We’re all glad for the return of the opportunity to travel internationally once again! The resumption of international travel for personal or professional reasons means IU faculty, staff, and students should again take a minute to consider whether export control regulations might impact their plans. Depending on the travel destination, the hardware, software, and/or technical data that is taken and any collaborators you will encounter, you should consider consulting with the IU Export Control Office.
Export control requirements for international trips are determined by:
- Where you are going:
The Office of Foreign Assets Control (OFAC) is part of the U.S. Treasury Department and manages the government sanctions and embargoes program.
Currently, CUBA, IRAN, NORTH KOREA, SUDAN, and SYRIA are on the list of embargoed countries, which prohibits ALL transactions (including imports and exports) without a license authorization or an exception.
Other countries are subject to targeted sanctions and restrictions as well. Fortunately, normal travel does not usually constitute a problem. However, the technology/information exported during your trip, the persons/organizations met, and the type of activity performed can trigger export control issues, depending on the destination. Also note that some countries have their own additional import and export controls regulations which may affect how you can use items while overseas, and which could restrict your ability to bring them back. You should be aware of all applicable regulations and how they could apply to you. - What you are taking:
When traveling outside the U.S., even to countries beyond the above list of embargoed countries, everything you take with you is subject to the U.S. export controls regulations. This includes tangible items (laptops, cell phones, equipment, samples, paper documents etc.) and intangible products (trainings, know-how, files, data etc.). In order to determine whether an export authorization is required prior to traveling, you should think about what you’re bringing and whether it is listed on one of the US government’s lists for export control items and technology. The IU Export Control Office can review the items with you and determine if there may be any restrictions that need to be considered.
Certain exceptions allow you to take your personal laptop to any countries except Cuba, Iran, Syria, and North Korea. Note, however, that if your laptop contains controlled software/data, a license will be required. This exception applies only to personal items and, thus, does not apply to items owned by IU (e.g., laptop bought with university funding).
Other temporary export/reexport of institution-owned items can be allowed if the equipment is being returned to the United States within one year. The items must remain under the effective control of the exporter/re-exporter. Please contact us to help verify that what you bring is within the scope of applicable federal law! - Who is working with you:
Specially Designated Nationals (SDNs) and Blocked Persons are entities or individuals owned or controlled by, or acting for or on behalf of, the governments of target countries. SDNs may also be associated with international narcotics trafficking or terrorism. United States persons may be prohibited from conducting certain activities with the listed individuals and entities without prior OFAC authorization.
Therefore, it is recommended to know in advance with whom you will be communicating and collaborating, and a Restricted Parties Screening (RPS) can be performed on those persons and entities. Certain foreign universities have been added to these various US government lists. Please contact the IU Export Office and allow us to help you screen potential partners.
Questions should be directed to IU's Export Control Office
Contact IU's Export Control Office at export@iu.edu. You may also schedule an in-person meeting at a campus location convenient for you.