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
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Where are you going?
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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 Export Controls team 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.
- International travelers should review guidance provided by the Information Security office on the International Travel Guidelines website. In addition, travelers should review the ISO position papers regarding Remotely Connecting to University Systems and use of Personal Devices in China
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Who will you be talking to?
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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.
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What will you take with you?
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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:
- Sharing information related to defense articles found on the United States Munitions List (ITAR)
- 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 Export Controls team at [email protected] for assistance.
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Why are you going?
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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
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Recommendations
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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.
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Resources
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The following resources are available to assist you prior to travel:
- University Travel Website: Covers everything from safety while traveling to expense reporting
- Graduate School International Travel Advice: Advice for graduate students traveling abroad for research, language learning, conferences, and other purposes
- Office of International Programs: Guidance for undergraduates planning a bridge year or other study abroad experience
- How to Protect Your Data and Devices when Traveling [PDF]: A presentation from OIT’s CISO and Senior Information Security Training and Outreach Specialist
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Encryption
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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.