International Travel

It is important to think about export controls when traveling internationally. If you are traveling with ITAR-controlled data, this is considered to be an export, just as it would be if you were sending data overseas electronically. Similarly, hand-carrying EAR-controlled equipment or data may require an export license.

Note: License exceptions may be available when Princeton-affiliated individuals plan to take University-owned or personal items out of the country.

    Key Considerations

    Where are you going?

    Travel to countries subject to United States government sanctions (i.e. Cuba, Iran, North Korea and Syria) may require prior United States government authorization. This includes travel for purposes that would not otherwise be subject to United States export control laws, such as participation in a conference.

    Action Items

    • Contact the Assistant Director of Export Controls to determine if your travel requires prior authorization.
    • Contact the Vice Provost for International Affairs and Operations for travel to all sanctioned countries and for detailed information about Princeton's initiatives in Cuba.
    • Review the U.S. Department of State's Current Travel Warning Website for information on the countries to which you plan to travel.
    • Upload your itinerary and contact information into Concur so Princeton may contact you in an emergency.
    • Download the International SOS insurance card, for which all University members on University-sponsored trips are automatically enrolled.

    Who will you be talking to?

    United States persons are prohibited from engaging in activities with individuals that have been determined to be acting contrary to the interests of the United States, also known as restricted parties. In addition, United States persons are prohibited from engaging in financial transactions with certain individuals and entities.

    Action Items

    Before traveling to a foreign country, you should request a screening of any known contacts against restricted party lists. The screening takes only minutes and can be performed by your ORPA administrator.

    What will you take with you?

    Many travelers do not realize that traveling overseas commonly involves the “export" of equipment and technology. For example, traveling overseas with your equipment, laptop, or cell phone is considered to be an export of the equipment, even though it will likely qualify for an exemption. 

    Federal Regulations and Travel

    Of particular concern from an export controls perspective is the export of military or space-related data subject to ITAR regulations. The export of such technical data or software, even if it is simply on a laptop taken out of the country, requires a license. Confidential or proprietary data (such as that provided by a sponsor) may also require an export license under the EAR if it is shared with non-U.S. persons.  

    What’s licensed, what’s not?

    The majority of exchanges between researchers off-campus can go forward without an export license. When in doubt, stick to information that is in the public domain or intended to be published. International conferences which are limited to published or publishable research are covered by the "publicly available/public domain" exclusions provided by the regulations. No export license is needed when these conference discussions take place.  

    However, there are two exceptions to this rule which may require an export license:

    1. Sharing information related to defense articles found on the United States Munitions List (ITAR) 
    2. Presenting at a conference in a sanctioned country

    Action Items

    If you are exporting equipment or data, even by hand, the export or data should be reviewed for compliance with export control regulations. In many cases, such exports may qualify for one of the exceptions to export control regulations. In other situations, an export license may be required, often depending upon the specific item and destination. Contact the Assistant Director of Export Controls for assistance.

    Why are you going?

    United States law prohibits the export, re-export, and certain transfers of equipment or technical data related to the following:

    • Chemical and biological weapons
    • Nuclear explosives
    • Rocket/missile systems
    • Unmanned air vehicles
    • Maritime nuclear propulsion systems
    • Weapons of mass destruction, including: Chemical weapons, biological weapons, and nuclear weapons
    • Military end-uses or end-users in China, Russia, or Venezuela

    Travel Planning

    Recommendations

    The following recommendations apply to all international travel by the Princeton community.

    Confidential or Proprietary Information 

    All confidential or proprietary information should be removed from your laptop, cell phone, and other electronic devices prior to travel. Clean "loaner laptops" may be available in some departments. To learn more, review OIT's International Travel Guidelines.

    Government Information

    You must remove information or data provided by U.S. Department of Defense agencies (AFRL, ONR, DARPA, AFOSR, etc.) prior to departure. Simply leaving the U.S. with such data, unless licensed by the U.S. government, is a violation of U.S. export control regulations.

    Export Fees

    You may be able to minimize or eliminate duties and taxes related to the import or export of equipment or commodities in some cases, including by using an ATA Carnet. Adequate time must be provided in order to investigate the options and obtain proper documentation.

    Country-Specific Requirements 

    Each country has its own import and export requirements. Just because a piece of equipment does not require a U.S. export license does not mean it will not require an import permit for entry into another country.

    Resources

    The following resources are available to assist you prior to travel:

    Encryption

    Depending on the country to which you are traveling, there may concerns with the type(s) of encryption software on your devices. Because encryption products can be used for illegal purposes, including terrorist activity, the U.S. and many other countries may ban or severely regulate the import, export, and use of encryption products.

    Moreover, taking a laptop with encryption software to certain countries without proper authorization could violate U.S. export control laws or the import regulations of the country to which you are traveling. This could result in confiscation, fines, or other penalties.

    Action Items

    Princeton's Office of Information Technology provides information about what software is permitted and what countries may be of concern. Review this information prior to traveling abroad.