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SECURITY CLEARANCE MANUAL


CHAPTER 10

ALCOHOL, PRIOR INVESTIGATIONS, & FINANCES



ALCOHOL
 
SECURITY FORM: Section 25—Your Use of Alcohol.
This is a full seven-year question and not limited by your age. The question asks, “In the last 7 years, has your use of alcoholic beverages (such as liquor, beer, wine) resulted in any alcohol-related treatment or counseling (such as for alcohol abuse or alcoholism)?” This includes situations where you were directed by a court or other authority (i.e. school, employer, military) to attend an alcohol course following an alcohol related arrest or incident.
If you sought counseling on your own or attended Alcoholics Anonymous meetings on your own within the past seven years, list it. If you received alcohol counseling or treatment through an Employee Assistance Program, you must list it.
 
If you list any information in this section, you should contact the offices or facilities where you received the counseling/treatment (except Alcoholics Anonymous) and ask if they have their own form for authorizing the release of patient information. If they have their own form, obtain a copy (in person or by fax) and take it with you to your PRSI or SPIN. This alone may reduce the time involved in your investigation by two weeks or more.
 
APPLICABLE ADJUDICATIVE GUIDELINES

GUIDELINE G: ALCOHOL CONSUMPTION

Paragraph 21. The Concern. Excessive alcohol consumption often leads to the exercise of questionable judgment or the failure to control impulses, and can raise questions about an individual's reliability and trustworthiness.

Paragraph 22. Conditions that could raise a security concern and may be disqualifying include:

(a) alcohol-related incidents away from work, such as driving while under the influence, fighting, child or spouse abuse, disturbing the peace, or other incidents of concern, regardless of whether the individual is diagnosed as an alcohol abuser or alcohol dependent;
 
(b) alcohol-related incidents at work, such as reporting for work or duty in an intoxicated or impaired condition, or drinking on the job, regardless of whether the individual is diagnosed as an alcohol abuser or alcohol dependent;
 
(c) habitual or binge consumption of alcohol to the point of impaired judgment, regardless of whether the individual is diagnosed as an alcohol abuser or alcohol dependent;
 
(d) diagnosis by a duly qualified medical professional (e.g., physician, clinical psychologist, or psychiatrist) of alcohol abuse or alcohol dependence;
 
(e) evaluation of alcohol abuse or alcohol dependence by a licensed clinical social worker who is a staff member of a recognized alcohol treatment program;
 
(f) relapse after diagnosis of alcohol abuse or dependence and completion of an alcohol rehabilitation program;
 
(g) failure to follow any court order regarding alcohol education, evaluation, treatment, or abstinence.
 
Paragraph 23. Conditions that could mitigate security concerns include:
 
(a) so much time has passed, or the behavior was so infrequent, or it happened under such unusual circumstances that it is unlikely to recur or does not cast doubt on the individual's current reliability, trustworthiness, or good judgment;
 
(b) the individual acknowledges his or her alcoholism or issues of alcohol abuse, provides evidence of actions taken to overcome this problem, and has established a pattern of abstinence (if alcohol dependent) or responsible use (if an alcohol abuser);
 
(c) the individual is a current employee who is participating in a counseling or treatment program, has no history of previous treatment and relapse, and is making satisfactory progress;
 
(d) the individual has successfully completed inpatient or outpatient counseling or rehabilitation along with any required aftercare, has demonstrated a clear and established pattern of modified consumption or abstinence in accordance with treatment recommendations, such as participation in meetings of Alcoholics Anonymous or a similar organization and has received a favorable prognosis by a duly qualified medical professional or a licensed clinical social worker who is a staff member of a recognized alcohol treatment program.
NACLC: There is no standard NACLC coverage for this section; however, a “yes” response to this question may result in a SPIN and you will be asked to provide written authorization for the interview of the counselor and the review of your patient records.
 
