When you travel abroad everything you take with you is considered an export, and depending where you go and who you interact with, it may be restricted. This applies not only to tangible items (scientific equipment, laptops, phones, smart devices, flash drives) but also to intangible items (software, research data, encryption code).
Perform a Restricted Parties Screening on potential collaborators and associated entities with which you plan to encounter. Alternatively, contact VEC to assist in a restricted parties screening.
Any travel to an embargoed country must be reviewed in advance by VEC. OFAC sanctions prohibit the transfer of assets (any value) and other transactions of embargoed countries. The countries with most comprehensive sanctions and embargoes are North Korea, Iran, Sudan, Syria, and Cuba. Check the Department of Treasury for the full list of current sanctions.
If you are taking Vanderbilt-owned property, some items may be temporarily exported as a “tool of the trade” under the Temporary Export Exception (TMP).
This exemption applies when these conditions are met:
- The item will be used to conduct Vanderbilt University business.
- The item will remain under the “effective control” of Vanderbilt personnel while abroad (physical possession or maintaining in a secure environment).
- The item will return to Vanderbilt within 1 year of departure or be destroyed.
|iPhone & iPad||5A992|
|Android Cell Phone/Tablet||5A992|
|Flash Drives (most)||EAR99|
|Commercially available basic software (Microsoft Office)||EAR99|
The TMP exemption is not valid for travel to the following countries:
- North Korea
Travelers are free to take and openly discuss any data or information that is published, in the public domain, is normally taught as part of a class or that resulted from Fundamental Research. However, you cannot take or share data or information that is in any way export-restricted, such as information about export-controlled technologies, proprietary information, or the results of a project not protected under the Fundamental Research Exclusion. Sharing these types of information may constitute an unauthorized export.
Please complete the International Travel Questionnaire to assist with export compliance analysis and denied parties screening. If you are taking Vanderbilt property out of the country, please fill the Temporary Export Certification. Email the completed form to firstname.lastname@example.org no less than 10 business days prior to departure.
Keep a copy of the completed documents for five (5) years past the last date of the visit.
General International Travel Best Practices
If you do not need it, do not take it with you!
- Take a loaner laptop or burner cell phone
- Utilize Virtual Private Network
- Use password systems and personal firewalls
- Disable Bluetooth
- Maintain “effective control” of your devices
- Protect your research; back up your data
- Assume Wi-Fi is secure
- Use internet cafes and untrusted networks
- Travel with or access any controlled or restricted data
It is illegal for U.S. persons to bribe a foreign official. Review the federal Foreign Corrupt Practices Act (FCPA) anti-bribery provisions.
You are responsible for securing information that is on your device, both personal and university owned. Once outside the U.S. you do NOT have privacy. Your property may be seized and searched without probable cause.
Keep export compliance documents and search results for 5 years past the last date of travel activity.
Other Travel Resources
Department of State International Travel Alerts and Warnings Embargoed Countries Best Practices
Going to an embargoed country?
The Department of Treasury, Office of Foreign Assets Control (OFAC) broadly regulates and restricts transactions with embargoed countries including certain academic collaborations and exchange of research materials and equipment. The most comprehensive controls apply to: China, Cuba, Iran, North Korea, Russia, Sudan, and Syria. The regulations are country/region specific.
For more information on a specific country:
Travel to the People’s Republic of China or the Russian Federation is not prohibited. However, cyber security is a large concern. U.S. travelers are believed to be priority targets for cyber-attack, particularly if they are known to be engaged in classified or proprietary research in a STEM (science, technology, engineering and mathematics) discipline. Electronic devices taken may be subject to involuntary governmental review and even complete duplication. They may also be successfully attacked and compromised without the user even knowing.
China does not allow the import of encrypted devices per the State Council Directive No. 273, Regulations on the Administration of Commercial Encryption. This regulation banned foreign encryption products, deemed all commercial encryption standards a state secret, and required that commercial encryption only be produced and sold by government authorities. An example of prohibited encryption is Virtual Private Network (VPN).
Russia has similar restrictions on the import of encrypted devices. Russia also requires advance approval to bring in satellite telephones. Global Positioning System (GPS) and other radio electronic devices, and their use, are subject to special rules and regulations in Russia.
- Assume your internet activity is private.
- Send any sensitive messages via email or access sensitive data.
- Open attachments, click unknown links, connect unknown USB devices or CDs.
- Use USB-based public battery charging stations; the USB interface to your device they may allow the charging station to do more than just provide power.
- Purchase new hardware while traveling; Do not purchase or download any new software.
- Have any of your electronic devices “repaired” or “worked-on” while abroad.
- Ensure your system is fully patched and has all institutionally recommended security software installed.
- Be aware your internet activity may be monitored.
- Power down your device whenever possible.
- Upon return, have your device inspected for compromise before hooking in to the Vanderbilt network.
If arrested, taken into custody, or interrogated, do not make any statements or sign any documents, particularly if they are written in a language you don’t know. Ask to have the U.S. Embassy or Consulate notified of your detention at once.
