International Travel
When traveling abroad there are three basic questions to consider when determining if export controls apply:
Where are you going?
In general, travel to most countries is not a concern; however, tighter export controls are in effect for countries that are sanctioned or have restrictions on trade enforced by the U.S. government.
The following, sanctioned countries will require advance planning and coordination with the Export Controls office: Cuba, Iran, North Korea, Sudan, Syria, and Venezuela. Contact the Export Controls Office as soon as you anticipate travel to one of these countries to discuss country specific travel and license requirements.
Travel to China:
- If you are traveling to China, electronic devices such as a cell phone, PDA, or laptop must remain in your personal custody and control at all times.
- Chinese Customs may check your electronics.
- Use a VPN instead of public Wi-Fi, hotspots or cellular data.
- Don not bring unpublished research, private or personal information on your devices; expect that anything on your hard drive will be copied upon entering the country. Upon return, scren your devices for viruses. It is common to bring a virus back on your device.
When traveling to other “comprehensively sanctioned” countries of Cuba, Iran, Syria, Sudan and North Korea, or providing access to your items to a citizen of one of those countries, an export license will most likely be required. Additional information on travel to Cuba is available through the U.S. Department of State.
DUO: NDSU requires the use of two-factor authentication with DUO. This log in security is especially important when traveling internationally; however, DUO itself is export controlled technology and its use in certain countries requires special considerations. If traveling to China or Iran, contact the Export Control office for additional information.
It is highly recommended that you register any items/equipment that you will be taking with you with U.S. Customs and Protection (CBP). Registration allows you to prove that you had the items before you left the U.S. and all CBP registered items will be allowed to return to the U.S. duty-free. The Export Controls office will assist you with completing theCertificate of Registration – Form 4455 .
When traveling abroad, it is always a good idea to contact the appropriate U.S. Embassy or Consulate before you depart. To register your travel plans with an embassy and receive helpful safety and emergency information related to your destination, visit the Department of State’s Smart Traveler Enrollment Program. For more information about U.S. Embassies and Consular Offices visit USEmbassy.gov
What are you taking with you?
Items & Equipment
When taking items abroad (including scientific equipment, laptops, encryption software, cell phones, tablets, flash drives, cameras, and GPS units), verify that the items are not export restricted based on your travel destination(s). When traveling between countries you may be asked to provide an Export Control Classification Number (ECCN) for each item you take.
ECCNs for Common Travel Items
Please refer to the chart below for the ECCNs for equipment most commonly taken abroad. Do NOT use this chart for travel to Cuba, Iran, North Korea, Russia, China or Venezuela.
ITEM | ECCN# | LICENSED AUTHORITY |
---|---|---|
Dell Laptop (no encryption) | 5A992c | No License Required (NLR) |
Mac Laptop | 5A992 | No License Required (NLR) |
iPhone and iPad | 5A992 | No License Required (NLR) |
Jump/Flash Drive (most) | 3A991 | No License Required (NLR) |
Android Cell Phone/Tablet | 5A992 | No License Required (NLR) |
Garmin GPS | 7A994 | No License Required (NLR) |
Bitlocker Encryption | 5D992 | No License Required (NLR) |
GoPro Camera | EAR99 | No License Required (NLR) |
Most commercially available basic software (such as Microsoft Office) is EAR99 and can be exported either individually or on your device without a license. However, proprietary software, software that includes encryption, and/or other complex software may require an export license and should be reviewed by the Export Controls Office.
Please contact the Export Controls office if you are planning to take equipment that is not listed in the avove chart or your device includes any of the above software. |
International Travel with Encrypted Mobile Devices- Import/Export Restrictions
Some countries restrict the import of encrypted devices and do not recognize a "personal use exemption." Before traveling to the countries listed below, you will need to apply for the country's specified governmental agency for a license. The lists below are subject to change. Please check with the embassy of the country you are leaving from and/or traveling to for the most up-to-date information. If you have encroption enabled on your device, please be sure to ask specifically about the regulations for encryption.
For travel to China, Russia or Venezuela, an electronic export information (EEI) filing is required by EAR 15 CFR 758.1(b)(10) for all personal or business-owned consumer electronics, such as cell phones and laptops, whether th items are shipped or being hand-carried. The Export Controls office will handle the required filing.