SSBI/SSBI-PR
Personal Subject Interview: You will be asked to verify the information you provided in this section. Be prepared to provide details of any alcohol counseling or treatment you listed on your SF86 or admit during the interview. You will be asked if you consume (or previously consumed) alcohol and if so, the frequency and amount of consumption. If you received any counseling or treatment for alcohol use within the past seven years, you will be asked to sign a release authorizing the interview of the counselor and review of medical records. If you have consumed alcohol and you are underage, you will be asked if you intend to continue drinking alcohol while underage. (See Chapter 2, page 23 for PRSI guidance.)
 
Field Investigation: Interviews of all references will include questions regarding alcohol use. Any indication of alcohol abuse contained in any record that is reviewed will be reported. Effort will be made to corroborate and obtain details of any listed or developed alcohol abuse, whether chronic or episodic. If there was alcohol counseling and a release was obtained from the applicant, an interview of the alcohol counselor will be conducted and the pertinent treatment records will be reviewed.
 
EXAMPLES OF CLEARANCE ADJUDICATION
 
CASE NUMBER: 02-16274.h1
Alcohol
04/29/2005
Applicant was twice convicted of alcohol related driving offenses in 1984 and 1997. Part of the sentence following his second conviction required him to attend an outpatient alcohol treatment program, which he did from November 1998 to April 1999. He stopped drinking for six to eight months after completing this program and began drinking again. In June 2003, he self-referred to an intensive outpatient alcohol treatment program and has been alcohol free for one year. Additionally, he has held a top secret clearance for 25 years while making substantial and significant contributions to the defense industry. He has successfully mitigated security concerns pertaining to past alcohol consumption. Clearance is granted.
 
CASE NUMBER: 04-09648.h1
Alcohol
05/16/2006
Applicant's periodic excessive consumption of alcohol resulted in four alcohol-related incidents within a five year period between 1998 and 2003. He was routinely abusing alcohol without realizing it, for his alcohol tests registered between .133% (in 1998) and .23% (in 2003). Since his last alcohol-related incident in 2003, and after completion of a second DUI program, Applicant reconsidered his options and focused on positive endeavors and eliminated his stressors, and at the same time, developed a diminished interest in alcohol. While he has not abstained from further alcohol consumption, he has reduced it to the point where he now drinks more responsibly. Applicant has successfully mitigated and overcome the government's case. Clearance is granted.
 
CASE NUMBER: 04-08975.h1
Alcohol
03/03/2006
Applicant has a long history of excessive consumption of alcohol, resulting in hospitalization for detoxification in August 1994, July 2002, March 2003, July 2003, and the Spring of 2004, and a conviction for Driving Under the Influence of Alcohol in 2000. Applicant was diagnosed as alcohol dependent and obtained treatment on several occasions, but later resumed drinking alcohol to excess. He has been abstinent for over one year, and is dedicated to living alcohol-free hereafter. Applicant failed to mitigate the security concerns arising from his alcohol consumption. Clearance is denied.
PRIOR INVESTIGATIONS
SECURITY FORM: Section 26—Your Investigations Record.
 
This section only pertains to employment or security clearance investigations conducted by the federal government.
 
For question 26a everyone who entered the U.S. Armed Force (including Reserves and National Guard) before 2000, was investigated by DoD, even though they may not have been granted a security clearance. Prior to 2000, all military and defense contractor personnel who received a security clearance from DoD were investigated by DoD. DoD civilians were often granted Confidential and Secret clearances by DoD based on an OPM National Agency Check with Inquiries (NACI). DoD also previously conducted security clearance investigations for the U.S. Coast Guard and certain State Department contractors.
 
The FBI only conducts background investigations on prospective U.S. Justice Department employees, Justice Department employees who need a security clearance, individuals being considered for a Presidential appointment, and a very limited number of prospective Department of Energy officials who will occupy “Positions of a High Degree of Importance or Sensitivity.” There are a few other federal agencies that conduct their own employment or security clearance investigations.
In the past the OPM conducted employment and security clearance investigations for most other federal agencies, including employment investigations of DoD civilians being placed in non-critical, non-sensitive positions. In 2000 OPM began conducting a portion of DoD security clearance investigations. In 2004 they began processing almost all DoD background and security clearance investigations. In 2005 the entire investigative staff of DSS transferred to OPM.
 