If you are considering travel to China or Russia, contact Vanderbilt Export Control as soon as possible to get an export control review of your plans and the types of items you would like to take so we can determine if any licenses would be required.
Although travel to Cuba is a hot topic in the news, it is still prohibited under most circumstances by U.S. State Department regulations. The recent change provides an exception under the Office of Foreign Assets Control (OFAC) general license for
It is very important that you check with OFAC to ensure that your conference or business purpose qualifies under the general license and/or a specific license. In addition, it is very important to note that while you may be authorized under the general license to travel to Cuba this does not automatically allow for the import of certain types of goods and or the provision of services. Additionally, there may be specific license requirements for equipment that you might need to take (e.g., laptop computers, cell phones, flash drives, other wireless/encryption technology, and other items). Cuban FAQs.
If you are considering travel to Cuba, contact Vanderbilt Export Control as soon as possible to get an export control review of your plans and the types of items you would like to take so we can determine if any licenses would be required.
Here is a link to the OFAC summary information on travel restrictions to Cuba along with information on who to contact if you have questions or need additional information.
Travel to Iran is not prohibited. However, prohibited transactions include exportation, re-exportation, sale or supply of goods, technology, or services to Iran. “Services” is broadly construed to mean providing anything of value, even if no money is exchanged.
Examples might be:
Providing technical assistance to an Iranian national in Iran or an Iranian institution
Providing unpublished data or research results to a person or institution in Iran
Teaching or lecturing as a guest of an institution in Iran
Conducting surveys and interviews inside Iran
OFAC publishes country-specific guidance on regulatory interpretation, but such guidance is not comprehensive. The Iranian Sanctions are updated frequently through publications to the Federal Register. If you are contemplating a collaboration with or research in Iran there may be licensing requirements. Licensing for Iran will take months to obtain approval and shipments or research timelines may be impacted.
General Don'ts regarding Iran:
Provide technical assistance or analysis to Iranian nationals that reside in Iran or to Iranian institutions that would constitute a “service” without an OFAC license.
Travel to Iran and bring anything other than personal belongings (note that if personal belongings include a controlled item, the item would still require a license) or equipment covered by an OFAC license. University owned equipment or material may require a specific export license.
Import from Iran or Export to Iran (apart from personal items you bring for personal use during travel) anything outside of informational materials or humanitarian donations without an OFAC license.
Transfer funds to Iranian financial institution or to an individual or entity on one of the government restricted party lists.
If you are considering travel to Iran, contact Vanderbilt Export Control as soon as possible to get an export control review of your plans and the types of items you would like to take so we can determine if any licenses would be required.
Travel to North Korea is generally not prohibited but if you plan to travel to North Korea, it is strongly recommended to consult the U.S. Department of State travel web page regarding such travel.
General Don’ts regarding North Korea:
U.S. persons are generally prohibited from engaging in transactions or dealings involving persons whose property and interests in property are blocked pursuant to North Korea-related authorities.
Although OFAC does not prohibit exports to North Korea per se, exports of goods and services to North Korea are generally subject to export controls administered by other agencies, including the Department of Commerce’s Bureau of Industry and Security (BIS). A license is required for the export or re-export to North Korea of almost all items (all items subject to the EAR other than food or medicines designated as EAR99).
Here is a link to the OFAC summary information on the North Korea sanctions program. If you are planning to travel to North Korea, you must consult the University’s Export Control Officer to determine if any licenses would be required.
Travel to Sudan is not prohibited. However, many transactions, including the provision of certain services, is prohibited or requires a license.
The following transactions are allowed under a General License:
donations of articles intended to relieve human suffering, such as food, clothing, and medicine;
the importation from and exportation to Sudan of information and informational materials whether commercial or otherwise, regardless of format or medium of transmission;
certain academic and professional exchanges with Sudan.
General Don'ts regarding Sudan:
- The importation to and exportation from the U.S. of goods and services is generally prohibited. Specifically, the following is prohibited:
The importation of goods and services of Sudanese origin;
The exportation and re-exportation to Sudan of goods, technology, or services from the U.S. or by a U.S. person;
The performance by a U.S. person of any contract in support of an industrial, commercial, public utility, or governmental project in Sudan
Note that on July 9, 2011, Southern Sudan gained its independence, becoming the new Republic of South Sudan, and was formally recognized by the United States Government. As of July 9, 2011, therefore, the Republic of South Sudan is no longer subject to the Sudanese Sanctions Regulations
Here is a link to the OFAC summary information on the Sudan sanctions program. If you are planning to travel to/research in Sudan, you must consult the University’s Export Control Officer to determine if any licenses would be required.
Travel to Syria is generally allowed although not advised. If you are planning to travel to Syria, please consult the U.S. Department of State website.
General Don’ts regarding Syria:
- You cannot directly or indirectly export, re-export, sell or supply any services to Syria with the exception of exports and re-exports of services in support of humanitarian and other not-for-profit activities in Syria by U.S. and third-country non-governmental organizations.
Here is a link to the OFAC summary information on the Syria sanctions program. If you are planning to travel to/research in Syria, you must consult the University’s Export Control Officer to determine if any licenses would be required.