Approved for release by ODNI on 12-29-2016, FOIA Case DF-2015-00229. SECRET//NOFORN OFFICE OF THE INSPECTOR GENERAL OF THE INTELLIGENCE COMMUNITY INVESTIGATIONS DIVISION WASHINGTON, DC 2051 1 REPORT OF INVESTIGATION CASE NUMBER: 2013-0034 SEP 10,2014 SUBJECT b3 b6 b7C - IG Subject ALLEGATIONS 1. (U I IFOUO) Subject engaged in conflicts of interest. 2. (U I IFOUO) Subject engaged in improper or unauthorized outside employment. 3. (U I IFOUO) Subject engaged in falsification and misrepresentation. 4. (U I IFOUO) Subject misused government information and information systems. 5. (U I IFOUO) Subject engaged in sexual misconduct while on duty. This document is intended only for authorized recipients. Recipients may not further disseminate this informa tion without the express permission of the signatory or other Office of Inspector General of the Intelligence Community personnel. This document may contain Inspector General sensitive information that is confidential, sensitive, work product or attorney-client privileged, or protected by Federal law, including protection from public disclosure under the Freedom of Information Act (FOIA), 5 USC§ 552. Accordingly, the use, dissemination, distribution or reproduction of this information to or by unauthorized or unintended recipients may be unlawful. Cl as s i f ied By: - I C IG Derived From : ODNI MET S-12 Declas s ify On: 2SX1, 2064 1 231 b3 b6 SECRET//NOFORN 000301 Approved for release by ODNI on 12-29-2016, FOIA Case DF-2015-00229. SECRET//NOFORN BACKGROUND (S/ fNF) On August 23, 2012, the Clearance Division of the CIA Office of ...--------., Security contacted the Special Investigations Branch (SIB) regarding ....._ __ .___ __, (AIN '),a Senior Security Database Program Officer for the Office of the Director of National Intelligence National Counterintelligence Executive (NCIX). During are-adjudication investigation for the Clearance Division found evidence that engaged in unreported outside activities. As part of the standard operating procedure for the Clearance Division, the matter was referred to SIB. __ b3 b6 b7C - IG Subject ___ ,__ (S/ /NF) During the SIB investigation, case reviewers discovered that had two unreported part-time facility security officer (FSO) consulting contracts, in addition to five part-time FSO consulting contracts she had reported. Based on that discovery, SIB audited her computer use to determine if she was engaged in personal business during duty hours. business relationships with approximately 14 com panies. SIB also discovered archived time and attendance sheets for work performed for these com panies and documentation noting her FSO relationship to those companies. excess of five hours per day on personal affairs and unofficial business. (S/ /NF) Based on information and belief, SIB suspected that ,___ _ _ used her security officer privileges to query whether SIB was investigating her. b3 b6 b7C - IG Subject b1 b3 b6 b7C - IG Subject b3 b6 b7C - IG Subject b3 b6 b7C - IG Subject b3 b6 b7C - IG Subject 2 SECRET//NOFORN 000302 Approved for release by ODNI on 12-29-2016, FOIA Case DF-2015-00229. SECRET//NOFORN b3 b6 b7C - IG Subject b3 b6 b7C - IG Subject (UI IFOUO) b3 b6 b7C - IG Subject (UI IFOUO) SCOPE (U I I FOUO) The Investigations Division (INV) of IC IG conducted this investigation pursuant to 50 USC§ 3033, Inspector General of the Intelligence Community, effective 7 October 2010; ODNI Instruction 10.34, Office of the Inspector General of the Intelligence Community, dated 22 Sept 2013; and, the Quality Standards for Investigations, dated 15 November 2011, set forth by the Council of the Inspectors General on Integrity and Efficiency. ALLEGATION 1 (UI IFOUO) Subject engaged in a conflict of interest. APPLICABLE LAW AND POLICY (U) Compensation to Members of Congress, officers, and others in matters affecting the Government. Title 18, United States Code, Section 203 provides that, with certain exceptions, "whoever... directly or indirectly dem ands, seeks, receives, accepts, or agrees to receive or accept any compensation for any representational services, as agent or attorney or otherwise, rendered or to be rendered either personally or by another at a time when such person is. an officer or employee ... of the United States in the executive ... branch of the Government .. .in relation to any proceeding, application, request for a ruling or other determination, contract, claim, controversy, charge, accusation, arrest, or other particular matter in which the United States is a party or has a direct and substantial interest, before any department... " is guilty of a federal offense. 