For most DoD investigations conducted between 2000 and 2004 it is difficult to know whether the investigation was conducted by DoD or OPM. Your security manager should be able to obtain this information for you.
 
Only employees and contractors of the Department of Energy are granted “Q” or “L” clearances. DoD issues Confidential, Secret, and Top Secret clearance. DoD also grants Sensitive Compartmented Information (SCI) access authorizations. Since the Single Scope Background Investigation (SSBI) was implemented in December 1991, everyone who was the subject of a favorably completed SSBI was eligible to be considered for SCI access, however, very few were actually granted an SCI access authorization. If you were “read on” to SCI, you know it, and there will be no question in your mind about it.
 
Question 26b asks if you have ever been debarred from federal employment and have ever had a security clearance or access authorization denied, suspended, or revoked. In this case the term “access authorization” refers to SCI or SAP or other DoD classified information where a formal “access authorization” was denied, suspended, or revoked. It also pertains to DOE “L” and “Q” Access Authorizations, since within DOE the term Access Authorization has the same meaning as security clearance. Question 26b does not pertain to access to DoD “collateral” classified information. There are situations where individuals were granted a Top Secret clearance, but had an access authorization, such as SCI, denied. There are also situations where cleared individuals have their access to collateral classified material suspended, but never actually have their clearance suspended. Only the security clearance granting authority (usually a Central Adjudication Facility) has the right to suspend, deny or revoke a security clearance. However, others in a position of authority, such as military commanding officers have the authority to suspend a cleared individual’s access to classified information. This usually occurs at the same time that a report of unfavorable information is forwarded to the CAF recommending the clearance be suspended and a security investigation initiated. Sometimes the CAF determines that the report does not contain sufficient information to suspend the clearance and may chose not to initiate an investigation. In which case appropriate notifications are made and the individual’s access is reinstated. It is also possible that a person could have an SCI access authorization suspended, but not have their security clearance suspended. If you are unsure about any clearance or access suspension action against you, list it on your SF86 and provide an explanation in the comment section. The agency that suspends, denies, or revokes a clearance or access authorization is usually not the same agency that conducted the clearance investigation.
APPLICABLE ADJUDICATIVE GUIDELINES
GUIDELINE K: HANDLING PROTECTED INFORMATION
 
Paragraph 33. The Concern. Deliberate or negligent failure to comply with rules and regulations for protecting classified or other sensitive information raises doubt about an individual's trustworthiness, judgment, reliability, or willingness and ability to safeguard such information, and is a serious security concern.
 
Paragraph 34. Conditions that could raise a security concern and may be disqualifying include:

(a) deliberate or negligent disclosure of classified or other protected information to unauthorized persons, including but not limited to personal or business contacts, to the media, or to persons present at seminars, meetings, or conferences;
(b) collecting or storing classified or other protected information in any unauthorized location;
 
(c) loading, drafting, editing, modifying, storing, transmitting, or otherwise handling classified reports, data, or other information on any unapproved equipment including but not limited to any typewriter, word processor, or computer hardware, software, drive, system, gameboard, handheld, "palm" or pocket device or other adjunct equipment;
 
(d) inappropriate efforts to obtain or view classified or other protected information outside one's need to know;
 
(e) copying classified or other protected information in a manner designed to conceal or remove classification or other document control markings;
 
(f) viewing or downloading information from a secure system when the information is beyond the individual's need to know;
 
(g) any failure to comply with rules for the protection of classified or other sensitive information;
 
(h) negligence or lax security habits that persist despite counseling by management;
 
(i) failure to comply with rules or regulations that results in damage to the National Security, regardless of whether it was deliberate or negligent.
Paragraph 35. Conditions that could mitigate security concerns include:

(a) so much time has elapsed since the behavior, or it happened so infrequently or under such unusual circumstances that it is unlikely to recur or does not cast doubt on the individual's current reliability, trustworthiness, or good judgment;
(b) the individual responded favorably to counseling or remedial security training and now demonstrates a positive attitude toward the discharge of security responsibilities;
 
