CASE BRIEF: Coordinate Activities Leading to Award of a Facility Security Clearance (FCL)
CLIENT: A large European company
PROBLEM: The client had acquired a U.S. company that was involved in providing temporary employees to a full range of customers, including several government contractors who performed classified work. As a foreign company, the client was required to comply with the provisions of the National Industrial Security Program (NISP) and establish a management structure, and policies and procedures to negate Foreign Ownership, Control or Influence (FOCI) and to isolate the foreign owners from access to any classified information.
ACTIONS: GMD Solutions supervised and actively participated in the following actions leading to award of multiple Facility Security Clearances.
 | Briefed the client on security requirements and options to negate FOCI. Met with appropriate staff of the Defense Security Service (DSS) to inform them of client activities. Also, coordinated with the Department of Energy (DOE) in that several classified contracts involved DOE nuclear facilities and labs. |
| Identified the various options and steps required to reduce FOCI risks to an acceptable level. Assisted the client in developing their management structure as well as the policies and procedures to accomplish this objective. |
| Provided guidance to and coordinated activities of several newly designated corporate client Facility Security Officers (FSO). Identified and nominated to DSS three individuals to serve as Outside Directors and two individuals to serve as Proxy Holders. Coordinated requests for multiple personnel security clearances. |
| Assisted in finalizing with DSS, the necessary FOCI agreement(s) and backup documentation (By-Laws, Articles of Incorporation, Resolutions, Key Management Personnel lists, etc. |
RESULTS: GMD Solutions assisted the client in overcoming a series of security obstacles created by different policies that existed within and between the Departments of Defense and Energy, as well as by multiple contracts that required security clearances ranging from Confidential to Top Secret. To help resolve these issues, GMD Solutions planned and participated in the sale of certain selected (DOE) contracts. Further, GMD Solutions gained approval from DSS to establish a Facility Clearance under the provisions of a Special Security Agreement (for all classified work at the Secret level and below) and organized a separate company (operating under a Proxy Agreement) to service all Top Secret contracts.
The approval of two complex Facility Clearances and a flexible organizational structure have enabled the company to seek and win numerous contracts involving classified work that would not have been possible under other corporate configurations.
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