2007.  He admitted all of the factual
allegations under both Guidelines but provided an explanation why the facts did not raise a security
concern.  He requested a hearing before an administrative judge, and the request was received by
DOHA on September 6, 2007.  Department Counsel was prepared to proceed with the case on
October 31, 2007. The case was assigned to another Administrative Judge on November 5, 2007,
and reassigned to me on November 20, 2007.  A notice of hearing was issued on November 28,
2007, and the hearing convened on December 5, 2007.  Eight government exhibits (Government
Exhibits 1-8) were received and admitted without objection.  Eight Applicant exhibits (Applicant
Exhibits A-H) were received and seven admitted into evidence without objection.  Applicant Exhibit
H was not admitted since it was a duplicate of a matter already in the case file.  The testimony of the
Applicant and three Applicant witnesses were received during the hearing.  The record was held
open for Applicant to submit an additional document (Applicant Exhibit I) which was timely
submitted and admitted without objection.  DOHA received the transcript on December 17, 2007.
FINDINGS OF FACT
After a thorough review of the pleadings, transcript, and exhibits, I make the following
essential findings of fact.
Applicant is 54 years old and an information technology specialist for a defense contractor.
He was born in Jordan, but has lived in other Middle East countries.  He and his family lived in a
Middle East country where he received his schooling through high school.  He attended college in
another Middle East country where he received a bachelor’s degree in electrical engineering in 1976.
He returned to the country where he received his early education, and worked as an engineer for four
years.  He emigrated to the United States on a student visa in 1980, receiving a Masters of Business
Administration degree from a United States university in 1982.  His student visa was changed to a
work visa and he commenced working for a friend’s import-export business until 1984 when he
started his own information technology business.  His company did computer programing on a
system for word processing in a variety of languages.  In 1989, his company ceased operations and
he became an independent information technology consultant.  In 2000, he started working for 
various companies in the information technology field.  He consulted on projects, including for a
Tr.24-31; Government Exhibit 1  (Security Clearance Application, dated June 23, 2005); Government Exhibit1
4 (Letter of Commendation, dated August 4, 2004).
Tr. 31-35; 50-52; Applicant Exhibit A (Passport, issued April 18, 1990); Applicant Exhibit E (Adoption Order,2
dated August 16, 2007).
Tr. 97-99.  Applicant’s wife’s brothers are not alleged as security concerns.3
Tr. 35-39, 78-80.4
Tr. 44-47; Applicant Exhibit C (United States passport, issued January 24, 2000).5
Tr. 50-51.6
Tr. 40; Applicant Exhibit B (Jordanian Passport, issued May 9, 2000).7
Applicant Exhibit D (Jordanian Passport, issued July 12, 2005).8
3
United States military command from which he received a letter of commendation.1
Applicant first married in 1982 , and divorced in 1996.  He has three children from that
marriage.  These children were born in the United States, are United States citizens, and  reside in
the United States attending college.  He married his present wife in 1997.  They have one child who
was born in the United States and is a United States citizen.  The child attends elementary school and
resides with Applicant and his wife in the United States.  Applicant and his wife recently adopted
an infant child from an orphanage in Israel.  The adoption has been approved by a United States
court.   His wife is a dual Jordanian and United States citizen.  Her Jordanian citizenship is merely2
because she was born in Jordan.  She has a brother who is a resident of the United States and another
brother who is a resident of United Arab Emirates.  Applicant and his family have resided in the
same house in the United States since 1997.3
Applicant became a United States citizen in 1990 and issued his first United States passport
the next day.  He used this passport in 1995 to take his family to Jordan to visit relatives.  When he
and the family entered Jordan with United States passports, they had to stand in a long line and pay
a fee.  Applicant also had to report to the local police station after two weeks.  He went to Jordan in
1996 using his United State passport and encountered the same long line and fee requirement.  He
also used the United States passport on various business trips to different countries, like Saudi