3 SECRET//NOFORN 000303 Approved for release by ODNI on 12-29-2016, FOIA Case DF-2015-00229. SECRET//NOFORN (U) Activities of officers and employees in claims against and other matters affecting the Government. Title 18, United States Code, Section 205 provides that, with certain exceptions, "whoever, being an officer or employee of the executive branch of the United States Government.. . acts as agent or attorney for anyone before any department, agency, court, court-martial, officer, or civil, military, or naval commission in connection with any covered mater in which the United States is a party or has a direct interest" is guilty of a federal offense. · (U) Use of Nonpublic Information. 5 C.F.R. § 2635.703 provides that "an employee shall not engage in a financial transaction using nonpublic information, nor allow the improper use of nonpublic information to further his own private interest or that of another, whether through advice or recommendation, or by knowing unauthorized disclosure." ANALYSIS (U/ /FOUO) began her tenure at the ODNI on May 10, 2010. She entered the ODNI as a GS- 14 in the role of Senior Security Database Program Officer at the Office of the National Counterintelligence Executive (NCIX). In her role as a program officer, is expected to "manage ... the Scattered Castles repository, , and the Sensitive Compartmented Information Facility (SCIF) Database."! Her role also requires her to "monitor the Security Databases Program budget and author and compile well-reasoned budget planning and execution recommendations to the Security Databases Program Manager."2 role at the ODNI allows her unfettered access to Scattered Castles, JPAS, and a host of other security related databases and sites. According to due to her role at the ODNI, she has the ability to change information within these security databases to include resolving redundancies, changing dates, or changing access for those with security clearances. 3 (UI /FOUO) According to .....___ _ _ and .....___ ___, Standard Form 86 (SF86), she has also worked as a Facility Security Officer since December 2007 for several companies. A Facility Security Officer (FSO) administers and assures compliance with security regulations and procedures in accordance with a 31 ODNI Vacancy Notices, ODNI/ DNI Security Databases Program Officer 20747, - Personnel File, 19 August 2009. 2 Ibid. personal interview with IC IG, 30 July 2014. 4 SECRET//NOFORN 000304 b3 b6 b7C - IG Subject b3 b6 b7C - IG Subject b3 b6 b7C - IG Subject Approved for release by ODNI on 12-29-2016, FOIA Case DF-2015-00229. SECRET//NOFORN contract's guidelines. They serve as the point of contact for contractor security matters and are familiar with all aspects of security including personnel, physical, operations, industrial, communications, information, and information technology security. An FSO directs and advises all departments regarding security regulations and procedures, and routinely interacts with Government agencies relative to security matters. 4 FSOs are considered Key Management Personnel (KMP), and must be at least part-time employees in order for a contractor to properly maintain a facility's security. According to .....