Policy Library

International Travel

Traveling abroad with hand carried items (ex. laptops, jump drives, and prototypes or samples) can trigger export control regulations, particularly if they include any proprietary export-controlled information. There are also special precautions researchers should take when travelling abroad, depending on the country of destination.

International Travel Checklist

Click here for a PDF of the Export Control Travel Checklist to assist you with preparation of your international travels.

International Conference Presentations and Seminars

All UChicago personnel are encouraged to contact the ECO for guidance and evaluation prior to attending or participating in an international conference. The ECO can assist with the following:

the screening of potential collaborators using Visual Compliance™;
determining whether the conference is "open";
determining what information may be shared without a license;
determining whether an export license is required; and
maintaining appropriate university records

International conferences can pose various export control risks, especially if you present at a conference. Presented and/or discussed material must be limited to topics that are not related to export-controlled items or technologies, unless that information is already in the "public domain" or is “fundamental research.” Information is considered in the “public domain” if it is published and generally accessible or available to the public. “Fundamental research” includes basic or applied research in science and/or engineering at an accredited institution of higher learning in the United States where the resulting information (in some cases), is ordinarily published and shared broadly in the scientific community, or (in other cases) where the resulting information has been or is about to be published.

Additionally, "Open" seminars are usually not problematic unless they take place in a sanctioned country or involve restricted parties. Exchanges of technical information, including academic discussions, could require a license. A conference is "open" if all technically qualified members of the public are eligible to attend, and attendees are permitted to take notes or otherwise make a personal record (but not necessarily a recording) of the proceedings and presentations. Access to the information must be free or for a fee that does not exceed the cost to produce and distribute the material or hold the conference (including a reasonable profit).

Please contact the ECO for assistance at exportcontrol@uchicago.edu.

Conducting International Research, Teaching and Collaborating Abroad

Foreign Collaborations & Exchanges of Technical Information:

Publicly available information or fundamental research can be shared with foreign colleagues as long as the recipients are not employees or representatives of the government of a sanctioned country, or restricted parties. This collaboration includes normal academic peer-review or publishing processes.

Research & Instruction Outside of the U.S.:

Teaching standard curriculum abroad or presenting research findings at international conferences or meetings generally do not present export-controlled issues, unless:

Samples or instruments require a license;
Controlled ITAR or EAR technology is not the result of fundamental research;
Disclosure of data triggers an ITAR defense service; and
Data received is under an NDA.

Note, engaging in a sidebar conversation that contains the kind of data described in b. – d. may trigger an export license requirement. Exporting any commodity abroad, even if to advance fundamental research, requires prior license review by the Export Control Office (ECO).

Research and course instruction conducted outside of the U.S. may not qualify for the fundamental research exclusion (FRE), and therefore may require an export control license. For instance, when interacting with foreign persons, you cannot provide a “defense service” which includes providing technical “know-how” related to the design, development, production, manufacturer, assembly, operation, repair, testing, maintenance or modification of a defense article or dual-use technology. Export control regulations may apply until the work is published or is otherwise in the public domain. Before teaching a course or disclosing information outside of the U.S. it is important to ensure that the information is not subject to export control laws and regulations.

Furnishing Financial Assistance:

OFAC regulations prohibit providing material financial assistance or anything of value, including services, to any blocked or sanctioned country, individual, entity or organization, including a government agency of a sanctioned country. This can involve subcontracts, international vendors or payments to research participants. For example, a professional presentation, whether or not it contains materials controlled under International Traffic in Arms Regulations (“ITAR”) or Export Administration Regulations (“EAR”), is a “service” and “something of value” provided to the recipient audience, under OFAC regulations. Contact the ECO for guidance and clearance before proceeding with this type of transaction.

Travelling with Electronic Devices and Encryption Software

If you are traveling abroad with your laptop or any other electronic devices, these items along with the underlying technology, any data on your device, proprietary information, confidential records, and encryption software are all subject to U.S. export control regulations. Some foreign governments have regulations that permit the seizure of travelers’ computers and the review of their contents.

U.S. export regulations apply whenever you take such equipment and data outside of the U.S. Items that could have a “dual-use” (both commercial and military or proliferation applications), proprietary information, or items that are considered defense articles (even if used in an academic or research environment) are generally prohibited from export without an export control license. Export control regulations will generally not restrain you from taking commercially available laptop computers and standard software to most countries.