Arabia, while marketing his information technology products.   Applicant renewed his United States4
passport in January 2000 and it expires in January 2010.  He used this passport to travel on business
to Saudi Arabia, United Arab Emirates, and Canada on business.  He also travel to Mexico and
Canada for pleasure trips using the passport.   He used his United States passport to enter Israel in5
2005 for the purpose of adopting a child.6
Applicant is considered by Jordan a Jordanian citizen because he was born in Jordan of
Jordanian parents.  He had a Jordanian passport when he emigrated to the United States.  He renewed
the passport in 2000, but never used it.   He was issued a current Jordanian passport on July 12,7
2005, which is to expire on July 12, 2010.   Applicant used the passport twice.  He went to Jordan8
in August 2005 to visit his mother and to bring her back to the United States.  He used the passport
as a matter of convenience so he did not have to stand in line, pay a fee, or check in with the local
Tr. 52-53.9
Tr. 78-81, 102-103.10
Applicant Exhibit F (Jordanian instructions and translation, dated December 3, 2007)11
Tr. 60-66.12
Tr. 67-78; Applicant Exhibit G (Copy Jordanian Passport, July 12, 2005, expiration July112, 2010); Applicant13
Exhibit I (Affidavit of Facility Security Officer, and delivery notice, dated December 18, 2007).
Tr. 92.14
Tr. 82-83.15
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police.  He used the passport again in April 2007, when he brought his mother back to Jordan.  He
wanted to make the passage through the Jordanian immigration as easy as possible for his mother.9
Applicant was interviewed by a security agent in December 2006.  The agent questioned him
about his Jordanian passport but did not inform him that possession of a foreign passport was a
security concern.  In fact, Applicant understood from the agent that there was no issue with his
Jordanian passport.   The first he knew there was an issue was on receiving the SOR.  He contacted10
his facility security officer and learned the company could not assist him and his only action was to
return the passport to the Jordanian government.  He had a friend contact the Jordanian embassy to
learn the procedure to return the Jordanian passport and renounce his Jordanian citizenship.  He did
not at first contact them himself because he did not want them to know he was applying for a security
clearance.  His friend learned that the process to return the passport and renounce the citizenship was
long, complicated, and expensive.  Applicant himself contacted the embassy and learned the same
information.  He was directed to an internet site for a form and directions.   The procedures required11
submitting the form, paying a $2,000 fee, and waiting for a decision by the Jordanian government.
Acceptance of the request to renounce Jordanian citizenship is not guaranteed.  Applicant knew the
Embassy would not accept his passport for return.  Applicant does not have the $2,000 fee readily
available nor the time to wait for a Jordanian government decision.  He stamped the passport
“cancelled” on his own.   Applicant destroyed the current Jordanian passport in the presence of his12
facility security officer as a cognizant security authority, and sent the destroyed passport to the
Jordanian Embassy.  Applicant no longer has a current Jordanian passport in his possession.13
Applicant had seven brothers and sisters.  His father passed away but his mother is still alive.
His mother was born in the 1920s in the area that at the time was Palestine.  The area became Jordan
in the late 1940s.   She is a dual citizen of Canada and Jordan.  She is 86 years old and receives no14
support from the Jordanian government.  She does receive benefits from the Canadian government.
His brother provides the main support for his mother, and Applicant does not provide support.
Applicant’s mother lived with Applicant and his family in the United States from 2005 to 2007.  She
became sick in late 2006, and returned to Jordan in April 2007 when strong enough to travel.   15
Applicant’s two sisters and a brother are residents and citizens of Jordan.  One sister and the
brother are also dual citizens of Canada.  The sisters are housewives who are not employed outside
the home.  One had been a school teacher but is now not employed.  The brother is a medical doctor
who is a university professor.  Applicant’s relationship with them is good.  They do not talk every
Tr. 56-57, 82-83, 93-94.16
Tr. 84-85.17
Tr. 92-93.18
Tr. 100-101; Government Exhibit 3 (Interrogatories, dated July 17, 2007).  These sisters are not listed as19
security concerns.
