The reporting of contacts, specifically foreign contacts, for clearance holders is of the utmost importance for continued access authorization. All security clearance holders have an obligation to report potential security concerns, whether they are about themselves or others. Guideline B of the Security Executive Agent Directive (SEAD) 4 lays out the disqualifying and mitigating conditions for potential foreign influence concerns. However, before even getting to these regulations, one must decide if they are required to report foreign contacts. The reporting requirements are set forth in SEAD 3, but both SEAD 3 and SEAD 4 should be used to determine if you are required to report a foreign contact.
Under SEAD 3, the reporting of foreign contacts is governed by section F(2) and requires, in part, that a person report any “continuing association with known foreign nationals that involves bonds of affection, personal obligation, or intimate contact; or any contact with a foreign national that involves the exchange of personal information.” The last part is important to note as it provides a far broader description of when a foreign contact needs to be reported.
Many individuals look to the Standard Form 86 (SF-86) to determine what information needs to be reported in relation to foreign contacts under section 19 when it asks in part if “you have close and/or continuing contact with a foreign national with whom you, your spouse, or partner are bound by affection, influence, common interests, and/or obligations.” However, SEAD 3 provides a more complete definition as it describes the requirement to report any foreign contact that involves the exchange of personal information.
