Foreign Travel
About Foreign travel
U.S. export control laws are applicable to U.S. persons who travel internationally. Everything that accompanies you is considered an export, even if you have no intention of selling, loaning, lending, or transferring anything to a non-U.S. person while overseas. Important considerations during international travel include, but are not limited to:
- What you will be taking with you
- Where you will be going
- What you will be doing
Keep in mind that you must notify the Office of Research Security and Export Controls if your international travel will involve any of the following:
- Taking items or information enumerated on the United States Munitions List (items subject to the ITAR) with you – a license is mandatory.
- Taking items or information enumerated on the Commerce Control List (items subject to the EAR) with you – a license may be required.
- Traveling to Cuba, Iran, North Korea, Russia or Syria – there are very specific travel restrictions when traveling to an embargoed and/or sanctioned country and in many instances will require a license
- You MUST obtain an export license. Please contact the Office of Research Security and Export controls for additional guidance and information when traveling overseas with ITAR-controlled information.
- Keep in mind it will usually take at least several months to obtain an export license for ITAR-controlled information.
Travel to Sanctioned or Embargoed Countries
Belarus, Cuba, Iran, North Korea, Russia, Syria, and certain Regions of Ukraine (Crimea,
Donetsk, Luhansk)Depending on your destination(s), travel to a comprehensively or
heavily embargoed country may require prior authorization in the form of a license
from the U.S. Treasury’s Office of Foreign Assets Control (OFAC) or a documented exemption from the Office of Research Security and Export Controls.
OFAC administers and enforces economic and trade sanctions based on U.S. foreign policy
and national security goals, and issues both civil and criminal penalties for non-compliance.
No University equipment should be taken without prior approval and no University business should be conducted without prior authorization. Most activities involving comprehensively sanctioned countries (even remotely) will require a license.
- Strict export restrictions apply to U.S. persons traveling to Cuba, Iran, North Korea, Russia or Syria. Please contact our office if you are traveling to one of these four countries.
- Additional information on travel to, and export license requirements for, Cuba, Iran, North Korea, Russia or Syria can be found on the Bureau of Industry and Security’s Sanctioned Destinations website.
- The following countries also have travel sanctions, which are regulated by the Office
of Foreign Assets Control. Please review the list to determine if you will be traveling
to a country with certain US travel sanctions.
- Balkans-Related
- Belarus
- Central African Republic
- China
- Cuba
- Democratic Republic of the Congo-Related
- Iran
- Iraq-Related
- Lebanon-Related
- Libya
- North Korea
- Russia
- Somalia
- Sudan
- South Sudan-Related
- Ukraine/Russia-Related
- Venezuela-Related
- Yemen-Related
The University licenses the Descartes Visual Compliance software tool to perform Restricted Party Screening. Individual and entities belonging to the following categories (at a minimum) should be screened:
- International vendors and service providers (including scientific instrument purveyors and related support services)
- International commercialization partners
- International industry partners (sponsored research/other)
- Visiting international delegations to science and engineering laboratories
- Industry partners and University lab space
- Consignees of international shipments
- J-1 Exchange Visitors prior to the University issuing a DS-2019 and employees on University-sponsored nonimmigrant visas prior to filing a Form I-129 with USCIS
- International donors
- International institutions that are flagged during the course of COI/COC reviews
- International institutions identified by faculty as sabbatical host institutions
- Parties to international academic teaming and collaboration agreements (outside of OSP); international MOUs/MOAs
- International Material Transfer Agreement partners (receiving/sending)
- International instrument surplus disposition: recipient persons/entities
- International entities located in foreign countries of concern that are part of proposed international travel itineraries.
To prevent and minimize the possibility of unknowingly taking export-controlled information overseas, you are strongly encouraged to obtain a sanitized laptop to bring with you if you participate on projects involving export controlled information. The university has a laptop loaner program. Research should not be stored on personal devices and taken internationally.
Customs officials are authorized to search or retain electronic devices, including digital cameras, cell phones, media players, and disk drives as well as the items listed above, even without probable cause, to look for violation of export control regulations as well as other laws and regulations. Some considerations to avoid or minimize complications include:
- Don’t carry data you don’t want others to see: medical records, data files from your research, financial information, photos, etc.
- You should have a backup plan if there is data you will need when you reach your destination.
- Consider taking a device equipped with only ordinary, recognizable software and minimal data so any search can be fast and the consequence of a loss less disruptive.
Travelers are encouraged to consider the following questions in relation to items that may be exported during international travel:
- Will you be transporting (either through carry-on luggage or checked bags) laboratory instruments, tools, samples, raw materials, or prototypes for any reason (including, but not limited to, for your own research, a collaborative purpose, or to give to someone)?
- Will you be traveling with a portable electronic device that contains or stores proprietary export-controlled data, University of South Alabama confidential or proprietary data as defined by law or University of South Alabama policy, or data which is associated with an export-restricted research project or instrument that you have been or are working on currently (even if such data has nothing to do with the purpose of your immediate travel)?
- Will you be transporting any device that incorporates specialized scientific software (not including typical operational software such as Microsoft Office, Adobe, etc.) or software programs utilizing specialized cryptographic functionality (not including routine commercial laptop cryptographic protection)?
- Will you be providing any specific training or technical assistance to another individual, entity, or governmental institution (or representatives) beyond scientific collaboration in fundamental research?
Officials in any country may inspect your belongings, including electronic content of computers, phones, tablets, and storage devices. They may take possession of these items for various periods of time, and possibly permanently.
Included below are travel checklists as it relates to traveling with Electronics: