Export Controls:
International Travel

Please be aware of the following information when traveling abroad. When completing your Travel Authorization for international travel, you will be asked to certify that you have read this form.

Those traveling internationally are “exporters”. It is important to keep the following in mind:

  • Any tangible items that you are taking to a foreign country are considered “exports” by the United States Government, even if you are planning on bringing the items back upon your return.
  • Technical information located on your laptop’s hard drive or in a hard copy notebook is considered to be an export of “technology”/ “technical data”, once the laptop or notebook leaves the U.S.
  • Even technical know-how that is in your head, if shared with a foreign national, is considered to be a type of export.

When Planning Your International Travel:

If any of these factors apply to your planned travel, please contact the URI Office of Research Integrity before you travel by using the contact information provided below.

  1. Will you be traveling to a country subject to Office of Foreign Assets Control (OFAC) sanctions?

The Department of the Treasury’s Office of Foreign Assets Control (OFAC) prohibits varying types of transactions (e.g., financial, commercial, and even academic) and activities with or in foreign countries (or with their citizens, regardless of location) through its sanction programs.

Examples of OFAC sanctioned countries include:

Western Balkans Region* Cuba North Korea Ukraine
Belarus Iran Russia Venezuela
Burundi Iraq Somalia Yemen
Central African Republic Lebanon South Sudan Zimbabwe
Democratic Republic of the Congo Libya Syria  

* Western Balkans Countries: Albania, Bosnia and Herzegovina, Croatia, Montenegro, North Macedonia and Serbia

For the most up to date list, visit the OFAC website.

Each sanction program is different. Some programs broadly prohibit imports and exports of goods, technology and services to/from certain countries. Other programs only prohibit transactions with certain listed entities and individuals. Sanction programs change over time, sometimes rapidly.

  1. Will you be taking commodities or technical information found on the Department of Commerce’s Commerce Control List (CCL) or the State Departments US Munitions List (USML) with you? Will you be taking outside the U.S. any tangible items, information related to research, or other activities that support defense-related projects or objectives?

Your export items may be found on one of two lists. “Dual-use” items are located on the CCL. To locate Dual-use items, use the CCL searchable format available on the Electronic Code of Federal Regulations website. “Defense” articles are located on the USML in the State Department’s Directorate of Defense Trade Controls (DDTC) International Traffic in Arms Regulations. If provided sufficient notice before your international trip, the Office of Research Integrity can assist you with your search.

  1. Do you expect to enter into transactions with persons or entities that the federal government has determined must be excluded from such transactions?

We recommend that you search the Department of Commerce Consolidated Screening List for the foreign parties with whom you expect to interact professionally during your international travel. If provided sufficient notice before your international trip, the Office of Research Integrity can assist you with your search. In the event that a company, entity or person on the list appears to match a party potentially involved in your export transaction, additional due diligence should be conducted before proceeding. There may be a strict export prohibition, requirement for seeking a license application, evaluation of the end-use or user to ensure it does not result in an activity prohibited by any U.S. export regulations, or other restriction.

Data Security when Traveling Internationally
Theft of personal, proprietary, and sensitive data is a major concern. Consider the following before you travel:

  • Prepare your device for travel. If you cannot take a loaner device, sanitize your device by backing up the information and remove all information not needed during your travels. Ensure up-to-date protections for anti- malware, security patching and firewalls.
  • Minimize the information you take with you. Take the minimum amount of information needed for your travel. Do not take sensitive information (electronic or printed) with you as you travel. Evaluate the sensitivity of the information you are considering taking by knowing in many countries/cultures there is no expectation of privacy. Backup all information you do take and leave the backup at work. Remove all external storage media (e.g. CDs, USBs, etc.) from the computer before you travel.
  • Evaluate options and alternatives for E-Mail and select strategy. Consider establishing a temporary account for use while traveling. Yahoo, G-Mail, Hotmail, etc. all provide a reasonable set of capabilities while traveling and then can be discontinued on return to the United States.
  • Consider disabling all Bluetooth capabilities on smart phones, tablets, computers, audio devices, etc.

 
Visit travel and data security for additional information.

The Office of Research Integrity provides export license determination services and assistance in obtaining an export license if one is required. Just because an item is listed on the CCL does not mean that you cannot take it with you to your destination country. Export restrictions on CCL items vary, depending upon your destination country, those to whom you expect to release such items to, and how you expect they will use them. Even if a license is indicated for your export, it is usually possible to find a documented reason why technical information can be excluded from regulation or a license exception for exported tangible items.

If an item is controlled for export, license applications require 30-90 days to obtain approval from the government. DO NOT wait until the last minute! It is unlawful to export controlled items before obtaining a required license. Email the Office of Research Integrity for assistance with Export License Determinations.