Foreign Travel Issues
Foreign travel creates opportunities for the researcher to have interactions with individuals and entities from foreign countries that may be subject to restrictions under the U.S. export laws and regulations and to export both items and technical information that may be controlled. University personnel responsible for arranging meetings or travel abroad, or researchers involved in such meetings should be aware of the requirements of the Foreign Corrupt Practices Act.
For University researchers involved in international travel, including faculty, staff, and students, the following University websites should be reviewed:
In addition, every researcher should consider before traveling abroad:
WHERE are you going?
University Travel Website
U.S. Department of State’s Current Travel Warning Website
U.S. Department of the Treasury Office of Foreign Assets Control Website - Check for sanctions or embargoes - For travel to Cuba, please see the Vice Provost for International Initiatives
WHO will you be talking to?
There are individuals and entities that U.S. citizens are prohibited from engaging in financial transactions under the U.S. laws and regulations. Before traveling to a foreign country, a researcher should find out who these restricted parties may be in the country(ies) to which they will be traveling. A restricted party screening only takes seconds and can be performed by your ORPA administrator.
WHAT will you bring with you?
Laptops (see Information Technology’s “...traveling out of the country with encryption software”)
Equipment, Technical Data, or Software – Please refer to the following FAQs:
"How are exports transferred"
"If I'm traveling abroad what should I be concerned about?"
"If I'm speaking to a foreign company or a foreign national, what should I be concerned about?"
"How do I determine if equipment or technical information I want to send out of the country is controlled?"
WHAT are the exceptions to license requirements and WHEN do they apply?
There are two License Exceptions that can be used for items that researchers may be taking abroad. The License Exception for temporary exports/reexports (TMP) includes laptops, PDAS, and other digital storage devices, items controlled under the EAR. When those items (and related technology and software) are being used for professional purposes, returned within 12 months, kept under effective control of the exporter while abroad (i.e., kept in a hotel safe or other secured space or facility), and other security precautions are taken against unauthorized release of technology (i.e., use of secure connections, password systems, and personal firewalls), the TMP License Exception may apply. The TMP License Exception might not apply if items are shipped or carried to certain OFAC-sanctioned countries such as Iran, Syria, Cuba, North Korea, or Sudan. It also does not apply to items, technology data or software regulated under ITAR.
The License Exception for baggage and personal items and technology (BAG) can be used for travel outside the U.S. when you are taking PERSONAL items or technology that would normally require a license from the Department of Commerce. The items must be owned by the individual, intended for appropriate use by the individual and not intended for sale or disposal. For example, if you plan to take your personal laptop rather than a university laptop when attending a conference or conducting research abroad, and you are taking controlled technology, software, or other information that would require a license, the BAG license exception is available.
If you have any questions about the use of this TMP or the BAG exceptions, please contact ORPA to confirm, as this exception requires that records be kept of their use.