Foreign Travel Issues
Foreign travel creates opportunities for researchers to interact 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, please review the Office of International Education website.
In addition, every researcher should consider the following before traveling abroad:
Where are you going?
- U.S. Department of State’s Current Travel Warnings
- U.S. Department of the Treasury Office of Foreign Assets Control
- Check for sanctions or embargoes.
Who will you be talking to?
There are individuals and entities that U.S. citizens are prohibited from engaging in financial transactions under 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 (or countries) to which they will be traveling. A restricted party screening only takes a few seconds and can be performed by Jerry Mauck.
What are the exceptions to license requirements and when do they apply?
There is a license exception that can be used for items that researchers may take 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 OFAC-sanctioned countries. It also does not apply to items, technology data or software regulated under ITAR.
If you have any questions about the use of the TMP exception, please contact ORSP to confirm, as this exception requires that records be kept of their use.