Export Controls:
Foreign Travel
During foreign travel, researchers often 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.
International Travel related to Sponsored Research
When completing your Travel Authorization for international travel, you will be asked to certify that you have read this page: Export Control International Travel.
Before foreign travel, it is important to consider:
- Where are you going?
- What will you bring?
- Who will you be talking to?
WHERE are you going?
The destination determines what export controls or regulations apply. There are several websites to check in advance of international travel.
- 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
If you are traveling to an OFAC-sanctioned country, you may need a license to spend certain funds in that country. As an example, under the Iranian embargo, you are permitted to spend money on hotels, food, or transportation without a license, but you may need a license from the Treasury Department in order to contract with local individuals and purchase certain supplies for research.
WHAT will you bring with you?
Laptops and other Electronic Equipment
If you will be bringing a laptop computer, it is a recommended best practice for foreign travel to take a “clean laptop” which is a laptop that does not include any export restricted hardware, software, data or information. This is especially true when traveling to China. URI Information Security provides more detailed travel recommendations for protection of both physical assets and data.
If a “clean laptop” is not an option you must consider the technical data and software contained on that equipment that would otherwise be controlled as an export fall under these still qualify as an export if carried out on a laptop. Fortunately, there are exceptions that cover the majority of personal and professional activities most researchers engage in while abroad.
License Exceptions for Travel 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 URI’s Export Control Officer to confirm, as this exception requires that records be kept of their use.
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 Sponsored Projects administrator.