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International Travel & Temporary Exports

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 become restricted by export controls. In order to protect Vanderbilt, your research, and yourself, it is important to consider the following:

  1. Where are you going?
  2. What are you taking with you?
  3. What are you doing?

You are responsible for securing information that is on your device, both personal and university-owned. By completing an  International Travel Questionnaire (ITQ), VEC can help assess whether export controls apply and advise how to best protect yourself and your research.

 

 WHERE ARE YOU GOING?

Travel to most countries is not restricted or prohibited; however, the Department of Treasury’s 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.

Travel to the People’s Republic of China 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).

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.

In June 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.

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.

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.

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.

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.

The US Government has a limited sanctions program against the Government of Venezuela and those closely tied to it. In May 2019, the BIS amended the Export Administration Regulations (EAR) to remove Venezuela from Country Group B, which affords favorable treatment for certain exports of National Security-controlled items, and moved Venezuela to Country Group D:1, which lists countries of national security concern. This final rule makes these changes to the EAR to reflect current national security concerns related to Venezuela, e.g., the introduction of foreign military personnel and equipment into Venezuela, and to better protect U.S. national security. The changes in this final rule also better align the Country Group designations for Venezuela with other EAR national security-related provisions that already apply to Venezuela, e.g., the military end-use and end-user controls that apply to certain items for export, reexport, or transfer (in-country) and provisions that are specific to countries subject to U.S. arms embargoes. In addition, this final rule adds Venezuela to Country Groups D:2-4, which list countries of nuclear, chemical and biological weapons, and missile technology concern, respectively.

Executive Order (EO) 13808 prohibits transactions by U.S. persons wherever they are located, and transactions within the United States. For transactions involving blocked persons, including the Government of Venezuela and any entity in which it owns, directly or indirectly, a 50 percent or greater interest, U.S. persons are prohibited from engaging in any activity or transaction with such blocked persons unless exempt or otherwise authorized by OFAC. If there is a Venezuela-related general license authorizing dealings with such blocked persons, but the transactions or dealings fall within the prohibitions of E.O. 13808, U.S. persons should reject such transactions, unless an authorization allowing transactions and other dealings otherwise prohibited by E.O. 13808 also applies. U.S. persons must report to OFAC any blocked or rejected transactions within 10 business days.

The United States has deepening concerns about the ongoing crisis in northern Ethiopia as well as other threats to the sovereignty, national unity, and territorial integrity of Ethiopia. People in northern Ethiopia continue to suffer human rights violations, abuses, and atrocities, and urgently needed humanitarian relief is being blocked by the Ethiopian and Eritrean militaries as well as other armed actors. On May 23, 2021, the Secretary of State announced restrictions with respect to Ethiopia and Eritrea, including certain restrictions related to security assistance. The Department is updating ITAR § 126.1, consistent with the Secretary's announcement, by adding Ethiopia in paragraph (n) and updating the existing entry for Eritrea in paragraph (h).The policy of denial applies to licenses or other approvals for exports of defense articles or defense services to or for the armed forces, police, intelligence, or other internal security forces of either Ethiopia or Eritrea.

UPDATE - FEBRUARY 2022: In response to Russia's invasion of Ukraine and the ongoing conflict in that country, the US Department of State has issued the following Travel Alert for Russia: "Do not travel to Russia due to the unprovoked and unjustified attack by Russian military forces in Ukraine, the potential for harassment against U.S. citizens by Russian government security officials, the Embassy’s limited ability to assist U.S. citizens in Russia, COVID-19 and related entry restrictions, terrorism, limited flights into and out of Russia, and the arbitrary enforcement of local law.  U.S. citizens should depart Russia immediately.

Due to Russia’s further invasion of Ukraine, an increasing number of airlines are cancelling flights into and out of Russia, and numerous countries have closed their airspace to Russian airlines. In addition, airspace around southern Russia is restricted, and a number of airports in the area have closed. U.S. citizens located in, or considering travel to, the districts of the Russian Federation immediately bordering Ukraine should be aware that the situation along the border is dangerous and unpredictable. 

Given the ongoing armed conflict, U.S. citizens are strongly advised against traveling by land from Russia to Ukraine. In addition, there is the potential throughout Russia of harassment of foreigners, including through regulations targeted specifically against foreigners. Given the ongoing armed conflict and the potentially significant impact on international travel options, U.S. citizens should depart Russia immediately via the limited commercial options still available."

Further, the US Government has imposed a number of new sanctions and export controls against Russia, some of which may impact certain University personnel and activities. Namely, the Department of Commerce's Bureau of Industry and Security (BIS) has issued two new rules detailing new restrictions against Russia and Belarus. The first rule, “Implementation of Sanctions Against Russia Under the Export Administration Regulations (EAR),” (Russia Sanctions rule) which became effective on February 24, 2022, implements new Russia license requirements and licensing policies to protect U.S. national security and foreign policy interests. The second rule, “Imposition of Sanctions Against Belarus Under the Export Administration Regulations,” (Belarus Sanctions rule) which was effective on March 2, 2022, implements new Belarus license requirements and licensing policies, also to protect U.S. national security and foreign policy interests. Taken together, these new controls, implemented through the issuance of amendments to the EAR, place significant restrictions on U.S. exports, re-exports, and in-country transfers, and on products manufactured abroad with U.S. technology or tooling to Russia and that are subject to the EAR, primarily in aerospace and military sectors. New controls on Belarus target the diversion of items to Russia through Belarus.The new rules also impose comprehensive export controls against the Donetsk People’s Republic and Luhansk People’s Republic regions of Ukraine for all items subject to the EAR with few exceptions, such as for food, medicine and certain Internet-based software for personal communications.

