Foreign Financial business ties


#1

I have read through these forums a good bit and am glad to find some expertise in the security clearance apparatus. I am hoping someone can give me some insight about foreign business ties and how it can impact my TOP SECRET clearance.

SCENARIO: I have been in the federal government doing foreign affairs work for 7 years now, and hold a TS/SCI clearance. Early this year, I started a side technology consulting business that would involve developing software applications for domestic and international small businesses. I am planning to hire software developers from the U.S., but also in international markets as well, especially those who have the expertise in the kind of software I am planning to develop. It would also likely involve contractual agreements with the individual developer and possibly other small business companies in foreign countries (United Kingdom, India and Uruguay are the only three). The last piece of this is that I would likely need start-up capital to run my business, and have considered looking to an overseas venture capitalist (in India) to help get me started.

MY QUESTIONS: What would pose a security risk here? I do not believe that just having a small business on the side poses risks, but the possible foreign influence (via hiring developers and/or the venture capitalist start-up capital) might pose some concerns. If these are red flags, what could be some mitigating factors?

Thanks in advance for your thorough response.

Caz


#2

I’m not the expert but did you run this past the FSO at your site? You don’t say what it is that you do in your current position, but your description sends up all sorts of flags for me before you even sign a foreign contract or go for VC.


#3

I understand.

If there happens to be an expert on this, that would be greatly appreciated.


#4

I would tread carefully…but if all is above board, make full disclosures. If the venture has nothing to do with the cleared work and you keep them separate I don’t see an issue. It is a global economy. Much IT work is outsourced to India and the like. Much manufacturing is off shore. Not all of them are a risk of any kind.


#5

Thank you. So would this be more of a financial disclosure/disclaimer issue or a security issue, or both? I don’t know many people who have side businesses like this, and its a tough question to be answered it seems.


#6

It is definitely a financial disclosure aspect but reporting it upfront negates it from being perceived as a potential security issue. I maintain foreign ties from my military days 15 years prior. Mostly just hitting “like” on facebook at this point. But I make sure I point it out on each SF 86 and I cover it on recurring Polygraphs these past 7 years. .


#7

Understood, thanks. I will go ahead and do both–financial disclosure and reporting to my security office.


#8

Depending on current level of clearance and agency/community employing you there may be a requirement to document and report this as an outside activity. Where I work Secret cleared folks report this to me and I notify government if it seems reportable. I am granted that discretion. For TS cleared it must be formally reported via their system. It can generate an interview or even a request for a new background investigation.


#9

The agency is the U.S. Department of State. Are you familiar with their regs?