International Travel Guidance

Export Control regulations apply to key aspects of international travel, including:

• Travel to and/or engagements with parties located in Sanctioned and Restricted countries
• Activities that may facilitate the export of technical data
• Exports of items, equipment, materials, and/or biologics before or during travel
• Activities which qualify as a “defense service” under the State Department’s ITAR regulations.
• In the case that an export license or authorization is required to export a physical item related to your proposed international travel (e.g., hand-carried equipment or materials, or controlled materials), our Research Security Office will work with you to obtain such a license and/or adjust your travel plans to preclude license requirements. Likewise, in the event that your proposed travel activity constitutes a defense service in relation to a foreign government or defense agency, we will coordinate the appropriate licensing and compliance measures.

While export controls apply to all countries, travel and other activities to/with OFAC-sanctioned countries (currently Cuba, Iran, Syria, or North Korea) is prohibited in most cases without a license or authorization. Likewise, most exports to these countries require licenses. The Research Security Office can work with travelers to determine compliance requirements, and early notification will help facilitate travel objectives. Please contact the Research Security Office as soon as you anticipate travel to a sanctioned country.

While most activities abroad do not require an export license (except with respect to OFAC-sanctioned countries), it is important for travelers to be aware of the following export control concerns:

Restricted and Prohibited Entities:

• There are a number of individuals and entities around the world that are subject to special restrictions. For many of these 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. It is important to determine whether a potential international partner is a Restricted Party, please contact the Office of Global Engagement, or Research Security Office to assist in a restricted party screening prior to engaging. Additionally, more information on Restricted Parties can be found in the Restricted Parties section of this website.

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 Research Security Office.

In most cases, fundamental research conducted outside the U.S. will qualify for the Fundamental Research Exclusion. However, ITAR defense-controlled research cannot be conducted internationally without an export license, even if it otherwise qualifies as fundamental research when conducted at the University of Utah or elsewhere in the U.S. Before conducting sponsored research internationally, including field work abroad, researchers should confirm that the work is not export restricted. Please contact our Research Security Office with questions, or if your work abroad involves any of the following:

• Exporting items in advance of travel (instruments, materials, software, controlled technical data)
• Providing payments of any kind to a foreign person, entity, or institution
• Purchasing or obtaining items or materials from international sources
• Importing samples to the U.S. from a foreign destination
• Working with a foreign government and/or military.

Items 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

Travelers are encouraged to preview the following questions in relation to items that may be exported during international travel:

• Will you be transporting (either through carry-on luggage or checked bags) laboratory instruments, tools, samples, raw materials, or prototypes for any reason (including, but not limited to, for your own research, a collaborative purpose, or to give to someone)?
• Will you be traveling with a portable electronic device that contains or stores proprietary export-controlled data, University of Utah confidential or proprietary data as defined by law or University of Utah policy, or data which is associated with an export-restricted research project or instrument that you have been or are working on currently (even if such data has nothing to do with the purpose of your immediate travel)?
• Will you be transporting any device that incorporates specialized scientific software (not including typical operational software such as Microsoft Office, Adobe, etc.) or software programs utilizing specialized cryptographic functionality (not including routine commercial laptop cryptographic protection)?
• Will you be providing any specific training or technical assistance to another individual, entity, or governmental institution (or representatives) beyond scientific collaboration in fundamental research?

IF THE ANSWER TO ANY OF THESE QUESTIONS IS YES PLEASE CONTACT THE RESEARCH SECURITY OFFICE FOR REVIEW PRIOR TO TRAVEL