DOE O 142.3C, Unclassified Foreign National Access Program
The Department of Energy (DOE) unclassified mission focuses on the critical challenges of our time, for both the country and the world. While much of this unclassified mission work is performed in collaboration with the international community, the federal government simultaneously holds a responsibility to protect its assets and deny unauthorized access to sites, information, or technologies.
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Section 1
AVAILABLE ONLINE AT: INITIATED BY:
www.directives.doe.gov Office of Environment, Health, Safety and Security
U.S. Department of Energy ORDER
Washington, DC
Approved: 3-31-2026
SUBJECT: UNCLASSIFIED FOREIGN NATIONAL ACCESS PROGRAM
1. PURPOSE. The Department of Energy (DOE) unclassified mission focuses on the critical
challenges of our time, for both the country and the world. While much of this
unclassified mission work is performed in collaboration with the international
community, the federal government simultaneously holds a responsibility to protect its
assets and deny unauthorized access to sites, information, or technologies. This program
defines the requirements for unclassified foreign national access to DOE sites,
information, or technologies by establishing requirements for the following:
a. A risk-based review and approval process for foreign national access consistent
with United States (U.S.) law; export control regulations; national and economic
security; and DOE program-specific policies, requirements, and objectives.1
b. A process for documenting and tracking foreign national access to DOE sites and
access to DOE information or technologies.
2. CANCELLATIONS. DOE O 142.3B, Unclassified Foreign National Access Program,
dated 01-15-21.
Cancellation of a directive does not, by itself, modify or otherwise affect any contractual
or regulatory obligation to comply with the directive. Contractor Requirements
Documents (CRDs) that have been incorporated into a contract remain in effect
throughout the term of the contract unless and until the contract or regulatory
commitment is modified to either eliminate requirements that are no longer applicable or
substitute a new set of requirements.
3. APPLICABILITY.
a. Departmental Applicability. Except for the equivalencies/exemptions in paragraph
3.c., this Order applies to all Departmental elements.
The Administrator of the National Nuclear Security Administration (NNSA)
1 This Order serves as DOE’s policy to assess the counterintelligence risk that covered visitors or covered assignees
pose to the research or activities undertaken at the National Laboratories, as required by Sec. 6432 of the
Servicemember Quality of Life Improvement and National Defense Authorization Act for Fiscal Year 2025, Public
Law 118-159 (December 23, 2024) (FY2025 NDAA). In addition, any legal prohibition on admittance, particularly
the absolute prohibition detailed in Section 4.n for citizens or agents of Covered Foreign Nations to specified
facilities under section 3112(c) of the FY2025 NDAA must be applied first in accordance with applicable DOE
guidance before proceeding with any request under this Order.
DOE O 142.3C
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must ensure that NNSA employees comply with their responsibilities under this
Order. Nothing in this Order will be construed to interfere with the NNSA
Administrator’s authority under section 3212(d) of Public Law (P.L.) 106-65 to
establish Administration-specific policies, unless disapproved by the Secretary.
b. DOE Contractors. Except for the equivalencies/exemptions in paragraph 3.c., the
CRD (Attachment 1) sets forth requirements of this Order that will apply to
contracts that include the CRD. The CRD must be included in contracts involving
foreign national access to DOE sites, information, or technologies. Except for the
equivalencies and exemptions in paragraph 3.c., applicable requirements of the
CRD set forth in this Order apply to government-owned, government-operated
(GOGO) facilities and federally staffed laboratories as the Field Elements of their
Program Secretarial Office.
Section 2
c. Equivalencies/Exemptions for DOE O 142.3C. Equivalencies and exemptions to
this Order are processed in accordance with DOE O 251.1, Departmental
Directives Program, current version.
(1) Equivalency. In accordance with the responsibilities and authorities
assigned by Executive Order 12344 (codified at Title 50 United States
Code (U.S.C.) sections 2406 and 2511), and to ensure consistency through
the joint Navy/DOE Naval Nuclear Propulsion Program, the Deputy
Administrator for Naval Reactors (Director) will implement and oversee
requirements and practices pertaining to this Order for activities under the
Director's cognizance, as deemed appropriate.
(2) Exemptions.
(a) Unclassified events and activities outside the U.S. or its territories.
(b) Dual citizens, only if one citizenship is U.S citizenship.
(c) Requests for access to information that is not a sensitive subject as
defined by this Order, and in accordance with applicable
procedures (i) is already available to the public or (ii) has been
documented to be published and shared broadly within the
scientific community. [NOTE: Physical access to a site will follow
normal site security procedures, including the applicable
requirements of this Order.]
(d) Requests for access to information (e.g., technical specifications, project
data, research results) by foreign nationals from countries that are
formally part of a specific DOE program-sponsored international
collaboration project under a DOE or U.S. Government-level bilateral or
multilateral international agreement (e.g., Deep Underground Neutrino
Experiment at Long-Baseline Neutrino Facility, Proton Improvement
Plan-II, Vera C. Rubin Observatory). This applies only to information
generated under these projects and agreed to be shared among the
participants. [NOTE: Physical access to a site that would otherwise be
4 DOE O 142.3C
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within this exemption will follow normal site security procedures,
including the applicable requirements of this Order.]
(e) Information exchanges conducted remotely by HQ program offices
and supporting laboratory and contractor personnel, in direct
support of DOE/NNSA nonproliferation, counterproliferation,
counterterrorism [NOTE: Physical access to a site that would
otherwise be within this exemption will follow normal site security
procedures, including the applicable requirements of this Order.]
(f) Unclassified information exchanges conducted by DOE employees
and supporting laboratory and contractor personnel who are
foreign nationals approved in FACTS under a specific DOE-
related work assignment. These individuals can participate in
virtual and in-person meetings, discussions, and phone calls with
other DOE federal and contractor employees outside of their duty
station to perform the duties specified in their FACTS assignment.
[NOTE: Physical access to a site that would otherwise be within
this exemption will follow normal site security procedures,
including the applicable requirements of this Order.]
(g) Public events held on or off DOE sites.
(h) Certain activities within General Access Areas (GAA):
1 Personal visits.
2 Third-party events (i.e., not related to the DOE mission)
hosted at the site.
3 Access by foreign national delivery, service, and vendor
personnel (NOTE: Also exempt in other areas outside of a
GAA if fully escorted and compliant with other relevant
security requirements).
4 Foreign nationals performing construction activities.
Section 3
(i) Foreign national emergency response and medical personnel who
require access for emergencies.
(j) Access by foreign nationals 17 years of age or younger who are
involved in non-work-related activities.
(k) International Atomic Energy Agency (IAEA) inspections, as
defined in the “Agreement between the United States and the IAEA
for the Application of Safeguards in the U.S.”
DOE O 423.1C 5
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(l) Mutual Defense Agreement (MDA) visits do not fall under this
Order; MDA visits follow the applicable Administrative
Arrangements and DOE O 470.1.
4. REQUIREMENTS. Foreign national requests for access to DOE sites, information, or
technologies will be reviewed based on all the information provided and any potential
impacts on site or program operations. All access requests must include all applicable data
elements outlined below and any additional information required by the Foreign Access
Central Tracking System (FACTS). Access requests involving the following must not
exceed two years continuous duration from the start date: requests by foreign nationals
from countries on the Sensitive and Other Designated Countries List (SCL), to include
State Sponsors of Terrorism (SST) and Countries of Risk (COR), and Covered Foreign
Nations (CFN)2; access requests to a physical security area more restrictive than a Property
Protection Area (PPA); or access requests for sensitive subjects. In other situations, an
approved access request must not exceed four years in continuous duration.
For the purposes of this Order, continuous duration means a single uninterrupted
period. However, access requests can only be valid for the duration of the lawful
immigration status of the foreign national regardless of the length of the access request. If
the foreign national requesting access has multiple country affiliations, the requirements are
applied based on the country that has the most associated restrictions as identified in this
Order based on country category (SST, COR, CFN, or Other Designated Country).
A determination of access approval is required before each access request is granted
and must ensure that any identified risk to the Government associated with the access
granted has been appropriately evaluated and mitigated, including a review against
the Science and Technology (S&T) Risk Matrix. All access approvals must be made
by U.S. citizens, be valid for the duration of the access request, and be documented in
FACTS no later than the first day of access.
a. Access Request. Each foreign national access request must include
the following items:
(1) Identification of the information or technology(ies) to be accessed, and
whether considered a sensitive subject as defined by this Order.
(2) Identification of the area (e.g., GAA, PPA) to be accessed for all
physical access requests.
(3) Justification for the requested access, including specific activities or
involvement.
(4) Identification of the DOE/NNSA program or sub-element and its
mission advanced by the access request.
(5) Proposed start and end dates of access request which cannot exceed the
2 Refer to Section 4, subsection n for Prohibition on Admittance for Citizens or Agents of Covered Foreign Nations
(CFN)
6 DOE O 142.3C
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duration identified in paragraph 4 above [NOTE: Access requests can
only be valid for the duration of the lawful immigration status of the
foreign national regardless of the length of the access request].
(6) The Required Data Elements in Attachment 3, as applicable.
Section 4
b. Supplemental Foreign National Access Questionnaire. A Supplemental Foreign
National Access Questionnaire must be submitted and entered into FACTS in
support of all foreign national access requests for individuals affiliated with SST
or COR countries. The data fields for this questionnaire are defined in Attachment
3.
c. Curriculum Vitae (CV). A CV must be provided for all non-SST and non-COR
foreign nationals conducting research at laboratories and entered into FACTS.
CVs must include all employment activities from the age of 18 years and provide
all the foreign national’s science and technology specialties. CVs must also
include the current/accurate name of all academic institutions attended and all
degrees/diplomas earned. There should be no lapses in time over the past 10 years.
d. The DOE office or contractor responsible must provide the following statement to
each foreign national who requires a curriculum vitae (CV) or equivalent
document and is requesting access. This statement must be signed by the foreign
national, certifying that all information provided is complete and accurate.3
I, [Full Name and Title], certify to the best of my knowledge and
belief that the information provided by me in a CV or equivalent
document and related to my immigration status is true, complete,
and accurate. I understand that any false, fictitious, or fraudulent
information, misrepresentations, half-truths, or omissions of any
material fact may subject me to criminal, civil or administrative
penalties for fraud, false statements, false claims or otherwise. (18
U.S.C. §§ 287, 1001, and 1031 and 31 U.S.C. §§ 3729-3733 and
3801- 3812). I further understand and agree that (1) the statements
and representations made herein are material to the U.S.