__ ___ and an audit of her US Governm ent system, one of the primary functions of her job as an FSO, is working within security databases and providing assistance to employees regarding their clearance paperwork and processing. (UI IFOUO) On April29, 2013, the IC IG opened a preliminary inquiry into upon receiving a referral from CIA OIG and SIB due to the subject's failure to adhere to and any subsequent laws or policies. The initial information included in the referral regarded unreported outside activities. As standard procedure, (U I IFOUO) The over 856 files pertaining to outside activities, including classified contracts (DD254s); time and attendance records; SF86s for employees; JPAS documents; offer letters; and invoices. In total, there was 337.54 MBS of outside activity related documents on AIN account. (U I IFOUO) The L - - - - - - - - - - - - - _ _ , web activity associated with FSO work, and the maintenance of over 600 files on a US Government system pertaining to FSO work. 6 ;, the IC IG found several instances where ....._ __, accessed JPAS from a US Government system while on duty as a federal employee for the purposes of FSO related activity.7 Furthermore, the multiple instances of communication between government __ Derived from vacancy notices at different government contractor websites and the Department of Security Services website. s 337.538MB is 1/3 of a GB, or the complete works of Shakespeare, 100 times. 6 Although ~utsife the scope of the investigation, it should be noted that engaged in sexually ex licit with a contractor for the first year of working at ODNI. Please see .______~------~~--~ 7 Improper maintenance of PII and improper use of government systems is discussed in the following allegations. b3 b6 b7C - IG Subject b3 b6 b7C - IG Subject b7E - IG Tech b3 b6 b7C - IG Subject b7E - IG Tech b1 b3 b6 b7C - IG Subject b7E - IG Tech 4 5 SECRET//NOFORN 000305 b3 b6 b7C - IG Subject Approved for release by ODNI on 12-29-2016, FOIA Case DF-2015-00229. SECRET//NOFORN agencies and in her role as an FSO on a US Government system during duty hours . Specifically, the communication between in her role as FSO representing a comp any back to the federal government through DSS as the point of contact for the comp any while on duty as a federal employee. (EXHIBIT AA, DD) b3 b6 b7C - IG Subject (U j /FOUO) During the investigation, continued to act as key management personnel for the companies, and continued working on these activities while on US Government systems during duty hours. (U/ jFOUO) In or around May 3, 2013, second line supervisor overheard negotiating terms of a contract on the phone while at work.B The second line supervisor was told by first line supervisor that she maintained outside activities. Out of concern regarding 18 USC§ 205, the second line supervisor asked for a list of the companies she represented and her duties for each company. provided a list of the companies (EXHIBIT CCCC, DDDD): Company Wheeler Network Design Link Solutions Inc Twin Soft Corp IncaTech Technology Science Corporation b3 b6 b7C - IG Subject Title Start Date December FSO 2007 October 2007 FSO May 2009 FSO April 2010 Geographic October Services Inc 2010 CSi Federal GuROOIT b3 b6 b7C - IG Subject b7E - IG Tech FSO "not FSO" May 2012 FSO July FSO 2012 November FSO 2012 Date was derived in where she tells 8 she met with an email dated May 9, 2013 to "on Friday." 6 SECRET//NOFORN 000306 , b1 b3 b6 b7C - IG Subject, Witnesses b7E - IG Tech Approved for release by ODNI on 12-29-2016, FOIA Case DF-2015-00229. SECRET//NOFORN Maverick LLC FS-ISAC Augusta Westland November FSO 2012 January FSO 2013 2008 "not FSO" (U I IFOUO) The second line supervisor met with and went over the company list, duties, as well as looked at her 879s. told the second line supervisor that she was told "just don't list you're an FSO and you'll be fine" by OGC, and that is why her 879s were vague. The supervisor found this to be unbelievable and asked that put a hold on all outside activities until it was resolved. He also alerted Office of Security and OGC to his concerns. (UI IFOUO) In an email dated May 8, 2013, the second line supervisor wrote to the Office of Security,"[ was notified of an approval for outside activities today, the problem is no one in her supervisory line approved the outside activity. The outside employment is very questionable regarding conflict of interest and we are still collecting information regarding ....._ ___... relationship and exact duties with these companies .. .I am requesting that you withdraw your approval of Ms. outside activities until you receive an approval from her supervisor." (EXHIBIT CCCC, DODD) _ (U I IFOUO) On May 8, 2013, the Office of Security responded, "We will add a note to Ms. 879 request noting that it is in pending status while we wait for more information from you." (U I IFOUO) After the initial confrontation with her second line supervisor maintained that there were conflicts of interest. On August 14, 2013, the IC IG interviewed the supervisor. He stated that after meeting with ......