The IWC’s in-house suitability screening before even submitting someone for an investigation is the complicating layer your take here is missing. Yes, a clearance denial in adjudication is generally the final show-stopper, but if the IWC’s screeners don’t find an applicant’s background favorable on the front-end, they don’t even submit that person to DCSA for investigation. No investigation, no adjudication (and hence, no assessment of how risk-mitigating factors would actually impact the final clearance determination).
Not to put too fine a point on this, but there’s plenty of anecdotal evidence posted on this site and elsewhere to suggest the IWC’s internal screeners aren’t too worried about deeming applicants “unsuitable” for TS investigations (especially on account of foreign family contacts) who’d otherwise have likely made it through the investigation and adjudication process just fine if they were actually submitted to DCSA. Even a five minute jaunt down the r/SecurityClearance subreddit turns up plenty of posts from verified investigators who’ve generally been baffled by green-side screeners’ tendency to nuke folks’ packets before even sending them up for investigation.
