Guideline C Foreign Preference Concerns Threatening Your Security Clearance? Here’s How to Mitigate and Fight Back

You never imagined that your ties to another country could put your patriotism in doubt. Yet here you are – perhaps you’ve received a Statement of Reasons (SOR) citing “Guideline C – Foreign Preference,” or an investigator raised concerns about dual citizenship or foreign obligations in your background. It’s a jarring, confusing, and frightening situation. You’re probably asking yourself, “Is this the end of my career?” The idea that a foreign connection – maybe a passport you hold or a benefit you received from abroad – could cost you your security clearance (and with it your job, income, and reputation) is causing some sleepless nights.

Here’s the good news: it doesn’t have to end this way. Guideline C concerns can be mitigated with the right approach. At National Security Law Firm (NSLF), we help clients in exactly your position every day. We understand the panic and uncertainty you’re feeling, and we know how to fight back so you can resolve these issues, keep your clearance, and move forward with confidence. This comprehensive guide will explain what Guideline C is, why you might be facing it, how to mitigate foreign preference allegations, and how our team can help you achieve the best possible outcome.

Understanding Guideline C: Foreign Preference

Guideline C (Foreign Preference) is one of the 13 adjudicative guidelines used to evaluate security clearance eligibility. In plain terms, this guideline asks: Has the person acted in a way that suggests a preference for a foreign country over the United States? If so, the government worries that their loyalty to the U.S. might be compromised. As the official guideline states, “When an individual acts in such a way as to indicate a preference for a foreign country over the United States, then he or she may be prone to provide information or make decisions that are harmful to the interests of the United States.” In other words, if you’ve engaged in certain foreign ties or activities, clearance adjudicators will question whether you might put another nation’s interests above America’s.

It’s important to note that holding dual citizenship or having foreign connections isn’t automatically disqualifying. Millions of Americans are dual citizens or were born abroad. Guideline C is concerned with behavior – specifically, actions that actively demonstrate foreign preference. The government isn’t saying you’ve done something traitorous; rather, they worry about what could happen if you had to choose between the U.S. and that other country. For example, if you’ve maintained a foreign passport or served in a foreign military, they might question where your ultimate loyalty lies in a crunch situation. Guideline C is essentially about these loyalty “what ifs.” The mere existence of a foreign tie doesn’t revoke your clearance, but it will trigger scrutiny if you’ve taken certain actions with that tie.

Common Foreign Preference Concerns (Guideline C Triggers)

Because Guideline C focuses on behavior, it can be raised by a variety of situations where you’ve exercised rights or privileges of foreign citizenship. Some of the most common examples include:

  • Possessing and using a foreign passport: If you maintain a current passport from another country – and especially if you have used it for travel instead of your U.S. passport – it raises a red flag. The government sees traveling on a foreign passport as an act that favors that country’s protection over U.S. oversight. Simply having an un-expired foreign passport, even if you haven’t used it recently, is enough to trigger concern under Guideline C.

  • Service in a foreign military (or willingness to serve): Mandatory military service in your birth country or voluntarily joining a foreign nation’s armed forces will alarm security officials. Even just stating that you would fulfill foreign military obligations or bear arms for another country is viewed as potentially preferring that country over the U.S. (There’s an obvious exception for those who serve in foreign militaries at the request of the U.S. Government, which we’ll discuss in mitigation.)

  • Holding public office in a foreign country: Serving in a political or governmental position for another nation (or actively seeking such a position) is a major concern. It implies an obligation to a foreign government. For example, if you were a local elected official in another country or ran for parliament there, that’s seen as incompatible with holding a U.S. clearance.

  • Accepting benefits from a foreign state: Receiving substantial educational, medical, retirement, or social welfare benefits from a foreign country can raise questions. The concern is that you might feel indebted or loyal to that country because of those benefits. A common example is a dual citizen using their foreign citizenship to get free or reduced university tuition abroad, or signing up for a foreign country’s government-funded healthcare or pension program.

  • Voting in foreign elections: Casting a vote in another country’s election (if you have that right as a dual citizen) is viewed as an active demonstration of allegiance to that nation. The U.S. doesn’t want to punish engaged citizenship, but from a security perspective, voting in a foreign election is taken as evidence you feel a duty or loyalty to that foreign government.

  • Other signs of foreign allegiance: This is a bit of a catch-all. It could include things like formally renouncing your U.S. citizenship (even if you didn’t follow through), or making public statements that appear to put another country’s interests above America’s. Even residing long-term in a foreign country to fulfill a requirement for keeping your other citizenship could be viewed as a preference if it’s a deliberate choice.