_ ___, in May, and asking more questions regarding her outside activities, he felt that her FSO duties were clearly in conflict with her role as a ___... government employee. He described as "problematic:" .....__ received counseling on several issues including time and attendance issues and poor leave time management. __ b3 b6 b7C - IG Subject b3 b6 b7C - IG Subject b3 b6 b7C - IG Subject b3 b6 b7C - IG Subject __ (UI IFOUO) On August 15, 2013, the supervisor wrote an email to the IC IG investigator stating, "[ first line supervisor] and I informed .....____, 7 SECRET//NOFORN 000307 b3 b6 b7C - IG Subject Approved for release by ODNI on 12-29-2016, FOIA Case DF-2015-00229. SECRET//NOFORN • - • that I have decided to non-concur on her request for outside employment for all ten firms. I cited my reasons as conflict of interest and my opinion of her not adhering to OGC guidance on representing a third party back to the government. When [her first line supervisor] attempted to reply to the outside activities request we found it had once again been approved without our approval. I asked the outside activities branch to reactivate the request so we can record our decision." (U/ /FOUO) On August 19, 2013, the IC IG spoke with the Deputy Director of the Special Security Directorate. She emailed the investigators to alert them to a meeting she was scheduled to have with . requested the meeting to appeal the non-concur by second line supervisor. After the meeting, the Deputy Director wrote again to update the investigators: "The decision hasn't changed, but there have been complications. Unfortunately, the Outside Activities reporting system had generated an automatic concurrence for at some point in May after it got no input from the designated supervisor after a certain amount of time (I believe 5 days) (this is actually the second time this has happened). Last week, [ second line supervisor] reached out to the office responsible for the system and told them he wished to non-concur as the supervisor, and they said would have to generate another Outside Activities report, and resend it through the process. They also instructed ':---:-' she had to do this. [He] still intends to non-concur (actually he is directing [the first line supervisor] as her supervisor to nonconcur) and he has told that. When met with me today she was looking for some way to appeal [the] decision. She said there was an appeal process for when OGC non-concurs, but nothing in the regs re when the supervisor non-concurs. She said she has spoken to the Ombudsman because she thinks [he] is being biased against her and she said they told her this might need to be an issue she needs to resolve with HR involvement. We ultimately decided: 1) she would send me the documentation on her outside employments that she's provided to [her supervisor]; 2) [The supervisor] would send his written concerns to her and me (justification for his non-concur); 3) I would send both of the above to the OGC rep who concurred on the Outside Activity report (since the nature of [his] concerns have to do with conflict of interest); 4) I would set up a meeting with me, [the supervisor], and OGC 8 SECRET//NOFORN 000308 b3 b6 b7C - IG Subject b3 b6 b7C - IG Subject b3 b6 b7C - IG Subject b3 b6 b7C - IG Subject Approved for release by ODNI on 12-29-2016, FOIA Case DF-2015-00229. SECRET//NOFORN to discuss the concerns. Out of that meeting, either [he) would still have his concerns and OGC could give clarification/ guidance, or OGC will explain to [him] why his concerns don't apply and [he) will likely be comfortable concurring. And finally 5) regardless of the outcome of the meeting, .....