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International Travel & Temporary Exports

 International Travel

TRAVEL ALERT: Personal Electronic Restrictions

University personnel often travel abroad as a positive part of their ongoing scholarly efforts. While international travel is free of export concerns under most circumstances, there are several factors that may cause it to be restricted by export controls. In order to protect Vanderbilt, your research, and yourself, it is important to consider the following:

Where are you going?

What are you taking with you?

What are you doing and who will you interact with?

Complete an  International Travel Questionnaire to evaluate the export requirements for your travel.

 

 Where are you going?

Travel to most countries is not restricted or prohibited. However, the Department of Treasury, Office of Foreign Assets Control (OFAC) broadly regulates and restricts interactions with embargoed countries. These restrictions vary depending on the country and change frequently depending on our economic and political relations.

  • Comprehensively Embargoed Countries are those with which most activities are prohibited and require a license.
    • Cuba
    • Iran
    • North Korea
    • Sudan
    • Syria
  • Limited Sanctions or Regime-Based Sanctions are those with which specific goods, technologies, and services are restricted.
  • Destinations with import concerns and security risk. See Embargoed Countries Best Practices for more information. 
    • China
    • Russia

If you are traveling to or providing services to a citizen of one of these countries, complete the  International Travel Questionnaire  for assistance in determining your export requirements. For and more information on sanctions and embargoes, see Restricted Parties & Countries of Concern

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 What are you taking with you?

When you travel abroad everything you take with you is considered an export. This applies not only to tangible items but also to intangible items. Some examples may be:

  • Scientific equipment
  • Biological agents
  • Chemicals, and toxins
  • Software
  • Research data
  • Encryption

Once outside the U.S. you do NOT have privacy. Your property may be seized and searched without probable cause. It is recommended that you document any items you take with you to help prove that you had the items before you left the U.S. If you are traveling abroad and taking Vanderbilt-owned property, complete the  International Travel Questionnaire  to assist with this documentation. 

Items and Equipment 

If you are taking Vanderbilt-owned physical items, some may be temporarily exported as a “tool of the trade” under the Temporary Export Exception (TMP). The TMP is an exemption from export controls and no license is required to take your equipment 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.
  3. The item will return to Vanderbilt within 12 months of departure or be destroyed.

The TMP is not eligible for use on any military items, EAR satellite or space-related equipment, or high-level encryption products. It is also not available when traveling to Iran, North Korea, Sudan, or Syria.

When taking equipment on your international travel, you may be asked to provide an Export Control Classification Number (ECCN). Please refer to the chart for items most commonly taken. If your item is not listed, the best resource for an accurate ECCN is to contact the manufacturer or sponsor. If you need additional classification assistance please contact vec@vanderbilt.edu

Common Travel Items

Item ECCN
Dell Laptop 4A994
Mac Laptop 5A992
iPhone & iPad, Android Cell Phone/Tablet 5A992
Flash Drives (most) EAR99
Global Positioning System (GPS) 7A994
Bitlocker Encryption 5D992
Commercially available basic software (Microsoft Office) EAR99

Research Data and Information

Travelers are free to take and openly discuss any data or information that is published, available 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. Examples could include information about export-controlled technologies or the results of a project not protected under the Fundamental Research Exclusion (FRE). Sharing these types of information may constitute an unauthorized export.

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 What are you doing and who will you interact with?

If you plan to conduct research while abroad, be aware that it does not qualify for the Fundamental Research Exclusion (FRE) and therefore may be subject to export controls. If you are performing field research abroad, it is recommended to complete the  International Travel Questionnaire to assist with evaluating export risk. 

If teaching abroad, limit to content of a catalog course. If you are presenting or sharing data and information, limit to only that which is published or qualifies for the FRE. The same applies when collaborating while abroad and what you share with your foreign collaborators. 

Who you interact with can play a role in export compliance. Perform a Restricted Parties Screening (RPS) on people and associated entities to ensure they are not listed on any government-issued blocked or denied parties lists.

