Prostitution Mitigating Factors

I am looking for advice on mitigating factors for a potential adverse clearance decision. I apologize if this is not the right place for this question, but any advice would be welcome.

I am a DOD IC employee. On two occasions–in 2014 and 2017–I engaged the services of prostitutes while overseas. In the latter instance (2017), I held an SCI at the time. (There was nothing particularly untoward about these events beyond the fact that money changed hands: I am unmarried, the women were well above legal age, the acts were heterosexual and also not fetishistic, etc.)

I disclosed these events during two FSPs with NSA (not my current employer). The FSPs were about one year apart, and I committed the 2017 act in the intervening period. Following the second disclosure, NSA terminated my processing but did not technically deny my clearance.

I likely will enter processing with CIA in the next six months or so.

I am wondering whether there are any actions I can take that would serve to mitigate these events from CIA’s optic.The only mitigating act I have taken to date has been to disclose these events to some friends, family, coworkers, clergy, etc.

It is my belief that the time that has elapsed (1.5-2 years) would not in itself be sufficient to mitigate; my sense from NSA is that they look at 3 years time separation as sufficient mitigation, but I don’t have a firm source for that.

Would counseling, for example, serve as a mitigating factor, or would that potentially risk painting me as some kind of sex addict/uncontrollable compulsive/etc.? Are there any mitigating actions I could take, or is time elapsed my only hope?

To be clear, I am not looking for ways to get away with continuing this behavior. It will be extremely easy for me to go the rest of my life without doing this again.

Thank you for reading, and for any advice.

Here is a case with a positive outcome where prostitution is addressed by the adjudicator rather comprehensively. There are also drug use issues on that case, but at least you have a reference point for your specific question. I think your current path has done much to mitigate your circumstances. Good Luck

Counseling would help if there is an underlying issue like sex addiction. Time is the best thing from what I’ve seen.

You went to prostitutes, in a foreign country, while you were cleared, with SCI . . .

Mitigation? Where both times in the same country? Do you regularly travel to this country? Will this country be part of your work? Were you traveling for work when this happened? Why did you see prostitutes in THAT country but you do not in THIS country?

Just a start . . .