Current policy permits dual citizens to hold a security clearance, and dual citizens are no longer required to surrender their foreign passport. Dual citizens who hold U.S. citizenship are neither foreign nationals nor non-U.S. citizens and may access NOFORN (NO FOREIGN DISSEMINATION). Foreign citizenship in and of itself is not disqualifying under Security Executive Agent Directive 4 (SEAD-4 ¶ 6). However, dual citizenship does indicate multiple areas of security concern under:
For dual citizens, there is considerable overlap between Guidelines B and C as both involve risk of conflict between U.S. and foreign interests. The country itself is only one factor in the risk assessment—but an important one.
Security clearance applicants with dual citizenship and security clearance holders considering applying for or exercising the benefits of foreign citizenship should tread carefully and strategically. The intersection of foreign influence and foreign preference concerns are complex and require specific, multilayered mitigation.
Here, we address the security concerns associated with foreign citizenship, how security clearance adjudicators assess these risks, and the complexities involved in foreign influence and foreign preference security concerns.
Security clearance adjudications are risk analysis. Decisions to deny, revoke, or grant security clearance are highly individualized but also use a common framework: the 13 Adjudicative Guidelines (SEAD-4),
SEAD-4’s 13 areas of security risk—e.g. Guideline B (foreign influence) and Guideline C (foreign preference)—have an underlying logic and context. The simple fact of foreign citizenship does not reflect the scope of this context (one reason renouncing citizenship is not advised unless first discussed with your agency).
While it is Guideline C that specifically cites dual citizenship, Guideline B and Guideline C often appear together in dual citizenship cases. Both share a common concern: a potential conflict between U.S. interests and your connection to the foreign country. Adjudicators consider:
Guideline B and Guideline C cover similar ground but operate differently. These distinctions illustrate the multipronged approach involved in evaluating dual citizenship cases: external and internal.
Guideline C, Foreign Preference emphasizes the individual’s interior world. It concerns your individual character, values, priorities, and behavior. How likely are you to choose another country over the U.S., and how likely is that choice to come up?
Guideline B, Foreign Influence emphasizes the external fact of foreign influence over you. The focus is powers beyond you: i.e., how much leverage could a foreign country hold over you, and how likely are they to use it?
Dual citizenship cases involve multiple angles of analysis. It is highly advised to consult a national security attorney with a proven history of success in similar cases.
Would you prioritize the interests of a foreign country over U.S. interests?
Guideline C explicitly covers dual citizenship, but also: applying for citizenship, applying for recognition of citizenship, or exercising any other benefit of citizenship (e.g. voting, accessing subsidized healthcare, applying for/holding a passport). Such exercise of foreign citizenship may be disqualifying under Guideline C if either:
Foreign preference concerns two sides: the character/actions of the individual, as well as the security profile of the country being preferred. While citizenship with a U.S. adversary may prove challenging to mitigate, the presumed “friendliness” of a country does not preclude Guideline C concerns if your actions speak poorly of your attitude toward U.S. security interests.
There is a substantial difference between citizenship acquired through parentage or descent versus application or naturalization as an adult.
Note for C-3 Canadians: Those who newly qualified as Canadian citizens under Bill C-3 did not apply for Canadian citizenship. The bill revised criteria for determining citizenship by descent, which triggered an automatic change in citizenship. Applying for recognition of citizenship entails an entirely different process (and should still be reported per SEAD-3).
Expressing a desire to expatriate from the U.S. is a red flag, as is applying for citizenship after becoming a U.S. citizen.
Be prepared to explain the reason; for example, some countries require their own citizens to travel in and out using that country’s passport. For many adjudicators, traveling on a foreign passport is broadcasting a foreign preference security concern.
Failing to truthfully answer application questions or failing to report in accordance with SEAD-3 and your agency’s guidelines compounds foreign preference risk.
Security clearance holders are required to travel in and out of the U.S. with their U.S. passport only. Canada allows dual U.S. citizens to travel in and out of Canada with their U.S. passport.
Adjudicators distinguish between benefits used before versus after becoming a U.S. citizen.