(c) the security violations were due to improper or inadequate training.
GUIDELINE E: PERSONAL CONDUCT
 
Paragraph 15. The Concern. Conduct involving questionable judgment, lack of candor, dishonesty, or unwillingness to comply with rules and regulations can raise questions about an individual's reliability, trustworthiness and ability to protect classified information. . . .
Paragraph 16. Conditions that could raise a security concern and may be disqualifying also include:

(d) credible adverse information that is not explicitly covered under any other guideline and may not be sufficient by itself for an adverse determination, but which, when combined with all available information supports a whole-person assessment of questionable judgment, untrustworthiness, unreliability, lack of candor, unwillingness to comply with rules and regulations, or other characteristics indicating that the person may not properly safeguard protected information. This includes but is not limited to consideration of:
(1) untrustworthy or unreliable behavior to include breach of client confidentiality, release of proprietary information, unauthorized release of sensitive corporate or other government protected information;
(3) a pattern of dishonesty or rule violations;
 
(f) violation of a written or recorded commitment made by the individual to the employer as a condition of employment;
Paragraph 17. Conditions that could mitigate security concerns include:

(c) the offense is so minor, or so much time has passed, or the behavior is so infrequent, or it happened under such unique circumstances that it is unlikely to recur and does not cast doubt on the individual's reliability, trustworthiness, or good judgment;
(d) the individual has acknowledged the behavior and obtained counseling to change the behavior or taken other positive steps to alleviate the stressors, circumstances, or factors that caused untrustworthy, unreliable, or other inappropriate behavior, and such behavior is unlikely to recur.
 
NACLC: A check of DCII (Defense Clearance and Investigations Index), SII (Security and Investigations Index), and JPAS (Joint Personnel Adjudications System) records are a standard part of a NACLC. These records contain listings of investigations and security clearance actions conducted by OPM and DoD. Having been debarred from federal employment or having had a security clearance or access authorization denied, suspended, or revoked may result in a SPIN.
SSBI/SSBI-PR

Personal Subject Interview: You will be asked to verify all information in this section. Be prepared to provide details surrounding the suspension, revocation, or denial of a security clearance or access authorization and any debarment from federal service. Be prepared to discuss details surrounding any suspension of access, security violation, or mishandling of classified, sensitive, or proprietary material. (See Chapter 2, page 23 for PRSI guidance.)
Field Investigation: Interviews of all references will include general questions regarding the handling of classified, sensitive, personal, or proprietary information. Any indication of mishandling protected information contained in any record that is review will be reported. Effort will be made to corroborate and obtain details of any listed or developed security clearance/access problems and mishandling of privileged or protected information.
EXAMPLES OF CLEARANCE ADJUDICATION

CASE NUMBER: 02-07444.h1
Personal Conduct
01/27/2004
While Applicant failed to reveal on his security form in 2002 that his security clearance was revoked in November 1991, his security officials advised he was only required to document the previous ten years and indeed the form specifically requires any military disciplinary record only for the past seven year. Further, he was never informed of the revocation as he was honorably discharged in October 1991. Any personal conduct concern is superseded by his subsequent long history of outstanding conduct on the job where Applicant is highly regarded for his integrity and honesty overall. He also has highly favorable references. Clearance is granted.
 
CASE NUMBER: 03-08519.h1
Security Violations
03/28/2006
Applicant's three security violations (failing to secure a DoD Approved Closed Area) between December 2001 and July 17, 2002 are aggravated by the fact they constitute a pattern of adverse conduct that is not isolated. Though the first security violation is extenuated by the lack of an adequate security briefing, the other two incidents are not assuaged by any of the mitigating conditions. Applicant was found not to be culpable for the last violation, but she admitted she was the last person in the secured area. The lack of security violations since July 2002 weighs in Applicant's favor but does not satisfy her ultimate burden of persuasion under the security violations guideline. Clearance is denied.
 
