Meeting the 32 CFR Foreign Travel Reporting Requirements
All employees holding a Personnel Clearance (PCL) must report any foreign travel to their Facility Security Officers (FSOs) as of Aug. 24, 2022. This is part of the change from the old National Industrial Security Program Operating Manual (NISPOM) to the 32 CFR Part 117, NISPOM that occurred in February 2021. With this new requirement, it’s important that cleared employees and FSOs are familiar with the process to report foreign travel.
How Employees Report
When a cleared employee plans to travel abroad, they need to email their FSO at least 10 business days before they leave. Some companies may require notice further out from the planned travel. This email should include where they’re traveling to and the dates they’ll be there. Once the FSO receives this, they will send the employee a form to collect further information required by Security Agent Directive 3 (SEAD 3) and look up any travel advisories from the Department of State to share with them.
This form will ask for information including the employee’s full itinerary and passport information. The employee will have to do a travel safety briefing prior to their departure, but the form can also count as the briefing if it includes safety information. This would include tips and requirements like “Don’t mention, discuss or even imply involvement in special or classified projects or activities,” and “Never take sensitive or classified materials outside the United States.”
After the employee completes the form and returns it to their FSO, they are ready to travel. Once they return, the FSO needs to give them a foreign travel debrief within five business days. This is another form that will ask questions including, “Did you meet with any foreign nationals who requested future contact?” and “Did you have contact with anyone under circumstances that you would consider suspicious?”
Related: FAQs About the New NISPOM Rule
If the employee answers “no” to all these questions, they’ve officially fulfilled their responsibilities for reporting foreign travel. However, if they answer “yes” to any, they will need to provide further information as to what occurred. For many of these questions, a “yes” answer is likely to be completely innocent, like if the employee happened to make a friend from another country. These questions are just to make sure the FSO can do their due diligence in their investigation. Once the employee has completed this form, they’ll sign it and return it to their FSO.
On occasion, things may occur during travel that need reporting. For example, if something happens that drastically changes travel plans and the dates the employee will return, they should let the FSO know as quickly as possible.
Reporting in DISS
Once the employee has sent the FSO their completed pre-travel form, the FSO will make a report in DISS. To do this, they’ll open the subject profile, go to the foreign travel tab and click “create foreign travel report.” This is where the FSO will enter the dates the employee will be traveling, the date they first reported their travel, their reason for travel (e.g., vacation), and any other notes, such as where they’re traveling, mode of transportation, and any other relevant information. Once the FSO has uploaded this information, they can continue to access and update the foreign travel report.
After the employee returns and completes their foreign travel briefing, the FSO will put any further relevant information in DISS and then click “debriefed.” However, once a travel report is marked as debriefed, it will be unavailable for a time. The report will eventually reappear, but the FSO should maintain physical records of the pre-travel form and debriefing that the employees fill out in case they need to access them before the report is accessible within DISS. This record can be maintained for as long as the employee remains at the company.
If you are an FSO feeling overwhelmed with navigating foreign travel reporting requirements or other responsibilities associated with maintaining your company’s FCL and employees PCLs, Adamo can help! Our FSO Support services can partner with your security team and free you up to focus on growing your business while we handle the day-to-day FSO responsibilities.