Department of Energy’s (DOE) decision to provide access to
DOE/NNSA sites, information or technology; and (2) I have a
responsibility to update the information provided should
circumstances change which impact such information.
Signature: [Full Name and Title]
Date:
e. FACTS Data Entry and Updates. The Supplemental Foreign National Access
3 A new review, based on the additional data elements required by Attachment 3, for individuals with existing access
approvals at the time of publication of this Order is not required. These individuals will need to provide the data
elements required by Attachment 3 at the time of their next access authorization renewal.
DOE O 423.1C 7
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Questionnaire or CV, as required in 4.b and 4.c, respectively, must be entered in
electronic form into the FACTS database.
(1) The DOE office or contractor responsible shall require foreign nationals to
provide information on changes in employment within 30 days of such a
change.
(2) Prior to access being granted: If the responsible DOE office or contractor
determines or becomes aware of additional information associated with
the foreign national requesting access that is materially relevant to the
risk-based process described in this Order, the access request for such
foreign national must not be approved until the additional information is
considered as part of the review of the request for access.
(3) After initial access is granted: If the responsible DOE office or contractor
determines or becomes aware of additional information associated with the
foreign national that is materially relevant to the risk-based process
described in this Order, the foreign national’s access must be reviewed
based on that additional information and the responsible DOE office or
contractor must determine within 30 days whether to suspend, revoke, or
continue the current access. If access is suspended, the responsible DOE
office or contractor has 45 additional days to make a final decision to
revoke or continue the access.
Section 5
(4) For the situations described in (2) and (3) above, the DOE office or
contractor responsible shall consult with the cognizant office within the
Office of Intelligence and Counterintelligence prior to making any final
determinations.
(5) To the extent that the responsible DOE office or contractor determines that
any misrepresentation or omission described in (1), (2), or (3) above was
deliberate or intentional, the access for the foreign national may be denied
or revoked.
f. Site Security Plan (SSP). The SSP must include the requirements and procedures
used to process foreign national access requests at the site. The SSP, as approved
by the Officially Designated Federal Security Authority (ODFSA), must include
requirements to ensure:
(1) appropriate documentation describing the process for application of the
exemptions listed in this Order, particularly the exemption in paragraph
3.c.(2)(6) allowing information exchanges with DOE employees and
contractors outside of the individual’s duty station;
(2) appropriate delegation of approval authority to the site management
official or laboratory director, and any related procedures;
(3) that appropriate export control and technology transfer reviews, and
8 DOE O 142.3C
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determinations of export license requirements, are conducted;
(4) that nationals of state sponsors of terrorism (SST) do not host other
foreign nationals;
(5) that nationals of countries of risk (COR) do not host other nationals of
CFN, CORs, SSTs, or other designated countries on the Sensitive and
Other Designated Countries List;
(6) coordination with designated Counterintelligence (CI) and Intelligence
(IN) elements;
(7) site-specific subject matter expert (SME) reviews, escort, and host
requirements;
(8) that the span of control of an individual host is reasonable (e.g., limit on
the number of foreign nationals being hosted by a single individual); and,
(9) that nationals of CFNs, CORs, SSTs, or other designated countries on the
Sensitive and Other Designated Countries List may not serve as the direct
supervisor to a cleared contractor employee, absent a waiver from the head
of the cognizant HQ departmental or field element.
g. Lawful Immigration Status, Citizenship, and Identity. Sufficient documentation of
immigrant or nonimmigrant status, citizenship, and identity is required for all
foreign nationals at DOE sites, facilities and laboratories to verify identity and
authority to work (when applicable for the activities involved) and to ensure that
the foreign national is eligible [i.e., in lawful immigration status, including those
who have received Delayed Action for Childhood Arrivals (DACA) status] to be
in the U.S. The lawful immigration status of foreign nationals must be valid for
the duration of the access request. There is an exception for intermittent periods by
foreign nationals entering the U.S. under the State Department Visa Waiver
Program, temporarily for business or pleasure, or for Canadian citizens who do not
require entrance visas.
h. Assignment of Approval Authority. Approvals for foreign national access must be
consistent with line management accountability requirements.
Section 6
(1) Headquarters Elements. Approval authority for foreign national access
to HQ activities and/or offices within HQ sites/organizations is the
head of the cognizant HQ departmental element. Heads of HQ
departmental elements may make final approval determinations for
access requests involving sensitive country nationals, non-sensitive
country nationals, and nationals of SSTs who are lawful permanent
residents (LPR) of the United States. The head of a HQ departmental
element may reassign his or her approval as appropriate. Further
reassignment of approval authority is not allowed. All reassignments
of approval authority must be in writing, and a copy must be provided
DOE O 423.1C 9
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to the Office of Environment, Health, Safety and Security. Heads of
HQ programs, staff, and support offices will be held accountable for
all decisions made by themselves or by those to whom they reassign
approval authority.
Access by foreign press to HQ sites is managed through the Office of
Public Affairs and involves official press interviews. Access by press
representatives from non-sensitive countries must be documented in
FACTS within two working days of access. Press representatives from
sensitive countries or representing press services of sensitive countries
require full pre-access reviews and approvals documented in FACTS
before access.
High-level protocol access is limited to meetings between the
Secretary of Energy, the Deputy Secretary, the Under Secretaries,
Program Secretarial Officers (PSOs) or other senior Departmental
officials, and foreign national representatives of foreign governments
or organizations of foreign governments in HQ buildings. The
Secretary, Deputy Secretary, Under Secretaries, and PSOs will
determine which senior Departmental officials within their
organizations are authorized to grant this access. Advance approval
reviews may be suspended if requested by these senior Departmental
managers subject to compliance with the security plans and procedures
developed for high-level protocol access to HQ sites. The duration of
high-level protocol access is limited to one day.
Documentation of these visitors in FACTS is required within one
working day of the access. Justification for this access must address
the protocol nature of the access.
(2) Field Sites. Approval authority and accountability for foreign national
access to a Departmental site and associated information and/or
technology is the head of the cognizant DOE field element for that site.
The head of the cognizant field element may make final approval
determinations for access requests involving sensitive country nationals,
non-sensitive country nationals, and nationals of SSTs that are LPRs.
The head of the cognizant field element may delegate approval authority
to the site management official or laboratory director after demonstration
of adequate procedures to handle these access requests. When the site
management official or laboratory official is not a U.S. citizen, the head of
the cognizant DOE field element may delegate approval authority and
accountability to only an individual who is a U.S. citizen. All site approval
authorities must be defined in the SSP. A site management official or
laboratory director may reassign approval authority to other U.S. citizen
employees within their organization. Further reassignment or delegation of
approval authority is not allowed. A site management official or
laboratory director must reassign or delegate approval authority in writing
and document this action in the SSP. Site management officials and
Section 7
10 DOE O 142.3C
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laboratory directors are accountable for all access approval decisions made
by themselves or by those to whom they have delegated or reassigned
approval authority.
i. Countries of Risk. Access requests for Country of Risk foreign nationals are
subject to the absolute prohibition described in Section 4.n. For requests not
subject to that prohibition, Country of Risk foreign nationals' access to certain
restricted technology or information as identified in the S&T Risk Matrix must
undergo an enhanced review process as described below in paragraphs 4.i.(1)-(3).
All proposed access requests in areas that are not identified as restricted in the
current S&T Risk Matrix can proceed with the access request review and approval
process as required by this Order.4
Requests for access to conduct research under a User Agreement at an Office of
Science, Critical Minerals and Energy Innovation, or Nuclear Energy User
Facility at a non-NNSA DOE laboratory are exempt from the review requirements
related to the S&T Risk Matrix discussed below. All other requirements of this
Order apply to these access requests.
(1) A request for access is reviewed by the site, in coordination with the Head
of the cognizant DOE Field Element, to determine if the access request is
in an area identified as restricted in the current S&T Risk Matrix before
submitting the proposed access request through the standard access
request review and approval process promulgated by this Order. When an
access request is from a Country of Risk foreign national and in an area
identified as restricted in the current S&T Risk Matrix, the cognizant DOE
Field Element must agree to proceed with the enhanced review process.
(2) Absent this agreement, the proposed access request is not pursued any
further.
(3) When the Head of the cognizant DOE Field Element agrees to proceed
with the enhanced review process, a justification and clear description of
why the access request benefits the U.S. must be prepared. The access
request must then be submitted through the appropriate PSO and
Cognizant Secretarial Officer (CSO), with final approval/disapproval
being provided by the cognizant Under Secretary or their designee.
(4) Completion of specialized enhanced vetting conducted by the DOE Office
of Intelligence and Counterintelligence is required prior to final approval
of the access request. A copy of the request, along with the required
additional information, must be submitted to the cognizant local CI office
to support the review. Indices checks will be conducted as part of the
specialized enhanced vetting process; therefore, it is recommended the
4 A new review, based on the additional S&T Risk Matrix requirements, for individuals with existing access
approvals at the time of publication of this Order is not required. These individuals will be assessed against the
current S&T Risk Matrix requirements at the time of their next access authorization renewal.
DOE O 423.1C 11
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request be submitted 45 days prior to the start date of the access request.
(5) DOE may consider broad approvals for specific categories of these types
of access requests, such as those supported under government-to-
government agreements and in line with National Security Council policy
guidance, to ensure existing priorities are not unduly impeded. These
broad approvals will be determined by the cognizant Under Secretary or
their designee in consultation with the cognizant DOE Program Office.
Section 8
j. Nationals of State Sponsors of Terrorism. Access requests for nationals of State
Sponsors of Terrorism are subject to the absolute prohibition described in Section
4.n. For requests not subject to that prohibition, access requests for nationals of
SSTs who are not LPRs require approval by the HQ Departmental element or site
approval authority before final approval determination. Final approval authority is
held by the Secretary of Energy and can only be assigned to the Deputy Secretary,
Under Secretary for Nuclear Security/Administrator of the National Nuclear
Security Administration, Under Secretary of Energy, or Under Secretary for
Science. The Deputy Secretary or appropriate Under Secretary, in consultation
with the Office of Intelligence and Counterintelligence, will make the final
approval determination for these access requests. Subsequent access requests
extending currently approved and on-going access to a HQ or contractor site or
laboratory may be approved by the HQ Departmental element or contractor site or
laboratory approval authority. For nationals of SST that are LPRs, final approval
determination is at the HQ Departmental element or site approval authority level.
k. Indices Checks. Indices checks are coordinated by the Office of Intelligence and
Counterintelligence and shall be requested through the process of documenting
access requests in FACTS. Indices checks are valid for a period of two years from
the indices completion date, as documented in FACTS by the Office of
Intelligence and Counterintelligence. If the approved access request exceeds this
two-year period, updated indices checks are automatically requested through
FACTS prior to the current expiration date.
