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1.Department of State telegram to all diplomatic and consular posts concerning dual citizenship of Department of State employees (March 2, 2002)




SUBJECT: Dual Citizenship - Security Clearance Implications

REF: (a)Executive Order 12968
(, (b)Executive Order
10450 (,
(c)32 C.F.R. Part 147
( 00/32cfr147
00.html) The blank spaces in the above web site address
should be underscores - that is the immediate space before
00/32cfr147 and before 00.html, (d)12 FAM 230

1. (U) The issue of dual citizenship of Department
employees and applicants for employment has recently
engendered questions about Department policy. The purpose
of this cable/notice is to explain existing Department
policy for all employees and to inform potential applicants
for both the Civil Service and Foreign Service of the
possible effect of dual citizenship on security clearance
determinations. Dual citizenship can present a security
issue whether to permit access to classified information
which affects recruitment, employment and assignments.

2. (U) State Department security clearance evaluations and
determinations are the responsibility of the Bureau of
Diplomatic Security (DS). DS is required to consider dual
citizenship in conducting personnel security investigations
and making security clearance evaluations/determinations in
accord with government-wide Executive Orders and
adjudicative standards (Executive Orders 10450 and 12968,
32 C.F.R. Part 147 and 12 FAM 230 are available online at
the referenced web addresses).

3. (U) Security clearance evaluations/determinations must
assure that access to classified information for a specific
individual is "clearly consistent with the interests of
national security." Under the adjudicative guidelines,
"any doubt as to whether access to classified information
is clearly consistent with national security will be
resolved in favor of the national security." When making
such a determination, DS must consider all available
information, both positive and negative. This is the
"whole person" concept. Dual nationality is a relevant
element in some cases. While U.S. citizenship is a basic
eligibility requirement to be considered for access to
classified information, it does not automatically confer
the right to a security clearance. Dual citizenship must
be considered in context of other circumstances in an
individual's background.

4. (U) The Department has not implemented, and does not
intend to implement, any "blanket rule" regarding dual
citizenship. In making security clearance determinations,
DS will continue to evaluate dual citizenship issues on a
case-by-case basis. Applicants will be questioned about
dual citizenship as part of their initial subject
interview. Current employees will not generally be
questioned about any foreign citizenship until the
regularly scheduled periodic reinvestigation. Should an
event trigger a review of an employee's access eligibility
before their routine update, any foreign citizenship will
be addressed at that time.

5. (U) Facts about any subject's conduct and behavior
developed through required background investigation are
weighed against criteria in the government-wide
adjudicative guidelines. DS must be able to determine that
granting access to classified information is clearly in the
national security interest. A fundamental adjudicative
principle is that the mere absence of derogatory
information is not sufficient grounds to grant a security

clearance. The government must, through an appropriate
investigation and evaluation, establish a personal and
professional history that positively affirms the
individual's judgment, reliability, trustworthiness and
loyalty to the United States. If there is any doubt about
unquestioned preference for and allegiance to the United
States, unencumbered by any undue foreign influence, DS
must render a determination in favor of the national
security and determine that individual ineligible for
access. These same adjudicative principles are used in all
federal personnel security programs.

6. (U) The evaluation element presented by dual
citizenship is that it could raise an issue of possible
divided loyalty to the United States. Title 32 C.F.R.
174.5, Adjudicative Guideline C, Foreign Preference,

(a) The concern. 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.

