Are you going abroad this summer?
Do you know how Export Controls affect 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 exportcontrolled 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 Sponsored Program’s
Website: http://www.uni.edu/osp/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: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/Programs.aspx
•
Computers – 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.
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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.
•
Software – 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:
http://www.microsoft.com/exporting/faq.htm, http://www.apple.com/legal/export.html,
http://www.adobe.com/support/exportcompliance.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.
•
Other Electronics – 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 http://www.uni.edu/osp/screening-lists for license requirements.
•
Travel Advisory – Please check the following website for current travel warnings and travel alerts
issued by the U.S. Department of State: http://travel.state.gov/travel/cis_pa_tw/tw/tw_1764.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: http://www.treasury.gov/ofac/downloads/t11sdn.pdf
•
Sponsored Projects – 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: Anita Gordon, Director of Research Services, and Export
Controls Coordinator at UNI, anita.gordon@uni.edu, 319-273-6148 or Medea Csoba DeHass, OSP
Program Associate, medea.csobadehass@uni.edu, 319-273-3956.
Have a safe and enjoyable trip!
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