Are you going abroad this summer?
Do you know how Export Controls affects your travel plans?
What are Export Controls?
Federal export control laws are a complex set of regulations. They restrict the export or transfer of information, goods, equipment, technology, related technical data and certain services to foreign countries and nationals in order to protect national security and the domestic economy.
Fortunately, most university scholarship and other activities are not subject to export controls, either because the activity does not involve export-controlled items or data, or because research involving such items or data qualifies for an exemption from the regulations.
Penalties for Export Control violations are severe (up to $1,000,000 per violation and imprisonment up to 10 years) and may be imposed against individual researchers as well as their institutions.
Do Export Control laws affect me?
Export Control regulations apply to all U.S. nationals, permanent residents or persons with refugee or asylum status. All UNI student, faculty, and staff are responsible to comply with Export Control laws within AND outside of the country.
It is your personal responsibility to learn about these obligations and to comply with Export Control laws at all times.
Exclusions from Export Controls
There are three different basic exclusions which can be applied during your foreign travels:
Fundamental Research Exclusion
Basic research where the results have been or will be shared within the scientific community – this exclusion can be applied when traveling abroad for research, conference participation, or collaboration with foreign colleagues.
Educational Information Exclusions
Information commonly taught in catalog courses – this exclusion also applies when teaching and/or studying abroad.
Public Information Exclusion
Any information that is already published or is in the public domain (books, papers, most publicly available technology and software, information on public websites, published U.S. patents, etc.)
A full description of Export Control regulations can be found on the Office of Research and Sponsored Program’s Website: https://rsp.uni.edu/export-controls.
Transit & Destination
If you are traveling to or through any countries that are currently on the U.S. Department of the Treasury’s sanctioned program list (Balkans, Belarus, Burma. Cote d’Ivoire, Cuba, Democratic Republic of Congo, Iran, Iraq, Liberia, Libya, Lebanon, North Korea, Somalia, Sudan, Syria, Zimbabwe), please review the appropriate list of sanctions at the Office of Foreign Assets Control website: https://www.treasury.gov/resource-center/sanctions/Programs/Pages/Programs.aspx.
If you don’t need it, don’t take it! We strongly suggest you only take necessary items on your international trip with you. Before taking your laptop abroad, consider other options, such as remote connecting to your home computer through your other electronic devices. If you must take a laptop, we suggest taking one with minimal data, programs and information on it. Please contact your College’s Computer Technician to learn about your specific options.
Please be aware: some countries do not allow any encrypted material within its borders. Keep in mind that your computer might be confiscated at any border-crossing, at any time, in any country.
U.S. persons are allowed to temporarily export software to foreign countries with the exception of some encryption software with a key length exceeding 64-bits. Most commonly used software programs are exempt from Export Control regulations, such as Microsoft Windows, Mac OS X, Microsoft Office, Mozilla Firefox/Thunderbird, Google Chrome, Symantec Endpoint Protection, Adobe Reader, Adobe Acrobat, Adobe Flash, Quicktime, iTunes, Oracle Java Runtime, Real Player, iWork, iLife, Adobe Creative Suite (Photoshop, Illustrator, etc.) among others.
For further information on Microsoft, Apple and Adobe programs please check the following websites: https://www.microsoft.com/en-us/exporting, https://www.apple.com/legal/more-resources/gtc.html, and https://www.adobe.com/legal/compliance.html.
Please be aware: exemptions do not apply to any software that is not commercially available at your destination or transit countries, including custom or personally-developed software, or software that is commercial available and uses the above described encryption technology - do not take these programs on your foreign travels. Check the manufacturer’s website for more information.
Most electronic devices made for civil use are exempt from export control or can be taken abroad for up to one year under the TMP (temporary export, import, and re-export) exemption. TMP can be used for personal effects and for equipment used as “tools of trade” as long as the device is used only by you or other US persons while abroad. If you are traveling with specialized electronic equipment, such as some GPS, cameras, audio recording devices, etc., please check the Commerce Control List and the U.S. Munitions List by visiting https://rsp.uni.edu/export-controls-screening-lists for license requirements.
Please check the following website for current travel warnings and travel alerts issued by the U.S. Department of State: https://travel.state.gov/content/travel/en/traveladvisories/traveladvisories.html/.
Please be aware: The Office of Foreign Assets Control maintains a list of Specially Designated Nationals, with whom no U.S. persons may engage in any kind of transaction or collaboration. Please see the full list on this website: https://www.treasury.gov/resource-center/sanctions/SDN-List/Pages/default.aspx.
If your international travel is sponsored by external funding, make sure that your foreign travel is in compliance with your grant/contract agreement. If you are working on a project that falls under export control regulations, please contact the UNI Export Control Coordinator.
Please be aware: your grant/contract agreement might contain specific requirements for use of funds, travel restrictions or publication restrictions. You might also need permissions and/or a license to take project related equipment, information, material, or research results with you on your international travels.
Whom to contact for more information:
Kyle Fogt, Export Controls Coordinator at UNI, at firstname.lastname@example.org, 319-273-7272.
Have a safe and enjoyable trip!