U.S. export control laws are applicable to U.S. persons who travel internationally. Everything that you take with you is considered an export, even if you have no intention of selling, loaning, lending, or transferring anything to a non-U.S. person while overseas. Important considerations during international travel include, but are not limited to, (1) what you will be taking with you, (2) where you will be going, and (3) what you will be doing.
Keep in mind that you must notify the Office of Export Controls (“OEC”) if your international travel will involve any of the following:
- Taking items or information enumerated on the United States Munitions List (items subject to the ITAR) with you – a license is mandatory.
- Taking items or information enumerated on the Commerce Control List (items subject to the EAR) with you – a license may be required.
- Traveling to Cuba, Iran, North Korea, Sudan, or Syria – there are very specific travel restrictions when traveling to an embargoed and/or sanctioned country and in many instances will require a license even if you’re not taking any ITAR or export-controlled items or information.
Overseas Travel Considerations
- You MUST obtain an export license. Please contact the OEC for additional guidance and information when traveling overseas with ITAR-controlled information.
- Keep in mind it will usually take at least several months to obtain an export license for ITAR-controlled information.
- You MAY need an export license. Please contact the OEC for additional guidance and information when traveling overseas with EAR-controlled information.
- Strict export restrictions apply to U.S. persons traveling to Cuba, Iran, North Korea, Sudan, or Syria
- Please contact the OEC if you are traveling to one of these five countries.
- Additional information on travel to, and export license requirements for, Cuba, Iran, North Korea, Syria, or Sudan can be found on the Bureau of Industry and Security’s Sanctioned Destinations website.
- The following countries also have travel sanctions, which are regulated by the Office of Foreign Assets Control. Please review the list to determine if you will be traveling to a country with certain US travel sanctions.
- Central African Republic
- Cote d-Ivoire (Ivory Coast)-Related
- Democratic Republic of the Congo-Related
- North Korea
- South Sudan-Related
- To prevent and minimize the possibility of unknowingly taking export-controlled information overseas, the OEC strongly encourages you to work with your department to obtain a sanitized laptop to bring with you if you participate on projects involving export controlled information.
- Although strong encryption software may be publicly available, it is tightly regulated by the EAR. Please contact the OEC if you will be taking strong encryption software overseas, even if it’s publicly available, to determine if a license is required or if an exception can be utilized.
- Additional information on encryption can be found on the Bureau of Industry and Security’s Encryption page.
- Your presentation or lecture might contain export-controlled information. The OEC can review the contents of your presentation to ensure there are no export control concerns.
- The OEC can assist you and perform restricted parties screening to ensure the individual(s) you will be meeting and/or working with while overseas are not on any denied parties lists.
U.S. Customs officials are authorized to search or retain electronic devices, including digital cameras, cell phones, media players, and disk drives as well as the items listed above, even without probable cause, to look for violation of export control regulations as well as other laws and regulations. Some considerations to avoid or minimize complications include:
- Don’t carry data you don’t want others to see: medical records, data files from your research, financial information, photos, etc.
- You should have a backup plan if there is data you will need when you reach your destination.
- Consider taking a device equipped with only ordinary, recognizable software and minimal data so any search can be fast and the consequence of a loss less disruptive.
Officials in any country may inspect your belongings, including electronic content of computers, phones, tablets, and storage devices. They may take possession of these items for various periods of time, and possibly permanently.