(1) The following access requests require completed indices checks prior to the
start of the foreign national’s access:
(a) All access requests by nationals of SSTs and CORs.
(b) All access requests to a physical security area are more restrictive
than a Property Protection Area (PPA).
(c) All access requests by all other sensitive country nationals to the
DOE/NNSA national laboratories, sites, information or
technologies.4 [NOTE: The indices check for requests by other
sensitive country nationals for access to conduct research under a
User Agreement at an Office of Science, Critical Minerals and
Energy Innovation, or Nuclear Energy User Facility at a non-
NNSA DOE laboratory can be completed after access is granted.]
12 DOE O 142.3C
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(2) All access requests for sensitive subjects. [NOTE: The indices check for
access requests by non-sensitive nationals for sensitive subjects at sites
with no classified work can be completed after access is granted.]
(3) Indices checks are not required for non-sensitive country national’s access
to non-sensitive subjects in a PPA or less restrictive areas.
Section 9
For access requests that require completion of indices checks prior to the start of
foreign national access, the request must be documented in FACTS in sufficient
time to complete the indices checks. It is recommended that the request be entered
into FACTS at least 45 days prior to the start date of the request to ensure
adequate time for completion of indices checks. The approval authority may
request a counterintelligence consultation in lieu of completion of the indices
checks. Such requests will require approval from the head of the DOE field
element and Senior Counterintelligence Officer (SCIO) and their agreement that
there are exceptional or exigent circumstances justifying the request. A
consultation may not be used for an access request that is for employment
purposes. For requests involving nationals of SSTs or Country of Risk foreign
national access to restricted technology or information as identified in the S&T
Risk Matrix, counterintelligence consultations may not be utilized until 60 days
after requests are documented in FACTS. Counterintelligence consultations may
not be employed as a standard alternative to indices checks. If there are valid
indices checks for the foreign national documented in FACTS, the indices checks
will be considered completed upon documentation of the request in FACTS using
the existing FACTS biographical record for that foreign national.
l. Documentation. FACTS is the Department’s official national database on
unclassified foreign national access requests. Access to FACTS is limited to U.S.
citizens. All required information regarding access requests that require
documentation, as detailed in this Order, must be entered into FACTS.
(1) Closeout Information. Information documenting the final status of access
requests must be entered into FACTS within 15 days after the last day of
access. This information includes the closeout status, closeout comments,
and actual start and end dates for access that have taken place. Closeout
statuses include: Completed, Canceled Before or After Approval, Denied,
or No Show.
(2) SME reviews, when conducted in compliance with SSP requirements,
must be documented in FACTS.
m. Restriction on Foreign National Supervision of Cleared Employees. Nationals of
CORs, SSTs, or other designated countries on the Sensitive and Other Designated
Countries List may not serve as the direct supervisor to a cleared contractor
employee, absent a waiver from the head of the cognizant HQ departmental or
field element.
(1) The head of the cognizant HQ departmental or field element will make the
DOE O 423.1C 13
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decision whether to grant or deny a waiver request through a standardized
process informed by a risk assessment provided by the DOE Office of
Intelligence and Counterintelligence. [NOTE: The granting of a waiver
does not mean that the foreign national supervisor may access classified
information derived from their supervision of the cleared contractor
employee and does not release the cleared contractor employee from all
requirements to protect classified material to which they have been
granted access.]
(2) Granted waivers are valid for a period of two years, at which point a new
waiver request should be submitted for reassessment.
n. Prohibition on Admittance for Citizens or Agents of Covered Foreign Nations
(CFN) to Specified Facilities (FY2025 NDAA Section 3112(c)).
Section 10
(1) Absolute Prohibition: Notwithstanding any other provision of this Order,
access by any citizen or agent of a 'Covered Foreign Nation' (People's
Republic of China, Russian Federation, Democratic People's Republic of
Korea, and Islamic Republic of Iran) to any of the following facilities
is absolutely prohibited and cannot be approved through any internal
administrative process of this Order:
(a) Any facility of a national security laboratory (i.e., Los Alamos
National Laboratory, Lawrence Livermore National Laboratory,
Sandia National Laboratories).
(b) Any nuclear weapons production facility.
(c) Any site that directly supports the protection, development,
sustainment, or disposal of technologies or materials related to the
provision of nuclear propulsion for United States naval vessels.
(d) Areas accessible to the general public at such facilities are exempt
from this prohibition.
(2) Statutory Waiver Process: Admittance under this statutory prohibition may
only occur if the Secretary of Energy (or, for NNSA-cognizant facilities,
the NNSA Administrator) grants a waiver on a case-by-case basis. Such a
waiver must include a written certification to the congressional defense
committees that the admittance is in the national security interest of the
United States. A statutory waiver, once granted and certified to Congress,
permits the individual to proceed with access; however, all other
applicable requirements of this Order (e.g., indices checks, host
responsibilities, site security plan compliance, duration limits not
superseded by the waiver terms) remain in effect.
14 DOE O 142.3C
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5. RESPONSIBILITIES.
a. Secretary of Energy.
(1) Establishes DOE policies, procedures, and requirements for foreign
national access to DOE sites, information or technologies.
(2) Assigns access approval authority to the Deputy Secretary and Under
Secretaries for requests for access by nationals of SSTs, consistent with
the policies and requirements of this Order.
(3) Grants statutory waivers for access by citizens or agents of Covered
Foreign Nations to specified facilities, and ensures certification to
congressional defense committees, in accordance with FY2025 NDAA
Section 3112(c), as detailed in Section 4.n of this Order.
b. Administrator of the National Nuclear Security Administration (NNSA).
(1) Ensure that NNSA employees comply with their responsibilities under this
Order.
(2) Grants statutory waivers for access by citizens or agents of Covered
Foreign Nations to NNSA-cognizant specified facilities, and ensure
certification to congressional defense committees, in accordance with
FY2025 NDAA Section 3112(c), as detailed in Section 4.n of this Order.
(3) Establishes Administration-specific policies, unless disapproved by the
Secretary, pursuant to section 3212(d) of Public Law 106-65, consistent
with this Order and all applicable statutory requirements.
c. Under Secretaries.
(1) Approve/disapprove foreign national access requests based on the current
S&T Risk Matrix or delegate this authority per paragraph 4.i.(2).
(2) Determine when a broad approval applies to foreign national access
requests as discussed in section 4.i.(2).
(3) Provide the final determination with respect to authorizing the access of a
foreign national if the Cognizant Secretarial Officer (CSO) and the
Director of Intelligence and Counterintelligence do not agree on the
assessment of the potential risk or the proposed mitigation factors related
to the access request.
Section 11
d. Under Secretary for Science.
(1) Maintains and updates, as needed, the definition of sensitive subjects for
the purposes of this Order, in consultation with the Under Secretary of
Energy and with the concurrence of the Under Secretary for Nuclear
DOE O 423.1C 15
3-31-2026
Security.
(2)Convenes a working group consisting of representation from each of the
Cognizant Secretarial Officers that will coordinate the maintenance of the
definition of sensitive subjects for the purposes of this Order and conduct
an annual review of the definition.
e. Cognizant Secretarial Officers (CSOs).
(1) Ensure that facilities under their cognizance have implemented this Order.
(2) Notify contracting officers of affected site/facility management
contractors to incorporate the CRD of this Order into their contracts.
(3) Ensure that procurement requests for new non-site/non-facility
management contracts require inclusion of the CRD to this Order in the
resulting contracts, if appropriate.
(4) Ensure systematic review of field and local site approvals for which the
CSO has responsibility to ensure that program-specific guidance is
followed, corrective action is taken as appropriate, and line management
responsibilities associated with the presence of foreign nationals are met.
(5) Review and concur/non-concur on foreign national access requests based
on the current S&T Risk Matrix.
(6) Participate in the maintenance and annual review of the sensitive subject
definition.
(7) Provide a determination with respect to authorizing the access of a foreign
national if the cognizant Head of Field Element does not agree with the
assessment of the potential risks by the cognizant field or HQ
counterintelligence officer. This determination will be made in
coordination with the Director, Office of Intelligence and
Counterintelligence, and provide any mitigation factors that may be
needed for this foreign national access request.
(8) Coordinate with the Deputy Director, Counterintelligence Directorate, and
maintenance of the Organizations of Concern (OOC) list.
f. Program Secretarial Officers (PSOs). Review and concur/non-concur on
foreign national access requests based on the current S&T Risk Matrix.
g. Heads of Headquarters Departmental Elements.
(1) Review procurement requests for new non-site/non-facility management
contracts and, if appropriate, ensure that the CRD of this Order is included
in the contracts.
(2) Serve as the foreign national access requests approval authorities for HQ
16 DOE O 142.3C
3-31-2026
activities and/or offices within their organizations and may reassign
approval authority to other U.S. citizen employees, as appropriate.
(3) Develop and implement operating procedures for approving foreign
national access to HQ program and contractor personnel, sites,
information and organizations in compliance with the requirements of this
Order.
(4) Designate points of contact (POCs) for foreign national access and provide
contact information to the Office of Environment, Health, Safety and
Security.
(5) Provide guidance and ensure oversight support to HQ program managers
and field elements regarding foreign national access to potentially
sensitive subjects, technologies, and information in unclassified program
activities.
(6) Ensure a systematic and effective process to provide managers, planners,
and hosts with appropriate guidance regarding technologies and
information that could lead to sensitive or export-controlled areas, and to
ensure that sensitive or export-controlled technologies and information are
properly identified.
Section 12
(7) Direct contracting officers in their organizations to incorporate the CRD of
this Order into all contracts that may involve foreign national access.
(8) Determine if proposed HQ foreign national access requests require an
enhanced review process based on the current S&T Risk Matrix and
submit such requests as appropriate.
h. Heads of Field Elements.
(1) Review procurement requests for new non-site/non-facility management
contracts and, if appropriate, ensure that the requirements of the CRD of
this Order are included in the contracts.
(2) Serve as approval authorities for foreign national access requests to the
DOE field element and may reassign approval authority to other U.S.
citizen employees, as appropriate.
