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Export Compliance > Visas, Foreign Visitors & Travel

VISAS

FOREIGN VISITORS

TRAVEL

Deemed Exports & Visas

A “deemed export” is the transfer of export controlled technology or technical data to a foreign national within the United States. Exposing a non-citizen to export controlled information is considered the same as exporting information directly to that person’s country. It can occur not only when the technology or data is shared with a foreign national, but also when U.S. person provides technical assistance on the development, production, or use of export controlled technology to a foreign national. Methods of transfer can include email, visual inspection, conversation, observation, or demonstration.


What does this mean for Vanderbilt? Vanderbilt University and the Vanderbilt Export Compliance office (VEC) are committed to maintaining a free and open academic environment that supports and administers fundamental research. However, Federal Regulations require Vanderbilt to assess any potential export concerns, evaluate whether an export license must be obtained, and to certify to those findings prior to hiring or hosting a visitor. The Visa Deemed Export Questionnaire (VDEQ) will fulfill Vanderbilt's compliance requirement as well as help VEC determine if an export license is necessary and work with the PI/departments to develop best practices and resolve any concerns.


If you are sponsoring a potential employee, please complete the Visa Deemed Export Questionnaire to assist with export compliance analysis and denied parties screening. Email the completed form to vec@vanderbilt.edu and allow 10 business day for review.  


Keep a copy of the completed documents for five (5) years past the last date of the visit.

Foreign National Visitors

Foreign national visitors are invited to Vanderbilt from around the world to speak, collaborate and study. Before inviting a foreign national visitor (e.g., student, faculty, colleague, business), it is important to determine if an export license is needed. Vanderbilt needs to review t he following considerations:

  1. Is the visitor from a sanctioned country?
  2. Is the individual, their associated organization, or the funding source listed on the Denied Parties List (DPL)?
  3. Will the visitor be exposed to any technology or information that is restricted or proprietary in nature?

Use the Foreign National Visitor Form to assist with export compliance analysis and denied parties screening. Email the completed document to vec@vanderbilt.edu no less than 10 business days prior to the foreign national’s visit.


Keep a copy of the completed documents for five (5) years past the last date of the visit.

Foreign Visitor Best Practices

  • Advise, in advance, all areas and individuals affected by this visitor to ensure information, items, area, etc. are secured appropriately. Some situations may require a license from the federal government before a visitor may see a lab, research results, etc.
  • For immigration assistance contact Global Support Services (GSS). A Business Visitor Questionnaire may be necessary. Contact GSS on their website or via email at gss@vanderbilt.edu.
  • For international tax assistance contact the International Tax Office (ITO). ITO will provide a questionnaire for the visitor to complete. Please allow sufficient time for processing.Click hereto view the questionnaire or you may contact ITO at ito@vanderbilt.edu.

International Travel

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:

  1. The item will be used to conduct Vanderbilt University business.
  2. The item will remain under the “effective control” of Vanderbilt personnel while abroad (physical possession or maintaining in a secure environment).
  3. The item will return to Vanderbilt within 1 year of departure or be destroyed.
Common Travel Items
Item ECCN
Dell Laptop 4A994
Mac Laptop 5A992
iPhone & iPad 5A992
Android Cell Phone/Tablet 5A992
Flash Drives (most) EAR99
Garmin GPS 7A994
GoPro Camera EAR99
Bitlocker Encryption 5D992
Commercially available basic software (Microsoft Office) EAR99

The TMP exemption is not valid for travel to the following countries:

  • Cuba
  • Sudan
  • Syria
  • Iran
  • 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 vec@vanderbilt.edu 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.

International Travel Best Practices

If you do not need it, do not take it with you!

Laptops, tablets, cellphones, and other electronic devices:

  • Take a 'clean laptop' and a 'burner cell phone': these devices do not include export-restricted hardware, software, data or information (such as VPN software).
  • If a 'clean laptop' is not an option, it is recommended that a temporary export certification (TMP) be completed and have copies made for project documentation and personal keeping.
  • VEC will assist in analyzing software and hardware on devices to help ensure the item(s) are within export compliance guidelines.
  • Procure item(s) and resources needed for U.S.-sponsored projects within the destination country.
  • Imports: International customs broker service, Emily Ashworth at V.Alexander, eashworth@valexander.com

Perform a Restricted Parties Screening on all known contacts and their affiliated entities using export.gov. If the potential collaborator is a denied or blocked party for any reason, please contact VEC immediately to assist in export review.


Review protocol to ensure information, items, area, etc. are secured appropriately.

Do not take or access your unpublished research, proprietary information, and/or technical data.


Once outside of or upon your re-entry to the U.S., your laptop or other items may be subject to search or it may be seized without probable cause, suspicion, or warrant.

SPA > Export Compliance > Visas, Foreign Visitors & Travel

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