___, would generate another Outside Report listing all of her outside employments and then OGC and [he] would chop on it documenting their final concurrence or non-concurrence for the record." (EXHIBIT VV) (U/ /FOUO) On August 20, 2013, the IC IG spoke with OGC concerning the upcoming meeting with and her supervisors. In the call, OGC explained to the IC IG that OGC would not be meeting with as the decision was at the management level. If management did not concur, then the 879 would be non-concurred on and never be received or reviewed by OGC, (U/ /FOUO) By August 20, 2013, had been admonished by OGC to maintain strict distance from outside activities that would have conflicts of interest, had been told by her first and second line supervisor to cease all outside activities, and had been told by OGC that the matter was not for appeal, and that was to oblige her management's decisions. b3 b6 b7C - IG Subject b3 b6 b7C - IG Subject b3 b6 b7C - IG Subject In the b3 b6 b7C - IG Subject b3 b6 b7C - IG Subject CONCLUSION b3 b6 b7C - IG Subject (U/ /FOUO) 9 SECRET//NOFORN 000309 Approved for release by ODNI on 12-29-2016, FOIA Case DF-2015-00229. SECRET//NOFORN ALLEGATION 2 (U1IFOUO) Subject engaged in improper or unauthorized outside employment. APPLICABLE LAW AND POLICY (U) Acts Affecting a Personal Financial Interest. Title 18, United States Code, Section 208 provides that, "except as permitted by subsection (b) hereof, whoever, being an officer or employee of the executive branch of the United States Government ... participates personally and substantially as a Government officer or employee, through decision, approval, disapproval, recommendation, the rendering of advice, investigation, or otherwise, in a judicial or other proceeding, application, request for a ruling or other determination, contract, claim, controversy, charge, accusation, arrest, or other particular matter in which, to his knowledge, he, his spouse, minor child, general partner, organization in which he is serving as officer, director, trustee, general partner or employee, or any person or organization with whom he is negotiating or has any arrangement concerning prospective employment, has a financial interest" is guilty of a federal offense. (U) Salary of Government Officials and Employees payable only by United States. Title 18, United States Code, Section 209 provides that, "whoever receives any salary, or any contribution to or supplementation of salary, as compensation for his services as an officer or employee of the executive branch of the United States Government, of any independent agency of the United States, or of the District of Columbia, from any source other than the Government of the United States, except as may be contributed out of the treasury of any State, county, or municipality" is guilty of a federal offense." (U) Use of Nonpublic Information. 5 C.F.R. § 2635.703 provides that "an employee shall not engage in a financial transaction using nonpublic information, nor allow the improper use of nonpublic information to further his own private interest or that of another, whether through advice or recommendation, or by knowing unauthorized disclosure." ANALYSIS (UI IFOUO) Form 879 Outside Activities Form ("879") is required to be submitted by any member of the ODNI under ~--------------------------J 10 SECRET//NOFORN 000310 b3 Approved for release by ODNI on 12-29-2016, FOIA Case DF-2015-00229. SECRET //NOFORN b3 The policy is in place to ensure, among other things, no conflicts of interest exist between the federal employee and the outside activity. · (U I IFOUO) Furthermore, as stated b3 - - - - - - - - - - - - - - -- o further information is sought; thus, the information on the 879 is the sole source in the determination. __ __, (UI IFOUO) On May 12, 2010, two days after joining the ODNI, ,___ submitted an 879 to OGCIELD for approval regarding work as a Facility Security Officer for four companies: Link Solutions, Inc; Wheeler Network Design; Twin Soft Corporation; and IncaTech LLC. She wrote, "I work for four small US Government contractors in my free time .... They do not have any contracts with the IC. I am paid a minimal amount by them." On May 20, 2010, ten days after joining ODNI, submitted a second 879 for approval