(3) Serve as the approval authority for foreign national access requests to sites
under their cognizance and delegate, where appropriate, such approval
authority to site management officials and laboratory directors under their
cognizance.
(4) Designate POCs for foreign national access and provide contact
information to the Office of Environment, Health, Safety and Security.
(5) Provide a determination with respect to authorizing the access of a foreign
DOE O 423.1C 17
3-31-2026
national if the designated approval authority does not agree with the
assessment of the potential risks by the cognizant field or HQ
counterintelligence officer. This determination will be made in
coordination with the cognizant field or HQ counterintelligence officer
and will provide any mitigation factors that may be needed for this foreign
national access request.
(6) Incorporate all CSO guidance into local management processes for
approving foreign national access to field element sites, information, and
organizations.
(7) When a CI consultation is requested by the hosting site in lieu of indices,
coordinate with the Senior Counterintelligence Officer (SCIO) to
determine whether there are exceptional or exigent circumstances
justifying the request.
(8) In coordination with the hosting site, determine if proposed foreign
national access requests require an enhanced review process based on the
current S&T Risk Matrix and, where appropriate, submit such requests.
(9) Heads of government-owned, government-operated (GOGO) sites and
sites not under the cognizance of a DOE field element fulfill the
responsibilities of the Heads of DOE Field Elements and Contracting
Officers as appropriate.
i. Heads of Hosting Sites.
(1) Consistent with the assignment of approval authority through the line
management chain, serve as approval authorities for foreign national
access activities and programs at their sites.
(2) Implement the foreign national access activities consistent with guidance
and direction from the appropriate DOE element with direct responsibility
for program performance.
(3) Designate POCs for foreign national access activities, and provide contact
information to the Office of Environment, Health, Safety and Security.
(4) Ensure that guidance is issued and followed, corrective actions are
implemented as appropriate, and responsibilities associated with the
presence of foreign nationals are met.
(5) Ensure systematic, effective processes to provide managers, planners, and
hosts with appropriate guidance regarding technologies and information
that could lead into sensitive or export-controlled areas, and to ensure that
sensitive or export-controlled technologies and information are identified.
Section 13
(6) In coordination with the cognizant field element, determine if proposed
foreign national access requests require an enhanced review process based
18 DOE O 142.3C
3-31-2026
on the current S&T Risk Matrix and, where appropriate, submit such
requests.
j. Hosts of Foreign Nationals. The DOE office hosting a foreign national is
responsible for the conduct and activities of the foreign national they host,
and must ensure the following requirements are met:
(1) Individual hosts are identified to the foreign national as their POC.
(2) Compliance with all requirements for access approval and conduct,
including timely, complete, and accurate information for FACTS,
compliance with SSP requirements, program sponsorship, and notification
to workers regarding requirements as appropriate.
(3) Suspicious activities are reported in accordance with local reporting
requirements.
(4) The span of control of an individual host is reasonable (e.g., limit on the
number of foreign nationals being hosted by a single individual) to
effectively meet these requirements.
(5) The DOE office must ensure that individuals identified as hosts meet the
following requirements:
(a) Foreign nationals hosting other foreign nationals must be DOE
employees.
(b) Nationals of state sponsors of terrorism (SST) may not host other
foreign nationals.
(c) Nationals of countries of risk (COR) may not host other nationals
of CORs, SSTs, or other designated countries on the Sensitive and
Other Designated Countries List.
(d) Have technical competence (i.e., knowledge of the work) to
understand the activities that the foreign national will be
performing.
(e) Understand their responsibilities and the processes by which they
are carried out.
(6) The DOE office must provide the following information to the foreign
nationals being hosted:
(a) The terms and conditions of access approval, including restrictions
and requirements for access, requirements to notify the host of
changes in name, immigrant/nonimmigrant status, and other
information as required.
DOE O 423.1C 19
3-31-2026
(b) The requirement to notify the host responsible of any civil or
criminal problems that could affect their status and association with
DOE.
(c) That the failure to provide appropriate documentation when
required, or providing fraudulent documentation, will result in
suspension of access approval, removal from the site, and possible
cancellation of future access.
k. Escorts.
(1) Ensure that foreign nationals working or traveling within a site are escorted
when required, as identified by the SSP, to ensure that there is no
unauthorized access.
(2) Comply with all requirements for escorts as identified in the SSP.
l. Director, Office of Environment, Health, Safety and Security.
(1) Develops the policy baseline and incorporates operational requirements into
DOE-wide guidance for foreign national access activities.
(2) Establishes and chairs foreign national access working groups as required.
(3) Ensures that HQ program, staff, and Secretarial Office policy requirements
for foreign national access approvals are incorporated into the foreign
national access policy.
(4) Defines, develops, and manages FACTS capabilities to provide operational
and analytical support and accountability.
(5) Develops and implements user training for FACTS.
(6) Provides policy and technical assistance and support to HQ and field
elements.
Section 14
(7) Develops and coordinates testimony, internal and external reporting, and
responses to requests for information regarding the DOE foreign national
access activities.
(8) Develops security policy for the foreign national access approval process
consistent with U.S. and DOE national security policies and objectives.
(9) Provides information on the requirements of foreign national access policy
for inclusion in the Security Survey Program.
m. Director, Office of Intelligence and Counterintelligence.
(1) Supports the unclassified foreign national access approval process by
20 DOE O 142.3C
3-31-2026
analyzing and coordinating issues of counterintelligence with other Federal
agencies and provides general and specific advice on potential risks
associated with foreign national access requests to DOE elements.
(2) Consults the relevant CSO if the cognizant Head of Field Element does not
agree with the assessment of the potential risks by the cognizant field or HQ
counterintelligence officer or the proposed mitigation factors related to the
request.
(3) Consults the relevant Under Secretary and CSO if the CSO and the Director
of Intelligence and Counterintelligence do not agree on the assessment of
the potential risk or the proposed mitigation factors related to this access
request.
(4) Coordinates with the Office of Defense Nuclear Nonproliferation on the
maintenance of the Sensitive and Other Designated Countries List related to
nonproliferation and technology transfer.
(5) Maintains the Sensitive and Other Designated Countries List in
coordination with appropriate HQ offices, including, but not limited to, the
CSOs.
(6) As appropriate, consults with the Heads of Field Elements and other
cognizant Departmental Elements on the review of a foreign national access
request that requires an enhanced review process based on the current S&T
Risk Matrix.
n. Deputy Director, Counterintelligence Directorate, Office of Intelligence and
Counterintelligence.
(1) Identifies counterintelligence requirements applicable to the management of
unclassified access approval for foreign nationals to DOE sites, information,
or technologies.
(2) Provides advice to HQ approval authorities and supports field
counterintelligence officers with guidance on foreign national access issues.
(3) Ensures that local capability and expertise are available to provide effective
counterintelligence advice to local approval authorities regarding access
approval requests.
(4) Coordinates the external indices checks process with the appropriate U.S.
Government agencies.
(5) Documents and maintains DOE-wide information on requests for and
completion of indices checks.
(6) Develops requirements and processes for specialized enhanced vetting for
the review of certain foreign national access requests based on the current
DOE O 423.1C 21
3-31-2026
S&T Risk Matrix.
(7) Pursuant to paragraph 4.h, advises the Secretary, Deputy Secretary, and
Under Secretaries regarding access requests involving nationals of countries
identified as SSTs, as requested.
(8) Develops and maintains, in coordination with the CSOs, a tiered list of
Organizations of Concern (OOC).
o. Headquarters and Field Counterintelligence Officers.
(1) Review requests for foreign national access approval for CI and
counterterrorism implications involving countries on the Sensitive and
Other Designated Countries List by:
(a) Facilitating indices checks as required by this Order;
Section 15
(b) Advising local approval authorities, prior to access
approval, on all Country of Risk foreign national access
requests; and
(c) Advising local approval authorities, prior to access approval, on
foreign national access requests not at user facilities involving
other designated countries on the Sensitive and Other
Designated Countries List.
(2) Ensure the OOC list is used when reviewing all foreign national access
requests covered by this Order.
(3) At the request of the hosting site, provide CI consultations to the approval
authority, or to his or her assignee(s), to evaluate foreign national access
requests in the absence of completed indices checks required prior to
access, and document consultations in FACTS.
(4) Conduct briefings and debriefings of hosts, sponsors, and escorts of foreign
nationals.
p. Deputy Administrator, Defense Nuclear Nonproliferation.
(1) Analyzes and develops policy guidance for the foreign national access
process in the areas of export control, technology transfer, and
nonproliferation.
(2) Provides advice and guidance to DOE elements on export controls,
technology transfer, and nonproliferation issues related to potential and
actual foreign national access approvals.
(3) Performs specific subject matter export control, technology transfer, and
nonproliferation reviews of foreign national access requests, as requested,
22 DOE O 142.3C
3-31-2026
and ensures that these reviews are documented in FACTS.
q. Assistant Secretary for Policy and International Affairs. As the DOE point of
contact with the Department of State in international organizations, provides
advice and information to the Office of Environment, Health, Safety and Security
concerning the policies and procedures promulgated in this Order.
r. General Counsel. Provides review and advice on all legal issues relating to
approval of unclassified foreign national access to DOE facilities and information.
s. NNSA Office of General Counsel. Provides review and advice on all legal issues
relating to approval of unclassified foreign national access to NNSA facilities and
information.
t. Chief Information Officer (CIO). Drafts policy for issuance by the Secretary of
Energy or Deputy Secretary regarding protective measures required for foreign
national cyber security access approval, whether onsite or by remote access.
u. Deputy Administrator for Naval Reactors. In accordance with the responsibilities
and authorities assigned by Executive Order 12344, codified at Title 50 U.S.C.
sections 2406 and 2511, and to ensure consistency through the joint Navy/DOE
organization of the Naval Nuclear Propulsion Program, implements and oversees
requirements and practices pertaining to this Order for activities under the Deputy
Administrator’s cognizance, as deemed appropriate.
v. Contracting Officers.
(1) After notification by the appropriate program official, incorporate the
CRD of this Order into affected existing contracts via the laws,
regulations, and DOE Directives clauses of the contracts.
(2) Assist originators of procurement requests who want to incorporate the
CRD of this Order in new non-site/non-facility management contracts, as
appropriate.
(3) Provide notification of DOE’s determination related to access requests
associated with the S&T Risk Matrix.
6. INVOKED STANDARDS. This Order does not invoke any DOE technical standards or
industry standards as required methods. Note: DOE O 251.1D, Appendix J provides a
definition for “invoked technical standard.”