Tr. 101-102.20
Tr. 86-88.21
Tr. 104-111.22
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day but do communicate by e-mail.  When their mother lived with Applicant in the United States,
they talk more frequently.  Now he talks to them only a few times a year, mainly concerning the
health of their mother.   He has a brother who is a dual Jordanian and Canadian citizen residing in16
the United Arab Emirates.  He is employed by a construction company.  When their mother lived
with Applicant, he had frequent contact with the brother by e-mail or telephone when the brother
inquired about their mother’s health.  Now the contact is very infrequent.  He communicates usually
over the internet by instant message.  His last contact with the brother was about three months ago.
Applicant also visited the brother in 2000 when Applicant was in the country on a business trip.17
Applicant has a brother that is a dual Canadian and Jordanian citizen residing in Saudi
Arabia.  His brother’s wife is the sister of his first wife.  Since he and his first wife divorce, he and
this brother are estranged.  At best, his contact with him is by e-mail once a year.   He has a sister18
who is a resident and citizen of Canada since 1972, and another sister who is a resident and citizen
of the United States.19
Applicant does not own any property outside the United States.  He has never voted in a
foreign election or run for political office in a foreign country.   When he owned his own company,20
he did some work for an American company that had a contract with a company from Saudi Arabia.
He traveled to Saudi Arabia to work on the project in 2000.  He was not a consultant to the Saudi
Arabian government but was a consultant to the United States company.  He also went to Saudi
Arabia in th early 1990s as an employee of another company to attempt to sell a computer program
to the Saudi Arabian government.  Under the same contract, he worked with Saudi Arabian military
officers at the embassy on a computer network.  The highest embassy official he worked with was
a military attache.21
An Applicant witness testified he holds a security clearance and worked closely with
Applicant for over four years from 1999 to 2003.  He was a company vice-president and Applicant
worked closely with him on a project that lasted a few years.  They traveled extensively together on
this project.  He does not know Applicant socially.  Applicant has an excellent reputation for honesty
and integrity.  He has seen and talked to Applicant since they both left their former employer.22
An Applicant witness, a retired military officer, testified he is a vice president of Applicant’s
Tr. 113-120.23
Tr. 121-126.24
See Government Exhibit 6 (Background notes, Saudi Arabia, dated June 2007); Saudi Arabia,( Country Report25
on Human Rights Practices, 2006); Department of State (Country Report on Terrorism, Chapter 2, Middle East and North
Africa Overview, dated April 30, 2007)..
6
present employer.  He has known Applicant for over two years, has frequent exchanges with him,
and receives reports from other managers.  Applicant is a very trustworthy, honest, and a direct
individual.  He works hard, is dedicated to achieving the goals, and goes above and beyond what is
required.  He is confident that Applicant is trustworthy and honest.23
Another Applicant witness testified she is the functional lead on a project for Applicant’s
employer.  She has worked with Applicant on the project for over two years.  She interacts with him
on a daily basis.  They work closely developing, testing, and implementing the system they designed.
Applicant is always honest, hard working, and performs the tasks needed to be done.  Applicant’s
reputation for integrity and honesty with her and his fellow employees is very positive.24
Jordan is a small constitutional monarchy in the Middle East with a developing economy.
The government follows a pro-western foreign policy and has had close relationships with the United
States for over 40 years.  There are human rights problems and torture by police and security forces.
Jordanian law applies to dual Jordanian and American citizens.  Jordan has aggressively pursued
terrorists and takes a firm stance against terrorist.  However, the threat from terrorists remains high.
Terrorists target areas frequented by westerners.  The Jordanian security forces have disrupted
numerous plots against United States interests.  However, there is a continued focus by terrorists
against United States and Jordan. 