In addition to expanding export controls against Russia, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) has imposed new economic sanctions against Russia, severely limiting Russia’s largest financial institutions and the ability of state-owned and private entities to raise capital, as well as further barring Russia from the global financial system.

If you currently have or anticipate research activities involving Russia, Belarus, or specially designated regions Ukraine, please contact Vanderbilt Export Compliance (VEC) as early as possible and before shipping or transferring any items or technologies to recipients located in these countries. VEC will assess the applicable export restrictions and seek the proper US Government licenses and authorization as necessary.

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: Russia, 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.

  • Comprehensively Embargoed Countries are those with which most activities are prohibited and require a license.
  • Limited Sanctions or Regime-Based Sanctions are those with which specific goods, technologies, and services are restricted.
  • Additionally some countries have travel warnings issued by the Department of State with special instructions to Americans traveling to those countries.

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

A Note About Using DUO Abroad (as of May 5, 2022):

In order to comply with U.S. regulations, Duo blocks authentications from users whose IP address originates in a country or region subject to economic and trade sanctions enforced by the U.S. Office of Foreign Assets Control. Users attempting to authenticate to a Duo-protected application from an access device with an IP address originating in an OFAC-regulated country or region will be blocked from completing their login and receive an error message. Web-based applications will display the following error message: “Access denied. Duo Security does not provide services in your current location.” Other applications may display a generic failed login message.

OFAC restrictions relevant to Duo currently apply to the following countries or regions:

  • Cuba
  • North Korea
  • Iran
  • Sudan
  • Syria
  • Crimea region
  • Donetsk region
  • Luhansk region
  • Sevastopol region

Blocked authentications will appear in the Authentication Log as “Restricted OFAC location.”

For questions about how this may impact your Duo use while abroad, please review the following and/or contact VUIT: https://it.vanderbilt.edu/security/messages/Zoom_Duo_Restricted_Counties_April2022.php

 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:

  • Laptop and smart devices
  • Scientific equipment
  • Biological agents
  • Chemicals and toxins
  • Software
  • Research data
  • Encryption

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

Do…

  • Take a Vanderbilt-issued loaner laptop or burner cell phone
    • Utilize a Virtual Private Network
    • Use password systems and personal firewalls
    • Disable Bluetooth
  • Maintain “effective control” of your devices
  • Protect your research by backing up your data

Do NOT…

  • Assume Wi-Fi in a foreign country is secure
  • Use internet cafes or other 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.

Keep export compliance documents and search results for five (5) years past the last date of travel activity.

Once outside the United States, you should NOT expect privacy. Your Wi-Fi connections are not secure and your personal property can be seized and searched by foreign authorities without probable cause. It is recommended that you document any items you plan to take with you to help prove they were in your possession before you left the United States. If you are traveling abroad and taking Vanderbilt-owned property, please 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 a license exemption (from export controls), meaning 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 below for the ECCNs of items most commonly taken. If your item is not listed, the best resource for an accurate ECCN is the manufacturer or sponsor of the item. If you need additional classification assistance, please contact vec@vanderbilt.edu.

Common Travel Items

Item ECCN
Dell Laptop 5A992
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) 5D992

If you are taking a laptop or other common electronic device, ensure there is no encryption source code.

Research Data and Information

Travelers are free to take and openly discuss any data or information that is published, available in the public domain, normally taught as part of a class, or resulting from fundamental research. However, you cannot take or share data or information that is in any way export-restricted. Examples include information about export-controlled technologies or the results of a project not protected under the Fundamental Research Exclusion (FRE). Sharing such information may constitute an unauthorized export.

 WHAT ARE YOU DOING?

If you plan to conduct research overseas, keep in mind that this does not qualify for the Fundamental Research Exclusion (FRE) and may be subject to export controls. If you are performing field research abroad, please complete the  International Travel Questionnaire to allow VEC to assist with evaluating export risks.

If teaching abroad, limit your content to that 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 overseas and sharing information with your foreign collaborators.

Who you interact with overseas also plays an important role in export compliance. Perform a Restricted Parties Screening (RPS) on people and associated entities you plan to interact with to ensure they are not listed on any US Government-issued blocked or denied parties lists.

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Other Travel Resources

Cybersecurity for the Vanderbilt Business Traveler 

FBI International Travel Brochure

Vanderbilt Concur Solutions

Vanderbilt Incident Response for Travel

International Student & Scholar Services

Department of State International Travel Alerts and Warnings