regarding work as a Facility Security Officer for Augusta Westland North America. In the second 879, . wrote, "I am requesting approval prior to consulting for Augusta Westland North America .. .I would be doing purely administrative work for them .. .I would do this work after my regular scheduled duty hours with ODNI." (EXHIBIT CCCC, DDDD) (UI IFOUO) Form 879 is automatically approved by a supervisor, should the request for approval remain in the supervisor's email inbox, unread, for five days. After five days, the form is automatically approved and sent to OGCIELD. According to first and second line supervisors, the 11 SECRET//NOFORN 000311 b3 b6 b7C - IG Subject b3 b6 b7C - IG Subject Approved for release by ODNI on 12-29-2016, FOIA Case DF-2015-00229. SECRET//NOFORN ____, was automatically approved and request for outside activities by ....._ sent to OGC/ELD. (U/ /FOUO) On May 24, 2010, and June 4, 2010, respectively, the 879s submitted by were concurred by OGC/ELD. The notification that an outside activities form has been approved includes several admonishments from OGC/ELD regarding 18 USC§ 205 and CFR 2635. Among the admonishments, OGCJELD advises, "Restriction on representation of private interest before the USG Executive branch employees are subject to criminal statutes that prohibit the representation of private interest before the Government. One of these laws prohibits an employee from acting as the agent or attorney of a private party before the government in connection with a particular matter in which the United States is a party of has a direct and substantial interest. See 18 USC 205." The guidance continues to specifically state, "The type of representation that is prohibited would include any personal appearance or comm unication to any federal agency on behalf of any of the four companies. For example, you could not sign documents or letters to be sent to any federal agency (not just ODNI) on behalf of any of the com panies." was also told that "an employee shall not allow the improper use of nonpublic information to further his own private interest." submitted a third 879 stating, "I work for 10 small US Government contractors in my free time. I provide them personnel security support (initiating, and submitting their clearance, fingerprinting their personnel for clearances and any general security questions/concerns). They all hold Secret & Top Secret facility clearances, issued by Department of Defense. None have foreign employees or foreign contracts. They do work for Department of State, WHCA, DHS, Army and DoD. They do not have any contracts with any agencies in the IC. They are: Link Solutions, Inc, employed since October 2007. Wheeler Network Design, employed since Dec 2007. Twin-Soft Corporation employed since May 2009. lncatech, one-woman company, employed since April2010. Geographic Services, Inc, employed since October 2010. C5i Federal, employed since May 2012, GuROO IT, employed since July 2012, Maverick LLC, employed since November 2012 and Financial Services-ISAC, employed since Jan 2013." b3 b6 b7C - IG Subject b3 b6 b7C - IG Subject (U/ /FOUO) On April24, 2013, - (U j /FOUO) The fo rm asks a series of prompts. One prompt asks "Indicate if you will be required to interact verbally or in writing with any federal government agency j department; please explain." ...._ _..,. wrote, "During my 12 SECRET//NOFORN 000312 b3 b6 b7C - IG Subject b3 b6 b7C - IG Subject Approved for release by ODNI on 12-29-2016, FOIA Case DF-2015-00229. SECRET //NOFORN own time, I send Visit Requests and Visit Authorization Letters using my personal email to government agencies for the company contractors to visit their facilities." At the bottom of the page, the form states "I understand I must report any changes to this particular Outside Employment activity'' to which ....._ __, responded, "Yes." OGC/ELD sought clarification on this particular answer from The OGC/ELD representative dealing with L - - - - - - - 1 879 asked, "When you refer to DoD contracting agencies, do you mean other DoD contractors or DoD agencies?" to which responded, "I mean other DoD contractors such as Lockheed Martin, Northrup Grumman and SAIC." __ (U/ /FOUO) Between EOD and March 11, 2013, the IC IG found • .._____. of communication between DoD agencies and while she was on US Government systems during duty hours, and zero emails between ..