Update on Reporting Requirements for Cleared Personnel

Industrial Security Letters (ISLs) are issued by the Defense Counterintelligence and Security Agency to inform cleared contractors, government contracting activities, and DoD components of developments relating to the National Industrial Security Program. The contents of these letters are for information and clarification of existing policy and requirements. DCSA published ISL 2021-02 on August 12, 2021 providing an update to Security Executive Agent Directive (SEAD) 3 which covers reporting requirements for cleared personnel.

The ISL reiterated defense contractors must report any adverse information coming to their attention concerning their covered individuals based on the 13 adjudicative guidelines found in SEAD 4. Adverse information is defined by the rule as any information that adversely reflects on the integrity or character of a cleared employee, that suggests that his or her ability to safeguard classified information may be impaired, that his or her access to classified information clearly may not be in the interest of national security, or that the individual constitutes an insider threat.

One significant update was in foreign travel reporting. The ISL extends the compliance date for contractors to report unofficial foreign travel to DCSA as prescribed in SEAD 3, beginning on August 24, 2022. This does not mean cleared contractors don’t have to report foreign travel to their Facility Security Officers right now, only that the company has until next August to develop and implement a plan on how to report it to DCSA. With Continuous Evaluation (CE) enrollment on the uptick you can be sure CE alerts from the Department of Homeland Security that show leaving and reentering the U.S. will cause grief for those who don’t report their foreign travel.