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Research Security

Foreign Travel Process and Guidelines

To ensure that the University complies with federal and state guidelines regarding Foreign Influences and Export Control, all faculty, staff, and students traveling outside the United States on University sanctioned trip must complete the Foreign Travel Form in Laserfiche for an evaluation prior to processing the Travel Authorization Request (TAR) in Concur. 

While exact requirements vary by destination, travelers should expect to give the Office of Research Compliance the following information:

    • Your destination and dates of travel,
    • Where the funding will come from,
    • A list of any equipment (and the serial numbers) or items belonging to the university you plan to take with you,
    • A list of any software packages and/or presentations you plan to use, demonstrate, present, or may otherwise be viewed by foreign nationals during your travel.

Note: Some countries have their own additional import and export controls regulations which may affect how you can use items while overseas, and which could restrict your ability to bring them back. Travelers should be aware of all applicable regulations and how they could apply to them.

The ‘Export Controls’ course on the CITI Program training site will be helpful as you prepare to travel, and in some cases, completion of this training prior to travel approval might be mandatory. Also, check the US Department of State website for travel advisories to countries you plan to visit.

Not attending the conference but submitting a paper?

There will be occasions when you will not be attending a conference in a foreign country, but are submitting a paper. As long as the paper being submitted is fundamental research, and the country is not on the sanctioned country list, the foreign travel checklist is not needed. Please remember that if designs, technical information, or proprietary information will be submitted, depending on the country, an export control license may be needed.

If you have been invited to give an online presentation of your research to an institution located in a foreign country, depending on the country, you may need an export control license. Please contact the Export Control Officer in the Office of Research Compliance if you have questions.

Where are you going?

Traveling overseas can present Export Control concerns depending on the destinations. The embargoed sanctioned countries (CRIMEA – REGION OF UKRAINE, CUBA, IRAN, NORTH KOREA, SUDAN, and SYRIA) prohibit ALL transactions (including imports and exports) without a license authorization. If you intend to travel to one of the countries listed, please contact the Export Control Officer in the Office of Research Compliance immediately so an evaluation can be done. Note: the list of sanctioned countries is constantly evolving, please make sure to check the embargoed sanctioned countries list prior to arranging travel plans.

What are you taking?

When traveling outside of the U.S., everything you take with you is subject to the U.S. Export Controls regulations. This includes tangible items (laptops, cell phones, equipment, samples, paper documents, etc.) and intangible products (skills training, knowledge, files, data, etc.). The AAMU community should be familiar with the applicable Export Controls regulations and strive to comply with them as violations can result in severe criminal and civil sanctions against individuals and/or the University.

Are you taking University equipment?

If you plan to take University equipment, please complete the TMP form. Any faculty, staff, or student traveling internationally and using university funding or carrying university-owned equipment or items must meet certain requirements before arranging or embarking on such travel. The TMP form must be submitted no less than 14 days before travel date.

BEST ADVICE
    • If you can do without the device, DO NOT TAKE IT!
    • Don’t expect privacy – computers can be searched.
    • Do not travel with unnecessary information or current research on a laptop.
    • Do not leave electronic devices unattended.
    • Use caution when sending information electronically.
    • Make copies of your passport, airplane ticket, driver’s license, and credit cards.
    • Do not take unnecessary identification or credit cards.
    • Do not use USB-based public battery charging stations. The USB interface to your device may be used to deliver viruses or malware.
    • In some countries, all internet traffic may be monitored. Assume your internet traffic is not private.
    • Don’t’ post where you are going and what you will be doing on social media.

Who are you working with and why?

When attending a meeting/conference/tradeshow for University business, the AAMU community must ensure that the data they release is fundamental research or publicly available. The release of export-restricted technologies or information, without prior authorization or in violation of the terms of a license, is an export violation and exposes you to severe penalties.

Note: You may share information resulting from Fundamental Research [Fundamental Research (EAR and ITAR) means basic or applied research in science and engineering performed or conducted at an accredited institution of higher learning in the United States where the resulting information is ordinarily published and shared broadly in the scientific community. Fundamental research is distinguished from research that results in information that is restricted for proprietary reasons or national security reasons (EAR) or pursuant to specific U.S. government access and dissemination controls (ITAR)] that is or was conducted in the U.S., at an accredited institution of higher learning. However, you are not allowed to share any items generated under the Fundamental Research or any non-publicly available information or software. In addition, you are not allowed to conduct Fundamental Research abroad, i.e. the Fundamental Research exemption does not apply to a laboratory or field research site in other countries.

In addition, AAMU campus community must ensure that they are not interacting with or providing financial assistance to a sanctioned or specially designated entity, such as persons or entities appearing on the OFAC’s Specially Designated Nationals and Blocked Persons List, or on the BIS’s Denied Person List or the Entity List. Therefore, it is recommended to know in advance with whom you will be communicating and collaborating, so that we can perform a complete Restricted Party Screening (RPS) of those persons and entities. The Export Control Officer in the Office of Research Compliance can assist with this.

License Exception

There are two license exemptions to the licensing requirements for traveling outside of the U.S with export-controlled items. These exceptions can be used only under certain conditions.

    • The Export License Exception TMP (EAR 740.9) authorizes temporary export/re-export of institution-owned items that will return to the United States within one year of when they leave. The items must remain under the effective control (“Effective control” means retaining the item(s) in my physical possession or maintaining the item(s) in a secure environment such as a hotel safe or a locked or guarded facility) of the exporter/re-exporter. The TMP “Tool of Trade” exception allows you to travel with usual and reasonable quantities of tools of the trade to any country, except Cuba, Iran, North Korea, Sudan, and Syria. If you are eligible to travel under this exemption, complete the TMP form and email it to the Export Control Officer at compliance@aamu.edu.

Note: Completion of the TMP form is mandatory if you are taking University equipment. The TMP license exception is available to U.S. persons (e.g., AAMU) or their employees (e.g., all AAMU legal employees regardless of citizenship status) without documents being required. The TMP form was created to help you demonstrate to a Customs Officer that you are aware of and have thought through the regulations. Therefore, we recommend this form be completed for “unusual” items only (research items) that are more likely to draw attention from Customs Officials than basic electronic devices (such as laptops, cell phones, and tablets).

    • The Export License Exception BAG(EAR 740.14) authorizes temporary export/re-export of personal items or technology. For instance, under this license exception, you can take your personal laptop for travel to any country except Cuba, Iran, North Korea, Sudan, and Syria. Note: However, if your laptop contains controlled software/data, a license will be required. This exception applies only to personal items and, thus, does not apply to items owned by AAMU (e.g. laptop bought with University funding). Complete the BAG form and email it to the Export Control Officer at research.compliance@aamu.edu. 

Note: Completion of the BAG form is not mandatory but encouraged.

The BAG and TMP license exceptions do not apply to technology associated with high-grade encryption products and ITAR-controlled items (i.e., defense articles and services).

Smart Traveler Enrollment Program (STEP)

AAMU recommends that you sign up for the Smart Traveler Enrollment Program (STEP) on the State Department website before traveling out of the country.

What is STEP?

The Smart Traveler Enrollment Program (STEP) is a free service to allow U.S. citizens and nationals traveling and living abroad to enroll their trip with the nearest U.S. Embassy or Consulate.

Benefits of Enrolling in STEP
    • Receive important information from the Embassy about safety conditions in your destination country, helping you make informed decisions about your travel plans.
    • Help the U.S. Embassy contact you in an emergency, whether natural disaster, civil unrest, or family emergency.
    • Help family and friends get in touch with you in an emergency.
 

Video Resources: STEP

Other Travel Resources
Training Resources

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