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International Travel & Export Controls
See References & Resources below for links to information and advice about maintaining effective security over an item.
- International Center
- Safe Computing
- Global Michigan
International travel by University employees or students may be subject to export control regulations depending on the travel destination and the hardware, software, and/or technical data that is taken.
Where Are You Going?
When you travel internationally in your role as U-M employee or student, you must register your travel with the U-M Travel Registry. Registering travel with the U-M Travel Registry is also encouraged for personal trips. The U.S Department of State also allows you to record information about your planned trip so that they can assist you in case of an emergency.
If your destination is subject to U.S. embargoes, the U-M Travel Registry will automatically send your travel information to the Export Control Program, and you will be contacted to assure your travel complies with export regulations. If you are traveling to or through any other destination that is subject to other travel restrictions, you will need to talk to the Export Control Program to ensure your travel complies with U.S. export control regulations.
Destinations currently subject to the most comprehensive US embargoes include:
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Cuba
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Iran
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North Korea
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Syria
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Crimea, Donetsk People’s Republic (DNR) and Luhansk People’s Republic (LNR) regions of Ukraine
Even if you do not need an export license to travel to your destination, you may need an export license to conduct certain activities in specific countries or to take certain items with you.
PLEASE NOTE: If you are planning to travel to Iran for a meeting or conference, you will need to obtain an export license prior to your trip. You should contact the Export Control Program immediately to allow time to apply for the license.
What Is The Purpose of Your Trip?
University employees and students travel internationally for many reasons, and different export control issues arise depending on the nature of your travel:
What Are You Taking With You?
When traveling out of the United States, everything you take with you is considered an “export,” under U.S. export control regulations. Some of these exports will require an export license from the government. However, in many situations, you will not need an export license because either (1) the items or data you are taking are not controlled to your destination or sometimes (2) a license exception is available.
What Do You Need To Be Careful Of?
The Foreign Corrupt Practices Act
It is illegal for U.S. persons to offer or pay anything of value to a foreign official for the purposes of obtaining, retaining, or furthering business activities, per the federal Foreign Corrupt Practices Act (FCPA) anti-bribery provisions. For example, making payments to custom officials in exchange for their agreeing not to inspect goods or to release goods held at points of entry would violate the FCPA. For more information, visit the U-M Export Controls FCPA guidance.
Be Aware
Customs officials in any country, including the U.S., may inspect your belongings, including electronic content of computers, phones, tablets, and storage devices. They may take possession of these items for various periods of time—even permanently. It is a best practice to only take items with you that are absolutely needed for your trip.
Some countries also have import regulations that specifically prohibit travelers from bringing into those countries encrypted laptops or other mobile devices. Violations of those countries’ prohibitions could result in confiscation of your device by customs authorities and/or fines or other penalties.
Preventing A Problem While Traveling
You are required to report a stolen or lost device or other IT Security Incident. The U-M Office of Global Engagement also provides detailed information on General Emergency Protocols for U-M International Travelers.
References and Resources
Questions?
Questions? Contact the Export Controls Office at: [email protected]