- Research Compliance
University of Florida faculty, researchers, and staff often travel internationally as part of their official UF duties. Depending upon your destination, what you intend to bring with you, or your planned activities, you may need to obtain a license or other authorization from the U.S. government before your trip.
In addition to your departmental approval process, there are three steps you need to take before you embark on an international trip:
1. Review the guidance on this webpage and contact the Division of Research Compliance and Global Support for assistance with export licenses or other authorizations.
2. Register your travel with the UF International Center.
3. If you are traveling with any UF-owned equipment, including your laptop, request pre-approval from UF Asset Management.
When planning your travel, it is important to note that the State of Florida has a unique law that prohibits the use of any state funds in support of travel to countries designated as state sponsors of terrorism. Currently, the U.S. Department of State has designated Iran, Sudan, and Syria as state sponsors of terrorism. As such, you cannot use any UF funds to support your travel to those destinations, including UF Foundation, gift, start-up, or sponsored research funds.
In addition to Florida law, the U.S. Office of Foreign Assets Control (OFAC) administers trade sanctions programs, which may impact your ability to travel to or perform certain activities in various sanctioned countries. The countries of most concern are those countries subject to OFAC’s comprehensive sanctions: Cuba, Iran, North Korea, Sudan, Syria, and the Crimea region. Most interactions with those countries will require a license from the U.S. government. Before you travel to or plan collaborations with any of the comprehensively sanctioned countries, contact the Division of Research Compliance and Global Support to determine whether your planned travel or activity requires a license.
Each time you leave the U.S. and bring items with you, even temporarily, you have engaged in an export of those items. In most cases, bringing items with you when you travel does not require any prior authorization. However, especially when traveling on university business, you may need to export an item or technology to a location that would require a license or other authorization (i.e., license exception). The Division of Research Compliance and Global Support can help you determine whether what you’re taking on your trip is subject to the export control regulations.
Rules of Thumb for Traveling with Equipment or Software:
– UF-owned equipment or software (other than basic laptops, tablets, and cell phones);
– Equipment, software, or data that you received with restrictions on its export or on access by foreign persons;
– Data or analyses that resulted from research that did not qualify as fundamental research (i.e., research that was subject to publication or foreign person access restrictions);
– Equipment, systems, or software that were specifically designed or modified for military or space applications;
– ITAR-controlled articles or technical data (including software);
– and Classified information.
Items that Generally Will Not Require a License:
– Note that both the laptop itself and all software and data stored on it are subject to export control regulations. In general, laptops cannot contain anything other than standard, off-the-shelf software and basic encryption in order to export them without a license. Additionally, you must remove any export controlled or proprietary data from your laptop before traveling.
Here are the TMP qualification requirements:
– The equipment or software must be a tool of your trade, which means that it must be an item that is of a usual and reasonable kind and quantity of tools of trade for use in your discipline;
– The equipment or software must be returned to the U.S. within one year;
– You must retain effective control of the equipment or software at all times during your trip; and
– Your travel cannot be to or through a comprehensively sanctioned country (Cuba, Iran, North Korea, Sudan, Syria, and the Crimea region).
In most cases, you’ll be able to present your research and collaborate with colleagues internationally without an export license from the U.S. government. However, if your work is controlled or proprietary, or if you engage in activities in certain countries, then you might need an export license before you share any items or information. To determine any applicable licensing requirements for your planned international activities, review the general guidance below and contact the Division of Research Compliance and Global Support for assistance.
Presentations (Domestic or International):
In general, mere attendance at an international conference will not require a license, except for attendance at a conference in Iran (see Iran section). If you plan to present at a conference or open meeting either in the U.S. or abroad, you will not need a license as long as you present information that is already within the public domain or is the result of fundamental research. Presenting information that relates to export controlled or proprietary technologies could require a license, even if held within the U.S.
Interactions with Foreign Colleagues:
You may share information or data with foreign colleagues as long as it is already within the public domain or resulted from the conduct of fundamental research and your foreign colleagues are not a sanctioned or specially designated entity or individual. Before you engage in collaborations with foreign colleagues, contact the Division of Research Compliance and Global Support and request a restricted party screening, which will help you identify sanctioned or specially designated entities and individuals.
Research & Teaching Outside of the U.S.
Research conducted outside of the U.S. may not qualify for the fundamental research exclusion. Thus, before sharing any research results from international research projects, contact the Division of Research Compliance and Global Support to determine whether the information is subject to export controls.
Teaching or instruction outside of the U.S. generally is allowable without an export license as long as the subject matter is within the public domain or is educational information ordinarily taught in university settings. If you plan to teach in a sanctioned country, certain restrictions may apply; contact the Division of Research Compliance and Global Support for guidance.
OFAC maintains a comprehensive sanctions program against Iran pursuant to the Iranian Transactions and Sanctions Regulations (ITSR), among other rules, executive orders, and policies. Additionally, the U.S. Department of State has designated Iran as a state sponsor of terrorism. These regulations and designations place significant restrictions on the interactions the UF community can have with Iran, its people, and its businesses. Additionally, Florida law prohibits the use of any university funds in support of travel to Iran.
In general, the following restrictions apply to all UF activities with Iran:
– This license requirement applies regardless of the topic of the conference and regardless of whether the information presented is within the public domain.
The chart below lists specific examples of activities with Iran that are prohibited or are allowable under a general license. Before traveling to or collaborating with Iran, review the chart below, contact theDivision of Research Compliance and Global Support to seek approval for your planned activities, and register your travel with the UF International Center. The Division of Research Compliance also can assist you in seeking an OFAC license.
|Prohibited Importation of Goods or Services from Iran||Except as otherwise authorized (e.g., pursuant to a license issued by OFAC), importation into the United States of any goods or services of Iranian origin or owned or controlled by the Government of Iran, other than information and informational materials, is prohibited.
