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 to export both items and technical information that may be controlled.
For University researchers involve in international travel, including faculty, staff and students, the following University websites should be reviewed:
Office of International Programs (guidance for undergraduate students)
In addition, every researcher should consider the following before traveling abroad:
WHERE are you going?
Travel to countries subject to US government sanctions (i.e. Cuba, Iran, North Korea, Sudan and Syria) may require US government authorization. This includes travel for purposes that would not otherwise be subject to US export control laws, such as participation in an open conference. In addition, all travelers to Cuba should contact the Vice Provost for International Initiatives for detailed information about Princeton's initiatives in Cuba.
All travelers are encouraged to review the following websites for information on the countries to which they plan to travel:
All travelers are encouraged to upload their itinerary and contact information into TripIt Pro. This will allow the university to contact the traveler in the event of an emergency.
Finally, all international travelers should remove information or data provided by US Department of Defense agencies (e.g. AFRL, ONR, DARPA, AFOSR, etc.) prior to departure. Simply leaving the US with such data (unless licensed by the US government) is considered to be a violation of US export control regulations.
WHO will you be talking to?
U.S. citizens are prohibited from engaging in activities with individuals that have been determined to be acting contrary to the interests of the US. In addition, US persons are prohibited from engaging in financial transactions with certain individuals and entities. Before traveling to a foreign country, a researcher should screen any known contacts against these lists of restricted parties. A restricted party screening takes only seconds and can be performed by your ORPA administrator.
WHAT will you take with you?
Before taking equipment other than your laptop, cell phone or other common items, consult with ORPA's Assistant Director of Export Controls.
- All confidential or proprietary information should be removed from laptops, cell phones or other electronic devices. Alternatively, "loaner laptops" may be available in some departments. Also see Information Technology's, ". . .traveling out of the country with encryption software".
- It may be possible to minimize or eliminate duties and taxes related to the import/export of equipment or commodities in certain circumstances. However, adequate time must be provided in order to investigate the options and obtain the necessary documentation.
- Keep in mind that each country has its own requirements related to imports and exports. Just because a piece of equipment does not require a US export license does not mean it will not require an import permit for entry into the foreign country.
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?"
WHY are you going?
US law prohibits the export, re-export and certain transfers of equipment or technical data related to the following:
- Chemical and Biological Weapons
- Nuclear explosives
- Rocket/missile systems
- Unmanned Air Vehicles
- Maritime nuclear propulsion systems
- Weapons of Mass Destruction, including
- Chemical weapons
- Biological weapons
- Nuclear weapons
- Military end-uses or end-users in China, Russia or Venezuela
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 take overseas. The License Exception for temporary exports/reexports (TMP) includes laptops, cell phones, PDAS, and other digital storage devices, 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 (i.e. items, software or technical data controlled for military or space applications.) .
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,used 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, 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.