Export Control Considerations for International Travel
WSU encourages and supports its faculty, staff, and students to participate in University-related activities abroad, including international research and collaboration. International travel on behalf of WSU may be subject to export control regulations due to the technology, software, and/or technical data being taken out of the country, and/or due to the travel destination. The following should be considered when planning international travel and/or research collaborations to ensure compliance with export control laws and regulations. Please ensure to reach out to the compliance office as soon as you are aware of your plans to travel, allowing at least five business days for review.
Where are you traveling?
If planning on traveling to China, Cuba, Iran, North Korea, Russia, Sudan, Syria, Crimea, or Donetsk and Luhansk regions of Ukraine, you are required to contact the Export Control Officer immediately. Activities and items that you can take into these countries will be highly restricted, and our policy for work-sponsored travel with access to WSU services (such as e-mail) is one of presumptive denial. All services provided to nationals of these countries necessitate review and may require an export license.
Other countries with notable sanctions and end-user restrictions include: Afghanistan, Balkans, Belarus, Burma (Myanmar), Central African Republic, Democratic Republic of the Congo, Ethiopia, Eritrea, Hong Kong, Iraq, Lebanon, Libya, Mali, Nicaragua, Somalia, South Sudan, Venezuela, Yemen, Zimbabwe, and others. Note: Layovers in foreign countries also count as a destination for export control purposes. Please be aware that restrictions may exist for a layover location, even though it is not your final destination.
Why are you going?
Foreign conferences – limit presentations, seminars, and discussion to topics that are not related to export-controlled items, software, or technology unless that information has been published, is currently publicly available or in the public domain, or qualifies as fundamental research. Do not provide details of your research or area of expertise to anyone who is not known to you. Please note: if you are planning to travel to the countries above for a meeting or conference, you will likely need to obtain an export license even if the material is not controlled prior to your trip. Contact the Export Control Office immediately to allow time to apply for a license.
Conducting Research or Meeting with Collaborators – sharing information or conducting research on export controlled items or technology will potentially require an export license, depending on the research and the destination(s).
Providing Defense Services/Governmental Services – Furnishing assistance to foreign persons or governmental or defense agencies in the design, development, engineering, manufacture, production, assembly, testing, repair, maintenance, modification, operation, demilitarization, destruction, processing or use of defense articles - any items or information restricted by ITAR - requires an export license, full-stop.
Who are you meeting?
The U.S. government maintains lists of restricted, denied, debarred, designated, or blocked individuals and entities. If named on one of these lists, WSU may be prohibited from doing business with or providing services to the individual or entity. Please contact the Export Control Office to ensure that any individual or entity you will be collaborating with overseas is not on a restricted party list.
What are you taking with you/shipping?
Do not travel with any of the following items without first obtaining specific guidance from the Export Control Office, 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 - think "high tech", "specialized" items or equipment, esp. for research.
- Devices, systems, or software that are specifically designed or modified for military or space research or applications
- Data or information received under an obligation of confidentiality, such as in private industry contracts, non-Fundamental Federal contracts, or NDAs
- Data or analyses that result from a project that has restrictions on the dissemination of the research results
- Classified information
- Export controlled information
Technology is information required for the development, production, use and/or maintenance of controlled items or work. This may include blueprints, drawings, designs, photos, plans, datasets, presentations, and instructions. Please consider these items when determining whether you are planning to bring controlled technology out of the U.S.
Traveling Internationally if you hold a Security Clearance
If you hold an active security clearance, you will need to contact Allysa Allton (allysa.allton@idp.wichita.edu) prior to leaving the country.
Items That You May be Able to Take with You
A license exception may be available to WSU personnel who plan to travel temporarily out of the U.S. and hand carry certain types of hardware, software and/or 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 Office if you would like more information on such travel exceptions when traveling internationally.
Items That Need to Be Properly Safeguarded for Travel
If you are traveling with any export-controlled information or other sensitive data on your devices, you may need to encrypt, properly safeguard, or request loaner 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 by confirming with Export Control. Please contact WSU’s Office of Information Security (askinfosec@wichita.edu) for more specifics on securing your data and devices.
WSU’s Export Control Office shall assist in evaluating export control concerns to reduce the likelihood of an export control or sanction violation.
James Elliott, Export Control & Compliance Officer (316) 978-COMP exportcontrols@wichita.edu