As you can see, these concerns revolve around actions – using the rights of foreign citizenship or indicating in word or deed that your loyalty might be divided. It’s understandable that seeing any of these on your SOR would be shocking; essentially the government is questioning your patriotism or trustworthiness. However, remember that allegations are not facts. Maybe you renewed that foreign passport purely for convenience, not because you love that country more. Perhaps you fulfilled a compulsory service requirement but your heart is 100% American. The key thing is you will get a chance to explain and mitigate the concern. Guideline C issues, like any clearance concern, can often be resolved if you address them head-on with the right evidence – which is exactly what we’ll cover next.

How to Mitigate Guideline C Security Clearance Concerns

If you’re facing a Guideline C concern, don’t panic. The adjudicative guidelines themselves list specific mitigating factors – essentially, facts about your situation that can lessen the government’s fears and demonstrate your loyalty. In plain English, you need to show that whatever foreign connection or activity raised the concern does not reflect a risk of you favoring another country over the U.S. Here are the key mitigating circumstances and how you can leverage them in your case:

  • It’s only by birth or family, not by choice: If your dual citizenship exists solely because of circumstances of your birth (e.g. you were born abroad or your parents are from another country), emphasize that. You didn’t actively seek out foreign citizenship out of disloyalty; it was bestowed on you. This is a recognized mitigating factor. The same goes for situations like a foreign passport that was issued to you as a child. If you’ve held foreign status only through birth or lineage – and not because you chose to become a citizen of Country X as an adult – it helps show that your foreign citizenship was not an intentional sign of divided loyalty.

  • All foreign ties preceded U.S. citizenship: Timing can be crucial. Maybe you did serve in a foreign military or vote in a foreign election – but it was before you became a U.S. citizen. If any indicator of foreign preference (foreign military service, oath of allegiance to another nation, etc.) occurred before you naturalized as an American (or while you were a minor and under parental direction), highlight that fact. The guidelines specifically note this as mitigating. The logic is that once you became a U.S. citizen, you left those behaviors behind. You can argue, for instance, “Yes, I served my mandatory military term in Country X, but I did that long before I moved to the U.S. and obtained citizenship here. Since becoming American, I have not engaged in any such activities.”

  • Willingness to renounce foreign citizenship or documents: One of the strongest things you can do is demonstrate that you place your U.S. loyalty above the foreign one. Often, this means renouncing your foreign citizenship or at least any advantages from it. Are you willing to renounce that second citizenship if required? Say so – and be prepared to follow through if push comes to shove. At a minimum, if you have a foreign passport, immediately surrender it (to the foreign country’s embassy or to your security officer as directed). Provide proof of that surrender. Showing that you’ve given up your ability to travel on that passport is huge. It’s concrete evidence that you’re not hedging your bets with Country X’s protection. Likewise, withdraw from any foreign benefit programs and close any doors that might hint you’re keeping an allegiance “plan B.” If you’ve already done these things proactively, even better – it demonstrates good faith. The guidelines list an “expressed willingness to renounce dual citizenship” as a mitigating factor, but actions speak louder than words. Actually taking steps to cut formal ties (where feasible) can powerfully mitigate the concern.

  • U.S. Government sanctioned the foreign activity: This one is less common but very important if it applies. Sometimes, what looks like foreign preference was actually done at the behest or encouragement of the U.S. For example, on rare occasions a U.S. agency might want someone to use a foreign passport for an authorized covert purpose, or might encourage a dual citizen to vote in a foreign election as part of a diplomatic or peacebuilding effort. Another example: perhaps you traveled on your foreign passport to carry out official U.S. business in a country that bars entry to U.S. passport holders – meaning you used the passport with your security officer’s knowledge to accomplish a mission. If any foreign allegiance-type activity was explicitly sanctioned by the U.S. government, it’s a complete game-changer. You’ll want documentation or affidavits from the officials involved to prove this. Admittedly, most people won’t have this scenario, but don’t overlook it if you do – it essentially tells the adjudicators “I wasn’t being disloyal; I was doing what my country asked of me.”

  • Clean break with the foreign allegiance now: Mitigation is also about the here-and-now. You need to persuade adjudicators that whatever foreign connections raised concern are no longer influencing you – and won’t in the future. Even if you once exercised foreign citizenship, show that you’ve since ceased and remedy the situation. For instance, if you voted in a foreign election a decade ago, but have not done so since and have formally withdrawn your name from foreign voter rolls, provide evidence of that. If you inherited a foreign property or account, and you worry it looks like a tie, consider selling the property or moving the funds to the U.S. (or at least demonstrate it’s being managed in a way that doesn’t affect your loyalty). Essentially, eliminate or minimize any ongoing aspects of foreign preference in your life. The more you can say, “That was in the past, and I’ve cut that tie,” the better. And for any past incidents you can’t undo (like a prior foreign military service), complement it by emphasizing all the ways you’ve been loyal to the U.S. since then – military or government service for the U.S., oath-taking, community involvement, etc. The whole-person concept is in play: if 95% of your life screams “Loyal American” and the foreign issue was an outlier, make sure the adjudicator sees that big picture.