Further, items may be exempt from the license under the temporary export exception (TMP) as a “tool of trade.” To qualify for the “tool of trade” exception, the export must:

Remain under the effective control of the exporter (or the exporter’s employees) by retaining physical possession of the equipment at all times or securing the item in a secure environment;
Consist only of reasonable equipment of the trade (equipment that people in your discipline would generally recognize as a “tool of trade”);
Not be to an embargoed country (Cuba, Iran, North Korea, Syria or Sudan);
Be carried with the exporter or shipped ahead within 30 days of exporter’s travel
Be data that is within the public domain; and
Be for less than one (1) year.

You should not take ANY of the following items, abroad, without first obtaining specific advice from the ECO:

UChicago-owned scientific equipment (other than a sanitized laptop computer, PDA or electronic storage device);
Data or information received under an obligation of confidentiality including private information about research subjects;
Data or analyses that result from a project for which there are contractual constraints on the dissemination of the research results;
Devices, equipment or computer software received with restrictions on export to or on access by foreign nationals;
Devices, systems or software that was specifically designed or modified for military or space applications; or
Classified information

Warnings and Tips

Warnings

If U.S. Customs and Border Protection officials suspect that a regulated item or defense article has been exported without a proper license, they may on your return examine files and software on your laptop computer as well as your baggage. For this reason, international travelers are encouraged to “sanitize” electronic devices by removing all non-essential data prior to leaving the United States. Inspectors in other countries may detain and copy your hard drive (this has been known to happen). Alternate safeguard methods include taking a blank laptop with only public domain files needed for the specific international trip or encrypting and then e-mailing to yourself any information you may need while overseas. Do not retrieve the e-mail until you have reached your destination, and remember you will need to remove it completely prior to returning to the U.S. or prior to crossing any international border.

Helpful Tips

When traveling internationally:

Use your best judgment in communicating with foreign nationals, and be alert to situations that may result in inadvertent, inappropriate, or illegal disclosure of controlled information or data;
Avoid situations that lead to providing advice or assistance outside of fundamental research parameters;
Do not discuss controlled or sensitive information (for example, proprietary information that you may happen to have) in public places;
Always keep controlled or sensitive items, information, or data secure;
Maintain a “need-to-know” policy when discussing work related information with others;
Do not leave equipment, documents, or data in your hotel safe.

Working with the Export Control Office well ahead of your international trip is the best way to ensure that your travel is permitted, and/or that your materials and data can be taken abroad without a license or without violating export control laws and/or regulations. Contact the ECO at exportcontrol@lists.uchicago.edu.

Travel to Embargoed and Sanctioned Countries

U.S. export regulations restrict imports and exports to embargoed and sanctioned destinations without a U.S. Government authorization (otherwise known as a "license"). Contact the Export Control Office at exportcontrol@uchicago.edu if you are planning to travel to any embargoed or sanctioned country for review if a license is required for your destination, intended activity, and/or for any items you are taking with you.

For some general guidelines on embargoed and sanctioned countries, please note the following—

Cuba

Travel to Cuba is restricted to only certain academic activities which may be pursued under a US government license. Please review the following checklist and contact the Export Control Office for more information about travel to Cuba prior to making any travel-related arrangements (hotel accommodations, airfare, etc.) – CUBA TRAVEL CHECKLIST

Note that the US Treasury Department’s Office of Foreign Assets Control (OFAC) imposes the regulations which govern travel to Cuba, and specifically prohibit all tourist-oriented activities in Cuba. Professional research and professional meetings may be permissible travel under very specific circumstances – there are four primary categories UChicago personnel may use for Educational Activities travel to Cuba (per 31 C.F.R. 515.565(a)(2)):

Participation in a structured educational program in Cuba as a part of a course offered for credit;
Noncommercial academic research in Cuba specifically related to Cuba and for the purpose of obtaining an undergraduate or graduate degree;
Establishment of academic exchanges and joint non-commercial academic research with Cuban universities or Cuban academic institutions; or
The organization of, and preparation for, activities described in the previous bullets.

For more information, please also visit the United States Department of the Treasury's "Resource Center" on Cuba sanctions: Guidance Regarding Travel Between the United States and Cuba.