Saudi Arabia is a monarchy ruled Middle East country.  There are no political parties or
elections.  There are significant human rights problems.  The religious police harass and abuse
individuals to comply with religious actions and customs.  However, Saudi Arabia and the United
States share a common concern over regional security.  The United States relationship with Saudi
Arabia was strained after September 11, 2001, because the overwhelming majority of terrorists that
day were from Saudi Arabia.  There have been other terrorists attacks against United States citizens
since 2001.  This required the State Department to issue a travel warning for Saudi Arabia because
of the terrorist activities targeted against American citizens and interest.  Saudi Arabia believes in
fighting terrorism in its own country, has taken steps to curtail terrorist and terror plans within its
borders, and has had some successes.25
The United Arab Emirates is a federation of individual ruled emirates.  The government is
a federal republic with a president and council of ministers.  Its laws and practices come from
Islamic ideals and beliefs.  The country is one of the leading partners in the region against terrorism,
providing military , diplomatic and financial assistance.  The United States and United Arab
Emirates have enjoyed a friendly relationship since the Emirates were established.  There are
human rights problems due to lack of elections, a questionably independent judiciary, and
See Government Exhibit 8, (Background Notes, United Arab Emirates, June 2007).  It should also be noted26
that Department counsel initially noted Israel as a country of concern. The government no longer considers Israel a
security concern.  Tr. 130.
See Government Exhibit 5, Background Note: Jordan, May 2007.27
Department of the Navy v. Egan, 484 U.S. 518 (1988).28
Directive ¶ E2.2.1.29
Directive ¶¶ E2.2.1.1 through E2.2.1.9.30
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restrictions on civil liberties.26
In general, United States intelligence agencies report that terrorists have targeted United
States personnel and interests to collect intelligence through human espionage and by other means.
Travelers are advised by the State Department to be cautious of their surroundings and to maintain
a high level of vigilance.27
POLICIES
The President has “the authority to . . . control access to information bearing on national
security and to determine whether an individual is sufficiently trustworthy to occupy a position . .
. that will give that person access to such information.”   Eligibility for a security clearance is28
predicated upon the applicant meeting the security guidelines contained in the Directive.29
The Directive sets out the adjudicative guidelines for making decisions on security
clearances.  Enclosure 2 of the Directive sets forth adjudicative guidelines for determining eligibility
for access to classified information, and it lists the disqualifying conditions and mitigating conditions
for each guideline.  Each clearance decision must be fair, impartial, and a commonsense decision
based on the relevant and material facts and circumstances, the whole person concept, and the factors
listed in the Directive ¶ 6.3.1 through ¶ 6.3.6.
The 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.  An Administrative
Judge must apply the “whole person concept,” and consider and carefully weigh the available
reliable information about the person,.  An administrative Judge should consider: (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 applicant’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; (7) the motivation for the conduct;
(8) the potential for pressure, coercion, exploitation, or duress; and (9) the likelihood of continuation
of recurrence.30
A person granted access to classified information enters into a special relationship with the
government.  The government must be able to repose a high degree of trust and confidence in those
individuals to whom it grants access to classified information.  The decision to deny an individual
See Exec. Or. 10865 § 7.31
Directive ¶ E3.1.14.32
ISCR Case No. 01-20700 at 3 (App. Bd. Dec. 19, 2002); see Directive ¶ E3.1.15.33
ISCR Case No. 01-20700 at 3 (App. Bd. Dec. 19, 2002). 34
ISCR Case No. 99-0597 (App. Bd. Dec 13, 2000).35
ISCR Case No. 95-0611 at 2 (App. Bd. May 2, 1996) (quoting DISCR Case No. 92-1106 (App. Bd. Oct. 7,36
1993))
Egan, 484 U.S. at 531; see Directive ¶ E2.2.2.37
AG ¶ 9.38
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a security clearance is not necessarily a determination as to the loyalty of the applicant.   It is merely31
an indication that the applicant has not met the strict guidelines the President and the Secretary of
Defense have established for issuing a clearance.