Hypothetical Scenario: Imagine a defense contractor, “Sarah,” who was born in the United Kingdom to American parents. Sarah automatically held dual U.S.–UK citizenship from birth. In her teenage years and early 20s, she used her UK passport for convenience when traveling in Europe. She even voted in a UK local election while studying abroad. Fast forward to today – Sarah, now in her 30s, is facing a Guideline C SOR citing her possession of a foreign passport and that past foreign voting. This situation is worrisome, but very much winnable. Here’s how Sarah could mitigate the concerns: First, she’d explain that her dual citizenship was not a matter of choice (mitigating factor (1) – it was based on birth). Next, she would show she has surrendered her UK passport and has sworn off using it further. She might include a letter from the British consulate confirming she turned it in. She could also point out that her exercise of those UK citizen rights (travel and voting) took place when she was quite young and before she fully understood the implications – importantly, before she held any clearance or U.S. government position. In addition, Sarah could declare in her response that she is willing to renounce her UK citizenship if necessary to keep her clearance. To bolster her case, she’d highlight her strong ties to the United States: she’s been a U.S. citizen her whole life, has lived in the U.S. exclusively since finishing school, and has built her career here. She might include reference letters from supervisors and colleagues attesting to her dedication and trustworthiness. By compiling all this, Sarah can persuasively argue that nothing about her dual citizenship poses a real security risk – her life demonstrates clear allegiance to America, and any past appearance of “foreign preference” has been dealt with and won’t recur.

The takeaway from this scenario is that Guideline C issues can often be resolved with a thorough, well-documented response. You’ll need to prove your U.S. allegiance through your actions and intent – but it’s absolutely doable. Many people have overcome foreign preference concerns by proactively cutting foreign ties and convincingly showing that their loyalty rests solely with the United States. Given what’s at stake – your clearance, career, and reputation – it’s wise to get experienced help to prepare that response and ensure all possible mitigations are presented.

Our Pricing and Flexible Financing Options

Quality legal representation can make all the difference in a Guideline C case, and we believe everyone should have access to it when their career is on the line. That’s why we keep our pricing transparent and fair. In fact, we publish flat fees for all common security clearance services:

  • SF-86 Review & Consultation: $950

  • LOI (Letter of Interrogatory) Response: $3,500

  • SOR (Statement of Reasons) Response: $5,000 (and if you already paid for an LOI response, we credit $3,000 toward this)

  • Formal Hearing Representation: $7,500 (flat fee, includes attorney travel to the hearing location)

We also offer flexible payment plans through Pay Later by Affirm, allowing you to break up the legal fees into 3, 6, 12, or even 24 monthly payments. It’s a fast and client-friendly process – checking your eligibility is quick and won’t affect your credit score. This means you can get the expert help you need now and manage the cost over time.

Why Choose National Security Law Firm?

When it comes to defending against a Guideline C concern, you want the best team in your corner. This isn’t a routine paperwork exercise – it’s essentially defending your loyalty and trustworthiness. Here are a few reasons we’re uniquely qualified to help you:

  • Unmatched Experience and Insider Knowledge: Our firm is staffed by former DOHA attorneys, ex-military JAG lawyers, and even a former Acting Chief Judge for security clearance appeals. We have literally been on the other side of the table – making clearance decisions and prosecuting cases for the government. Now we use that insider insight to benefit our clients. We know how adjudicators think, what evidence carries weight, and how to preempt the arguments they might use. Few firms can boast this level of relevant experience in the national security arena.

  • Attorney Review Board for Every Case: When you hire NSLF, you don’t just get one lawyer – you get a team. We have an internal Attorney Review Board that reviews every case from multiple angles. Guideline C cases can involve nuanced questions of law and perception (e.g. how to frame dual citizenship in a favorable light); our collaborative approach means no detail is missed. We strategize together to formulate the strongest defense for you, applying all applicable mitigating factors and crafting the most persuasive narrative. This team approach is a major advantage, ensuring quality control and creative solutions.

  • Specialization in Security Clearances: Beware of general practice lawyers who only dabble in clearance work. At NSLF, security clearances are our primary focus. We stay up-to-date on the latest policy changes, DOHA appeal decisions, and trends in adjudications. From Guideline A through Guideline M, we’ve seen it all. This specialized knowledge means we can often anticipate issues and address them proactively. In Guideline C cases, for example, we know the subtle differences in how different agencies view dual citizenship. (Did you know some agencies have specific policies about foreign passports? We do, and we use that intel.) This kind of nuance can be the difference between a clearance denial and an approval.