___ __. and Lockheed Martin, SAIC, or Northrup Grumman. (EXHIBIT M) b3 b6 b7C - IG Subject b3 b6 b7C - IG Subject b7E - IG Tech b3 b6 b7C - IG Subject b7E - IG Tech On one occasion, used Scattered Castles for her duties as an FSO: On September 6, 2013, wrote to one company she represents, "JPAS still shows the 2007 investigation. In Scatter Castles, the FBI shows the 2013." On the same day, .....__ __ communicated with a DSS official while on duty at ODNI and provided him with her contact information so that they could further discuss the facility clearance for a company. (EXHIBIT N) (U/ /FOUO) On November 20, 2013, DCIS and IC IG of personal email. The revealed over six gigabytes of inform ation, including communication between and fourteen companies.9,10 In one email dated October 2, 2013, wrote C5i Federal; AWNA; Maverick LLC; Twin Soft Corporation; IncaTech LLC; Link Solutions Inc; GuROO IT; FS-ISAC; Electromagnetic Systems; GSI; Wheeler Network; Technology Science Corporation; Red Arch Solutions; Century Link. 10'fhe list of fourteen companies is non-exhaustive. Several times in the emails reviewed, referred to her "work email" in regards to different companies. The personal email L - - - -..... 9 13 SECRET//NOFORN 000313 b3 b6 b7C - IG Subject b7E - IG Tech b3 b6 b7C - IG Subject Approved for release by ODNI on 12-29-2016, FOIA Case DF-2015-00229. SECRET//NOFORN an email to contractors with the subject header "Leave (a furloughed vacation I suppose):" "Good morning everyone, I am writing to let you know next Tuesday, Oct 8 through Monday, October 14 I will not have access to JPAS. However, I will have access to email and regular internet connectivity." The email indicates that was unable to perform her duties as an FSO while on furlough. Several tax documents were sent by the companies represents over the 30 day period. However, some companies did not send tax documentation, raising suspicion in regard to tax fraud. as well as a review of (UI IFOUO) The the search warrant revealed several instances where she referred to her Linkedln account and used it to solicit new work. On March 4, 2014, DCIS, Linkedln account. IRS, and IC IG executed a search warrant on The Linkedln account search warrant results confirmed the use of Linkedln as ____, connections to some of a means to garner business, and confirmed ....._ the key management personnel at the companies. b3 b6 b7C - IG Subject b3 b6 b7C - IG Subject b7E - IG Tech b3 b6 b7C - IG Subject b7E - IG Tech ___ (UI IFOUO) After the IRS joined the investigation, on March 11, 2014, DCIS, IRS,andiCIG ~~~~~~~~~~~~~~~~~~~----- b3 b6 b7C - IG Subject b7E - IG Tech a. b. c. d. - - - - would use the account when her company email was is a law enforcement investigative technique in which 14 SECRET//NOFORN 000314 b3 b6 b7C - IG Subject b7E - IG Tech Approved for release by ODNI on 12-29-2016, FOIA Case DF-2015-00229. SECRET//NOFORN e. f. g. b3 b6 b7C - IG Subject b7E - IG Tech h. 1. j. k. 1. m. (U j jFOUO) In total, (counting only full, 365 day years that she has been employed by ODNI, and falsely reported outside activities), . b3 b6 b7C - IG Subject b7E - IG Tech b3 b6 b7C - IG Subject b7E - IG Tech (U/ /FOUO) From March 5, 2014 to March 25, 2014, (EXHIBIT WWW, XXX, YYY) : a. March 5, 2014 - An envelope addressed to at , from 99999 Consulting LLC, 7032 Lee Mills Court, Springfield, VA. A pay stub was found in the opened envelope. The pay stub listed and her Employee ID as 4. The pay period was listed as February 1, 2014 to February 15, 2014 and a check date of February 14, 2014 . Gross pay on the pay stub was $400.00 and a net pay of $367.95. Year to date earnings as $367 .95; b. March 25, 2014- An envelope addressed to 12 A at , from Maverick Cyber . Law enforcement officers SECRET//NOFORN 000315 b3 b6 b7C - IG Subject b7E - IG Tech is an undercover investigative technique. 