SF 86 question 20b

I currently work for a multinational law firm with many nonUS clients. I have given legal advice to hundreds of foreign companies and foreign governments. Obviously that involves contact with foreign individuals employed by those companies and governments. None of this work had anything to do with defense, security, diplomacy etc. I don’t have close relationships with these foreign individuals; they are just clients. Now I’m filling out SF 86 and looking for advice on how to respond to question 20b. First question: is there a way to provide an overview of the situation without having to provide information on dozens or hundreds of foreign individuals? Second question: in some cases our contracts with clients don’t permit us to reveal that they are clients. Is there a way to deal with that?

This is not an easy answer, but the response is… it depends.

You will want to identify that you have had business dealings with foreign companies, foreign governments, and foreign persons. The details of the relationships are going to be who you had those relationships (business/person/government) and how much continuing contact you will have and/or how much of your current/future financial well being depends on those relationships. For instance, if you will continue to have a business relationship (income stream, partnership, etc) with your old company - you could be vulnerable to influence, even from US citizens who might try to gain access to your new access for business/client/foreign government business purposes.

You will need to talk to the company/agency hiring you for more specific advice.

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