International travel by University employees or students may be subject to export control regulations depending on the destination, equipment, data, and/or software carried by the traveler.
USU’s International Travel Policy, Policy 536, requires individuals who plan to travel abroad to register in International SOS, USU’s travel registry, prior to departure.
Where Are You Going?
While travel to most countries does not require an export license, the U.S. government has sanctioned or embargoed activity with certain countries. Travel to sanctioned or embargoed destinations is subject to federal licensing and trade sanction regulations which regulate and sometimes prohibit travel and other interactions (research, teaching courses, etc.) with such countries.
Travelers should consult directly with the Research Integrity & Compliance Office as soon as they anticipate travel to the following countries: Cuba, Iran, North Korea, Syria, Crimea, or the Donetsk or Luhansk regions of Ukraine.
Even though you may be able to travel to a particular country without an export license, you may still need an export license to conduct certain activities, or to bring equipment, data, or software with you abroad.
What Are You Taking With You?
When taking items abroad, travelers need to verify that the items are not export restricted. Export restrictions are based on both the item and the country of destination.
Researchers commonly travel with commercially available electronics such as laptops, cell phones, tablets, flash drives, and other storage devices. Many of these items can be temporarily “exported” under the EAR “Temporary Exports-Tools of the Trade” (TMP) exception.
In order to qualify for the TMP license exception, the traveler must verify that the devices:
- Are being used for a professional purpose;
- Will be returned to the United States within 12 months;
- Will be kept under the effective control of the traveler while abroad (i.e., the traveler must keep the device on their person, or in a hotel safe at all times); and
- Incorporate the use of security precautions (i.e., use of Virtual Private Network (VPN) connections, password systems, and personal firewalls) to prevent an unauthorized release of controlled equipment, data, or software.
NOTE: The TMP exception may not be claimed when traveling to Cuba, Iran, North Korea, or Syria.
You should NEVER take any of the following equipment, data, or software abroad without first consulting the Research Integrity & Compliance Office:
- University owned equipment beyond the commercially available items mentioned above
- Proprietary data or information received under an obligation of confidentiality
- Patentable or classified information
- Data or analyses that result from a project for which there are contractual constraints on the dissemination of the research results
- Equipment, data, or software received with restrictions on export to or on access by foreign nationals
- Equipment, data, or software that was specifically designed or modified for military or space applications
- Technology subject to the International Traffic in Arms Regulations (ITAR) or regulated by the Nuclear Regulatory Commission
If a traveler wishes to take export controlled equipment, data, or software with them abroad, they should coordinate with the Research Integrity & Compliance Office to apply for and obtain an export license from the appropriate federal agency prior to travelling.