Export Regulations and International Travel
Export Control regulations apply to key aspects of international travel, including:
- Travel to and/or engagements with parties located in OFAC Sanctioned and Restricted countries
- Exports of items, equipment, materials, and/or biologics before or during travel
- Activities which qualify as a “defense service” under ITAR regulations.
OFAC Sanctioned and Restricted Countries, Individuals, and Entities
Travel and other activities to/with OFAC sanctioned countries (currently Cuba, Iran, Syria, or North Korea) is prohibited in most cases without prior licensure or authorization. Likewise, most exports to these countries require licenses. Please contact the Export Control Officer as soon as you anticipate travel to a sanctioned country. For additional information on a specific sanction program, see OFAC Sanction Program Summaries.
In addition to the OFAC sanctioned countries, there are specific individuals and entities around the world that are subject to special restrictions. For many of these individuals and entities, ALL exports of even basic items (e.g., promotional materials, office supplies, etc.) require an export license. Likewise, OFAC regulations prohibit the University from providing material or financial assistance to any blocked or sanctioned individual or entity. Please contact the Export Control Officer for assistance in determining whether a potential international partner or entity is a Restricted Party.
International Research and Academic Presentations
Presenters must ensure that all research and academic information in their presentation is publicly available, eligible for publication/dissemination, and/or non-proprietary. Many presenters find it helpful to confirm that these criteria are satisfied prior to travel so that any necessary adjustments can be made in a timely manner. If there are any questions about whether material is eligible for dissemination during international travel, please contact the Export Control Officer.
Exports
Items, equipment, materials, and/or biologics taken to an international destination are considered “exports” under U.S. export control regulations, even when such items return to the U.S. with the traveler. As such, some items may require an export license or authorization to be hand-carried or baggage-packed in the course of international travel. Failure to obtain an export license or authorization in these cases may result in Customs detention or delays, significant fines or penalties, and/or inability to enter the foreign destination. If you are taking any items, equipment, materials, and/or biologics to an international destination please complete an Export Control International Travel Form before traveling.
Cybersecurity Best Practices for Travel to China
- Travel with Clean Devices: Encourage faculty to travel with devices (laptops, smartphones, tablets) that contain no sensitive personal or professional information. Ideally, these should be devices specifically designated for travel, containing only the information necessary for the trip.
- Use VPN Services: Ensure that all devices are equipped with reliable, updated virtual private network (VPN) software to encrypt their internet traffic. This step is crucial for protecting data when using public or untrusted networks.
- Enable Two-Factor Authentication: Require two-factor authentication for accessing university accounts and any other sensitive services. This adds an extra layer of security beyond just passwords.
- Digital Data Encryption: Ensure that all data stored on devices is fully encrypted. This measure helps protect the data even if a device is lost or stolen.
- Awareness of Local Laws: Educate faculty on local Chinese laws and regulations regarding digital data and privacy, including restrictions on certain types of online content and the use of VPNs.
- Secure Communications: Recommend the use of secure, encrypted messaging and email services for communicating sensitive information. Faculty should avoid discussing sensitive topics over unsecured channels. SUMail and MS Teams are encrypted.
- Regular Software Updates: Ensure that all devices are updated with the latest security patches and antivirus software before and during the trip.
- Physical Security: Advise faculty to maintain physical control of their devices at all times and to use strong passwords and biometric features to prevent unauthorized access.
- Data Backup: Encourage faculty to back up all data from their travel devices to secure, encrypted storage before, during, and after the trip.
- Post-Trip Procedures: Upon return, have IT professionals conduct a thorough review of the devices for any signs of compromise and ensure that no persistent threats are brought back into the university’s network. Device should then be “wiped and reloaded”.
- Training and Awareness: Before travel, provide faculty with training sessions or resources to ensure they are aware of potential cybersecurity threats and know how to respond effectively.