Export Control and Travel

International Travel

US Department of State and Federal Bureau of Investigation (FBI) travel guidance
Traveling with UMBC owned equipment and personal items
UMBC DoIT Information Security Travel Tips
Sanctioned Countries

When planning a trip abroad, travelers should be familiar with export controls and embargoes. Export control regulations may come into play when:

  • Taking items with you when you travel, such as
    • Laptops
    • Encryption products (hardware and software)
    • Research data or technology
    • Blueprints, drawings, schematics, prototypes
  • Attending “closed” conferences or meetings (are not open to all technically qualified members of the public, you cannot take notes, or may come with a request to complete a form DD2345).
  • Money transactions and the exchange of goods and services (country specific)
  • Travel to sanctioned or embargoes countries no matter what the purpose
  • Doing business with certain people or entities
  • Providing a Defense Service to a foreign person

You must ensure that any information that you will discuss or any proprietary, unpublished, or export-restricted data or information as that may constitute an unauthorized export items. Because you, as an individual, and UMBC can be held liable for improperly transferring controlled items or technology, it is important that you review the federal requirements. Most travel outside of the U.S for conferences will fall under an exclusion to the export control regulations and does not require a license when the sole purpose of the meeting is to present research findings that have been or are intended to be published, provided they do not concern detailed information regarding controlled items or technologies (information and items subject to Export Controls).

As you plan your trip, verify your technology or information you are taking with you falls into one or more of the following categories prior to travelling:

US Department of State and Federal Bureau of Investigation (FBI) travel guidance

The US Department of State provides detailed information regarding any International Travel Information including warnings, country specific information, travel alerts, and general tips for traveling abroad. Also recommended is enrolling in The Smart Traveler Enrollment Program (STEP), a free service to allow U.S. citizens and nationals traveling and living abroad to enroll their trip with the nearest U.S. Embassy or Consulate. STEP provides travelers with information from the destination country embassy about safety conditions, help making informed decisions about travel plans, and provide U.S. Embassy contact information about the traveler in the event of an emergency, natural disaster, civil unrest, or family emergency, and help family and friends get in touch with persons in an emergency.

The FBI provides useful information for students and business travelers who go abroad, best practices for academics to follow (courtesy of University of Denver, Information Technology), as well as a training video to help raise awareness of the foreign intelligence recruitment threat to U.S. college students while studying overseas. The FBI has developed information on avoiding the loss of intellectual property and theft of research related data during the course of collaborations, conversation or tours of UMBC facilities. For more information , click on the below:

Traveling with UMBC owned equipment and personal items

The U.S. Office of Foreign Assets Control maintains economic and trade sanctions on countries or regions to accomplish foreign policy and national security goals. If you will be taking a UMBC laptop or other common electronic devices to a foreign country, please ensure that there is no encryption source code or technical know-how (e.g. designs, schematics, non-public technical data) on your device. Generally, as long as you retain your devices under your personal custody and effective control for the duration of your travel, do not intend to keep these items in these countries for longer than 1 year, and are not traveling to Cuba, Iran, North Korea, Sudan or Syria, no government export license is required.

Access to email or internet services would also require travelers to ensure connections to these services are safe and secure. UMBC uses Duo to provide options to meet your needs when traveling. Before leaving, review DoIT’s wiki article “What do I need to know before traveling with Duo?” for guidance on adding a device and using Duo options and advice on using Duo if trips are planned for travel to embargoed countries. 

Any physical materials, electronic devices, research or technical data in your possession is considered by US regulations to have been “exported” from the US to your final destination and any intermediate destinations. There are exemptions from export licensing available for travelers carrying both university-owned equipment (“TMP”)  and personal items (“BAG”). These exemptions are intended to cover commercially available computer equipment and other electronic devices used in business or general science applications.   These exemptions DO NOT cover technology designed for a military application.

The TMP and BAG exemption have limitations that travelers need to understand:

  • Travel to Iran, Syria, Cuba, North Korea and Sudan is not eligible for these exemptions
  • Length of trip is limited to 12 months; a license may be required for longer periods
  • Items must remain under “effective control” of the traveler at all times, meaning keeping your laptop computer, PDA, cell phone, data storage devices and encrypted software under your personal custody and effective control for the duration of your travel keeping it secured in a place such as a hotel safe
  • These exemptions do not cover any hardware controlled under the United States Munitions List (USML)  and high-tech encryption products (generally over 64 bit)
  • Travelers cannot possess “controlled technical data” defined as “data required for the design, fabrication, operation, or maintenance of military or dual-use technology, and, not in the public domain or otherwise exempt from licensing requirements”.

(information courtesy of Adam Grant, UMCP Export Controls Office)

The ORPC recommends travelers obtain departmental authorization using the UMBC Off Campus Equipment Loan Form while making travel arrangements.  Additionally, travelers planning to take research data out of the country should review the Office of Sponsored Programs Data Use Agreements webpage for information about how this agreement will assist with the transport and sharing of data with international  collaborators. 

Tools of the Trade Traveler Certification Letter

The ORPC has created a “Tools of the Trade” Traveler Certification Letter for international travelers carrying university-owned equipment or research data to confirm and certify that they meet the requirements of the exemption.  The letter serves as a document that can be carried with the traveler and shown to US or foreign customs agents in the event that they are questioned about the content of their belongings.  While there is no way to guarantee that the letter will prevent searches and seizures, it may demonstrate that the traveler is familiar with the regulations and responsible for the equipment that they are exporting. Please follow the directions to complete and return to the ORPC at compliance@umbc.edu at least five (5) days prior to leaving for your travel.

 

UMBC DoIT Information Security Travel Tips

Follow the IT Security – DoIT myUMBC page for information technology and security. Valuable travel tips are posted; take time to read these before your next trip.

Other University Equipment

Researchers frequently need to take other university equipment temporarily outside of the United States for use in university research. Often, but not always, the tools of trade license exception applies. Some equipment (e.g., global positioning systems (GPS), thermal imaging cameras, inertial measurement units, and specialty software), are highly restricted and may require an export license to take with you, even if you hand carry it. If you are taking university equipment other than your laptop computer, PDA, cell phone, data storage devices contact ORPC to determine if an export license or other government approval is required prior to your taking the equipment out of the country.

Sanctioned Countries

The Department of the Treasury (OFAC), Department of Commerce (EAR) and Department of State (ITAR) administer economic and trade sanctions and maintain lists of sanctioned programs, entities and countries that restrict transactions and travel, or require licensing in order to travel to a foreign country, or to conduct business with a foreign entity or individual. Before considering travel to embargoed countries to conduct research or educational activities, check first with ORPC.   Please review this webpage for more information.

Current travel advice for UMBC hosts 

The U.S. Department of State, Overseas Security Advisory Council, Bureau of Diplomatic Security recently issued travel advice for individuals coming to US from countries in the European Union, the UK and Ireland at the request of UMBC for research or scholarly activities. This advice provides information that will be useful to university hosts who plan to pursue visitors that hold travel visas, including F-1, J-1 and Hi-B.

Health Information for International Travel

The Centers for Disease Control and Prevention  (CDC)  offers a resource called the Yellow Book which describes current U.S. government travel health guidelines, including pre-travel vaccine recommendations, destination-specific health advice, and easy-to-reference maps, tables, and charts. Written by CDC’s travel health experts, the Yellow Book is provides a web based reference for travelers planning international travel.

 

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