International Travel and Shipping

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, Cuba, North Korea, 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, 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 UF Research Integrity, Security and Compliance 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). UF RISC 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:

• Do not take the following items with you on the trip without first consulting UF RISC:

– UF-owned equipment or software (other than basic UF-laptops, tablets, which can be submitted via the myAssets Portal with UF RISC consultation);

– 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.

• Plan ahead! Getting an export license from the U.S. government may take several months, so contact the UF RISC as soon as possible to begin your export review.

Items that Generally Will Not Require a License:

• Laptops, Tablets, Cell Phones – You likely will not need a license to take most low-tech, commercially available items with you during travel to most countries except the comprehensively sanctioned countries (Cuba, Iran, North Korea, Syria, and the Crimea region). For travel to or through the comprehensively sanctioned countries, an export license likely will be required, even for common items like laptops and cell phones. (See more information on Cuba and Iran, below)

– 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.

• Specific Lab or Research Project Equipment – For laboratory or research equipment or software that is subject to the Export Administration Regulations (EAR), you may be able to take it with you without first obtaining a license because the export either may not require a license to your destination or you may be able to qualify for the TMP (Temporary Export) license exception. Common equipment examples include GPS units and various cameras (even those that are commercially available). Contact the UF RISC to determine if your equipment or software will qualify for export under the TMP license exception (or another exception) and to obtain a TMP approval letter that you can carry with you during your trip.

  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, Syria, and the Crimea region).

• Personally-Owned Items – In most cases, you may rely on the BAG (Baggage) license exception to bring personally-owned commercially available items on your trip for your personal use.

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 UF RISC 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 UF RISC 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 UF RISC 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 UF RISC for guidance.

Before traveling abroad for any UF sponsored activity, there are three things to consider:

1. Where are you going?
   • Please register all international travel at https://internationalcenter.ufl.edu. Registration with the UF International Center not only ensures individuals have travel insurance, but is used to recognize potential export control concerns.
2. What are you taking with you?
   • Rule of thumb: If you don’t need it, don’t take it. Most low-tech commercial devices such as laptops and iPads do not need an export license; however, the destination, length of time abroad, and cost of the items transported may affect the outcome. Be sure to register the transfer or temporary export of all UF-owned items through https://myassets.fa.ufl.edu.
3. What is the purpose of your travel?
   • General travel to present at conferences or conduct research in the field can trigger export control concerns based on the nature of the work and destination of travel. It is best to have the destination and research partners screened to ensure no work will be conducted with Restricted Parties.

An export control license may be required when shipping or traveling outside the US with chemical, biological or nuclear materials, temporarily or permanently. To ensure that such materials are not exported in violation of US export control laws, the person transferring such materials outside the US should follow the processes established by Environmental Health and Safety so that the appropriate license and/or government authorizations are obtained. Please visit the Shipping & Transport of Biological Materials webpage for more information.