So I currently hold an active TS/SCI clearance. I recently accepted a new position that requires me to receive DHS suitability and complete the DHS Foreign Influence and Foreign Preference (FIFP) review. I now live with my fiancé who qualifies as a cohabitant. My question lies with the Foreign Associations form that states “To be completed if you, your spouse or cohabitant have any continuing contact with citizens of another country or dual citizens. One template must be completed for each foreign associate.”
My fiancés background is Iranian (she was born in Iran but she holds a clearance and officially denounced citizenship years ago so no issue there). I see her family on a regular basis, specifically my future in-laws, for small family gatherings such as dinner. They were born in Iran and migrated to the United States almost 25-30 years ago and have not visited since. None of them hold valid passports or have any plans on ever returning to Iran. Since Iranian citizenship is considered a birth right under Iranian law, would they still count as a dual national? Under Iranian law, Iran does not recognize US Citizenship and vice versa so I’m really stuck on what I should be reporting.