Initially, the Government must present evidence to establish controverted facts in the SOR that
disqualify or may disqualify the Applicant from being eligible for access to classified information.32
Thereafter, Applicant is responsible for presenting evidence to rebut, explain, extenuate, or mitigate
facts.   An applicant “has the ultimate burden of demonstrating that it is clearly consistent with the33
national interest to grant or continue his security clearance.”   The government is under no duty to34
present evidence to disprove any Adjudicative Guideline mitigating condition, and an Administrative
Judge cannot assume or infer that any particular mitigating condition is applicable merely because the
government does not present evidence to disprove that particular mitigating condition.  “[T]he35
Directive presumes there is a nexus or rational connection between proven conduct under any of the
criteria listed therein and an applicant’s security suitability.”   “Any doubt as to whether access to36
classified information is clearly consistent with national security will be resolved in favor of the
national security.” 37
Conditions that could raise a security concern and may be disqualifying, as well as those which
would mitigate security concerns, pertaining to the adjudicative guideline are set forth and discussed
in the conclusions section below.
CONCLUSIONS
I carefully considered all of the facts in evidence and the legal standards discussed above.  I
reach the following conclusions regarding the allegations in the SOR.
When an individual acts in such a way as to indicate a preference for a foreign country over
the United States, then he may be prone to provide information or make decisions that are harmful to
the interests of the United States.   Applicant became a United States citizen in 1990, but is38
considered by Jordan a citizen of that country because of his birth in Jordan.  He received a United
States passport when he became a United States citizen.  He used this passport on his travels, including
travels to Jordan,  except as noted below.  Applicant twice renewed his Jordanian passport after
AG ¶ 6.39
9
obtaining United States citizenship.  He possessed and used that passport to enter Jordan in 2005 and
2007. Possession and use of the Jordanian passport raises Foreign Preference Disqualifying Condition
(FP DC) AG ¶ 10(a) (Exercise of any right, privilege, or obligation of foreign citizenship after
becoming a United States citizen or through the foreign citizenship of a family member.  This includes
but is not limited to: (1) possession of a current foreign passport.)  
Applicant did not know that possession and use of the passport was a security concern until
he received the SOR.  Thereafter, he became aggressive in attempting to denounce his dual citizenship
with Jordan and relinquish his Jordanian passport.  He presented information and evidence that he
informed officials in the Jordanian embassy of his desire to renounce his citizenship.  He destroyed
the passport in front of a cognizant security official from his employer and sent it to the Jordanian
embassy.  He mitigated the security concerns for foreign preference under Foreign Preference
Mitigating Conditions (FP MC) ¶ 11(b) (The individual has expressed a willingness to renounce dual
citizenship), and FP MC ¶ 11(e) (The passport has been destroyed, surrendered to the cognizant
security authority, or otherwise invalidated.)  He no longer has a current Jordanian passport.  He took
the necessary step to renounce his Jordanian citizenship and destroying his Jordanian passport.
Applicant has mitigated security concerns for foreign preference.
Under Guideline B, foreign contacts and interests may be 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 the United States interest, or is
vulnerable to pressure or coercion by any foreign interest.  Adjudication under this Guideline can and
should consider the identity of the foreign county 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 United States citizens to obtain protected information and/or is associated with a risk of
terrorism.39
Applicant’s mother, a sister, and a brother are dual citizens of Canada and Jordan and reside
in Jordan.  He also has a sister who is a citizen and resident of Jordan.  He has two brothers that are
dual citizens of Jordan and Canada, one residing in Saudi Arabia, and the other in the United Arab
Emirates.  He visited Jordan in 2005 and 2007 for pleasure, and traveled on business to Saudi Arabia
and the United Arab Emirates in 2000.  Appellant’s relatives who are citizens and residents of Jordan,
his brothers in Saudi Arabia and United Arab Emirates, and his travels to see them raises Foreign
Influence Disqualifying Condition (FI DC) ¶ 7(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, manipulation, pressure, or
coercion).  Since each individual contact or activity by itself may or may not create a heightened risk
of foreign influence, the totality of the contacts must be considered to determine if there may be a
heightened risk of foreign influence.
