Foreign Travel, Foreign Considerations, Suspicious Contact, Outside Activities

The United States is the dominant political, economic, and military force in the world. We have power, information, and technology that other countries want, and they will not hesitate to harm or exploit U.S. persons to obtain it.

Every U.S. person is a potential target for exploitation. Our work in the government space means that we are of particular interest to foreign actors. For this reason, we must take extra precautions when interacting with any foreign person(s), foreign entity, foreign business, or foreign organization.

Foreign Travel

U.S. Citizens are often targeted while traveling outside the U.S. Even in “safe” countries, there are risks and precautions we must take to ensure safety and awareness when traveling.

Federal contractor facilities and their personnel are subject to foreign travel briefing and reporting requirements as outlined in 32 CFR Part 117, SEAD 3, and certain program specific reporting guidelines. FSOs are required to provide travel safety briefings, country specific briefings, and post-travel debriefing.

For this reason, we recommend that all contractor personnel (employees and consultants) report any travel outside of the United States, both personal and professional, to their company’s FSO at least 30 days prior to departure (whenever possible).

Pre-Travel: Ideally any travel outside the US should be reported to your FSO at least 30 days prior to your departure. When 30 days’ notice is not possible, the travel should be reported immediately upon booking. For those that live in border areas, unexpected day trips to Mexico and Canada must be reported within 5 days of return.

Post-Travel: Foreign travel debriefing is required. Covered individuals should contact their company’s FSO immediately upon return to complete post travel debriefing requirements.

Foreign Considerations (Contact, Influence, Interests, Activities, Conflicts of Interest)

Covered individuals are required to self-report any contact with foreign nationals, potential foreign influence, foreign activities or interests, suspicious contact, and any other information pertinent to connections with a foreign country or foreign persons.

Conditions that must be reported include, but may not be limited to:

• Any contact (through any method including social media) with a foreign family member, business or professional associate, friend, acquaintance, or any other person who is a citizen or resident of a foreign country
• Any business, financial, or property interests in a foreign country, or in any foreign-owned or foreign-operated business
• Any unauthorized association with a suspected or known agent, associate, or employee of a foreign intelligence entity
• Any connection to any foreign person, group, government, or country that could potentially create a perceived conflict of interest

Foreign Preference

When an individual gives preference to a foreign country over the U.S., they are far more vulnerable to exploitation. Conditions that could raise concern, and must be reported, include but are not limited to:

• Applying for and/or acquiring citizenship in any other country
• Failure to use a U.S. passport when entering or exiting the U.S.
• Assuming employment, position, or political office in a foreign government or military organization
• Any act of expatriation from the U.S.

Suspicious Contact

Suspicious contact is any effort by any individual, regardless of nationality, to obtain illegal or unauthorized access to information or to compromise an individual.

Examples of suspicious contact that must be reported include:

• Any individual’s efforts, regardless of nationality, to obtain illegal or unauthorized access to sensitive or classified information
• All contact with known or suspected foreign intelligence operatives
• Any contact requesting a person to participate in a foreign conference, seminar, tradeshow, etc.
• Any contact seeking information about your work, job duties, coworkers, etc.

Outside Activities

Involvement in certain types of outside employment or activities could be a security concern if it poses a conflict of interest or if it could increase the risk of unauthorized disclosure of classified or sensitive information.

Some conditions that could raise concern, and must be reported, include:

• Any employment or service with the government of a foreign country or any foreign nation, organization, or other entity
• Any foreign, domestic, or international organization engaged in analysis, discussion, or publication of material on intelligence, defense, foreign affairs, or protected technology

Why Reporting is Critical

Full transparency and self-reporting about any foreign considerations is vital. Failure to report will always be viewed by Adjudicators as “what is this person trying to hide and why?” If investigators find information on their own before you self-report, the consequences are significantly greater.

All covered individuals must report any foreign travel, foreign considerations, suspicious contact, and outside activities to their company’s FSO.

Resources and Additional Learning

• CDSE Foreign Travel Defensive Briefing
• DCSA Self-Reporting
• SEAD 3 – Reporting
• 32 CFR Part 117 (NISPOM Rule)

As always, if you have any questions, ask your FSO!