15 b3 b6 b7C - IG Subject Approved for release by ODNI on 12-29-2016, FOIA Case DF-2015-00229. SECRET//NOFORN - Defense, 1400 C Street, Germain Drive, Centerville, VA 20121, postmarked March 19, 2014; c. March 25, 2014 - An Earnings Statement from Maverick- Security LLC, 14408 Chantilly Crossing Lane, Chantilly, Virginia 20151, for at , pay date March 11, 2014. Earnings for the pay period are $276.05 with a year to date earning of $600.00; d . March 25, 2014 - An envelope addressed to at , from Link Solutions, Inc. 12007 Sunrise Valley Drive, Reston, VA 20191, postmarked December 16, 2013. (S/ /NF) On March 14, 2014, the IC IG com piled a list of the com panies represented by that have Intelligence Community contracts. Despite claims that none of the companies she represented worked for the Intelligence Community, a number of companies she represented held IC contracts. For example, Maverick LLC maintained contracts with ODNI and Defense Intelligence Agency (DIA); m aintained contracts with and FS-ISAC maintained contracts with DHS and 13 (EXHIBIT ODNI; and . maintained contracts with b3 b6 b7C - IG Subject b3 b6 b7C - IG Subject b3 b6 b7C - IG Subject WW, XX) (U/ /FOUO) Between March 2014 and May 2014, revealed continued misuse of US Government systems through AIN and CWE , continued misuse of nonpublic information through JPAS and Scattered Castles, and continued false statements through time and attendance verifications and written statements to her supervisors regarding her outside activities . For example, on March 25, 2014, used her US Government system while on duty at ODNI to agree, clarify, and help write the security portion of a bid for a DIA proposal for Technology Science Corporation. (EXHIBIT KK, LL) (U j /FOUO) On June 9, 2014, the IC IG received access to contract databases that would allow for a wider breadth of information pertaining to PURYEAR. It was discovered , that is listed in government databases as key management personnel for GuROO IT LLC; 13 Information for data gathered from and gathered from 16 SECRET//NOFORN 000316 ; all other contract b3 b6 b7C - IG Subject b7E - IG Tech b3 b6 b7C - IG Subject b7E - IG Tech b1 b3 b7E - IG Tech Approved for release by ODNI on 12-29-2016, FOIA Case DF-2015-00229. SECRET//NOFORN Augusta Westland; Wheeler Network Design; INCATech LLC; FS-ISAC; Link Solutions; iKare Corporation; and Twin-Soft Corporation. (U/ / FOUO) On July 30, 2014, the IC IG interview, interviewed _L.....-.::==~ In the _____ ~==~------------------------------------------~ __. ·14 ....._ Company Start Year Pay Rate I J r r j r 879 Status Notes ~ ~ i J b3 b6 b7C - IG Subject \ ; 1 I LJ LJ L I r ~ J r ~ 1 b3 b6 b7C - IG Subject I 1 u I l ~ J I r I r I r I "r - b3 b6 b7C - IG Subject 17 SECRET//NOFORN 000317 Approved for release by ODNI on 12-29-2016, FOIA Case DF-2015-00229. SECRET//NOFORN r ~ J j ~ I I I I I J J l.J l r I LJ r J r j r b3 b6 b7C - IG Subject f i j I I J ~ I I I J I J ~ i LJ LJ ~ r u LJ r L... r I J I j 1 ~ ~ I I J ~ r b3 b6 b7C - IG Subject b3 b6 b7C - IG Subject 18 SECRET //NOFORN 000318 Approved for release by ODNI on 12-29-2016, FOIA Case DF-2015-00229. SECRET//NOFORN (UI IFOUO) explained that she felt her second line supervisor was singling her out, although she could not explain why. She cited his checking of her time and attendance as evidence of his bullying and categorically denied any time and attendance fraud when it came to her physical presence. 15 b3 b6 b7C - IG Subject (U I IFOUO) When asked about time and attendance fraud and dual compensation in regard to working on FSO duties and game playing while at ODNI, said she understood that by recording her time and attendance as nine hours, when she spent at least four of those nine working on FSO duties, she was committing time and attendance fraud. - b3 b6 b7C - IG Subject CONCLUSION b3 b6 b7C - IG Subject ALLEGATION 3 (U 1IFOUO) Subject engaged in falsification and misrepresentation. APPLICABLE LAW AND POLICY (U) False Statements. Title 18, United States Code, Section 1001 provides that, with certain exceptions, "whoever, in any matter within the jurisdiction of the executive, legislative, or judicial branch of the Government of the United States, knowingly and willfully (1) falsifies, conceals,