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A Review of FBI Security Programs

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have been granted. In accordance with the governing Executive Order, adjudications should<br />

be completed within 180 days after interim clearances are granted. The Bureau should also<br />

implement tighter controls on personnel granted interim clearances, limiting facility access<br />

and minimizing contact with <strong>FBI</strong> employees and assets.<br />

THE FINANCIAL DISCLOSURE PROGRAM<br />

Financial gain is a primary factor motivating espionage. Thus, most agencies within<br />

the Intelligence Community have systems in place to detect personnel with unexplained<br />

financial gain, excessive debt, and financial vulnerabilities.<br />

In the aftermath <strong>of</strong> the Ames case, the President and Congress took steps to enhance<br />

financial monitoring <strong>of</strong> cleared personnel. For instance, Executive Order 12968 provides for<br />

financial disclosure, expanded use <strong>of</strong> Bank Secrets Act databases, and broad financial<br />

waivers and releases from certain government employees. The Order sets guidelines for<br />

determining who must make financial disclosures and requires that all employees with access<br />

to classified information consent in writing to disclosure <strong>of</strong> financial records.<br />

The <strong>FBI</strong> is not in compliance with Executive Order 12968. With the exception <strong>of</strong><br />

certain senior personnel and members <strong>of</strong> the Senior Executive Service, the Bureau does not<br />

require employees or contractors to complete a Financial Disclosure Form (FDF). Financial<br />

information provided by non-SES personnel is in response to a limited series <strong>of</strong> questions<br />

on a standard form, which has little adjudicative value.<br />

The FDF is a means <strong>of</strong> identifying persons with unexplained affluence or excessive<br />

debt. Studies have shown that most spies do not hoard their illicit gains, but purchase assets<br />

that are difficult to hide, such as real estate and automobiles. The FDF can deter potential<br />

spies by reminding filers annually that resources are devoted to identifying those who engage<br />

in espionage. The FDF can also serve as valuable documentary evidence in criminal<br />

prosecutions for espionage or false statements. The form can identify employees on a path<br />

toward serious financial difficulties and, thus, potentially vulnerable to espionage. Once<br />

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