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- International Travel & Export Controls (v2)
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 being taken.
Many devices and equipment (e.g., laptops) have minimal constraints under the export control regulations.
See References & Resources below for links to information and advice about maintaining effective security over an item.
- Safe Computing
- International Center
- Global Michigan
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 Controls Program to ensure your travel complies with U.S. export control regulations.
Destinations currently subject to the most comprehensive US embargoes include:
Crimea region 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.
University employees and students travel internationally for many reasons, and different export control issues arise depending on the nature of your travel:
When traveling out of the United States, everything you take with you is considered an “export,” under U.S. export 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.
Items That Require Export Control Review Before You Travel
Do not travel with any of the following items without first obtaining specific advice from the Export Control Program, as these items may require an export license:
Devices, systems or software that are not standard, off-the-shelf products generally available to the public
Devices, systems, or software that are specifically designed or modified for military or space applications
Data or information received under an obligation of confidentiality
Data or analyses that result from a project that has restrictions on the dissemination of the research results
Export controlled information
Items That You May Be Able to Take With You
U-M employees and students may be able to use a “Tools of Trade” license exception to travel temporarily out of the U.S. and hand carry certain types of hardware, software and/or data. This license exception may be used by U-M employees and students traveling with personally-owned or U-M-owned hardware, software and data provided that the terms of the license exception are met. This exception does not apply to items, technology, data, or software regulated by the International Traffic in Arms Regulations (ITAR). Please contact the Export Control Program if you would like more information on using this exception when traveling internationally.
If your hardware, software or data are not eligible for the “Tools of Trade” license exception, the Export Control Program will discuss other options with you. There are other less frequently used license exceptions that may apply, and if no license exception is available, you may be able to work with the Export Control Program to apply for an export license.
Items That Need to Be Properly Secured For Travel
Whether you are traveling with a personally owned computer, a U-M owned computer, or any other device, you must make sure that you properly secure your hardware, software and data for international travel. U-M Safe Computing has detailed guidance to help you secure your devices before, during and after travel.
If you are traveling with any export controlled information or other sensitive data on your devices, you must encrypt your devices to protect the data from unauthorized disclosure. Please remember that before you travel with any data or devices, make sure that these items are able to be exported out of the country and taken with you to your intended destination. Encryption software that is not commercially available on a mass market basis may be regulated or restricted from being brought into some countries. See Export Controls on Encryption Software for more specifics.
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.
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.
What If You Encounter A Problem While Overseas?
You are required to report a stolen or lost device or other IT Security Incident. The U-M Office of Global Engagement provides detailed information on General Emergency Protocols for U-M International Travelers.