Section 16
7. REFERENCES. Find DOE directives online at www.directives.doe.gov.
a. Title 10, Code of Federal Regulations, Nuclear Regulatory Commission, Export
and Import of Nuclear Equipment and Material, Part 110.
b. Title 10, Code of Federal Regulations, Energy, Chapter III, Assistance to Foreign
Energy Activities, Part 810.
DOE O 423.1C 23
3-31-2026
c. Title 15, Code of Federal Regulations, Commerce and Foreign Trade, Export
Administration Regulations, Parts 730-744.
d. Title 22, Code of Federal Regulations, Chapter I, Department of State,
International Traffic in Arms Regulations, Parts 120-130.
e. Servicemember Quality of Life Improvement and National Defense Authorization Act for
Fiscal Year 2025, Public Law 118-159 (December 23, 2024), Sections 3112 and 6432.
f. Presidential Decision Directive 61, Energy Department Counterintelligence (U),
dated February 1999. This document is classified (Confidential). For more
information, contact the Office of Intelligence and Counterintelligence.
g. Homeland Security Presidential Directive-2, Combating Terrorism Through
Immigration Policies, dated October 29, 2001.
h. National Security Decision Directive 189, National Policy on the Transfer of
Scientific, Technical and Engineering Information, dated September 21, 1985.
i. National Security Presidential Memorandum on United States Government-
Supported Research and Development National Security Policy (NSPM-33) dated
January 14, 2021.
j. 5 U.S.C 552a, Privacy Act of 1974, as amended.
k. DOE O 206.1, Department of Energy Privacy Program, current version.
l. DOE P 485.1, Foreign Engagements with DOE National Laboratories, current
version.
m. DOE O 142.2, Voluntary Offer Safeguards Agreement and Additional Protocol
with the International Atomic Energy Agency, current version.
n. DOE O 205.1, Department of Energy Cybersecurity Program, current version.
o. DOE O 243.1 Records Management Program, current version.
p. DOE O 251.1, Departmental Directives Program, current version.
q. DOE O 470.1, Safeguards and Security Program Operations Management, current
version.
r. DOE O 470.6, Technical Security Program, current version.
s. DOE O 471.7, Controlled Unclassified Information, current version.
t. DOE O 473.1, Physical Protection Program, current version.
u. DOE O 473.2, Protective Force Operations, current version.
24 DOE O 142.3C
3-31-2026
v. DOE O 475.1, Counterintelligence Program, current version.
8. DEFINITIONS. Terms used for the purpose of this Order are defined in Attachment 2.
9. CONTACT. Questions concerning this Order should be addressed to the Office of
Environment, Health, Safety and Security at 301-903-0352.
BY ORDER OF THE SECRETARY OF ENERGY:
JAMES P. DANLY
Deputy Secretary
DOE O 142.3C Attachment 1 – CRD, Contractors Only
3-31-2026 Page 1-1
ATTACHMENT 1
CONTRACTOR REQUIREMENTS DOCUMENT
DOE O 142.3C, UNCLASSIFIED FOREIGN NATIONAL ACCESS PROGRAM
This Contractor Requirements Document (CRD) and Attachment 2 (Definitions) establish
requirements and provide information for Department of Energy (DOE) and National Nuclear
Security Administration (NNSA) contractors, whose contracts involve foreign national physical or
remote access to DOE/NNSA-owned or leased sites, information, or technologies.
Regardless of the performer of the work, the contractor is responsible for complying with the
requirements of this CRD. The contractor is responsible for flowing down the requirements of this
CRD to subcontractors at any tier to the extent necessary to ensure the contractor’s compliance
with the requirements.
Section 17
1. PURPOSE. The Department of Energy (DOE) unclassified mission focuses on the critical
challenges of our time, for both the country and the world. While much of this unclassified
mission work is performed in collaboration with the international community, the federal
government simultaneously holds a responsibility to protect its assets and deny
unauthorized access to sites, information, or technologies. This program defines the
requirements for unclassified foreign national access to DOE sites, information, or
technologies by establishing requirements for the following:
a. A risk-based review and approval process for foreign national access consistent
with United States (U.S.) law; export control regulations; national and economic
security; and DOE program-specific policies, requirements, and objectives.5
b. A process for documenting and tracking foreign national access to DOE sites and
access to DOE information or technologies.
2. EXEMPTIONS.
a. Unclassified events and activities outside the U.S. or its territories.
b. Dual citizens, only if one citizenship is U.S. citizenship.
c. Requests for access to information that is not a sensitive subject as defined by this
Order and in accordance with applicable procedures (i) is already available to the
public or (ii) has been documented to be published and shared broadly within the
scientific community. [NOTE: Physical access to a site will follow normal site
security procedures, including the applicable requirements of this Order.]
5 This Order serves as DOE’s policy to assess the counterintelligence risk that covered visitors or covered assignees
pose to the research or activities undertaken at the National Laboratories, as required by Sec. 6432 of the
Servicemember Quality of Life Improvement and National Defense Authorization Act for Fiscal Year 2025, Public
Law 118-159 (December 23, 2024) (FY2025 NDAA). In addition, any legal prohibition on admittance including under
section 3112(c) of the FY2025 NDAA must be applied first in accordance with applicable DOE guidance before
proceeding with any request under this Order.
Attachment 1 – CRD, Contractors Only DOE O 142.3C
Page 1-2 3-31-26
d. Requests for access to information (e.g., technical specifications, project data,
research results) by foreign nationals from countries that are formally part of a
specific DOE program-sponsored international collaboration project under a DOE or
U.S. Government-level bilateral or multilateral international agreement (e.g., Deep
Underground Neutrino Experiment at Long-Baseline Neutrino Facility, Proton
Improvement Plan-II, Vera C. Rubin Observatory (formerly the Large Synoptic
Survey Telescope (LSST)), Dark Energy Search Collaboration). This applies only
to information generated under these projects and agreed to be shared among the
participants. [NOTE: Physical access to a site that would otherwise be within this
exemption will follow normal site security procedures, including the applicable
requirements of this Order.]
e. Information exchanges conducted remotely by HQ program offices and supporting
laboratory and contractor personnel, in direct support of DOE/NNSA
nonproliferation, counterproliferation, counterterrorism. [NOTE: Physical access to
a site that would otherwise be within this exemption will follow normal site security
procedures, including the applicable requirements of this Order.]
Section 18
f. Unclassified information exchanges conducted by DOE employees and supporting
laboratory and contractor personnel who are foreign nationals approved in FACTS
under a specific DOE-related work assignment. These individuals can participate in
virtual and in-person meetings, discussions, and phone calls with other DOE federal
and contractor employees outside of their duty station to perform the duties
specified in their FACTS assignment. [NOTE: Physical access to a site that would
otherwise be within this exemption will follow normal site security procedures,
including the applicable requirements of this Order.]
g. Public events held on or off DOE sites.
h. Certain activities within General Access Areas (GAA):
(1) Personal visits.
(2) Third-party events (i.e., not related to the DOE mission) hosted at the site.
(3) Access by foreign national delivery, service, and vendor personnel (Note: Also
exempt in other areas outside of GAA if fully escorted and compliant with other
relevant security requirements).
(4) Foreign nationals performing construction activities.
i. Foreign national emergency response and medical personnel who require access for
emergencies.
j. Access by foreign nationals 17 years of age or younger who are involved in non-
work-related activities.
DOE O 142.3C Attachment 1 – CRD, Contractors Only
3-31-2026 Page 1-3
k. International Atomic Energy Agency (IAEA) inspections, as defined in the
“Agreement between the United States and the IAEA for the Application of
Safeguards in the United States.”
l. Mutual Defense Agreement (MDA) visits do not fall under this Order; MDA visits
follow the applicable Administrative Arrangements and DOE O 470.1.
3. REQUIREMENTS. Foreign national access requests to DOE sites, information, or
technologies will be reviewed based on all the information provided and any potential
impacts on site or program operations. All access requests must include all applicable data
elements outlined below and any additional information required by the Foreign Access
Central Tracking System (FACTS). Access requests involving the following must not
exceed two years continuous duration from the start date: requests by foreign nationals
from countries on the Sensitive and Other Designated Countries List (SCL), to include
State Sponsors of Terrorism (SST) Countries of Risk (COR) and Covered Foreign Nations
(CFN)6; access requests to a physical security area more restrictive than a Property
Protection Area (PPA); or access requests for sensitive subjects. In other situations, an
approved access request must not exceed four years in continuous duration. For the
purposes of this Order, continuous duration means a single uninterrupted period. However,
access requests can only be valid for the duration of the lawful immigration status of the
foreign national regardless of the length of the access request. If the foreign national
requesting access has multiple country affiliations, the requirements are applied based on
the country that has the most associated restrictions as identified in this Order based on
country category (State Sponsor of Terrorism, Country of Risk, Covered Foreign Nation, or
Other Designated Country).
A determination of access approval is required before each access request is granted and
must ensure that any identified risk to the Government associated with the access granted
has been appropriately evaluated and mitigated, including a review against the Science and
Technology (S&T) Risk Matrix. All access approvals must be made by U.S. citizens, are
valid for the duration of access request, and must be documented in FACTS no later than
the first day of access.
Section 19
a. Access Request. Each foreign national access request must include the following
items:
(1) Identification of the information or technology(ies) to be accessed, and
whether considered a sensitive subject as defined by this Order.
(2) Identification of the area(s) (e.g., GAA, PPA) to be accessed for all physical
access requests.
(3) Justification for the requested access, including specific activities or
involvement.
6 Refer to Section 4, subsection n for Prohibition on Admittance for Citizens or Agents of Covered Foreign Nations
(CFN )
Attachment 1 – CRD, Contractors Only DOE O 142.3C
Page 1-4 3-31-26
(4) Identification of the DOE/NNSA program or sub-element and its mission
advanced by the access.
(5) Proposed start and end date of access request which cannot exceed the
duration identified in paragraph 3 above (NOTE: Access requests can only
be valid for the duration of the lawful immigration status of the foreign
national regardless of the length of the access request).
