Ethics, Compliance and Audit Services
Traveling overseas with high tech equipment, confidential, unpublished, or proprietary information or data - Traveling with certain types of high tech equipment including but not limited to advanced GPS units, scientific equipment, or with controlled, proprietary or unpublished data in any format may require an export license depending on your travel destination. 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. ECAS can assist with export and sanction determinations related to your international travel. Helpful information may be found below concerning international travel procedures and best practices to ensure compliance with these federal regulations.
International Travel Tips and Additional Information
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 traveling:
- Research that qualifies as fundamental research
- Published information
- Publicly available software
- Educational information
Check with your local export control contact prior to traveling with any commodities, software, or technology that fall into one of the following categories:
- Controlled Unclassified, or Export Controlled or information under any other restriction including 3rd party proprietary information received under a non-disclosure agreement (NDA)
- Limited Distribution, Proprietary, Confidential, or Sensitive
- Specifically designed for military, intelligence, space, encryption software, or nuclear related applications
- Data or information received under a Non-Disclosure Agreement
- Data or information that results from a project with contractual constraints on the dissemination of the research results
- Computer software received with restrictions on export to or on access by non-US Persons
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. Contact your local export control resource to request a restricted party screening for entities and individuals with whom you will be doing business.
- Countries on EAR Entity Chart (15 CFR 744, Supp. 4): China, India, Israel, Pakistan, Russia (countries with restricted entities on the EAR "entity chart" at 15 CFR 744, Supp.4)
- Office of Foreign Assets Control (OFAC) Embargoed Countries: Cuba, Iran, Iraq, Libya, N. Korea, Burma (Myanmar), Liberia, Sudan, Syria, Zimbabwe. See Sanctions Program and Country Summaries for more specific information.
- Other US Embargoed Countries: Rwanda and the OFAC embargo list
- ITAR Prohibited Countries: Afghanistan, Belarus, Cuba, Iran, Iraq, Libya, N. Korea, Syria, Vietnam, Burma (Myanmar), China, Haiti, Liberia, Rwanda, Somalia, Sudan, or Zaire (Democratic Republic of the Congo), any UN Security Council arms embargoed country (e.g., for certain exports to Rwanda)
- Denied Persons List (A list of individuals who are denied export privileges by the Commerce Department)
Countries for which exemptions may be available
- NATO Countries: Belgium, Canada, Czech Republic, Denmark, France, Germany, Greece, Hungary, Iceland, Italy, Luxembourg, The Netherlands, Norway, Poland, Portugal, Spain, Turkey, UK, USA
- Strong Non-NATO Allies: Argentina, Australia, Bahrain, Egypt, Israel, Japan, Jordan, Kuwait, New Zealand, Philippines, Republic of Korea (S. Korea), Taiwan, Thailand
- EUROPEAN SPACE AGENCY Countries: Austria, Belgium, Denmark, Finland, France, Germany, Ireland, Italy, the Netherlands, Norway, Portugal, Spain, Sweden, Switzerland, the United Kingdom
- The EUROPEAN UNION: Belgium, Denmark, Germany, Greece, Spain, France, Ireland, Italy, Luxembourg, the Netherlands, Austria, Portugal, Finland, Sweden, the United Kingdom
International Field Work – Research projects where any part of the research will take place outside the U.S. (e.g., field work outside the U.S.) may not qualify under the Fundamental Research Exclusion and may be subject to export controls. For help in determining potential export control issues see your local export control contact.
International Consulting – Providing professional consulting services overseas may require an export license, and providing professional consulting services embargoed or sanctioned countries (e.g., Iran, Syria, Cuba, Sudan and North Korea) is, in most cases, strictly prohibited.
Tools for international travel
- iJet and UC Travel
- Travel Advisories are provided by iJet for all international travelers who register.
- FCPA Course
- Consolidated screening
- Ten Things You Must Know Before Taking Your Laptop Overseas
- Visual Compliance RPS
International Travel Links
- Department of State Country Specific Information
- Department of State Travel Warnings and Alerts
- Traveling Light in a Time of Digital Thievery