CASE NUMBER: 02-28059.h1
Security Violations: Personal Conduct
03/30/2006
Applicant, with several years of experience handling classified information, gave communications security (COMSEC) hardware loaded with material classified secret to an employee at work in June 2001 without verifying this person's clearance or need-to-know. In February 2002, Applicant loaded secret information onto a work computer that had not been approved for the storage of classified information and then sent the file over an unencrypted (unclassified) intranet at work. In May 2002, Applicant failed to properly document the receipt of a classified fax before shredding it in an unapproved shredder. His pattern of gross negligence in the handling of classified information is not mitigated where he continues to make excuses for his noncompliance with security regulations. Clearance is denied.
FINANCES
SECURITY FORM: Section 27—Your Financial Record.

These are all full seven-year questions and not limited by your age. You may think you have an unblemished credit record, but something may appear on your credit report that you were unaware of. You are entitled to one free credit report every 12 months from each of the three nationwide consumer credit reporting agencies– Equifax, Experian, and TransUnion. As mentioned in Chapter 2, it is extremely important for you to know what appears in all three of these reports prior to completing this section of the SF86. You can go online to https://www.annualcreditreport.com/cra/index.jsp and get a free copy of your credit reports.
If you had a Chapter 13 bankruptcy within the past seven year and had it converted to a Chapter 7 bankruptcy, you should list both bankruptcy actions on your SF86. In most cases wage garnishments occur because of an unsatisfied court judgment . However, in some states, child support and spousal support payments are automatically collected through wage garnishments. Also, if you are in the Armed Forces and become excessively delinquent on your credit account with military exchange services (i.e. AAFES or NAVEX) or owe any money to your military branch, it will probably be collected by wage garnishment (without a court order), even if the indebtedness was no fault of yours. These all need to be listed on your SF86 with an explanation in the comment section.
If you answered “yes” to any of the Section 27 questions, you will need to indicate month and year the action occurred, type of action (i.e. BK13, BK7, Garnishment, Tax Lien, Judgment, Repossession), dollar amount involved, the name used to identify you in the action, and the name and address of the court, plaintiff, and/or government agency involved.
 
SECURITY FORM: Section 28—Your Financial Delinquencies.

Question 28a is a full seven-year question and not limited by your age. This question asks about previously delinquent debts that were more than 180 days delinquent when they were paid off or were more than 180 days delinquent when you resumed making regular payments that were satisfactory to the creditor. Question 28b concerns only debts that are more than 90 days delinquent as of the date you complete your SF86.
If you responded “yes” to question 28a or 28b, list the date the debt was incurred. For current or former delinquent debts related to revolving credit accounts, such as credit cards, list the date the account was opened and in the comment section indicated the date the account became delinquent. If the debt has been paid off, list the date the debt was satisfied. Also list the amount that is currently delinquent or the amount that was formerly delinquent, as well as the other identifying information requested.
 
If you have any past due debts, the best thing you can do is to get completely caught up on your payments. Say you have a credit card account that you haven’t made a payment on for five months. If immediately before you complete your SF86, you pay the credit card company (or collection agency handling the account) the total amount of the past due payments including the fees and penalties, you do not have to list it on your SF86. If you keep the account current or pay it off completely, it will not become an issue during your PRSI. If you are already delinquent 180 days or more, contact the creditor, quickly set up a debt repayment plan, and start making payments as soon as possible.
Serious financial issues almost always delay the completion of an investigation, because the issues usually can not be resolved until after a PRSI and/or SPIN has been conducted, credit releases obtained, and credit records reviewed. These investigative actions occur sequentially and almost always involve multiple investigative offices. As each office, in turn, is tasked to accomplish a specific action, a new (later) suspense date is assigned to the case, and the case drags on, and on. To qualify as serious, a financial issue must generally exceed a certain dollar amount and be delinquent more than a certain number of days as reported on your SF86 or in your credit bureau report. The dollar amount of a delinquent debt is based on the past due amount, not the total debt. Some types of financial issues can be serious regardless the duration of time involved.
 