In determining if Applicant’s family in Jordan causes security concerns, I considered that
Jordan has enjoyed friendly relations with the United States for many years.  I also considered that
there are human rights violations and concerns because of the actions of police and security forces.
In determining if his brother in Saudi Arabia causes a security concern, I considered that the United
10
States and Saudi Arabia share a common concern for regional security in the Middle East and there
are significant human rights concern.  As for the security concern for his brother in the United Arab
Emirates, I considered that the United States has a long history of friendly relations with the country
since its founding.  I also considered the threat of terrorism and terrorist activity in each country.
There is no doubt that terrorists are active in each country and there have been terrorists activities
targeting western and United States interest.  However, these are general terrorist actions, like suicide
bombings and shootings, that did not target specific individuals but are just meant to kill any person
that happened to be in an area.  Each country has been active in fighting terrorism in their countries
and have had some successes.  Each country also cooperates with the United States in fighting
terrorism and terrorist groups.  While terrorists in general will target individuals to obtain intelligence
against the United States, there have been no reported instances of citizens of any of these countries
being specifically targeted by terrorists for intelligence purposes.  While none of these considerations
by themselves dispose of the issue, they are all factors to be considered in determining Applicant’s
vulnerability to pressure or coercion from his family members in Jordan, Saudi Arabia, and the United
Arab Emirates.
Applicant raised Foreign Influence Mitigating Condition (FI MC) ¶ 8(c) (Contacts and
communication with foreign citizens is so casual and infrequent that there is little likelihood that it
could create a risk for foreign influence or exploitation) as to his brother in Saudi Arabia.  Applicant
has little if any contact with this brother because of his divorce from his first wife who is the sister of
his brother’s wife.  The contact is very infrequent by e-mail and the strained relationship does not
create a likelihood of creating a risk for foreign exploitation of Applicant through his brother.
Applicant has mitigated the security concern for this brother because his contact with the brother is
infrequent and casual.  His contacts with his mother and siblings in Jordan and his brother in the
United Arab Emirates are more frequent and are normal for a family.  They are not casual and
infrequent, therefore, this mitigating condition does not apply to these family members.
As for the family members in Jordan and the United Arab Emirates, Applicant has raised
Foreign Influence Mitigating Conditions (FI MC) ¶ 8(a) (The nature of the relationship 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 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 interests of
the United States).  Applicant’s mother, brother, and one sister are dual Canadian and Jordanian
citizens residing in Jordan.  His other sister is a Jordanian citizen residing in Jordan.  His brother is
a dual Canadian and Jordanian citizen residing in the United Arab Emirates.  His mother is elderly and
in poor health.  His sisters are housewives and his brother in Jordan is a university professor.  His
brother in the United Arab Emirates works in construction.  None ever worked for any foreign
government.  Applicant’s contact with them is usually by e-mail with occasional telephone calls.  He
did see his siblings when he accompanied his mother on her return to Jordan in April 2007.  While
there is terrorism in Jordan and the United Arab Emirates, it is not of a high intensity or specifically
targeting people like his family members.  The level and type of terrorist activity does not cause a
security concern for Applicant and his family members.  The family members’ living conditions, life
style, and professions, and his limited contact with them show it is unlikely Applicant will be placed
in a position to choose between the interests of his family and the interests of the United States.
Applicant has met his burden to establish that his family in Jordan and the United Arab Emirates do
not present a heightened risk of foreign exploitation, inducement, manipulation, pressure, or coercion.
They are ordinary citizens leading normal lives which also does not indicating a heightened risk for
exploitation, pressure, or coercion.  FI MC ¶ 8(a) applies.
