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When traveling abroad there are four basic questions to consider when determining if export controls apply to your travel.
Where are you going? Country Sanctions and Restrictions
In general, travel to most countries is not a problem with the exception of Cuba. In almost all cases, travel to Cuba requires a license from the Treasury Department. Research or other activities may be restricted in comprehensively sanctioned countries (i.e., Cuba, Iran, Syria, Sudan, and North Korea). The U.S. Treasury Office of Foreign Assets Control maintains the sanction regulations, which are unique to each country.
All UMB travelers who will be traveling outside the United States for any period of time must register their international travel plans and furnish updated emergency contact information using the International SOS medical and travel security assistance service. This service is used for travel on UMB business only, whether or not travel will be reimbursed by UMB.
- International SOS information
- Register now
U.S. citizens traveling or living overseas are encouraged to register with the U.S. Department of State Smart Traveler Enrollment Program. Non-U.S. citizens should register with their country’s embassy in the destination country or countries. These registrations are recommended for travel on for both personal and business purposes.
Who will you be interacting with?
It is important to ensure that you do not accidentally export restricted information or provide any type of assistance or benefit to a sanctioned or blocked entity. The ORD export officers can assist with screening individuals that you plan to visit, and their organizations.
What are you taking with you?
When taking items abroad (including scientific equipment, computers, cell phones, and GPS units) you need to verify that the items are not export restricted based on your travel destination(s). For most low-tech, commercially-obtained items, an export license will NOT be required unless you are traveling to or through a comprehensively sanctioned country (i.e., Cuba, Iran, Syria, Sudan, and North Korea) in which case an export license will almost certainly be required – even for everyday items such as cell phones and laptop computers.
When traveling abroad, you are free to take and openly share or discuss any data or information resulting from Fundamental Research or that qualifies under the Educational or Public Information Exclusions. However, you cannot take or share data or information that is in any way export-restricted (e.g., related to export controlled technologies, proprietary information, or is information resulting from a project not protected under the Fundamental Research Exclusion). All controlled or restricted data or information should be completely removed from laptops, phones, PDAs, or other portable storage devices (e.g., flash drives) before you leave the U.S.
What will you be doing?
When presenting data/information in an international setting (including in the U.S. where the audience may include foreign nationals), you need to ensure that you limit your presentation to only information or data that is published, or is publicly available, or that qualifies as Fundamental Research. Be careful not to include or discuss any proprietary, unpublished, or export-restricted data or information as that may constitute an unauthorized export.
You are free to openly discuss any published or publicly available information or information generated as the result of Fundamental Research as long as the recipient is not a sanctioned or specially designated entity. It is important to remember that while the results/information resulting from Fundamental Research are not subject to export controls and can be shared without a license, any items, technology, or software generated under that Fundamental Research would be subject to export controls and may require an export license.
Any university research activity done outside the U.S. may not qualify for the Fundamental Research Exclusion and would therefore not be protected from export controls until the work is published or otherwise made publicly available. Before disclosing or sharing information or data resulting from international field work, it is important to ensure that the information is not export restricted.
In order to ensure compliance with OFAC regulations prohibiting the university from providing material or financial assistance to any blocked or sanctioned individual or entity, any UMB activity that involves payment to a non-U.S. person, business, or organization must be verified against all appropriate sanctioned party and entity lists.