- Are there restrictions on where I can go?
- Are there restriction on what can I take?
- Personal Electronic Devices
- Are there restrictions on who I can transact with?
- What other resources are available for university related overseas travel?
Are there restrictions on where I can go?
Travel to comprehensively embargoed countries (Iran, Syria, Cuba, North Korea) requires a license from the U.S. Department of the Treasury Office of Foreign Assets Control (OFAC). Other countries may also be subject to sanctions that affect travel. Check the OFAC website for a list of current Country Sanctions Programs. If you are considering travel to an embargoed or sanctioned country, please contact the Export Control Manager.
OFAC also maintains lists of restricted entities which include individuals, institutes, businesses, and universities. Interactions with restricted entities are prohibited. Contact the Export Control Manager for restricted party screening to determine if the institute you are visiting is on the Restricted Party Lists.
Check the Department of State’s Travel Alerts and Warnings and OFAC websites for information on the latest travel warnings.
UPDATE: TRAVEL TO CUBA AND IRAN
Despite media coverage on the lifting of some sanctions, Cuba and Iran are still effectively embargoed for travel except for very specific and limited purposes. Faculty travel to academic conferences in Iran, for example, requires a license from the Office of Foreign Assets control. Processing time for license requests can take several weeks to several months. Any personnel interested in traveling to Cuba or Iran should contact the Export Control Manager as early as possible for assistance with license requirements.
Are there restrictions on what I can take?
When you leave the U.S., everything you take is an export, including devices, software, and technical data. Depending on the item and the destination, you may need an export license.
Even if generated by “fundamental research,” materials, equipment, technology, and software are not exempt from export controls if transferred outside of the U.S.
In order to avoid travel delays and possible export violations, if you are bringing items (other than a laptop and cell phone) with you or shipping items ahead to a foreign country, please send an email as far in advance as possible detailing the
- Item make, model number, brief description, vendor link if possible
- Destination country
- Institution you are visiting or collaborating with, if any
- Dates of travel and
- Whether you will be returning the item(s) to the United States.
to the Export Control Manager at email@example.com.
Personal Electronic Devices
Personal electronic devices (laptops, tablets, PDA, phones, flash drives) and ordinary (mass market) software typically do not need a license for most destinations. If a license is needed, two exceptions may be used to allow export without a license:
U.S. persons may take personal devices out of the U.S. under the “BAG” (15CFR §740.14) exception and University owned devices under the “TMP” (15 CFR §740.9) exception, if:
- You will return with the device within 12 months
- The device and technology will remain in your effective control throughout the trip (in your physical possession or in a secured space e.g., hotel safe)
- You do not release or share any controlled technology while overseas
- You take responsibility for preventing inadvertent releases. You should use secure connections, a password to protect technical data, and a firewall while using your computer
- Your device does not contain non-mass-market encryption applications or software
- The device does not contain satellite, space, or defense related items and will not be used to support or assist foreign military or space programs
- Your device, technology, or software will not be directly or indirectly used for nuclear activity
These exceptions do not apply to non-U.S. persons.
Advice on electronic devices from the FBI:
- Sanitize your laptop, telephone, & PDA, prior to travel and ensure no sensitive contact, research, or personal data is on them. Back-up all information you take and leave that at home. If feasible, use a “clean” laptop, phone and a new email account while traveling. Or If you can do without the device, Do Not Take It! Cell phones can be hacked to steal contact lists, usernames, passwords, and browser history. NOTE: WashU has clean laptops available for temporary use overseas. To request a clean laptop, visit the IT Loaner Equipment website.
- Use up-to-date protections for antivirus, spyware, security patches, and firewall. However, be aware some countries do not allow encrypted devices and may seize them at the border.
- Do not leave electronic devices unattended. Do not transport them (or anything valuable) in your checked baggage. Shield passwords from view. Avoid Wi-Fi networks if you can. In some countries they are controlled by security services; in all cases they are insecure.
- Do not allow foreign electronic storage devices to be connected to your computer or phone. They may contain malware or automatically copy your stored electronic data. Do not use thumb drives given to you – they may be compromised.
- Clear your Internet browser after each use: delete history files, caches, cookies, and temporary internet files.
- If your phone or laptop is stolen, report it immediately to the local US Embassy or Consulate.
- Do not use non-company computers to log into your company’s network. Always consider any information conveyed through a non-company computer to be compromised, even if encrypted. Cyber criminals from numerous countries buy and sell stolen financial information including credit card data and login credentials (user names and passwords).
- Beware of “phishing.” Foreign security services and criminals are adept at pretending to be someone you trust in order to obtain personal or sensitive information.
- Beware that your conversations may not be private or secure. Unlike the United States, most other countries do not have legal restrictions against technical surveillance. Most foreign security services have various means of screening incoming visitors to identify persons of potential intelligence interest. They also have well established contacts with hotels and common hosts that can assist in various forms of monitoring you. Electronic eavesdropping has been reported on airlines, in hotel rooms, taxis, and meeting rooms. Business and government travelers have reported their hotel rooms and belongings were searched while they were away. Sometimes there was no effort to conceal the search.
Are there restrictions on who I can transact with?
U.S. agencies maintain several lists prohibiting transactions with specific persons and entities in many countries. Many benign sounding foreign institutes appear on these lists. Restricted party screening should be conducted before transacting with foreign persons or entities. For example, a faculty member invited to speak at a university or institute overseas should have the institute screened against the Restricted Party Lists before accepting the invitation. Similarly, foreign persons requesting tours of or visits to University facilities should be screened before a letter of invitation is extended. To check the status of any person or entity, contact the Export Control Manager at firstname.lastname@example.org.
Cuba, Iran, North Korea, and Syria are subject to comprehensive sanctions. Other countries may be sanctioned or may be subject to extensive controls (e.g. China). Before interacting with individuals or entities from these countries, contact the Export Control Manager.
Please consult with the Export Control Manager email@example.com when planning international travel for restricted party screening and for consultation on the export of equipment or technical information.
What other resources are available at Washington University to assist with university related international travel?
Please visit the Washington University Global Engagement website for information on short term international health insurance, emergency travel services, and the international travel registry.