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Other Travel Resources

Vanderbilt Concur Solutions

Vanderbilt Incident Response for Travel

International Student & Scholar Services

Department of State International Travel Alerts and Warnings

 

 General International Travel Best Practices

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

Do…

  • 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

Don’t…

  • 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.

 

 Embargoed Countries Best Practices

Going to an embargoed country?

The Department of Treasury, Office of Foreign Assets Control (OFAC) broadly regulates and restricts interactions with embargoed countries. Regulations vary depending on the country or region and change frequently due to economic policy and national security. But the most comprehensive controls apply to: Cuba, Iran, North Korea, Sudan, and Syria. Most travel and transactions require an export license to these destinations which can affect your research and educational relations.

Additionally, travel to certain countries, while not prohibited, should have special considerations for security risk. China and Russia travelers may experience a range of cyber security issues that deserve mention.

For more information on a specific country:


  China and Russia

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. 

Encryption

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.

 

Don't ...

  • 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.

Do ...

  • 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.

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 Cuba

Travel to Cuba is a hot topic in the news. On June 16, 2017, it was announced that travel to Cuba is still prohibited under most circumstances by U.S. State Department regulations. There are 12 categories under which travel from the U.S. to Cuba is still permitted. Some are listed here:

  • Educational activities for credit towards a degree
  • Educational activities not for credit towards a degree when organized by a US entity and accompanied by an employee or agent of that entity
  • Professional research and professional meetings
  • Public performances, workshops, clinics, competitions, and exhibitions
  • Journalism
  • Teaching

The ban on tourism remains in place. Travelers must maintain a full-time schedule of activities related to an authorized travel category and must maintain records of their activities (itinerary, receipts, etc.). Expect increased scrutiny at the US border when traveling to or from Cuba.

Travelers will also be prohibited from engaging in travel-related transactions with entities owned or controlled by Grupo de Administración Empresarial (GAESA).  The U.S. State Department will be issuing a list of GAESA entities, which may include hotels, restaurants, and various service providers a traveler may encounter.

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, certain goods and the provision of services are prohibited. Note: Shipping or hand-carrying any items (and certain technology or software) to Cuba remains subject to strict export control restrictions. 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.

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 Iran

Travel to Islamic Republic of Iran is not prohibited. However, many interactions are sanctioned and require an export license. A restriction of note for researchers is providing a “service”. “Service” is construed to mean providing anything of value, even if no money is exchanged.

Examples might be:

  • Providing technical assistance to an Iranian national or an Iranian institution
  • Presenting data or research results to a person or institution
  • Teaching or lecturing as a guest of an institution
  • Attending a conference

In addition, Iranian authorities continue to unjustly detain and imprison U.S. citizens, including students and academics on charges of espionage. The U.S. government does not have diplomatic or consular relations with the Iran and therefore cannot provide protection or routine consular services to U.S. citizens in Iran.

Don't ...  

  • Provide technical assistance or analysis to Iranian nationals or institutions that would constitute a “service” without an OFAC license.

  • 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 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.

The Iranian Sanctions are updated frequently, but the Department of Treasury provides additional guidance on their websiteIf you are considering travel to Iran, contact Vanderbilt Export Control immediately, regardless if your trip purpose is professional or personal.

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 North Korea

On August 2, 2017, the Department of State published a notice that prohibits the use of U.S. passports for travel to the Democratic People's Republic of Korea (North Korea). The restriction will go in to effect on September 1, 2017 and it will be required to get "special validation" to travel to this destination. It is strongly recommended to consult the U.S. Department of State travel web page regarding travel to North Korea.

General Information ...

  • 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, 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 considering travel to North Korea, you must contact Vanderbilt Export Control immediately.

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 Sudan

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.

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 the Sudan, you must consult  Vanderbilt Export Control to determine if any licenses would be required.

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 Syria

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

You cannot export, re-export, sell or supply any services to Syria without an export license, with the exception of exports and re-exports of services in support of humanitarian and other not-for-profit activities.

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 Vanderbilt Export Control to determine if any licenses would be required.

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