It is critically important that you know precise details concerning any unfavorable credit information contained in any of the reports available from the three national credit reporting agencies and that you disclose the appropriate information on your SF86 and during your PRSI or SPIN. If you do not provide this information when required, your investigation will be delayed. For each such debt you need to know the name and address of the creditor, account number, current balance, high balance, the amount delinquent, the date of your last payment, how may months you are behind in payments, date the account was open, and payment history. To that end you should contact any creditor with unfavorable information listed on your credit reports and obtain all relevant information directly from the creditor. Remember, OPM will obtain a credit report on you. However there may be a delay of up to three months between the time you submit your SF86 and the time OPM obtains the report. Therefore, if your financial situation changes between the time you submit your SF86 and the time of your PRSI or SPIN, be prepared to provide all relevant information about those accounts (or legal actions) at your security interview.
 
If any significant information appears on the credit report that you should have disclose on your SF86 (and if applicable, during your PRSI), it will result in a SPIN. When a SPIN is required for an SSBI or SSBI-PR, it always occurs after all initial investigative actions have been accomplished and the case is being reviewed for completeness. Sometimes SPINs are not tasked until after the case has been sent to the appropriate Adjudicative Facility, and the Adjudicative Facility returns the case to OPM with a request for a SPIN. Most SPINs add one to three months to the final completion time of an investigation.
APPLICABLE ADJUDICATIVE GUIDELINES

GUIDELINE F: FINANCIAL CONSIDERATIONS
Paragraph 18. The Concern. Failure or inability to live within one's means, satisfy debts, and meet financial obligations may indicate poor self-control, lack of judgment, or unwillingness to abide by rules and regulations, all of which can raise questions about an individual's reliability, trustworthiness and ability to protect classified information. An individual who is financially overextended is at risk of having to engage in illegal acts to generate funds. Compulsive gambling is a concern as it may lead to financial crimes including espionage. Affluence that cannot be explained by known sources of income is also a security concern. It may indicate proceeds from financially profitable criminal acts.
Paragraph 19. Conditions that could raise a security concern and may be disqualifying include:
 
(a) inability or unwillingness to satisfy debts;
(b) indebtedness caused by frivolous or irresponsible spending and the absence of any evidence of willingness or intent to pay the debt or establish a realistic plan to pay the debt;
(c) a history of not meeting financial obligations;
(d) deceptive or illegal financial practices such as embezzlement, employee theft, check fraud, income tax evasion, expense account fraud, filing deceptive loan statements, and other intentional financial breaches of trust;
(e) consistent spending beyond one's means, which may be indicated by excessive indebtedness, significant negative cash flow, high debt-to-income ratio, and/or other financial analysis;
(f) financial problems that are linked to drug abuse, alcoholism, gambling problems, or other issues of security concern;
(g) failure to file annual Federal, state, or local income tax returns as required or the fraudulent filing of the same;
(h) unexplained affluence, as shown by a lifestyle or standard of living, increase in net worth, or money transfers that cannot be explained by subject's known legal sources of income;
(i) compulsive or addictive gambling as indicated by an unsuccessful attempt to stop gambling, "chasing losses" (i.e. increasing the bets or returning another day in an effort to get even), concealment of gambling losses, borrowing money to fund gambling or pay gambling debts, family conflict or other problems caused by gambling.
Paragraph 20. Conditions that could mitigate security concerns include:

