Int’l Travel

When you leave the U.S., even temporarily, for any reason (i.e. teaching, research, or to attend a conference) everything you take with you is an export, including electronic devices, software and data.  This applies to any hand-carried items, materials, and devices.  Thus, international travel by UAMS employees may be subject to export control regulations depending on the destination and the hardware, software, and/or technical data that is taken.  Under most circumstances international travel is free of export concerns, however there are several factors that may cause heightened restrictions. 

In order to comply with UAMS policy and provide the Office of Export Control the necessary information to evaluate whether a license is necessary, please complete the International Travel Checklist below.  As you complete your checklist, it is important to consider the following questions:

FAQs

Where are you going?

While any item or technology that is taken outside the US is subject to export regulations, each country may be subject to different US export control requirements.  Some destinations are subject to heightened export controls.   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 US economic and political relations. In particular, the following nations are currently subject to the most comprehensive sanctions:

  • Cuba
  • Iran
  • North Korea
  • (North) Sudan
  • Syria

Any interaction with these nations will likely require a license from OFAC.  For additional information, see Sanctions Programs and Country Information.

What are you taking?

Most items do not require a license when being taken outside the US.  However, items that may be subject to heightened export control restrictions include, in particular:

  • Chemicals, biological materials, and scientific equipment
  • Blueprints, drawings, and schematics containing export controlled technology
  • Technology related to encryption

In addition to becoming familiar with applicable export control requirements, UAMS travelers should note that any international travel with an electronic device may result in the disclosure of personal information installed on that device. In some countries, customs officials may examine information contained in devices or seize devices.  Instances of laptop seizures have been widely reported in the press.  Travel in and out of the U.S. is no exception: Homeland Security personnel may inspect information contained in a traveler’s device, or seize the device.  UAMS travelers should therefore consider carefully which devices that they take with them on international trips.

What are you doing?

Attendance at a conference or meeting in a non-sanctioned country does not generally require a license, and 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 results from Fundamental Research.

Areas of concern include:

  • Doing business with, or providing services to, certain people or entities on a sanctions list (including human subjects and collaborative research)
  • Supplying certain export controlled technologies or data at a “closed” conference or meeting (a meeting that is not open to all technically qualified members of the public and where attendees are not permitted to take notes)

Fortunately, most international travel does not raise any export control concerns, in part because no export license is required for the temporary export to a non-sanctioned country of commercially available laptops, tablets and/or cell phones with standard commercially available software.  In other instances, an exclusion or exception to a license requirement maybe available.

However, in order to assess any potential export control issues associated with your upcoming international trip, please answer the International Travel Checklist questions carefully. NOTE: Individuals can be help personally liable for exporting controlled items, controlled technical data, or controlled software without a license or license exception.  Contact the Office of Export Control if you have any additional questions.


International Travel Form

Please note: in accordance with the UAMS Export Control Policy &  UAMS travelers must complete the International Travel Form (available below) prior to international travel.

If the responses are “yes” to any of questions 1-9 in the International Travel Form below, please ensure this form is completed at least 45 days prior to trip commencement in order permit to the Office of Export Control to review.  The Office of Export Control may contact you for additional information to complete the export review process.  In the event a license if required, the Office of Export Control will submit a license application to the appropriate government agency.

If the response is “yes” to question 10 only, please provide a description of the property to be taken outside the US.  In the event additional information is required, the Office of Export Control will contact you.  If an Export License Exception Certification is necessary, the Office of Export Control will provide it to you for completion prior to your trip.

 If you are unable to certify the statements contained on the Export License Exception Certification, contact the Office of Export Control.  In the event a license is required, the Office of Export Control will submit a license application to the appropriate government agency

When the International Travel Form is completed, you will receive an email.  Please include this email when submitting your travel request to the UAMS Travel Office. If any additional information is required, the Office of Export Control will contact you.

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