(6) The Required Data Elements in Attachment 3, as applicable.
b. Supplemental Foreign National Access Questionnaire. A Supplemental Foreign
National Access Questionnaire must be submitted and entered into FACTS in
support of all foreign national access requests for individuals affiliated with SST or
COR countries. The data fields for this questionnaire are defined in Attachment 3.
c. Curriculum Vitae (CV). A CV must be provided for all non-SST and non-COR
foreign nationals conducting research at laboratories and entered into FACTS. CVs
must include all employment activities from the age of 18 years and provide all
foreign national’s science and technology specialties. CVs must also include the
current/accurate name of all academic institutions attended and all degrees/diplomas
earned. There should be no lapses in time over the past 10 years.
d. Foreign National Certification Statement. The DOE office or contractor responsible
must provide the following statement to each foreign national who requires a
curriculum vitae (CV) or equivalent document and is requesting access. This
statement must be signed by the foreign national, certifying that all information
provided is complete and accurate.
I, [Full Name and Title], certify to the best of my knowledge and belief
that the information provided by me in a CV or equivalent document
and related to my immigration status is true, complete, and accurate. I
understand that any false, fictitious, or fraudulent information,
misrepresentations, half-truths, or omissions of any material fact may
subject me to criminal, civil or administrative penalties for fraud, false
statements, false claims or otherwise. (18 U.S.C. §§ 287, 1001, and
1031 and 31 U.S.C. §§ 3729-3733 and 3801-3812). I further
understand and agree that (1) the statements and representations made
herein are material to the U.S. Department of Energy’s (DOE)
decision to provide access to DOE/NNSA sites, information or
technology; and (2) I have a responsibility to update the information
provided should circumstances change which impact such
information.
Signature: [Full Name and Title]
Date:
e. FACTS Data Entry and Updates. The Supplemental Foreign National Access
DOE O 142.3C Attachment 1 – CRD, Contractors Only
3-31-2026 Page 1-5
Questionnaire or CV, as required in 3.b and 3.c, respectively, must be entered in
electronic form into the FACTS database.
(1) The contractor shall require foreign nationals to provide information on
changes in employment within 30 days of such a change.
Section 20
(2) Prior to access being granted: If the contractor determines or becomes aware
of additional information associated with the foreign national requesting
access that is materially relevant to the risk-based process described in this
CRD, the access request for such foreign national must not be approved until
the additional information is considered as part of the review of the request
for access.
(3) After initial access is granted: If after initial access is granted, the contractor
determines or becomes aware of additional information associated with the
foreign national that is materially relevant to the risk-based process
described in this CRD, the foreign national’s access must be reviewed based
on that additional information and the contractor must determine within 30
days to either suspend, revoke, or continue the current access. If access is
suspended, the contractor has 45 additional days to make a final decision to
revoke or continue the access.
(4) For the situations described in (2) and (3) above, the contractor shall consult
with the cognizant office within the Office of Intelligence and
Counterintelligence prior to making any final determinations.
(5) To the extent that the contractor determines that any misrepresentation or
omission described in (1), (2), or (3) above, was deliberate or intentional, the
access for the foreign national may be denied or revoked.
f. Site Security Plan (SSP). The SSP must include the requirements and procedures
used to process foreign national access requests at the site. The SSP, as approved by
the Officially Designated Federal Security Authority (ODFSA), must include
requirements to ensure:
(1) appropriate documentation describing the process for application of the
exemptions listed in this Order, particularly the CRD exemption in paragraph
2.f allowing information exchanges with DOE employees and contractors
outside of the individual’s duty station;
(2) appropriate delegation of approval authority to the site management official
or laboratory director, and any related procedures;
(3) that appropriate export control and technology transfer reviews, and
determinations of export license requirements, are conducted;
(4) that nationals of state sponsors of terrorism (SST) do not host other foreign
nationals;
Attachment 1 – CRD, Contractors Only DOE O 142.3C
Page 1-6 3-31-26
(5) that nationals of countries of risk (COR) do not host other nationals of CFNs,
CORs, SSTs or other designated countries on the Sensitive and Other
Designated Countries List;
(6) coordination with designated Counterintelligence (CI) and Intelligence (IN)
elements;
(7) site-specific subject matter expert (SME) reviews, escort, and host
requirements;
(8) that the span of control of an individual host is reasonable (e.g., limit on the
number of foreign nationals being hosted by a single individual); and
(9) that nationals of CFNs, CORs, SSTs, or other designated countries on the
Sensitive and Other Designated Countries List may not serve as the direct
supervisor to a cleared contractor employee, absent a waiver from the head
of the cognizant HQ departmental or field element.
g. Lawful Immigration Status, Citizenship, and Identity. Sufficient documentation of
immigrant or nonimmigrant status, citizenship, and identity is required for all
foreign nationals at DOE sites, facilities and laboratories to verify identity and
authority to work (when applicable for the activities involved) and to ensure that the
foreign national is eligible (in lawful immigration status, including those who have
received Delayed Action for Childhood Arrivals (DACA) status) to be in the
Section 21
U.S. The lawful immigration status of foreign nationals must be valid for the
duration of the access request. There is an exception for intermittent periods by
foreign nationals entering the U.S. under the State Department Visa Waiver
Program, temporarily for business or pleasure, or for Canadian citizens who do not
require entrance visas.
h. Assignment of Approval Authority. Approvals for foreign national access must be
consistent with line management accountability requirements.
Field Sites. Approval authority and accountability for foreign national access to a
Departmental site and associated information or technology is the head of the
cognizant field element for that site. The Head of the cognizant field element may
make final approval determinations for access requests involving sensitive country
nationals, non-sensitive country nationals, and nationals of SSTs that are lawful
permanent residents (LPRs). The head of the cognizant field element may delegate
approval authority to the site management official or laboratory director after
demonstration of adequate procedures to handle these access requests. When the site
management official or laboratory official is not a U.S. citizen, the head of the
cognizant DOE field element may delegate approval authority and accountability to
only an individual who is a U.S. citizen. All site or facility approval authorities
must be defined in the SSP.
DOE O 142.3C Attachment 1 – CRD, Contractors Only
3-31-2026 Page 1-7
A site management official or laboratory director may reassign approval authority
to other U.S. citizen employees within their organization. Further reassignment or
delegation of approval authority is not allowed. A site management official or
laboratory director must reassign or delegate approval authority in writing and
document this action in the SSP. Site management officials and laboratory directors
are accountable for all access approval decisions made by themselves or by those to
whom they have delegated or reassigned approval authority.
i. Country of Risk. Country of Risk foreign nationals’ access to certain restricted
technology or information as identified in the Science and Technology (S&T) Risk
Matrix must undergo an enhanced review process as described below in paragraphs
(1)-(3). All proposed access requests in areas not identified as restricted in the S&T
Risk Matrix can proceed with the access review and approval process as required by
this Order.7
j. Requests for access to conduct research under a User Agreement at an Office of
Science, Critical Minerals and Energy Innovation, or Nuclear Energy User Facility
at a non-NNSA DOE laboratory are exempt from the review requirements related to
the S&T Risk Matrix discussed below. All other requirements of this Order apply to
these access requests.
(1) A request for access is reviewed by the site, in coordination with the Head
of the cognizant DOE Field Element, to determine if the access request is in
an area identified as restricted in the current S&T Risk Matrix before
submitting the proposed access request through the standard access request
review and approval process promulgated by this Order. When an access
request is from a Country of Risk foreign national and in an area identified
as restricted in the current S&T Risk Matrix, the cognizant DOE Field
Element must agree to proceed with the enhanced review process. Absent
this agreement the proposed access request is not pursued any further.
Section 22
(2) When the Head of the cognizant DOE Field Element agrees to proceed with
the enhanced review process, a justification and clear description of why the
access request benefits the U.S. must be prepared. The access request must
then be submitted through the appropriate Program Secretarial Officer
(PSO) and Cognizant Secretarial Officer (CSO), with final
approval/disapproval being provided by the cognizant Under Secretary or
their designee.
(3) Completion of specialized enhanced vetting conducted by the DOE Office of
Intelligence and Counterintelligence (IN) is required prior to final approval
of the access request. A copy of the request, along with the required
additional information, must be submitted to the cognizant local CI office to
support the review. Indices checks will be conducted as part of the
7 A new review, based on the additional S&T Risk Matrix requirements, for individuals with existing access approvals
at the time of publication of this Order is not required. These individuals will be assessed against the current S&T Risk
Matrix requirements at the time of their next access authorization renewal.
Attachment 1 – CRD, Contractors Only DOE O 142.3C
Page 1-8 3-31-26
specialized enhanced vetting process; therefore, it is recommended the
request be submitted 45 days prior to the start date of the access request.
(4) DOE may consider broad approvals for specific categories of these types of
access requests, such as those supported under government-to-government
agreements and in line with National Security Council policy guidance, to
ensure existing priorities are not unduly impeded. These broad approvals
will be determined by the cognizant Under Secretary or their designee in
consultation with the cognizant DOE Program Office.
k. Nationals of State Sponsors of Terrorism. Access requests for nationals of State
Sponsors of Terrorism are subject to the absolute prohibition described in Section
4.n. Access requests for nationals of SSTs who are not LPRs require approval by
the site approval authority before final approval determination. Final approval
authority is held by the Secretary of Energy and can only be assigned to the Deputy
Secretary, Under Secretary for Nuclear Security/Administrator of the National
Nuclear Security Administration, Under Secretary of Energy, or Under Secretary
for Science. The Deputy Secretary or appropriate Under Secretary, in consultation
with the Office of Intelligence and Counterintelligence, will make the final approval
determination for these access requests. Subsequent access requests extending
currently approved and on-going access to a contractor site or laboratory may be
approved by the contractor site or laboratory approval authority. For nationals of
SSTs that are LPRs, final approval determination is at the site approval authority
level.
l. Indices Checks. Indices checks are coordinated by the Office of Intelligence and
Counterintelligence and must be requested through the process of documenting
access requests in FACTS. Indices checks are valid for a period of two years from
the completion date, as documented in FACTS by the Office of Intelligence and
Counterintelligence. If the approved access request exceeds this two-year period,
updated indices checks are automatically requested through FACTS prior to the
current expiration date.
(1) The following access requests require completed indices checks prior to the
start of the foreign national access:
(a) All access requests by nationals of SSTs and CORs.
Section 23
(b) All access requests to a physical security area more restrictive than a
Property Protection Area (PPA).
(c) All access requests by all other sensitive country nationals to the
DOE/NNSA national laboratories, sites, information, or
technologies. [NOTE: The indices check for requests by other
sensitive country nationals for access to conduct research under a
User Agreement at an Office of Science, Critical Minerals and
Energy Innovation, or Nuclear Energy User Facility at a non-NNSA
DOE O 142.3C Attachment 1 – CRD, Contractors Only
3-31-2026 Page 1-9
DOE laboratory can be completed after access is granted.]