It is important to limit exercising benefits of foreign citizenship, like voting. Though a passport is a benefit of citizenship, traveling using a foreign passport is not a red flag unless the foreign passport is used to travel in or out of the U.S.
How much leverage could a foreign country hold over you, and how likely are they to use it?
Foreign citizenship as such is not of security concern, but what it implies is. Divided loyalties are not the sole issue. Citizenship is often accompanied by some degree of benefit, obligation, relationship(s), and/or investment. These are potential levers of pressure. Bad actors may use such levers to compel cleared individuals to divulge classified information.
Simply renouncing citizenship may not mitigate the concern of what accompanies the dual citizenship. Concerns are often less direct, such as having close family abroad or other obligations not directly tied to current citizenship status.
Security Clearance eligibility is a matter of acceptable risk, not merit. Individual character and choices are critical, but matters beyond your individual control are material when they heighten risk. For example, you may not have chosen to have PRC citizenship or parents living abroad but those facts may trigger foreign influence concerns.
The particular country of citizenship or any other alleged foreign preference or foreign influence is highly relevant in most cases. A country’s risk level varies depending on the larger context: the countries involved and your network of relationships and investments. The more potential levers of control you present, the higher the risk.
Even with a country like Canada, Guideline B and C concerns may still present if you demonstrate more preference for and investment in Canada than the U.S.. The following may be seen as investing in a country:
On the other hand: if you are a citizen of a hostile country but have zero attachments, relationships, or obligations tying you to that country, it may be possible to mitigate foreign influence and foreign preference concerns.
The geopolitical conditions and security profile are highly relevant to assessing a country’s risk level. However, the relevant context is far more complex than a safe vs. risky or friendly vs. hostile distinction can account for.
In general, “friendliness” refers to shared goals, values, bilateral or multilateral cooperation (security, military, or economic) trade agreements, and alliances. We can share these things with countries that present heightened security risk. A government may be friendly to the U.S., but the country at large may be occupied by terrorists or criminal cartels.
Preference for a “friendly” country cannot be relied upon. This is for a few reasons:
Much like security clearance holders are assessed as a “whole person,” foreign countries are assessed as a “whole country”: their current conditions, character, relationship to the U.S. and the rest of the world are highly relevant—particularly if hostile or adversarial. An individual may be patriotic and reliable, but that has no bearing on the foreign government.
The following considerations apply when assessing the potential risk of foreign influence for a particular country:
Friendly countries may still engage in espionage. But connections to high-risk countries with the above characteristics may endanger you as an individual and the loved ones abroad (and their loved ones) who may be leveraged against you. Even for otherwise loyal and trustworthy individuals, fully mitigating this risk is challenging.
Context is everything: the country’ current conditions, their relationship to the U.S., and their relationship to other countries who may or may not be security risks themselves.
For example, Israel is cited as sharing a “close friendship” with the U.S. but still flags substantial Guideline B concerns due to the threat of terrorism and civil unrest (ISCR Case No. 19-03737).
These conditions may change; countries not considered high-risk several years ago may be considered risky now.
Hong Kong presents a heightened risk of foreign influence because of China’s activities since 2019; Hong Kong presents risk as an extension of the PRC’s risk (ISCR Case No. 24-00750).
Taiwan also now triggers heightened security concerns despite our “friendly” relationship because of China’s actions in the region (ISCR Case No. 23-01584). Like Hong Kong, Taiwan presents security risk by virtue of the PRC.
Adjudicators must take the country into account in Guideline B and Guideline C cases. In administrative proceedings like security clearance adjudication, this happens through administrative notice: information taken as fact, often official government reports or well-established information. These facts inform the decision by providing important context. enabling adjudicators to focus on what is specific to the individual case at hand rather than debating geopolitics.
Apart from the country’s relationship to the U.S., adjudicators weigh facts such as:
Even if the country at hand does not present a poor human rights record, they may be influenced by a country that does (e.g. Taiwan and PRC pressure).
Administrative notice in security clearance hearings often includes official U.S. government reports, many from the U.S. Department of State. For example, the State Department’s annual Country Reports on terrorism, Country Reports on Human Rights Practices, Crime & Safety Reports, and Travel Advisories may factor into assessment.
