Federal export and sanctions regulations prohibit the unlicensed export of specific commodities, software, technology and payments to or from certain countries, entities and individuals for reasons of national security, foreign policy or protection of trade. University employees are required to comply with United States export and sanctions regulations when traveling abroad with commodities, software, and technology.
The Office of Research Integrity and Export Controls (ORI-EC) can assist with export and sanction determinations related to your international travel. You will find helpful information below concerning international travel procedures and best practices to ensure compliance with these federal regulations. If you have any questions pertaining to international travel not covered on this page, please contact Linda Morris at firstname.lastname@example.org or 303-492-2889.
In accordance with the PSC travel policies and procedures, international travelers (including presenters, students, visitors, and other business associates) whose travel expenses are to be charged to university public funds (e.g., sponsored programs, foundation, operating, various, etc.) should contact ORI-EC if they are traveling to another country with equipment or information subject to export controls.
Presentations and discussions must be limited to topics that are not related to controlled commodities, software, or technology unless that information is already published or otherwise already in the public domain.
Verify that your technology or information falls into one or more of the following categories prior to travelling:
Do not take any commodities, software, or technology that fall into one of the following categories:
When taken outside of the United States(3), university property such as commodities, software, and technology (hereafter called items) may be subject to export licensing under the Export Administration Regulations (EAR) or regulations by other government agencies. Many items such as laptops, tablets, cell phones and PDA’s containing commercial software, may be temporarily exported as "tools of trade" under the export license exception TMP. "Tools of Trade" can be simply defined as items that are used for university business, conferences, trade shows, etc. The TMP exception only applies to university property. For information on encryption items, please contact the Office of IT Security to review the level of encryption and determine the proper registration requirements.
License Exception BAG allows individuals departing the US either temporarily (travel) or longer-term (relocation) to take with them as personal baggage family-owned retail-level encryption items including laptops, personal digital assistants (PDAs), and cell phones and encryption software in source or object code. The encryption items and software must be for their personal use in private or professional activities.
**These exemptions do not apply to any equipment, components, technical data or software specifically designed for military, space, or intelligence applications or otherwise controlled under the International Traffic in Arms Regulations (ITAR). Nor do they apply to any nuclear or atomic energy items regulated by the Nuclear Regulatory Commission (NRC) or Department of Energy (DoE). In these cases, please contact ORI-EC at email@example.com.**
Restricted Party Screening (RPS) is an essential component of export compliance. RPS determines if the individuals and companies with whom you desire to do business are on any government issued restricted, blocked, or denied party lists. Request a restricted party screening for entities and individuals with whom you will be doing business!
During your travel, if you are contacted by one of these entities or individuals, please record as much information as you can about the incident and contact this office at firstname.lastname@example.org or 303-492-2889.
(1) See our Definitions page for more information on Fundamental Research and Public Domain exclusions.
(2) In some cases, education in the form of technical assistance (particularly with regard to military or space applications) may qualify as a defense service and would not be covered under this exclusion.
(3) United States. Unless otherwise stated, the 50 States, including offshore areas within their jurisdiction pursuant to section 3 of the Submerged Lands Act (43 U.S.C. 1311), the District of Columbia, Puerto Rico, and all territories, dependencies, and possessions of the United States, including foreign trade zones established pursuant to 19 U.S.C. 81A-81U, and also including the outer continental shelf, as defined in section 2(a) of the Outer Continental Shelf Lands Act (43 U.S.C. 1331(a)).
Substaintial portions of these guidelines have been taken, with permission, from the Virginia Tech website on export controls.