(b) Conditions that could raise a security concern and may
be disqualifying include:
(1) the exercise of dual citizenship;
(2) possession and/or use of a foreign passport;
(3) military service or a willingness to bear arms for a
foreign country;
(4) accepting educational, medical or other benefits, such
as retirement and social welfare, from a foreign country;
(5) residence in a foreign country to meet citizenship
(6) using foreign citizenship to protect financial or
business interests in another country;
(7) seeking or holding political office in the foreign
(8) voting in foreign elections;
(9) performing or attempting to perform duties, or
otherwise acting, so as to serve thE interests of another
government in preference to the interests of the United

(c) Conditions that could mitigate security concerns
(1) dual citizenship is based solely on parents'
citizenship or birth in a foreign country;

(2) indicators of possible foreign preference (e.g.,
foreign military service) occurred before obtaining United
States citizenship;
(3) activity is sanctioned by the United States;
(4) individual has expressed a willingness to renounce dual

7. (U) To illustrate the DS evaluation process regarding
dual citizenship, some past examples that have arisen
recently are provided below. DS' goal is to maintain
consistency in its determinations. There may appear to be
many similarities between cases; however individual
circumstances vary greatly and may not be known to the
hiring entity. While not all inclusive, the following
examples give an indication of how such factors are
evaluated and determinations made:

Example A. A subject derived foreign citizenship from hiS
or her parents. In this case, DS would examine whether or
not the subject has exercised the foreign citizenship: by
accepting educational, medical or social welfare benefits
for himself/herself or family; possessing and using the
foreign passport; serving in the foreign military; working
for the foreign government; etc. In the absence of the
subject's exercising foreign citizenship, and if subject's
current and past actions consistently demonstrated
preference for and allegiance to the United States, then
dual citizenship would not preclude a security clearance.

Example B. A subject only recently became a naturalized
U.S. citizen through marriage and has no previous ties to
the United States. In this case, DS could not likely grant
an immediate security clearance, since the demonstrated
loyalty requirement could not be satisfied immediately.
Eligibility for access could be reconsidered after a
passage of time during which the subject would have the
opportunity to clearly demonstrate preference for and
unquestioned allegiance to the United States, and the
absence of any undue conflicting influence, as required by
the referenced guidelines.

Example C. A subject was born in the U.S. as the child of
foreign visitors. The subject left the U.S. in infancy,
never returned and has no ties or history which indicate a
preference for and allegiance to the United States. DS
would not have the background information required to grant
a security clearance.

Example D. A subject is a naturalized U.S. citizen and
dual national who is willing to relinquish his foreign
passport but is not/not willing to renounce foreign
citizenship of birth. The subject explains that the reason
for this position Is: (1) so that children can continue to
enjoy free foreign education benefits; (2) for possible
future employment opportunities; and (3) for foreign
inheritance purposes. DS would not be able to clearly
determine the individual's preference for the United
States, sufficient to grant a security clearance.

8. (U) DS will continue adjudicating security clearances
pursuant to the "whole person" concept. The fact that a
person holds citizenship with another country, as well as
citizenship with the United States, does not automatically
result in a security clearance denial. Conversely, the
simple renunciation of foreign citizenship would not
necessarily result in granting a clearance. An individual
must demonstrate unquestioned allegiance to the United
States, preference for the United States over any other
country, and also be free from any undue foreign influence.
If this cannot be established, a security clearance cannot
be granted. Where a newly naturalized citizen is seeking
State Department employment, DS may be unable to adequately
investigate the person's background in the country of
origin or elsewhere to make this determination. When DS is
unable to clear a new entrant, DS will so inform HR, and HR
will take steps to withdraw the offer.

9. (U) Should DS make an unfavorable determination on a
security clearance, E.O. 12968 guarantees appeal rights to
applicants and employees alike. The Department's final
clearance determination is rendered by a panel consisting
of the Under Secretary for Management, the Director General
of the Foreign Service and Director of Human Resources and
the Assistant Secretary, Bureau of Administration. The
Department's appeal process can be found in 12 FAM 230.

10. (U) Dual citizenship also presents an issue in the
assignment of staff to overseas posts. For example, the
Vienna Convention on Diplomatic Relations does not provide
diplomatic privileges and immunities for dual nationals;
most countries do not unilaterally grant such privileges
and immunities. Absent extraordinary circumstances, the
Department will not assign an employee to a country where
he or she is a citizen.

11. (U) The Director General is ensuring that this
Department policy is made known to potential applicants at
the earliest possible stage of the recruitment process.

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