(d) All access requests for sensitive subjects. [NOTE: The indices check
for access requests by non-sensitive nationals for sensitive subjects at
sites with no classified work can be completed after access is
granted.]
(2) Indices checks are not required for non-sensitive country national access to
non-sensitive subjects in a PPA or less restrictive areas.
For access requests that require indices checks prior to the start of foreign
national access, the request for indices checks must be documented in
FACTS in sufficient time to complete the indices checks. It is recommended
that the request be entered into FACTS at least 45 days prior to the start date
of the request to ensure adequate time for completion of indices checks. For
access requests that require indices checks to be completed before access is
granted, the approval authority may request a CI consultation in lieu of
completion of the indices checks. Such requests require approval from the
head of the DOE field element and Senior Counterintelligence Officer
(SCIO) and their agreement that there are exceptional or exigent
circumstances justifying the request. A consultation may not be used for an
access request that is for employment purposes. For requests involving
nationals of SSTs or Country of Risk foreign national access to restricted
technology or information as identified in the S&T Risk Matrix, CI
consultations may not be utilized until 60 days after requests are
documented in FACTS. CI consultations may not be employed as a standard
alternative to indices checks.
If there are valid indices checks for the foreign national documented in
FACTS, the indices checks will be considered completed upon
documentation of the request in FACTS using the existing FACTS
biographical record for that foreign national.
m. Documentation. FACTS is the Department’s official national database on
unclassified foreign national access requests. Access to FACTS is limited to U.S.
citizens. All required information regarding access requests that require
documentation, as detailed in this Order, must be entered into FACTS.
n. Closeout Information. Information documenting the final status of access requests
must be entered into FACTS within 15 days after the last day access. This
information includes the closeout status, closeout comments, and actual start and
end dates for access that have taken place. Closeout statuses include: Completed,
Canceled Before or After Approval, Denied, or No Show.
SME reviews, when conducted in compliance with SSP requirements, must be
documented in FACTS.
Attachment 1 – CRD, Contractors Only DOE O 142.3C
Page 1-10 3-31-26
o. Restriction on Foreign National Supervision of Cleared Employees. Nationals of
CORs, SSTs, or other designated countries on the Sensitive and Other Designated
Countries List may not serve as the direct supervisor to a cleared contractor
employee, absent a waiver from the head of the cognizant HQ departmental or field
element.
Section 24
(1) The head of the cognizant HQ departmental or field element will make the
decision whether to grant or deny a waiver request through a standardized
process informed by a risk assessment provided by the DOE Office of
Intelligence and Counterintelligence. [NOTE: The granting of a waiver does
not mean that the foreign national supervisor may access classified
information derived from their supervision of the cleared contractor
employee and does not release the cleared contractor employee from all
requirements to protect classified material to which they have been granted
access.]
(2) Granted waivers are valid for a period of two years, at which point a new
waiver request should be submitted for reassessment.
4. RESPONSIBILITIES.
a. Heads of Hosting Sites. Hosting sites may include contractor-operated field sites and
national laboratories.
(1) Consistent with an authorized assignment of authority, serve as the approval
authority for foreign national access requests within their organizations.
(2) Implement the foreign national access activities consistent with guidance
and direction from the head of the DOE field element with direct
responsibility for program performance.
(3) Designate points of contact (POCs) for foreign national access activities and
provide contact information to the cognizant DOE field element and
Cognizant Secretarial Officer (CSO), and to the Office of Environment,
Health, Safety and Security.
(4) Ensure that guidance is issued and followed, corrective actions are
implemented as appropriate, and responsibilities associated with the
presence of foreign nationals are met.
(5) Ensure a systematic, effective process to provide managers, planners and
hosts with appropriate guidance and insight regarding all technologies and
information that could lead to sensitive or export-controlled areas, and to
ensure that sensitive or export-controlled technologies and information are
identified.
(6) In coordination with the cognizant field element, determine if proposed
foreign national access requests require an enhanced review process based on
DOE O 142.3C Attachment 1 – CRD, Contractors Only
3-31-2026 Page 1-11
the current S&T Risk Matrix and, where appropriate, submit such requests.
b. Hosts of Foreign Nationals. The contractor hosting a foreign national is responsible
for the conduct and activities of the foreign national they host, and must ensure the
following requirements are met:
(1) Individual hosts are identified to the foreign national as his/her POC.
(2) Compliance with all requirements for access approval and conduct,
including timely, complete, and accurate information for FACTS,
compliance with SSP requirements, program sponsorship, and notification to
workers regarding requirements as appropriate.
(3) Suspicious activities are reported in accordance with local reporting
requirements.
(4) The span of control of an individual host is reasonable (e.g., limit on the
number of foreign nationals being hosted by a single individual) to
effectively meet these requirements, and the process for determining and
maintaining this is documented in the contractor’s SSP.
(5) The contractor must ensure that individuals identified as hosts meet the
following requirements:
(a) Foreign nationals hosting other foreign nationals must be DOE
contractor employees.
(b) Nationals of SST may not host other foreign nationals.
Section 25
(c) Nationals of countries of risk (COR) may not host other nationals of
CORs, SSTs, or other designated countries on the Sensitive and
Other Designated Countries List.
(d) The host must have technical competence (i.e., knowledge of the
work) to understand the activities that the foreign national will be
performing.
(6) The contractor must provide the following information to the foreign
nationals the contractor is responsible for hosting:
(a) The terms and conditions of access approval, including, restrictions
and requirements for access, requirements to notify the host of
changes in name, immigrant/ nonimmigrant status, and other
information as required.
(b) The requirement to notify the responsible host of any civil or
criminal problems that could affect their status and association with
DOE.
Attachment 1 – CRD, Contractors Only DOE O 142.3C
Page 1-12 3-31-26
(c) That the failure to provide appropriate documentation when required,
or providing fraudulent documentation will result in suspension of
access approval, removal from the site, and possible cancellation of
future access.
c. Escorts of Foreign Nationals.
(1) The contractor is responsible for ensuring that foreign nationals working or
traveling within a site are escorted, when required, as identified by the SSP, to
ensure there is no unauthorized access.
(2) The contractor must also ensure compliance with all requirements for escorts
identified in the SSP.
5. DEFINITIONS. Terms used for the purpose of this Order are defined in Attachment 2.
DOE O 142.3C Attachment 2 – Federal Employees and Contractors
3-31-2026 Page 2-1
ATTACHMENT 2
DEFINITIONS
This Attachment provides information applicable to contracts in which the CRD (Attachment 1 to
DOE O 142.3C) is inserted.
1. Access Request. Seeking permission to enter a DOE site and/or use DOE information or
technologies. This includes remote access to DOE information or technology.
2. Approval Authority. An individual who has been assigned responsibility and
accountability to approve requests for access by foreign nationals to a DOE site, program,
information, or technology.
3. Cognizant Secretarial Officer (CSO). Headquarters Assistant Secretaries, Deputy
Administrator, and Directors responsible for oversight or institutional management of
DOE/NNSA facilities.
4. Contractor. This term, for the purposes of this Order, means an entity that has a contract
with DOE/NNSA that incorporates the CRD or its requirements.
5. Country of Risk. Any foreign country determined to be of risk, following consideration
of, but not limited to, the Office of the Director of National Intelligence World Wide
Threat Assessment and The National Counterintelligence Strategy of the United States of
America, by the Under Secretary for Science in consultation with the Under Secretary of
Energy; the Under Secretary for Nuclear Security; and the Office of Intelligence and
Counterintelligence. The Countries of Risk are listed at:
https://www.energy.gov/science/office-science-laboratory-policy-research-security
6. Covered Foreign Nation. The countries of the People’s Republic of China; the Russian
Federation; the Democratic People’s Republic of Korea; and the Islamic Republic of Iran.
7. Curriculum Vitae (CV). A CV is a detailed document highlighting professional and
academic history. A CV must include any education and employment history. There
should be no lapses in time. CVs include extensive information on academic background,
including teaching experience, degrees, research, awards, publications, presentations, and
other achievements. In the absence of a CV, a resume may be used.
Section 26
8. Dual Citizen. An individual who is a citizen of more than one country.
9. Foreign National. A person without U.S. citizenship or nationality (may include a stateless
person).
10. General Access Area. A type of security area established to allow access to certain areas
with minimum security requirements as determined by the cognizant security authority.
These designated areas are accessible to all personnel including the public.
Attachment 2 – Federal Employees and Contractors DOE O 142.3C
Page 3-2 3-31-26
11. Heads of Departmental Elements. Heads of Departmental Elements include DOE’s Under
Secretaries, Assistant Secretaries, the NNSA Administrator, Program Office Directors,
Power Marketing Administrators, or equivalent DOE officials, or any other official(s) the
Head of Departmental Element designates to carry out his or her responsibilities under
this Order.
12. Heads of Field Elements/Field Office Managers. Officials who direct activities of
DOE/NNSA field or site offices and field organizations reporting directly to
Headquarters and serve as line management, site-level mission integrators, and as the
authorizing officials for activities at the site on behalf of the Department.
13. Host. The DOE or DOE contractor employee responsible for the activities associated with
foreign national access.
14. Indices Checks. A procedure whereby a request is made to appropriate U.S. Government
agencies to determine whether information exists on a particular foreign national. Indices
checks are valid for a period of two years from the indices completion date, as
documented in the Foreign Access Central Tracking System (FACTS) by the Office of
Intelligence and Counterintelligence.
15. Information. DOE information of a programmatic, scientific or technical nature,
regardless of format or medium on which it is recorded, created, or possessed by the
Government or a Contractor.
16. Lawful Permanent Resident (LPR). A foreign national who has the right to reside
permanently and work in the United States. An LPR may also be known as a permanent
resident alien or Green Card holder.
17. National of a Country of Risk. A foreign national who was born in, is a citizen of, is
employed by, or represents a government, company, institution or other organization
based in a country identified as a Country of Risk.
18. National of a State Sponsor of Terrorism. A foreign national who was born in, is a citizen
of, is employed by, or represents a government, company, institution, or other
organization based in a country on the Department of State list of State Sponsors of
Terrorism.
19. National Security. The national defense and foreign relations of the United States.
20. Non-Sensitive Country National. A foreign national who was born in, is a citizen of, is
employed by, or represents a government, company, organization, or institution that is in
a country not on the Sensitive and Other Designated Countries List, not a Country of
Risk, and not a State Sponsor of Terrorism as identified by the Department of State.
