Export control regulations may impose travel restrictions
Washington State University faculty and staff often find themselves traveling internationally to conduct research, meet with a collaborator, attend a conference, or present research findings. In general, travel to most countries isn’t a concern. In some cases, though, you may need to obtain an export license or license exception before your trip. Certain destinations, items, and activities are either restricted or forbidden.
Ask yourself the following questions
Where are you going?
Are you planning to go to an embargoed or sanctioned country? The Office of Foreign Assets Control (OFAC) administers economic and trade sanctions that can restrict transactions or travel, or require a license prior to travel or conducting business with an individual or entity.
For a listing of current sanctions please see the OFAC Sanctions Lists.
What are you taking with you?
Any item, technology, or service subject to the USML requires a license to be exported.
For items subject to the CCL, a license exception may be available depending on the item and destination or you may have to apply for a license prior to export.
The two most commonly used license exceptions when traveling outside the U.S. are license exceptions BAG and TMP.
- License exception BAG (EAR 740.14) authorizes temporary export of personal items such as a cell phone or laptop to any country except Cuba, North Korea, Iran, Sudan, or Syria. This exception allows the item to be used for personal use of the individual or use by your immediate family members only.
- License exception TMP, Tools of trade [EAR 740.9 (a)(1)]: Authorizes exports of institution owned items for temporary use abroad as long as you meet the following conditions.
- The item(s) will be returned to the U.S. within one year
- The item(s) must remain under effective control. This means the item must be in your physical possession or must be maintained in a secured environment, such as a hotel safe or a locked or guarded facility.
- Allows travel to any country except Cuba, North Korea, Iran, Sudan, and Syria.
Who will you be interacting with and what will you be sharing?
Do you know if the foreign colleague or entity whom you plan to engage with is sanctioned or a specially designated entity or individual?
Prior to entering into a foreign collaboration, please request a restricted party screening . This screening will help to vet out potentially restricted entities and individuals.
When attending a meeting, conference, or meeting with a foreign research collaborator, it is important to remember that you can only share data or information that has been published, or is publicly available, or that falls within the fundamental research exclusion. Be diligent not to discuss any proprietary, unpublished, or export-restricted data or information.