  • D.C.-Based and Nationwide Reach: We are headquartered in Washington, D.C., the epicenter of security clearance adjudication, and many of our attorneys cut their teeth working in the DoD and Intelligence Community hubs. But we represent clients nationwide (and even overseas when needed). Whether you’re in Virginia or California or stationed abroad, we can help. We leverage secure video conferencing and an advanced online client portal to make it easy to work with us from anywhere. And when it comes time for a hearing, our attorneys travel to DOHA and federal hearings around the country – wherever your case is being decided, we’ll be right there by your side.

  • Veteran-Owned, Veteran-Staffed: National Security Law Firm was founded by disabled U.S. military veterans, and most of our attorneys and staff are veterans or former federal employees themselves. We know what it means to serve, and we bring that sense of duty and tenacity to fighting for our clients. We also understand military culture and the clearance process from the servicemember’s perspective – you won’t have to explain acronyms or the importance of mission readiness to us. This connection to the community fuels our passion. It’s our turn to serve you.

  • Proven Track Record of Success: Our success is measured in saved careers and restored clearances. We’re proud to have helped hundreds of clients – from young enlistees to seasoned defense executives – overcome clearance issues. Many come to us after trying to navigate the process alone, and we’re able to turn their cases around. We invite you to read our 4.9-star Google Reviews from past clients. You’ll see story after story of real people whom we helped stay in the fight and win. When everything was on the line for them, we delivered. We bring that same commitment to every case, including yours.

  • Client-Focused Service: High-stakes cases require a high level of support. We pride ourselves on being accessible and communicative. You’ll have direct contact with your attorney, frequent updates, and answers to all your questions – no wondering what’s happening with your case. Our goal is not only to win your case, but also to make the process as stress-free for you as possible. We know you’re under a lot of stress; our job is to shoulder that burden and give you peace of mind that a professional team is handling it.

In short, NSLF is the go-to law firm for Guideline C issues because of our expertise, our team approach, and our unwavering commitment to our clients’ success. When you choose us, you’re getting an elite unit of national security lawyers who wake up every day ready to protect clearances – and fight for those who protect America.

Additional Resources on Security Clearances

Dealing with a foreign preference concern might be just one part of your security clearance journey. You may have other questions, like how the overall clearance process works, what to expect in a DOHA hearing, or how other guidelines (like Foreign Influence or Financial Concerns) could come into play. We’ve got you covered. Be sure to visit our Security Clearance Resource Center, a free online library of resources to help you succeed. There, you’ll find articles on common mistakes that lead to clearance denial, step-by-step guides on responding to SORs and DOHA hearings, and deep dives into defense strategies for every type of security concern. It’s essentially a one-stop hub for clearance knowledge – empowering you with insight to avoid pitfalls and strengthen your case.

Your Clearance, Your Career, Your Future – Don’t Risk It

Every day you wait to address a Guideline C issue is another day the government’s concerns may solidify. Security clearance investigators and adjudicators are not slowing down – if anything, they continue digging while you delay. The sooner you act, the better your chances of a positive outcome. It’s far easier to mitigate these concerns before a final denial than to appeal one after the fact. Time truly is of the essence. If you’ve received an LOI or SOR, the clock is ticking on your deadline to respond. If you haven’t heard anything yet but know there’s a potential foreign preference issue in your background (and you’re losing sleep over it), getting ahead of it can make all the difference.

This is not the time for “wait and see” or DIY fixes. Guideline C cases involve nuanced judgments about loyalty and national allegiance – things too important to get wrong. You need an elite legal team with insider knowledge, practical experience, and a battle-tested strategy. We have your six. When you engage National Security Law Firm, we move quickly to take the pressure off your shoulders and start building your defense. From the first free consultation, we’ll give you clear guidance on what to do (and what not to do) to maximize your chances of success. You’ll walk away from that call with an action plan and renewed peace of mind.

Imagine being able to sleep soundly again, knowing that your clearance issue is in capable hands. Our clients often tell us that after hiring us, they felt a huge weight lifted – instead of constantly worrying, they could focus on their job while we handled the case. You deserve that peace of mind and the best possible defense. We offer free, no-pressure consultations and lightning-fast onboarding. In fact, you can schedule a consultation right now and have a meeting with an attorney in a matter of days (if not hours). No phone tag, no waiting weeks – just pick a slot on our online calendar and we’ll get to work.

National Security Law Firm: It’s Our Turn to Fight for You. You’ve spent your career working to protect U.S. national security; now let us protect your security clearance. The quickest way to put this issue behind you is to take action today – reach out for a consultation and let’s secure your clearance so you can get back to your important work with full confidence. Don’t let a solvable concern derail your life. Take control of your future now: Book Your Consult and let’s get started. We look forward to helping you safeguard your career and your good name.