- Belarus- a license issues by the Belarus Ministry of Foreign Affairs of the State Center for Information Security of the Security Council.
- Burma (Myanmar)- a license is required, but a licensing regime documentation is unavailable. Contact the US State Department for further information.
- China- a permit issued by the Beijing Office of State Encryption Administrative Bureau.
- Hungary- an International Import Certificate is required. Contact the US State Department for further information.
- Iran- a license issued by Iran's Supreme Council for Cultural Revolution
- Kazakhstan- a license issued by Kazakhstan's Licensing Commission of the Committee of National Security.
- Moldova- a license issued by Maldova's Ministry of National Security
- Morocco- a license is required, but licensing regime documentation is unavailable. Contact the US State Department for further information.
- Russia- licenses issued by both the Federal Security Service (Federal'naya Slushba Bezopasnosti- "FSB") and the Ministry of Economic Development and Trade are required. License applications should be submitted by an entity officially registered in Russia. This would normally be the company that is seeking to bring an encryption product into Russia.
- Saudi Arabia- is has been reported that the use of encryption is generally banned, but research has provided inconsistent information. Contact the US State Department for further information.
- Tunisia- a license issued by Tunisia's National Agency for Electronic Certification (ANCE).
- Ukraine- a license issued by the Department of Special Telecommunication Systems and Protection of Information of the Security Service of Ukraine (SBU).
The Department of Commerce's Export Administration Regulations forbids the export of any encrypted device to Cuba, Iran or North Korea.
What will you be doing and who will you be interacting with?
It is important to ensure that you do not accidentally export restricted information or provide any type of assistance or benefit to a sanctioned or blocked entity. The following are a few things to keep in mind as you plan your travel activities:
Research Data & Information
You are free to take and openly discuss any data or information that is published, in the public domain, is normally taught as part of a catalog course at NDSU, or that resulted from Fundamental Research. However, you cannot take or share data or information that is in any way export-restricted, such as information about export-controlled technologies, proprietary information, unpublished or the results of a project not protected under the Fundamental Research Exclusion. Sharing these types of information may constitute an unauthorized export. All controlled or restricted data and information should be completely removed from laptops, phones, PDAs, or other portable storage devices (e.g., flash drives) before you leave the U.S.
Presentations
When presenting data/information in an international setting (including in the U.S. where the audience may include foreign nationals), limit your presentation to only information or data that is published, or is publicly available, or that qualifies as Fundamental Research. Be careful not to include or discuss any proprietary, unpublished, or export-restricted data or information as that may constitute an unauthorized export.
Interactions with Foreign Colleagues
As noted above, you are free to openly discuss any published or publicly available information or information generated as the result of Fundamental Research as long as the recipient is not a sanctioned or specially designated entity. It is important to remember that while the results/information resulting from Fundamental Research are not subject to export controls and can be shared without a license, any items, technology, or software generated under that Fundamental Research would be subject to export controls and may require an export license.
Field Work
Any university research activity done outside the U.S. may not qualify for the Fundamental Research Exclusion. Before disclosing or sharing information or data resulting from international field work it is important to ensure that the information is not export restricted.
In addition, please contact us as soon as possible if any of the following factors are involved with your research:
- Taking equipment other than items listed in the ECCN chart above;
- Providing payments of any kind to a foreign person, university or organization;
- Purchasing or obtaining items or materials from international sources;
- Planning to bring back samples;
- Sending equipment, materials, or information from the U.S. to a foreign destination; or
- Potential or existing non-disclosure agreements or restrictions on the publication of research results.
Provision of Financial Assistance
To ensure compliance with OFAC regulations prohibiting the University from providing material or financial assistance to any blocked or sanctioned individual or entity, any university activity that involves payment to a non-U.S. person, business, or organization (e.g., international subcontracts, purchase of items from international vendors, or payments to research participants) must be verified against all appropriate sanctioned party and entity lists. The Export Controls office will assist with screening payees and verifying any international financial transaction(s).
Contact the Export Controls office:
Compliance with export control regulations is an individual responsibility. To ensure smooth international travel and complaince, contact the NDSU Export Controls office as soon as possible with questions or concerns about export controls as they may apply to your travel plans. |