Example: accepting samples or data shipped from Iran for testing or analysis.
|31 C.F.R. § 560.201|
Prohibited Exportation, Reexportation, Sale, or Supply of Goods, Technology, or Services to Iran
|Except as otherwise authorized, a United States person cannot export, reexport, sell, or supply any goods, technology, or services to Iran or the Government of Iran.
Note that OFAC broadly construes “services.” Examples of providing a service might include:
|31 C.F.R. § 560.204|
|Prohibited use of University Funds to Support Travel-Related Activities to Iran||By law in the State of Florida, UF cannot use any of its funds to implement, organize, direct, coordinate, or administer (or support those acts) activities related to or involving travel to any state sponsor of terrorism, as designated by the U.S. Department of State. Currently, Iran is designated as a state sponsor of terrorism.
Note that the prohibition is on any UF funds, including Foundation or gift funds, start-up funds, college/departmental funds, or any sponsored research award funds.
|Information or Informational Materials||The general prohibitions described above do not apply to the importation or exportation of information or informational materials, as defined in § 560.315, whether commercial or otherwise, regardless of format or medium of transmission.
“Information or Informational Materials” includes, but is not limited to, publications, films, posters, phonograph records, photographs, microfilms, microfiche, tapes, compact disks, CD ROMs, artworks, and news wire feeds.
However, this exemption does not apply to the following:
|Academic Exchanges and Educational Services||Academic Exchanges: Accredited graduate and undergraduate degree-granting institutions are authorized to enter into student academic exchange agreements with Iranian universities related to undergraduate or graduate education courses and to engage in all activities related to such agreements (including providing scholarships to Iranian students to attend U.S. institutions).
1. U.S. academic institutions are authorized to export services:
2. U.S. persons who are actively enrolled in U.S. academic institutions are authorized to:
This authorization does not include exporting any goods (including software) or technology to Iran, except for technology and software designated as EAR99 or constitutes “educational information” under the EAR.
|31 C.F.R. Part 560 – General License G|
|Peer Review & Publishing||U.S. persons are authorized (subject to certain restrictions) to engage in transactions “necessary and ordinarily incident to” the publishing and marketing of manuscripts, books, journals and newspapers. This includes collaborating on the creation and enhancement of written publications and substantive editing of written publications.
This exemption does not apply if one of the parties to the transaction is the Government of Iran, which does not include academic and research institutions and their personnel.
|31 C.F.R. § 560.538|
|Services Related to Conferences in the U.S. or Third Countries||
Conferences in the U.S.
U.S. persons may import or export services, if the services are performed or provided in the U.S., for an Iranian person to participate in a public conference, performance, exhibition, or similar event, and if such services are consistent with that purpose.
Conferences in Third Countries
U.S. persons may sponsor a public conference in a third country (not U.S. or Iran) that is attended by Iranian persons provided that attendance and participation at the conference is open for the public and that the conference is not tailored in whole or in part to or for Iran or Iranian persons.
This exemption may not be used for the Government of Iran, an Iranian financial institution, or any person whose property or interests are blocked.
This exemption does not authorize the release of technology or software to an Iranian person.
|31 C.F.R. § 560.554|
|Activities of Persons with Certain Nonimmigrant or Immigrant Classifications||Persons otherwise eligible for nonimmigrant classification under category F (students), J (exchange visitors), or H (temporary worker), among other categories, are authorized to carry out in the U.S. those activities for which such a visa or nonimmigrant status has been granted by the U.S. government.
For students in the U.S. on F visas, U.S. persons may release technology and software to those students, provided that all of the following are met:
|Travel||In general, when you are traveling to Iran for an authorized purpose, the resulting travel-related transactions are exempt from the Iranian Transactions and Sanctions Regulations. However, you still cannot use any UF funds in support of your travel.
Examples of exempt travel-related transactions include:
|31 C.F.R. § 560.210(d)|
|Personal Communications||The prohibitions in the Iranian Transactions and Sanctions Regulations do not apply to any postal, telephonic, or other personal communication that does not involve the transfer of anything of value.||31 C.F.R. § 560.210(a)|
Many restrictions on travel to Cuba were lifted following the reestablishment of diplomatic relations with the United States. The November 2017 changes to the Cuba regulations, however, have affected UF engagement with Cuba. While most UF activities — including research, conference participation, professional meetings and study abroad — continue to be authorized under a “General License,” additional steps are now required to supplement the standard travel approval process.
As with all official travel, UF faculty and staff must complete and submit a Travel Authorization request in advance. In addition, all faculty and staff must register their international travel through the online UFIC Travel Registry. When registering for travel to Cuba, you will receive a notification that your travel registration is on hold, pending approval from the UFIC Dean.
For approval, all travelers must complete and submit the “UF Travel to Cuba: Acknowledgement of Compliance with Regulations” form before traveling. Key provisions in those regulations include the requirement to avoid engaging in transactions with a number of denied entities in Cuba, including many hotels. You are also responsible for maintaining records of your trip for five years. Once approved, you will receive the required Cuba travel letter from the UFIC dean.
The comprehensive US embargo on trade with Cuba also remains in effect. This embargo restricts the items that you are permitted to take when traveling to Cuba. All UF travelers are responsible for ensuring that they are in compliance with relevant regulations.
You may take the following approved items to Cuba without the need for further consultation or permission:
Any UF traveler planning to take items beyond those normally allowed as enumerated above or if permanently exporting ANY ITEM must consult and receive approval from the Division of Research Compliance before traveling.
In no circumstance may you bring items to Cuba that qualify as defense articles controlled under the International Traffic in Arms Regulations (ITAR).