Again, contact the Export Control Office prior to any UChicago travel to Cuba for a full review to ensure your compliance with federal export control laws at – exportcontrol@uchicago.edu

Iran

The Treasury’s Office of Foreign Assets Control (OFAC) imposes strict sanctions against Iran. If you are planning on travelling to Iran, please review the following checklist and contact the Export Control Office at your earliest convenience – IRAN TRAVEL CHECKLIST

Authorizations and General Licenses

Additionally, please note that OFAC has issued some authorizations and general licenses in order to allow for a few otherwise prohibited activities. These authorizations and general licenses are approved without the need to apply for a specific license, however do contact the Export Control Office prior to utilizing one of the authorizations below, as some restrictions may apply—

General License G: Activities that fall under General License G—

Enter into student exchange agreements with universities located in Iran.
Conduct the following educational services to engage with students in Iran:
- Filing and processing of admissions applications and accepting tuition payments from or on behalf of Iranian citizens.
- Recruiting and employing Iranian citizens in a teaching capacity who are already employed in such capacity at an Iranian university, provided the appropriate US visa is granted.
- Providing services to Iran in support of combating illiteracy, increasing access to education, and assisting in educational reform projects;
Facilitating the following for University enrolled students:
- participation in educational courses or engagement in non-commercial academic research at Iranian universities at the undergraduate level by the student so long as they are actively enrolled at UChicago.
- participation in educational courses or engagement in non-commercial academic research at Iranian universities at the graduate level in the areas of humanities, social sciences, law or business.
Note also that the participation by Iranian citizens in undergraduate level online courses provided by U.S. academic institutions in the fields of the humanities, social sciences, law or business is permitted provided that the courses are of the type ordinarily required for the completion of undergraduate degree programs in the humanities, social sciences, law or business, or are introductory undergraduate level science, technology, engineering, or math courses ordinarily required for the completion of undergraduate degree programs in the humanities, social sciences, law or business.
Certain publishing-related activities (Note, this does not include research activities leading to publication).

North Korea

Travel to North Korea is extremely restricted. There are no exemptions currently for academic activities.

Additionally, nearly all technology, software, defense articles, or defense services, will likely require a license from the Bureau of Industry and Security (BIS) or the Directorate of Defense Trade Control (DDTC) prior to being transferred or released to North Korea or North Korean nationals.

For more information on the North Korea Sanctions Regulations (NKSR) under 31 CFR Part 510, please see the Department of State website for North Korean Sanctions. Or, if you intend on conducting any UChicago activity with entities or individuals located in North Korea, please contact exportcontrol@uchicago.edu.

Syria

The Department of Treasury’s Office of Foreign Assets Control (OFAC) primarily regulates sanctions under the Syrian Sanctions Regulations (SySR), under 31 CFR Part 542. Syrian Sanctions will generally require authorization from OFAC for any U.S. person who wishes to conduct any transaction or engage in any activity with the country of Syria, or sanctioned individuals or entities under the SySR.

Moreover, nearly all technology, software, defense articles, and defense services, are likely to require a license from the Bureau of Industry and Security (BIS) or the Directorate of Defense Trade Control (DDTC) prior to being transferred or released to Syria or any Syrian nationals.

Note: as of May 12, 2022, transactions for new investment in Syria or exports, reexports, sales, or the supply of services to Syria (SySR §§ 552.206 or 542.207) that are ordinarily incident and necessary to activities in the following economic sectors are authorized under a general license for both the northeast and northwest regions of Syria (See Annex of General License No. 22):

Agriculture;
Information and telecommunications;
Power grid infrastructure;
Construction;
Finance;
Clean energy;
Transportation and warehousing;
Water and waste management;
Health services;
Education;
Manufacturing; and
Trade.

Nothing under this update covers transactions involving any person, including the Government of Syria, whose property or interests in property are blocked pursuant to the SySR or the Caesar Syria Civilian Protection Act of 2019. For more information on this update, please see General License No. 22.

More information on U.S. relations with Syria can be found on the Department of State website for Syria Sanctions. For more information on the SySR, or if you intend on conducting any UChicago activities with entities or individuals located in Syria, please contact exportcontrol@uchicago.edu.

Countries Under Targeted Sanctions Programs

For a list of some countries targeted under U.S. sanctions programs, please Click Here.

Any travel-related questions related to export control should be directed to the Export Control team at exportcontrol@lists.uchicago.edu