Money-Laundering Activity, Foreign Bank Accounts and Your Clearance

It is well known that Nigeria is a haven for financial scams, fraudulent internet activities and money laundering schemes. The use of 3^rd party bank accounts is a way for criminals to disguise illicit activities and move money to legitimate businesses and accounts. A DoD contractor, born in Nigeria and is now a naturalized U.S. citizen, was denied eligibility for a security clearance due to concerns about foreign influence and personal conduct. Here are the highlights of the case:

The applicant’s wife is still a Nigerian citizen and they have many relatives and contacts who live in Nigeria. At the wife’s prompting, the applicant engaged in helping a distant relative transfer large sums of money using the applicants U.S. based bank accounts. The amounts varied from $10,000 up to $100,000. He would deposit these funds into his accounts and then wire them to various foreign bank accounts in China, Nigeria, Turkey, and South Africa. Inevitability, the FBI caught wind of it and interviewed the applicant and his wife in 2017, and although not officially charged, were suspected of money-laundering and the FBI froze their bank accounts.

In his appeal to the Defense Office of Hearing and Appeals (DOHA) the applicant did not provide any mitigation for the foreign influence concerns and only tried to challenge the judge’s conclusions about the evidence leading to the accusation of money-laundering and use of his U.S. bank accounts. There really was no way this applicant could overturn the initial clearance denial, and that he actually submitted an appeal was ill-advised.