(a) the behavior happened so long ago, was so infrequent, or occurred under such circumstances that it is unlikely to recur and does not cast doubt on the individual's current reliability, trustworthiness, or good judgment;
(b) the conditions that resulted in the financial problem were largely beyond the person's control (e.g. loss of employment, a business downturn, unexpected medical emergency, or a death, divorce or separation), and the individual acted responsibly under the circumstances;
(c) the person has received or is receiving counseling for the problem and/or there are clear indications that the problem is being resolved or is under control;
(d) the individual initiated a good-faith effort to repay overdue creditors or otherwise resolve debts;
(e) the individual has a reasonable basis to dispute the legitimacy of the past-due debt which is the cause of the problem and provides documented proof to substantiate the basis of the dispute or provides evidence of actions to resolve the issue;
(f) the affluence resulted from a legal source of income.
NACLC: Obtaining a credit bureau report is a standard part of the NACLC. Any significant delinquent debts (past or present), as well as any “yes” response to question 27a through 27d or to question 28b may result in a SPIN, if the amounts listed under questions 27 and 28 exceed a certain dollar amount.
SSBI/SSBI-PR
Personal Subject Interview: You will be asked to verify the information you provided in this section. Be prepared to provide details of regarding any information you listed on your SF86 and any information you disclose during the interview, as well as the reasons for the indebtedness. You will be asked about any consumer credit counseling you received. If the amounts of your current or past delinquent debts exceed a certain dollar amount, you will be asked to sign releases authorizing OPM to review specific records concerning your debts. You will be asked about gambling. (See Chapter 2, page 23 for PRSI guidance.)
Field Investigation: Interviews of all references will include questions regarding financial responsibility, gambling, and evidence of any unexplained affluence. Any indication of financial irresponsibility or unexplained affluence contained in any record that is reviewed will be reported. Effort will be made to corroborate and obtain details of any listed or developed financial problems. If a specific financial release was obtained from the applicant, a review of the financial record will be conducted. Records of any bankruptcies, tax liens, wage garnishments, and civil court judgment s will be reviewed.
Additional Investigation For SSBI-PR: Check of the Department of the Treasury's Financial Data Base, under terms and conditions prescribed by the Secretary of the Treasury, to search automated data bases consisting of reports of currency transactions by financial institutions, international transportation of currency or monetary instruments, foreign bank and financial accounts, and transactions under $10,000 that are reported as possible money laundering violations.

EXAMPLES OF CLEARANCE ADJUDICATION
CASE NUMBER: 02-11177.h1
Financial; Personal Conduct
02/14/2005
Applicant's financial difficulties began in 1993, and continued until 2004. Such financial difficulties stemmed primarily from excessive gambling which began in 1993 and tapered off in 2002. In November 2003, he sought the services of a consumer credit counseling service. He embarked on a path of financial rehabilitation, and has successfully resolved all six debts alleged. Two separate minor administrative actions taken against him in 1993 and 1999 do not constitute a pattern of rule violations. Applicant has successfully mitigated security concerns stemming from his past financial and personal conduct. Clearance is granted.
CASE NUMBER: 02-23604.h1
Financial
04/15/2004
Applicant received a discharge of more than $17,000.00 in debts under chapter 7 of the bankruptcy code in July 1993. As of June 2003, he had accumulated more than $21,000.00 in delinquent accounts, and had deferred repayment of approximately $64,000.00 in student loans. He has now either satisfied or made arrangements to expeditiously satisfy his delinquent accounts, and entered into an agreement that will allow him to repay his student loans over the course of the next thirty years. Applicant's belated effort to repay long-standing past-due creditors is insufficient to mitigate the security concern caused by his many years of financial irresponsibility. Clearance is denied.
CASE NUMBER: 02-30017.h1
Financial
06/03/2004
Applicant was granted three Chapter 7 bankruptcy discharges between 1988 and 2002. On each occasion, the circumstances that forced him to seek protection under the bankruptcy code were largely beyond his control. He took advantage of his last financial downturn by obtaining an education and now has well-paying employment with a defense contractor. Applicant has mitigated the security concern that arose from his financial instability. Clearance is granted.
CASE NUMBER: 04-02367.h1
Financial
09/29/2005
Applicant is a 33-year-old veteran who has worked for a federal contractor since 2001. Applicant accumulated delinquent debt while on active duty and continued to add to his debt after he was discharged from the service in 1999. Applicant was unemployed for a short period of time in 1999, but has been fully employed since then and his salary has steadily increased in the past six years. Applicant has made minimal effort to resolve his delinquent debts. Applicant has failed to mitigate the security concerns regarding his financial situation. Clearance is denied.
CASE NUMBER: 03-00929.h1
Financial
07/16/2004
Applicant incurred $80,000 in debt over 10 years. She filed a Chapter 13 bankruptcy in 2001, on which she has paid faithfully for three years. She has one year remaining until discharge. Applicant is an office administrator for a defense contractor. Applicant mitigated the financial consideration security concern. Clearance is granted.