For those looking for a sense of how a particular country may be viewed for security clearance purposes, consult the U.S. Department of State website. OSAC-issued Country Security Reports are also a useful indicator. They flag areas of concern which overlap with the factors adjudicators use to assess the relative threat of a foreign power in Guideline B cases.
A country may be considered “friendly” to the U.S. but still present heightened security risk. Much how security clearance denial is not a statement on the individual’s loyalty, recognizing a country’s heightened risk does not reflect America’s diplomatic stance.
Country conditions can change quickly. The degree to which a country’s threat level will impact an individual’s security clearance determination is variable. In general terms, security clearance holders and applicants may expect the following.
|
Security Risk of Foreign Citizenship |
||
| Country of Foreign Citizenship | Friendly to U.S.? | Heightened Security Risk? |
| Australia | Yes | No |
| Canada | Yes | No |
| China (PRC) | No | Yes |
| Germany | Yes | No |
| Hong Kong | Yes/No* | Yes |
| Iran | No | Yes |
| Ireland | Yes | No |
| Israel | Yes | Yes |
| Italy | Yes | No |
| Mexico | Yes | Varies* |
| Russia | No | Yes |
| Taiwan | Yes | Yes |
| United Kingdom (U.K.) | Yes | No |
| *Hong Kong is an SAR of the PRC and is considered in adjudications through lens of PRC. | ||
| **The U.S. State Department considers the safety of Mexico to vary widely by state: from lowest to highest risk. A combination of bilateral and multilateral cooperative agreements and treaties, a shared border, shared commitments, trade, | ||
Under current policy, dual U.S. citizens are eligible for security clearance. For security purposes, a U.S. citizen who holds an additional citizenship is not a “foreign national.” Neither foreign citizenship nor holding a foreign passport are disqualifying in and of themselves.
NOFORN stands for NO FOREIGN DISSEMINATION. Information classified as NOFORN may not be shared with foreign nationals, foreign governments, or anyone who is not a U.S. citizen. Because dual citizens who hold U.S. citizenship are not considered foreign nationals, they may access NOFORN.
For security clearance holders, application for foreign citizenship or exercising the benefits of foreign citizenship (e.g. voting, tuition coverage, etc.) would likely raise foreign preference concerns, and potentially foreign influence concerns. It is highly advised to speak with a private national security attorney to review the potential risks to your clearance and career before proceeding.
For security clearance applicants, even applying for foreign citizenship or exercising the benefits of foreign citizenship (e.g. voting, tuition coverage, etc.) after becoming a U.S. citizen would likely raise foreign preference concerns, and potentially foreign influence concerns.
There are cases in which a security clearance holder may become a foreign citizen without taking action. For example, in December 2025, Canada amended its citizenship by descent rules, extending Canadian citizenship to millions of Americans. How one becomes a citizen matters to Security. C-3 Canadians did not apply for foreign citizenship. The process of applying for recognition of Canadian citizenship is distinct from applying for Canadian citizenship, but may still qualify as an exercise of the benefits of foreign citizenship.
To learn more about the impact of Canada’s Bill C-3 on security clearance holders, read our article here.
It is not necessary and may be harmful in some circumstances. Speak with your agency’s Security Office or a national security attorney before proceeding. Pursuing renouncement may itself pose a security risk.
Likewise, contacting the foreign government to ask questions about citizenship, renouncement, and related matters could also pose a risk.
If your citizenship is with a country known to engage in espionage against the U.S., the concern is that you the citizen may be targeted for coercion, manipulation, exploitation, or duress. Alerting the foreign government in question to your intentions to renounce citizenship could clue them on to the fact that you may soon have access to U.S. classified information.
It is not uncommon for Guideline C, foreign preference to be paired with Guideline B, foreign influence. Surrendering a passport or citizenship is unlikely to resolve foreign influence concerns.
Dual nationals have the same reporting requirements under SEAD-3 as non-dual citizens.
Security concerns are not examined in isolation, but as part of a larger context (i.e. the “whole-person analysis”). Failing to report foreign travel is damaging for any security clearance holder. Failing to report foreign travel for someone with dual citizenship may exacerbate other concerns in a way that makes potential foreign preference disqualifying.
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