International Travel

Restrictions

Procedure for International Travel for all UPRM faculty, researcher, student or employee

If you are travelling internationally

• Follow the regular UPRM travel procedure
• AND Go to https://docs.google.com/a/upr.edu/forms/d/1RpLKMVgpFhzDS_P2nRVYec-Cz-yAKPX6uOzTNML9yPA/viewform and fill the application for the International Travel - Export Controls Certificate

On what you can take

When you leave the country, everything you take is an export, including devices, software, and data.

• You cannot take ITAR-controlled articles, technical data, or software (which the ITAR considers to be technical data) without a license from the State Department. Tangible items developed through fundamental research which was excluded from export controls are still subject to the ITAR.
• To be clear:  if you have ITAR-controlled technical data, such as a document or drawing, on your laptop, you cannot take it out of the US, even if you have no intent to transfer the items to a non-US person.
• In most cases, US and non-US persons can take EAR-controlled items and software, including your laptop and PDA, using EAR license exception TMP or BAGcan use the exceptions to take EAR items and software
• US persons can use the exceptions to take EAR-controlled technology, but this does not authorize its transfer to someone not otherwise authorized to receive it.
• To be clear:  these exceptions don’t authorize a non-US person to take EAR-controlled technology out of the US, even if it has been transferred to them as an acceptable deemed export
• Continue to Using TMP or BAG exceptions for more detail on when you can use these exceptions, and for documents you can take with you to demonstrate compliance with the provisions of the exceptions.

Remember that destination countries have their own import and export controls (seeTravel.State.Gov) which may affect how you can use items while there and which could restrict your ability to take them out of the destination country.  You should be familiar with any that apply to you.

On where you can go

• Check the U S Department of the Treasury, Office of Foreign Assets Control web site for a list of Embargoed Countries (or in our site: Sanctioned and Embargoed Countries)
• Read the UPRM’s Export Controls Rules.  If you decide to travel to an embargoed country, you must sign UPRM’s travel form before departure, acknowledging the risk and personal responsibility for the decision to travel. 
• Travel to Cuba: New Rules in http://www.treasury.gov/resource-center/sanctions/Programs/Documents/cuba_faqs_new.pdf 

On what you can do when you get there

 While US sanctions programs and restrictions on transactions with specific parties always apply, the likelihood of being affected by them increases when you’re outside the US. 

Iran, North Korea, (North Sudan) and Syria are subject to strict controls on the EAR’s Commerce Control List, and are also subject to OFAC sanctions programs.  If you will be working with nationals of these countries, you should be familiar with both.

Working with China entities and nationals can be complicated by US policy toward China, which includes both enthusiastic support for commercial transactions and strong aversion to support of the Chinese military.  Some apparently benign China institutions are considered by the US government to be closely related to the military, resulting in restrictions on transactions with them.

OFAC’s Specially Designated Nationals and Blocked Persons List and the Commerce Department’s Entity List are the most relevant, but the government maintains a total of 35 lists with various restrictions.  You can check most of these using the National Export Initiative’s consolidated list, or consult UPRM’s Export Control Team.

If you plan to travel to any of these locations or have any questions regarding international travel please contact Dr. María Amador-Dumois, Interim Export Control Officer, Research and Development Center, at extension 5344 and via e-mail at exportcontrols@uprm.edu.