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Tools of Trade License Exception
Applicable:
In order to use the “Tools of Trade” license exception to travel temporarily out of the U.S. with items (e.g., instruments, equipment, software, technology, etc.) needed for an individual’s occupation or employment, both personal and item requirements must be met:
1. Personal requirements:
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You must be a U.S. person or the employee of a U.S. person,
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Any accompanying family member must be a U.S. person,
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You must take only the usual and reasonable kinds and quantities of items for use in a lawful enterprise or undertaking, or the trade, occupation, employment, vocation or hobby of you or an accompanying family member,
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You must bring the items back with you upon your return or within 12 months,
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You must keep the item under your effective control at all times rather than leaving it in your locked hotel room, and
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You must take precautions against the unauthorized release of software and technology.
2. Requirements for the items (e.g., hardware, software, and data) you take with you:
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The laptops and other computing and data storage devices are all standard, off-the-shelf products and are generally available to the public through retail outlets.
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The operating system and all software applications are generally available to the public and are either pre-installed on standard, off-the-shelf hardware or can be purchased and installed by a user without vendor support.
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Any "mass market" encryption software (i.e., encryption of the kind that is generally available to the public and does not allow for user revisions) used to enhance communciations security capabilities is either pre-installed on standard, off-the-shelf hardware or can be purchased and installed by a user without vendor support. Examples include: FileVault for Mac, Bitlocker for Windows, U-M Cisco VPN, and Okta Verify.
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Any data and analyses you take are publicly available (e.g., published in journals or published on the web). Data and analysis from research that ordinarily would be published and that are not restricted by contract from general dissemination can be treated as publicly available; and
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There are no other export constraints on any of the equipment, software, data or information that would apply to your intended travel. Examples of items with export constraints that are not eligible for this exception include satellite or other space related equipment, components or software, high level encryption products, and defense items covered by the International Trade in Arms Regulations (ITAR).
NOTE: “Mass market” multi-factor authentication (MFA) applications, such as Okta Verify Mobile app, Security Keys (e.g., Yubikey), and hardware tokens are encryption items that are themselves subject to U.S. export control regulations.
Generally, you may ship or travel with and use these export controlled MFA items internationally, except to the following comprehensively embargoed and sanctioned countries:
- Cuba
- North Korea
- Iran
- Crimean region of Ukraine
- Donetsk region of Ukraine
- Luhansk region of Ukraine
In order to comply with U.S. regulations, Okta (and other MFA applications) block authentications from users whose IP address originates in a country or region subject to economic and trade sanctions enforced by the U.S. Office of Foreign Assets Control (OFAC).
Faculty, staff and students attempting to authenticate from a comprehensively embargoed and sanctioned country using Okta Verify will be blocked from completing their login and will receive an error message.
In very specific cases, an exception can be made to allow individuals to use SMS or Phone Call as their MFA method. To request an exception, fill out this form: ITS Multi-Factor Authentication SMS/Phone Call Exception Request Form (UMICH password and two-factor authentication required).
Self-Assessment / Documentation
If you would like to document your export compliance and self-assess that your electronic devices comply with the "Tools of Trade" license exception, download the applicable form(s) to take with you when you travel:
Not Applicable
The “tools of the trade” exception does not apply, and a federal export license is required when:
- Traveling to a comprehensively embargoed or sanctioned country with hardware containing multi-factor authentication applications or other encryption software
- Accessing services from within a comprehensively embargoed or sanctioned country, such as online learning courses or online training platforms.
- Shipping items to a comprehensively embargoed or sanctioned country.