University employees who travel internationally to teach or conduct research should be aware of the possibility of export license requirements for items, materials, or equipment that they carry with them. Hand-carrying items, materials, or equipment outside of the U.S. (even temporarily) is considered an export. Depending on the destination and the equipment involved, an export license may be required. In most cases, a license exception may be available, and is processed at the time of request for international travel. The Office of Research Compliance and Assurance will make this determination and provide the appropriate documentation. See list for sanctioned destinations.
Prior to traveling abroad there are three basic questions that university personnel must consider when determining if export controls apply to their travel:
WHERE ARE YOU GOING?
Generally, travel to most countries is not a problem, however, travel to sanctioned or embargoed destinations is subject to federal licensing and trade sanction regulations which heavily regulate and sometimes prohibit travel and other interactions with such countries.
WHAT ARE YOU BRINING?
Refer to the chart for the Export Control Classification Number (ECCN) for equipment most commonly taken abroad.
- Most commercially available basic software (such as Microsoft Office) is EAR99 and can be exported either individually or on your device without a license. Do not take any kind of encryption products (beyond the normal Microsoft Office Suite). Some encryption items may require a license or a documented exception if the product(s) are listed on either the Commerce Control List or the United States Munitions List (USML).
ECCNs for Common Travel Items*
*Do NOT use this chart for travel to Cuba, Iran, Sudan, Syria or North Korea
|Dell Laptop (no encryption)||4A994||No Licensed Required (NLR)|
|Mac Laptop||5A992||No Licensed Required (NLR)|
|IPhones & IPads||5A992||No Licensed Required (NLR)|
|Jump/Flash Drive (most)||3A991||No Licensed Required (NLR)|
|Android Cell Phone/Tablets||5A992||No Licensed Required (NLR)|
|Garmin GPS||7A994||No Licensed Required (NLR)|
|BitLocker Encryption||5D992||No Licensed Required (NLR)|
|GoPro Camera||EAR99||No Licensed Required (NLR)|
RESEARCH DATA & INFORMATION
Take only published, educational or research information intended for public distribution (such as a paper being presented at a conference, commercial software, and patent applications)
Do not take or share data or information that is in any way export-restricted, such as information about export-controlled technologies, proprietary information, or the results of a project not protected under the Fundamental Research Exclusion. Sharing these types of information may constitute an unauthorized export.
Foreign Collaborations: Publically available information or fundamental research can be shared with foreign colleagues so long as the recipients are not employees or representatives of the government of a sanctioned country, or restricted parties. This includes normal academic peer-review or publishing processes.
Maintain effective control of any USA items or equipment in your possession. This means you either retain physical possession of the item or you secure the item in such an environment as a hotel safe, or a locked or guarded meeting or conference facility. Avoid using other computers to log into a USA network or website. Consider any information or electronic component that leaves your possession and visual control for more than two minutes, compromised.
Rule of Thumb: If you don't need it, don't take it with you!
PROVISIONS OF FINANCIAL ASSISTANCE
In order to ensure compliance with OFAC regulations prohibiting the university from providing material or financial assistance to any blocked or sanctioned individual or entity, any university activity that involves payment to a non-U.S. person, business, or organization (e.g., international subcontracts, purchase of items from international vendors, or payments to research participants) must be verified against all appropriate sanctioned party and entity lists.
INTERNATIONAL TRAVEL LINKS