Will foreign investments affect my TS?

2022-04-18T12:17:52-04:00

I’m looking to invest in Peer to Peer lending, specifically in Mintos, a company based in Latvia. The Mintos platform provides a connection between lending companies and investors. These loans are taken by private citizens and companies, obviously all foreign. Would this affect my TS?

Response by SSgt Christophe Murphy made Apr 18 at 2022 1:40 PM

2022-04-18T13:40:09-04:00

It could be an issue depending on the specifics. I'd be careful.
https://themilitarywallet.com/security-clearances/#:~:text=The%20Department%20of%20Defense%20(DoD,investments%2C%20cryptocurrency%20and%20foreign%20investments.

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Response by MSG Private RallyPoint Member made Apr 18 at 2022 2:11 PM

2022-04-18T14:11:56-04:00

It may or may not affect it negatively. However....you BETTER report any foreign investments. For if you do invest in foreign companies and NOT report it....then that WILL affect your TS in a negative way. You want the best answer on this....then you need to seek out your Security Manager.

Response by CSM William Everroad made Apr 18 at 2022 2:29 PM

2022-04-18T14:29:11-04:00

SGT Private RallyPoint Member, The issue isn't whether or not you invest, it is if you don't disclose and don't invest responsibly.

When you rectify your TS, you must disclose changes in your investments if they include in foreign markets. This may, by itself, trigger a deeper dive into the investments themselves. While you may be playing the market, it is not assumed that the investor is picking vehicles at random. So if one of the companies are listed as a bad actor, involved in illicit or illegal activity, connected to or is itself a national security threat, it may delay your recertification. If you are doing fractional or P2P lending, the number of companies (or individuals) you are vested in can get quite long.

The bigger question is why P2P over traditional investment vehicles? 401K/ORP/ and BRS can return upwards of 15% without the national security interest issue. You can get that in P2P, but not without much more exposure to investment risk. Some of those companies are dealing with sub-par lenders that lend to anyone and let these loans go way into default and now your principal is tied up. Additionally, Mintos is global, so you have the currency exchange rate to factor into any loss/gains, which may affect it exponentially.

Response by SFC Private RallyPoint Member made Apr 18 at 2022 10:35 PM

2022-04-18T22:35:49-04:00

You better report ANY foreign investments you make to your security manager. If you are read on to SCI, you also HAVE to report it to your SSO - and if you get read on after this you have to report it on the screening sheet.

But you should be reporting ANY changes like this to your security manager. In fact, anything foreign you report to your security manager (generally the S2) and they can put it in DISS.

It's not going to cause you to lose your TS necessarily but you need to report it. If you're unsure what to report (and this goes for anyone with a clearance) here are the 13 adjudicative guidelines:

Adjudicative Guideline A: Allegiance to the United States
Adjudicative Guideline B: Foreign Influence
Adjudicative Guideline C: Foreign Preference
Adjudicative Guideline D: Sexual Behavior
Adjudicative Guideline E: Personal Conduct
Adjudicative Guideline F: Financial Considerations
Adjudicative Guideline G: Alcohol Consumption
Adjudicative Guideline H: Drug Involvement
Adjudicative Guideline I: Psychological Conditions
Adjudicative Guideline J: Criminal Conduct
Adjudicative Guideline K: Handling Protected Information
Adjudicative Guideline L: Outside Activities
Adjudicative Guideline M: Use of Information Technology Systems

There's a possibility it triggers something in continuous vetting especially if you're enrolled in CE for Deferred Investigation but probably not. Go talk to your S2 asap.