21. Organizations of Concern. For the purposes of this Order, organizations that are identified
as possessing foreign intelligence or non-traditional collection risk to the Department.
DOE O 142.3C Attachment 2 – Federal Employees and Contractors
3-31-2026 Page 2-3
22. Personal Visit. A Personal Visit does not include access to DOE or Contractor
information or technology. Examples may include lunches with friends or relatives,
retirement celebrations, or other social events.
Section 27
23. Program Secretarial Officer (PSO). Headquarters Assistant Secretaries, Deputy
Administrator, and Directors who have management responsibility for program planning,
budgeting, and execution of DOE/NNSA mission program activities.
24. Public Event. Public events are those that include only information that is not protected by
statute, regulation, or DOE policy, and are determined to be releasable to the general
public; are held in locations that are accessible to the general public; and are available for
attendance by the general public.
25. Property Protection Area. A type of security area having defined boundaries and access
controls for the protection of Departmental property.
26. Research. Systematic investigation, including research, development, testing, and
evaluation designed to develop, expand or contribute to general knowledge.
27. Science and Technology Risk Matrix (S&T Risk Matrix). Critical emerging research and
technologies that require protection which do not otherwise have control mechanisms
(e.g., classified information, International Traffic in Arms Regulations, export controls).
The S&T Risk Matrix is intended to highlight areas of emerging and potential concern
associated with economic and/or intellectual competitiveness and not to overlap or
supersede existing controls associated with national security or commerce restrictions.
28. Sensitive and Other Designated Countries List (SCL). This list is DOE developed,
maintained, and utilized in support of DOE policies and procedures guiding Departmental
interactions with foreign nationals. The SCL is primarily used to identify when additional
DOE internal reviews and approvals are required for foreign national access to DOE
sites, information, or technologies. The SCL is also utilized in conjunction with DOE
policies for review and approval of official foreign travel and to guide DOE personnel on
reporting requirements for unofficial foreign travel.
29. Sensitive Country National. A foreign national who was born in, is a citizen of, or is
employed by a government, employer, institution or organization of a country identified
on the Sensitive and Other Designated Countries List.
30. Sensitive Subjects. Unclassified subjects and topics identified (i) as subject to Federal
regulations governing export control, (ii) as research areas determined to be restricted in
the current S&T Risk Matrix, and/or (iii) as Critical Energy Infrastructure Information
(CEII), Unclassified Controlled Nuclear Information (UCNI), or Information Systems
Vulnerability Information within the Controlled Unclassified Information (CUI) Registry.
31. Site. A geographical area where one or more facilities are located, or DOE-controlled
land area including DOE-owned facilities (e.g., the Oak Ridge National Laboratory, the
Nevada National Security Site, the Hanford Site, Idaho National Laboratory, the Pantex
Plant).
Attachment 2 – Federal Employees and Contractors DOE O 142.3C
Page 3-4 3-31-26
32. Specialized Enhanced Vetting. Vetting conducted by the Office of Intelligence and
Counterintelligence based on the individual’s background required to support the S&T
Risk Matrix enhanced review process and approval determination. The S&T Risk Matrix
approval request, including the completed supplemental questionnaire, is utilized to
perform an enhanced background check with Intelligence Community partners.
Section 28
33. State Sponsors of Terrorism. Countries that have been identified by the Department of
State as sponsors of groups and/or activities which support terrorism or terrorist
activities. The list of state sponsors of terrorism is available at
https://www.state.gov/state-sponsors-of-terrorism/.
34. Subject Matter Expert. An individual who is knowledgeable about the professional
standards, requirements, and practices used within the discipline he/she represents (i.e.,
security, export control, technology transfer, counterintelligence, or intelligence).
35. Technology. Technology is derived from basic or applied research, development,
engineering, technological demonstration, economic and social research, or scientific
inquiry into phenomena or technology applications. It includes the use and application of
scientific equipment, may be recorded or spoken, may be represented in a medium for
storage of communication, and may be contained in computer software with scientific
and technical applications.
36. Third-Party Events. Activities that a DOE site hosts that are not directly in support of the
DOE mission; do not include information that is protected by statute, regulation, or DOE
policy; and are determined to be releasable to the general public.
37. Talent Program. Talent Program has the same definition as the term Foreign
Government-Sponsored Talent Recruitment Program in DOE Order 486.1A (current
version) which means an effort directly or indirectly organized, managed, or funded by a
foreign government to recruit science and technology professionals or students
(regardless of citizenship or national origin, and whether having a full-time or part-time
position). Some foreign government-sponsored talent recruitment programs operate with
the intent to import or otherwise acquire from abroad, sometimes through illicit means,
proprietary technology or software, unpublished data and methods, and intellectual
property to further the military modernization goals and/or economic goals of a foreign
government. Many, but not all, programs aim to incentivize the targeted individual to
physically relocate to the foreign state for the above purpose. Some programs allow for or
encourage continued employment at U.S. research facilities or receipt of Federal research
funds while concurrently working at and/or receiving compensation from a foreign
institution, and some direct participants not to disclose their participation to U.S. entities.
Compensation could take many forms including cash, research funding, complimentary
foreign travel, honorific titles, career advancement opportunities, promised future
compensation, or other types of remuneration or consideration, including in-kind
compensation.
DOE O 142.3C Attachment 3 – Federal Employees and Contractors
3-31-2026 Page 3-1
ATTACHMENT 3
DATA ELEMENTS FOR SUPPLEMENTAL FOREIGN NATIONAL ACCESS
QUESTIONNAIRE
The data fields below must be collected as part of the Supplemental Foreign National Access
Questionnaire that is required for foreign national access requests for individuals affiliated with
State Sponsors of Terrorism or Countries of Risk. Data fields 1 and 4 must be collected for all
foreign national access requests.
1. Contact Information:
a. All email addresses.
b. All phone numbers.
c. Current U.S. address (if applicable).
2. Work Experience:
a. Complete work history for the past 10 years or since the age of 18, whichever is
shorter, with no lapses in time.
Section 29
b. Include the name, email address, and phone number of the current supervisor.
3. Education History:
a. All education, to include names of all academic institutions attended, and all
degree/diplomas earned.
b. For PhDs completed in the last 10 years, provide the names, email addresses, and
phone numbers of PhD advisors.
4. Identification and Citizenship(s):
a. Current countries of citizenship(s).
b. Passport number(s) and expiration date(s).
c. List any other names used and the corresponding time periods.
d. Indicate if the individual has ever held dual or multiple citizenships. If so, provide
country(ies) and timeframe(s).
5. Science & Technology Specialties:
a. All areas of expertise in science and technology.
Attachment 2 – Federal Employees and Contractors DOE O 142.3C
Page 3-2 3-31-26
6. Publications:
a. All published papers, including the names of coauthors.
7. Peer Review Activities:
a. Names of any journals for which the individual acts or has acted as a peer
reviewer in the last 10 years.
8. Intellectual Property:
a. All patents (US or otherwise).
9. Sponsorship/Funding:
a. Information on what entity is currently sponsoring and/or funding the individual
to work in the United States.
10. Government Funding:
a. Indicate if the individual has received funds from a CoR government in the last 7
years, including any talent program affiliations. If yes, provide details.
11. Military, Intelligence, or Security Service:
a. Indicate if the individual has ever served in a military, intelligence, or security
service of a CoR government. If yes, provide organization(s) and timeframe(s).
12. Immediate Family Members:
a. To the best of the individual’s knowledge, indicate if any immediate family
members work for a CoR government. If yes, provide organization(s) and
name(s).
1. PURPOSE
2. CANCELLATIONS
3. APPLICABILITY.
a. Departmental Applicability
b. DOE Contractors
c. Equivalencies/Exemptions for DOE O 142.3C.
4. REQUIREMENTS
a. Access Request
b. Supplemental Foreign National Access Questionnaire.
c. Curriculum Vitae (CV).
d. The DOE office
e. FACTS Data Entry and Updates
f. Site Security Plan (SSP).
g. Lawful Immigration Status, Citizenship, and Identity.
h. Assignment of Approval Authority
i. Countries of Risk
j. Nationals of State Sponsors of Terrorism
k. Indices Checks
l. Documentation
m. Restriction on Foreign National Supervision of Cleared Employees
n. Prohibition on Admittance for Citizens or Agents of Covered Foreign Nations(CFN) to Specified Facilities (FY2025 NDAA Section 3112(c)).
5. RESPONSIBILITIES.
a. Secretary of Energy
b. Administrator of the National Nuclear Security Administration (NNSA).
c. Under Secretaries.
d. Under Secretary for Science.
e. Cognizant Secretarial Officers (CSOs).
f. Program Secretarial Officers (PSOs).
g. Heads of Headquarters Departmental Elements
h. Heads of Field Elements
i. Heads of Hosting Sites
j. Hosts of Foreign Nationals
k. Escorts.
l. Director, Office of Environment, Health, Safety and Security
m. Director, Office of Intelligence and Counterintelligence
n. Deputy Director, Counterintelligence Directorate, Office of Intelligence andCounterintelligence
o. Headquarters and Field Counterintelligence Officers
p. Deputy Administrator, Defense Nuclear Nonproliferation
q. Assistant Secretary for Policy and International Affairs.
r. General Counsel
s. NNSA Office of General Counsel.
t. Chief Information Officer (CIO).
u. Deputy Administrator for Naval Reactors
v. Contracting Officers
Section 30
6. INVOKED STANDARDS
7. REFERENCES
8. DEFINITIONS
9. CONTACT
Attachment 1 Contractor Requirements Document
1. PURPOSE
2. EXEMPTIONS
3. REQUIREMENTS
a. Access Request
b. Supplemental Foreign National Access Questionnaire
c. Curriculum Vitae (CV).
d. Foreign National Certification Statement
e. FACTS Data Entry and Updates
f. Site Security Plan (SSP).
g. Lawful Immigration Status, Citizenship, and Identity
h. Assignment of Approval Authority
i. Country of Risk
j. Requests for access to conduct research
k. Nationals of State Sponsors of Terrorism
l. Indices Checks
m. Documentation
n. Closeout Information
o. Restriction on Foreign National Supervision of Cleared Employees
4. RESPONSIBILITIES
a. Heads of Hosting Sites
b. Hosts of Foreign Nationals
c. Escorts of Foreign Nationals
5. DEFINITIONS
Attachment 2 Definitions
Attachment 3 Data Elements for Supplemental Foreign National Access Questionaire