Frequently Asked Questions
Last updated May 27, 2026
As a Department of Energy (DOE) federal contractor, Berkeley Lab is required to comply with DOE requirements for employment and access, including applicable background checks and DOE standards for access by non-U.S. citizens. These requirements are outlined in DOE Order 142.3C, Foreign National Access Program (FNAP).
DOE’s Foreign National Access Program establishes requirements for access to DOE national labs by non-US employees, affiliates, visitors, and others. The DOE may continue to evolve its FNAP or FNAP approval workflows in response to changes in risk or research security. For example, in late 2025, the DOE issued changes to FNAP regarding timing of certain DOE approvals to happen largely before foreign nationals are granted access, rather than after.
There are other reviews and checks required as part of FNAP’s workflow regarding access for foreign nationals. As these requirements continue to evolve, this page serves as a general guide for understanding who FNAP applies to and what it means for employees, affiliates, and visitors.
Key Acronyms
- FNAP = Foreign National Access Program
- SCL = DOE’s Sensitive Countries List. This list includes countries labeled as
- CoR = Countries of Risk
- SST = State Sponsors of Terrorism
- “Other Designated Countries” on the SCL
Who does FNAP apply to at the Lab?
| Foreign National Access Program requirements apply to all foreign national employees, affiliates (including users), and most visitors (see exemptions below). FNAP requirements do not apply to U.S. citizens. FNAP requirements vary depending on the individual’s birth location, citizenship, or organizational affiliations. Individuals associated with a country on the Sensitive Country List (SCL) face differing access approval workflows and have a higher risk of not being approved. Foreign nationals from countries designated by the federal government as State Sponsors of Terrorism (SST) countries remain prohibited from site access unless they meet certain exemption criteria. |
For potential foreign national employees and affiliates, when do DOE-required reviews need to be completed for access to be granted?
| Foreign national employee and affiliate candidates from DOE’s Sensitive Countries List (SCL) must complete DOE reviews before their appointment start date. All other foreign national employee and affiliate candidates may complete reviews after their start date. Please see this flow chart for specifics: View a flow chart of these access timing requirements. |
For foreign national visitors, when do DOE-required reviews need to be completed for access to be granted?
| All foreign nationals visiting Lab sites must be processed through DOE. Foreign national visitors from a country not on the SCL may be permitted to access the Lab before DOE reviews are complete. For foreign nationals from countries on the SCL, these individuals must be granted DOE approval before access is permitted. See a flow chart of the differences. Certain visitors are excluded; see questions below. |
Who counts as a foreign national?
| Anyone not holding U.S. citizenship is considered a foreign national. U.S. Green Card holders, legal permanent residents, and visa holders are not naturalized U.S. Citizens; they are considered by DOE to be foreign nationals. If an individual was born with citizenship in another country and has become a naturalized U.S. citizen, they are no longer considered a foreign national and FNAP does not apply to them. |
What countries are on the DOE Sensitive Countries List?
| Sensitive Countries include countries labeled as “State Sponsors of Terrorism,” “Countries of Risk” and “Other Designated Countries”. All CoR are considered Sensitive Countries, but not all Sensitive Countries are CoR. A shared drive hosts the list and is available to anyone with an @lbl.gov email. Follow these steps to gain access. |
What additional information do current foreign employees and affiliates need to know about FNAP?
| While current foreign national Lab employees and affiliates have already completed their initial DOE reviews and have been granted access, DOE reviews happen again every 2 years from the appointment date or if there is a change made to the appointment. Successfully passing these continued reviews is required to maintain access and employment. These biennial reviews are initiated by FNAP and not the employee/affiliate or their supervisor. Additionally, foreign national employees from CoR are restricted from hosting visitors from any country on the Sensitive Countries List. For more information, see a separate question below. |
When it comes to receiving an appointment at the Lab, what do we mean by “access”?
| Broadly speaking, DOE defines access both in terms of physical (i.e. site access) and intellectual (remote access). LBNL’s application of these requirements for those not physically on site varies depending on the systems and information being accessed. Successful passing of DOE reviews is required for employment and physical site access including for remote employees. Please read the Lab’s Terms and Conditions of Employment for more information. |
Why does DOE require these reviews for foreign nationals and who at the Lab runs this program?
| Reviews are a required component of the DOE process for screening foreign nationals who have visits and appointments at National Labs. The primary objective is to ensure the individual’s engagement with the Lab is fully consistent with national security interests and compliance requirements. The Lab’s FNAP team within the SES Division formally initiates a review by documenting the access request in the DOE Foreign Access Central Tracking System (FACTS). Once reviews are complete, our local DOE Counterintelligence (CI) Office conducts a final review and provides a formal sign-off to grant access, and that the appointment is approved and/or the individual may come on site. |
How long do DOE reviews take?
