Foreign National Contact Reporting

In accordance with Security Executive Agency Directive (SEAD) 3 all security clearance holders are required to report suspicious contact with foreign nationals, especially if they are associated with a foreign government. In a recent Department of Justice (DOJ) case an Air Force civilian employee, Xiaoming Zhang, was convicted of providing false statements to the Federal Bureau of Investigations (FBI) while being interviewed about his contact with a Chinese government official during his travels back and forth to see family living there.

Zhang was a professor at the Air War College in Alabama, held a Secret clearance since 2003, and received initial and annual security briefing regarding reporting requirements. He underwent a background reinvestigation in 2017 and was questioned by an investigator about contact with the foreign government official. Zhang denied any contact and OPM subsequently referred the investigation to the FBI. During interviews with the FBI he initially denied any contact, but eventually confessed to having met 6 times and exchanging around 40 emails with him. He also stating he had hidden the relationship because he knew it would cause problems for him.

The DOJ press release doesn’t indicate how the OPM investigator knew to question Zhang about the foreign government official, but I would speculate it had to do with the Air Force Office of Special Investigations digging into foreign travel alerts and other sources in the investigation. As a reminder to current and future clearance holders regarding this matter, SEAD-3 states you must report contact with any foreign national that involves the exchange of personal information, regardless of how the relationship is maintained (personal contact, telephonic, internet, etc).