Export Control Considerations

When traveling abroad, any physical material or technical data in your possession is considered by US regulations to have been “exported” from the US to your final destination and any intermediate destinations. For this reason, it is important to understand whether there are any restrictions against exporting the material or data in your possession to your travel destination.

US Department of Treasury administers a number of sanctions programs which could impact travel, carrying of items, and provisions of services to certain locations. Currently, the most comprehensive sanctions program are for Iran, Syria, N. Korea, Cuba, and Sudan. If travel to any of these locations is contemplated, researchers should contact the Export Compliance Office as soon as possible to determine if their travel activities may be restricted by sanctions or if a license is required.

There are exemptions from export licensing available for travelers carrying both university-owned equipment ("TMP") and personal items ("BAG"). These exemptions are intended to cover commercially available computer equipment and other electronic devices used in business or general science applications. These exemptions DO NOT cover technology designed for a military application. Please contact the Export Compliance Office (ECO) if there are any questions about application and eligibility of the exemption.

The TMP and BAG exemption have limitations that travelers need to understand:

• Travel to Iran, Syria, Cuba, North Korea and Sudan is not eligible for these exemptions. Please contact the ECO as soon as possible when you become aware of a potential need to travel to any of these locations.
• Length of trip is limited to 12 months; a license may be required for longer periods.
• Items must remain under "effective control" of the traveler at all times which is defined as: "Retaining physical possession of items or keeping it secured in a place such as a hotel safe, a bonded warehouse, or a locked or guarded exhibition facility".
• These exemptions do not cover any hardware controlled under the United States Munitions List (USML) and high-tech encryption products (generally over 64 bit).
• Travelers cannot possess "controlled technical data" defined as "data required for the design, fabrication, operation, or maintenance of military or dual-use technology, and, not in the public domain or otherwise exempt from licensing requirements".

Note: This item is of critical importance for faculty engaged in outside consulting activities with technology and defense contractors due to their potential for having access to controlled technical data.

Please refer to the “Tools of the Trade Letter” page for additional information and to complete a letter request related to this TMP and BAG exemption.