Unreported Income or Large Transfers Raise Flags for Clearance Holders

Originally published at: Unreported Income or Large Transfers Raise Flags for Clearance Holders | ClearanceJobs Blog

Approximately half of all security clearance holders are now enrolled in Continuous Evaluation (CE) and more are getting enrolled each day as reinvestigation timelines come due. Most reinvestigations are deferred after review of the SF-86 application and other checks are completed. CE enrollment for DoD contractors is input into the Defense Information Security System and…

Some government employees and on-site contractors may have access to an online reporting tool that indeed makes this quick and easy.

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Until banks and financial institutions have consistent strictly enforced reporting regulations for transactions this is all moot. Too many banks (especially local ones) can and do justify not reporting transactions for favored customers for valid reasons. The “banks must report” is a myth. But, then again these triggers are going to give investigator’s job security when the “more information” needs to be obtained.

Say if one has a regular savings account with the same bank they have a checking account with…no thrift savings plan. At what amount does one need to report their withdrawal from their savings account ?

I believe the limit is $10,000. And I think that is a daily total, so dont try one withdrawal/transfer for $6,000 and another one an hour later :slight_smile:

Gotcha. I’m assuming it is safe to transfer/withdraw less than 10k then ? even if one withdraws/transfers 6k…and decides to do another similar transaction an hour later (lesser amount of course), as long as the total is below the 10k threshold for the day, it’s fine.

USD $10,000 is the amount for banks in the US - whether this comes from fincen or not I’m not sure. They also look for ‘staging’ of money deposits/withdrawals as well so as to look for patterns of NOT going above 10k. For example - you had 110K but you didnt want to trigger any checks, or so you thought, so you figured you’re break up your deposits into 9k increments. When you start depositing those 9k amounts periodically…you STILL trigger a fincen/banking alert.

And even if you have to file a report, it is no big deal. Just make sure to report it if you are required to… check with your security office beforehand to make sure.

Yeah makes sense. My FSO stated that for internal transfers like from savings to checking account or any withdraw from savings, no need to report, but if there is a large deposit, mostly around the 10k+ range or even if it is in small increments over a short time frame into either accounts, will need to report.

Is there any recent DOD guidance about reporting gains from cryptocurrency?

The only information I can find is from a Feb 2018 Document (Page 6) in which cryptocurrency does not need to be reported → https://www.dcsa.mil/Portals/91/Documents/CTP/tools/VOI_February_2018.pdf

I would also like to provide Evidence B from the IRS for this year tax reporting on cryptocurrency → IRS Rules On Reporting Bitcoin And Other Crypto Just Got Even More Confusing

Couple of things of note regar - for some agencies and some positions this amount can be more or less than 10K. If in doubt check with your security office/fso to ensure you are in compliance.

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Hi @Marko

Is there a mandated/informal timeframe of how long a financial CE flag is investigated for, how long until it goes to adjudication and how long does it take once it goes to adjudication? Are CE flags adjudicated individually or is an individual’s full eligibility at play? This is for an IC agency.

Thank you-

There are no required timelines for reviewing and adjudicating CE alerts. If a suspension of clearance is warranted then the review should not be open-ended, but rather be done expeditiously. The whole person concept is taken into consideration for CE alert reviews and can include information in previous investigations to determine if a pattern exists.

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