Unreported Income or Large Transfers Raise Flags for Clearance Holders

Approximately half of all security clearance holders are now enrolled in Continuous Evaluation (CE) and more are getting enrolled each day as reinvestigation timelines come due. Most reinvestigations are deferred after review of the SF-86 application and other checks are completed. CE enrollment for DoD contractors is input into the Defense Information Security System and the clearance holder’s information is added to the list of checks being continuously run through various systems. One of those checks involves a bureau in the Department of Treasury called the Financial Crimes Enforcement Network (FinCEN) which flags certain transactions that are out of the norm.

As an example, Joe Clearance Holder decides to withdraw $60,000 from his Thrift Savings Plan funds to pay for some home upgrades and a pool installation. In accordance with the Bank Secrecy Act, banks must report transfers, incoming or outgoing, for amounts over a specific amount and when this notification reaches FinCEN it is flagged because Joe is identified by the system as being enrolled in CE. The agency responsible for granting Joe’s clearance is notified of the transaction for review and an adjudicative determination. If Joe reported this transfer to his Facility Security Officer (FSO) prior to the flag, then the review process is quick and easy. If he did not, then more information must be obtained from Joe before the flag can be resolved.

As I always advise, getting out in front of potential issues is preferable and will help mitigate concerns before they become issues. Transparency and honesty will show you have nothing to hide and are above board.