KEYWORD: Foreign Influence, Personal Conduct DIGEST: Applicant has immediate and extended family members in Nigeria. For several months in late 2016, Applicant collaborated with his wife’s distant cousin in Nigeria, someone he had never met, in transferring several hundred thousand dollars through Applicant’s U.S. bank accounts to Nigerian or other foreign accounts. The funds were deposited into Applicant’s accounts by other individuals, who Applicant also did not know. Applicant did not provide sufficient evidence to mitigate foreign influence security concerns about his family members in Nigeria or the personal conduct security concerns about these financial practices. Eligibility for access to classified information is denied. CASE NO: 19-03558.h1 DATE: 02/16/2021