| We ask that cases be submitted 60 calendar days prior to the desired appointment date or visit to allow sufficient time for DOE reviews to be completed. While reviews may be completed sooner and others may require additional time, this estimate is based on known processing time data from prior cases. We understand this may impact desired appointment start dates, visits, and events. We are continuously exploring ways to minimize these impacts and build efficiencies to our local processes. |
Is it possible to not be approved for access?
| Yes, it is possible for a foreign national employee, affiliate, or visitor’s access to not be approved by DOE. Successful passing of these reviews is required to maintain access and employment. For more information, please read the Lab’s Terms and Conditions of Employment. |
If a foreign national employee or affiliate successfully completes DOE reviews and is granted access to LBNL, are they automatically granted access to other national labs?
| No, DOE applies location-specific criteria. This means that an individual approved at LBNL may not be granted access to another site, and vice versa. |
How do FNAP approvals impact the length of the recruitment and onboarding cycle?
| In general, we are advising that the recruitment timelines account for an additional 60 calendar days for those employees and affiliates whose DOE-required reviews must be completed prior to their start date, and to anticipate potential delays in start dates. This guidance applies to both on-site and remote employees and affiliates. |
Will the DOE reviews occur before or after an offer of employment is made to a foreign national candidate?
| Typically DOE reviews occur after a conditional offer of employment is made. Prospective employees will receive conditional offers of employment while cases are being reviewed. If needed, the HR Solutions Center will work with the hiring manager to adjust the start date accordingly. If the individual came on site for their interview they will already have a current FACTS case with DOE and their processing time for their appointment will be less. |
How do we obtain site access for foreign nationals who are invited for a job interview?
| A new foreign national access request must be submitted for on site job interviews because these are considered a visit and therefore require site access approval. We understand that delays in scheduling in-person interviews create challenges in a competitive hiring environment. Therefore, we recommend that hiring managers be aware of these timelines and coordinate with administrative staff as soon as they identify a candidate they wish to interview on site. Some groups have found success with beginning the approval process immediately after candidate screening is completed. While it may take up to 60 days to get site access approval, we are finding that many candidates receive approval in time for the interview. Beginning the approval process early, while separately scheduling a Zoom panel interview in the interim, can help reduce delays and allow for a later site visit once DOE approval has been granted. |
I would like to host a foreign national visitor on site, what is the visitor access process?
| The first key is to submit visitor access requests as early as possible. These reviews may take up to 60 calendar days to complete. Use this new form for individuals from a country on the Sensitive Country List (SCL). The process for visitors from the U.S. or from countries not on the SCL continues to use the standard site access management form. |
I’m an employee from a CoR and I am restricted from hosting a foreign national visitor from countries on the SCL. What should I do?
| We understand this is a significant change that may impact your collaborations. Please work with your line management to identify an alternate qualified host. Hosts must complete host training (SEC 505), be on site during the visit, have knowledge of the activities being performed, and not be from a CoR if hosting someone on the Sensitive Country List. |
What if there are completed DOE reviews for a visitor previously? How long do the reviews last?
| DOE reviews are valid for two years. If the visitor has cleared the checks within two-years of the current request being reviewed, they may experience shorter processing times. With that said, it is best to plan for a full 60 calendar days for access processing. |
How is the status of DOE reviews communicated to the host?
| The only notices the host will receive is when the visitor requires indices checks prior to coming on site, and then when the site access request has been approved. There are no status updates in between. We suggest planning for 60 calendar days for indices checks to clear. |
Does FNAP apply to public events?
| No, FNAP requirements do not impact public events. Please follow the public events approval request process and continue with the normal processes for visitors and participants. |
Does FNAP apply to off-site events?
| No, FNAP requirements do not impact how we conduct offsite events at this time. However, keep in mind that site access refers to not only our main Lab site, but Potter St., JBEI, ABPDU, and any off-site excess property & storage facilities as well (see a list of off-site facilities here). Any individual planning to come to any of these locations will need to complete all DOE-required reviews beforehand if they are a foreign national (with the exception of users as outlined in a previous question). |
Are there exemptions to these requirements?
| Yes. Children under 18, vendors, deliveries, rideshares, emergency response personnel, or construction contractors are exempt from FNAP and DOE-required reviews. |
Will I be required to take additional training?
| SEC 0505 – Hosting Foreign National Visitors/Assignees is periodically updated to reflect any changes to foreign national access requirements. Anyone who hosts a foreign national as a visitor or affiliate is required to take this updated training, even if they have previously completed an earlier version of the course. |
Why do DOE review requirements or processes change periodically?
| The DOE may continue to evolve its FNAP or FNAP approval workflows in response to changes in risk or research security, and in line with other federal efforts around national security. We understand that uncertainty is difficult. Our top priority is preserving our scientific mission and supporting our people. SES is working closely with key stakeholders inside and outside the Lab to communicate and implement any changes with as little impact to research and operations as possible. |
For any critical questions not answered by these FAQs, please reach out to FNAP@lbl.gov.