11
Applicant raised FI MC ¶ 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 minimal, or the
individual has such deep and longstanding relationships and loyalties in the United States, that the
individual can be expected to resolve any conflict of interest in favor of the United States interest.) 
Applicant left the Middle East to come to the United States for a better education.  He has been here
for over half his life, raised a family here, and been successful.  His sense of loyalty is to the United
States and the life he has established for himself.  His sense of obligation to Jordan is minimal since
he renounced his Jordanian dual citizenship and destroyed his passport.  Since becoming a United
States citizen, he has used his United States passport for most of his travels thus highlighting his
United States citizenship.  FI MC ¶ 8(b) applies.
I carefully considered all of the circumstances discussed above in regard to disqualifying and
mitigating conditions as well as the following factors in light of the “whole person” concept.  The
“whole person” concept requires consideration of all available information about Applicant, not a
single item in isolation, to reach a common sense determination concerning Applicant’s security
worthiness.  Applicant has family members in Jordan, Saudi Arabia, and the United Arab Emirates.
These simple facts alone might be sufficient to raise security concerns over Applicant’s vulnerability
to coercion, exploitation, or pressure.  However, mere family ties with people in a foreign country is
not, as a matter of law, disqualifying under Guideline B.  Whether an applicant’s family ties in a
foreign country poses a security risk depends on a common sense evaluation of the overall facts and
circumstances of the family ties.  Applicant’s family in Jordan and the United Arab Emirates, both
individually and collectively, are in positions and circumstances that make it unlikely Applicant will
be placed in a position to choose between the interests of his family and the interest of the United
States, or that he can be exploited, pressured, or coerced because of them.  Applicant has been in the
United States for over half his life, and a citizen of the United States for over 17 years.  His co-worker
and his supervisor consider him to be security conscious and not a security risk. 
Applicant’s life story is an example of the success of many immigrants to the United States.
He came to the United States early in his life to better himself through education, and became a United
States citizen.  The family enjoys a typical United States life style with his children being educated in
the United States.  He visits to  Jordan, Saudi Arabia, and the United Arab Emirates have been limited
and for personal or business reasons rather than any connection to the foreign governments.  He has
established that his motivation for his contacts and activities with his family in Jordan, Saudi Arabia,
and the United Arab Emirates do not indicate a security risk.  He has renounced his Jordanian
citizenship and destroyed his Jordanian passport.  
The general threat of terrorism in and of itself does not cause a security concern.  There is a
general threat of terrorism and terrorist activity throughout the world, including in the United States.
The countries involved are actively fighting terrorists and have succeeded in stopping some terrorist
activities.  In Jordan and the United Arab Emirates, there is a general threat and not a specific threat
targeting terrorism of Applicant’s family members.  Applicant has presented sufficient information to
mitigate any security concerns under the “whole person” concept.  I conclude Applicant is eligible for
access to classified information.
FORMAL FINDINGS
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Formal findings for or against Applicant on the allegations set forth in the SOR, as required
by section E3.1.25 of Enclosure 3 of the Directive, are:
Paragraph 1, Guideline C: FOR APPLICANT
Subparagraph 1.a: For Applicant
Subparagraph 1.b: For Applicant
Subparagraph 1.c: For Applicant
Subparagraph 1.d: For Applicant
Paragraph 2, Guideline B: FOR APPLICANT
Subparagraph 1.a: For Applicant
Subparagraph 1.b: For Applicant
Subparagraph 1.c: For Applicant
Subparagraph 1.d: For Applicant
Subparagraph 1.e: For Applicant
Subparagraph 1.f: For Applicant
Subparagraph 1.g: For Applicant
Subparagraph 1.h: For Applicant
Subparagraph 1.i: For Applicant
DECISION
In light of all of the circumstances presented by the record in this case, it is clearly consistent
with the national security to grant a security clearance for Applicant.  Clearance is granted.
Thomas M. Crean
Administrative Judge