International Travel Advisories
When planning a trip abroad, travelers should be familiar with export controls and embargoes. You must ensure that any information that you will discuss or any items that you will take with you are either not controlled, or if controlled, proper licenses are in place. Because you, as an individual, and UMBC can be held liable for improperly transferring controlled items or technology, it is important that you review the federal requirements. The US Department of State provides detailed information regarding any International Travel Information including warnings, Country Specific Information, Travel Alerts, and general Tips for Traveling Abroad.
Most travel outside of the U.S for conferences will fall under an exclusion to the export control regulations and does not require a license. However, information presented at seminars must be limited to topics that are not related to export-controlled items or technologies unless that information is already in the public domain. An open gathering is one in which members of the general public are eligible to attend and attendees are permitted to take notes.
The export control regulations may come into play when:
- Taking items with you when you travel, such as
- Encryption products (hardware and software)
- Blueprints, drawings, schematics
- Attending “closed” conferences or meetings (are not open to all technically qualified members of the public, you cannot take notes, or may come with a request to complete a form DD2345).
- Money transactions and the exchange of goods and services (country specific)
- Travel to sanctioned or embargoes countries no matter what the purpose
- Doing business with certain people or entities
- Providing a Defense Service to a foreign person
An export license is not required when the sole purpose of the meeting is to present research findings that have been or are intended to be published, provided they do not concern detailed information regarding controlled items or technologies (information and items subject to Export Controls). Be careful not to include or discuss any proprietary, unpublished, or export-restricted data or information as that may constitute an unauthorized export.
As you plan your trip, verify your technology or information you are taking with you falls into one or more of the following categories prior to travelling:
- Research which qualifies for the fundamental research exclusion
- Published information
- Publicly available software
- Educational information
- Patent applications
Please contact the ORPC at EC@umbc.edu or 410-455-2737 if you have any questions concerning the above. In addition, we are available to perform a restricted party screening for entities and individuals with whom you will be doing business.
The Department of the Treasury, through its Office of Foreign Assets Control, administers economic and trade sanctions (see list of Sanctions Programs) that at times can restrict transactions and travel, or require licensing in order to travel to a foreign country, or to conduct business with a foreign entity or individual. Before considering travel to embargoed countries to conduct research or educational activities, check first with the Office for Research Protections and Compliance (ORPC). A determination will be made by ORPC as to whether a license and/or permission is required. Some countries can require a specific license that may take several weeks to obtain. The current list of sanctioned countries include:
- Cote d'Ivoire (Ivory Coast)
- Cuba - see this link for traveling to Cuba
- Democratic Republic of the Congo
- North Korea
When you travel outside of the United States (except Canada), your university provided laptop computer, PDA, cell phone, data storage devices and encrypted software may require an export license or other government approval to be taken to many countries outside of the United States. The University is required to document the export (even a temporary export) of these items if they are owned by the University, and the records must be kept for 5 years. Contact the Dean Drake, 410-455-5642 for more information.
Temporary exports under the "Tools of Trade" license exception apply when the laptop, PDA, cell phone, data storage devices and encrypted software are:
- Hand carried with you while you travel,
- Carried in your luggage or baggage that travels with you, or
- Shipped no more than thirty days prior to your departure, or may be shipped to you at any time while you are outside the country
Generally, so long as you (1) retain your laptop computer, PDA, cell phone, data storage devices and encrypted software under your personal custody and effective control for the duration of your travel; (2) do not intend to keep these items in these countries for longer than 1 year; and (3) you are not traveling to Cuba, Iran, North Korea, Sudan or Syria, no government export license is required. Note that this license exception is not available for equipment, components, or software designed for use in/by/with most satellites or spacecraft. “Effective control” means retaining physical possession of an item or maintaining it in a secure environment.
Other University Equipment
Researchers frequently need to take other university equipment temporarily outside of the United States for use in university research. Often, but not always, the tools of trade license exception applies. Some equipment (e.g., global positioning systems (GPS), thermal imaging cameras, inertial measurement units, and specialty software), are highly restricted and may require an export license to take with you, even if you hand carry it. If you are taking university equipment other than your laptop computer, PDA, cell phone, data storage devices contact ORPC to determine if an export license or other government approval is required prior to your taking the equipment out of the country.