The authors of this report examine the challenges and complexities that surround the personnel vetting (PV) process for dual or naturalized citizens (D/NCs) who are seeking roles in the national security workforce. Applicants for national security positions must navigate the federal PV process to adjudicate their eligibility for a security clearance, a process that may be more complex for individuals who are D/NCs.

Vetting of Dual Citizens and Naturalized Citizens for Service in the National Security Workforce

Addressing Complexities, Challenges, and Opportunities Related to the Personnel Vetting Process

Stephanie J. Walsh, Sina Beaghley, David Stebbins, Nikolay Maslov, Theiline Pigott

ResearchPublished Oct 7, 2025

The authors of this report examine the challenges and complexities that surround the personnel vetting (PV) process for dual or naturalized citizens (D/NCs) who are seeking roles in the national security workforce. Applicants for national security positions must navigate the federal PV process to adjudicate their eligibility for a security clearance. For individuals who are D/NCs, the process may be more complex due to such factors as perceptions about foreign citizenship, perceptions about the possession of a foreign passport, and government concerns about extensive foreign connections.

D/NCs often have language skills and cultural knowledge that are needed for national security work. However, D/NCs can be deterred from even applying for clearances because of uncertainty and even misinformation about the citizenship requirements to obtain a clearance, the complex and sometimes confusing PV process, and perceptions regarding both lengthy processing times and a higher potential for rejection. These issues can prevent departments, agencies, and cleared industry contractor organizations from fully using the needed skills and expertise of D/NCs in sensitive positions. The authors of this report offer insights and recommendations to address relevant aspects of the PV process for D/NCs.

Key Findings

  • Vague and inconsistent language about reporting foreign connections on U.S. government (USG) vetting forms, in policies, and in guidance is confusing for prospective D/NC applicants and USG and industrial security officers.
  • Some workforce professionals (e.g., recruiters and human resources staff) and security clearance personnel (e.g., security officers and investigators) do not consistently convey accurate information about PV policies and requirements for D/NCs, and some PV personnel describe a lack of resources and training to address specific needs and requirements for handling D/NC applicant cases.
  • Widespread misinformation about PV requirements for D/NC applicants can create confusion for the applicants and may deter them from seeking national security positions.

Recommendations

  • Update USG regulations, policies, forms, and guidance documents to include consistent and easy-to-understand language about the requirements for reporting foreign connections.
  • Create and distribute resources for USG personnel that summarize and clarify how PV requirements apply to D/NC applicants, and provide resources that are tailored to address D/NC applicant cases.
  • Create and distribute resources that clarify the PV requirements that are most relevant to D/NC applicants.

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Walsh, Stephanie J., Sina Beaghley, David Stebbins, Nikolay Maslov, and Theiline Pigott, Vetting of Dual Citizens and Naturalized Citizens for Service in the National Security Workforce: Addressing Complexities, Challenges, and Opportunities Related to the Personnel Vetting Process. Santa Monica, CA: RAND Corporation, 2025. https://www.rand.org/pubs/research_reports/RRA3461-1.html.
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This research was sponsored by the Security, Suitability, and Credentialing Performance Accountability Council Program Management Office (PAC PMO) and conducted within the Personnel, Readiness, and Health Program of the RAND National Security Research Division (NSRD).

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