Interpretation of Dual Citizen

Hey everyone,

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.

I would err on the side of caution. List them and if there is a place for comment, state what you stated here, i.e. birthright citizenship only, naturalized U.S. citizen, residing in the U.S. since 19xx, holds no foreign passports, etc.

This is an interesting question and hope others will chime in as well.

At first I was thinking there was no point in reporting this, but then I thought if and when you do get married, then you will definitely have to list in-laws. At that time, it could raise some issues as to why you never reported these possible “contacts” until then. So yes, go ahead and list them now just to get out in front of it.

Hopefully it won’t slow things down too much.

I’ve had several of these cases.

Most likely you will need the naturalization info for sure from the cohab and her parents, probably any siblings she has.

If you have been connected to any family friends or extended family members with the Iranian connection, those persons might need to be reported as your foreign contacts.

For all involved you might need:

Full name, akas
Current address
Current employer
If connected to foreign government
When met
What current contract there is

You will need to list that these individuals do no consider themselves citizens of Iran and the reason why: never went back, has no contact with anyone there, has no foreign passport, and the best reason possible (but very few do this) officially informed an embassy (us or Iran) that the Iranian citizenship is denounced - when that took place and where thst notice was provided.

Should the naturalized persons have contact with Iran (family/friends/business/banking/ownerships/foreign gov connections) that will need to be reported with detail.

As well, if those persons have knowledge of your investigation, you will need to address that.

If an interview is triggered, you will need sources who are aware of these persons- sources not connected to Iran but with enough awareness of the situation that can speak to who the are, where they are from, and what activity if any there’s been with a foreign connection.

It’s a challenge to have connection with individuals originating from the listed heightened risk countries but it doesn’t necessarily mean the loss of a clearance.

From what I’ve been told, all DHS positions require an interview with an investigator.

We had a situation where the follow-on/upgrade of the existing system went from 99% unclass to TS/SCI level security. Several naturalized citizens were put in for the SCI. They were told, make sure you get contact information for your relatives back in the old country, but dont tell them why you need it.

One guy said, they want contact info for an uncle I haven’t seen in 20 years and barely speak to. Now I’m supposed to all of a sudden get his address without saying why?

If all of these relatives tell you they now consider themselves sole US citizens and have no valid foreign passports make sure to put that in your optional comments section. Most contracts don’t suggest you contact your foreign contacts to obtain their personal information for reporting. It’s generally not a good idea.

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DCSA does- their requirements are rather specific and in depth.

Citizenship is not about what you “consider” yourself. If they did not actively renounce the other citizenship then they are dual citizens.

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Comments are optional…please, please, please don’t type a book or anything for that matter in the comments section., thats what the interview is for. Every single word in comments section has to exactly match your 3 hour on and on explanation of your problen…way more complicated.

Tip: There are optional comments, explanations, and, “if yes,” provide an explanation (or comment). Some are required based on your answers to certain questions. Not all comments are optional.

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Citizenship is more complicated than any forum can ever explain. It varies too widely for any blanket statements. I would be very careful and cautious about contacting foreign contacts in a foreign country for their detailed information to report on one’s own background investigation. It’s probably best to check with your security officer before doing so. Even though many don’t always have that option or even know how to contact their security officer.