What Can You Take?
Items and Equipment - When taking items abroad (including scientific equipment, computers, cell phones, and GPS units) you need to verify that the items are not export restricted based on your travel destination(s). For most low-tech, commercially-obtained items, an export license will NOT be required unless you are traveling to or through a comprehensively sanctioned country (i.e., Cuba, Iran, Syria, Sudan, and North Korea) in which case an export license will almost certainly be required – even for everyday items such as cell phones and laptop computers.
Under the license exception for temporary export (TMP) you can take usual and reasonable kinds and quantities of tools of trade(commodities and software) for use by you or your employees in a lawful enterprise. The tools of trade must remain under your effective control or your employee's (you or your employee must retain physical possession of the item, lock it in hotel safe, or have it guarded). Encryption commodities and software may be pre-loaded on a laptop, handheld device or other computer or equipment. All tools of trade may accompany you departing from the US or may be shipped unaccompanied within one month before your departure from the US, or at any time after departure. All commodities and software must, if not consumed or destroyed in the normal course of authorized temporary use abroad, be returned as soon as practicable, but no later than one year after the date of export. No tools of trade may be taken to embargoed countries. A current list of embargoed countries is available. For additional information regarding the TMP "Tools of Trade" License Exception, reference 15 CFR Part 740.9(a)(2)(i).
Research Data & Information – When traveling abroad, you are free to take and openly share or discuss any data or information resulting from Fundamental Research or that qualifies under the Educational or Public Information Exclusions. However, you cannot take or share data or information that is in any way export-restricted (e.g., related to export controlled technologies, proprietary information, or is information resulting from a project not protected under the Fundamental Research Exclusion). All controlled or restricted data or information should be completely removed from laptops, phones, PDAs, or other portable storage devices (e.g., flash drives) before you leave the U.S.
What will you be doing and who will you be interacting with?
It is important to ensure that you do not accidentally export restricted information or provide any type of assistance or benefit to a sanctioned or blocked entity. The following are a few things to keep in mind as you plan your travel activities:
- Presentations – When presenting data/information in an international setting (including in the U.S. where the audience may include foreign nationals), you need to ensure that you limit your presentation to only information or data that is published, or is publicly available, or that qualifies as Fundamental Research. Be careful not to include or discuss any proprietary, unpublished, or export-restricted data or information as that may constitute an unauthorized export.
- Interactions with Foreign Colleagues – As noted above, you are free to openly discuss any published or publicly available information or information generated as the result of Fundamental Research as long as the recipient is not a sanctioned or specially designated entity. It is important to remember that while the results/information resulting from Fundamental Research are not subject to export controls and can be shared without a license, any items, technology, or software generated under that Fundamental Researchwould be subject to export controls and may require an export license.
- Field Work – Any college research activity done outside the U.S. may not qualify for the Fundamental Research Exclusion and would therefore not be protected from export controls until the work is published or otherwise made publicly available. Before disclosing or sharing information or data resulting from international field work it is important to ensure that the information is not export restricted.
- Provision of Financial Assistance – In order to ensure compliance with OFAC regulations prohibiting the college from providing material or financial assistance to any blocked or sanctioned individual or entity, any college activity that involves payment to a non-U.S. person, business, or organization (e.g., international subcontracts, purchase of items from international vendors, or payments to research participants) must be verified against all appropriate sanctioned party and entity lists. Contact OSP for help in verifying any international financial transaction(s).