Office of Export and Secure Research Compliance

Guidance for International Travel on behalf of Virginia Tech

Federal export and sanctions regulations prohibit the unlicensed export of specific commodities, software, technology and payments to or from certain countries, entities and individuals for reasons of national security, foreign policy or protection of trade. University employees are required to comply with United States export and sanctions regulations when traveling abroad with commodities, software, and technology. The Office of Export and Secure Research Compliance (OESRC) can assist with export and sanction determinations related to your international travel. You will find helpful information below concerning international travel procedures and best practices to ensure compliance with these federal regulations. If you have any questions pertaining to international travel not covered on this page, please contact our office at oesrc@vt.edu or 1-6642.

Plan Ahead!

1. Prepare your information and equipment before leaving the U.S. Do you need an export license?

   When taken outside of the United States, university property such as commodities, software, and technology (hereafter called items) may be subject to export licensing under the Export Administration Regulations (EAR) or regulations by other government agencies. Many items such as laptops, tablets, cell phones and PDA’s containing commercial software, may be temporarily exported as “tools of trade” under the export license exception TMP. “Tools of Trade” can be simply defined as items that are used for university business, conferences, trade shows, etc.

   If a license or license exception is required, it must be in place prior to travel. If an exception is not applicable and a license is required, a Bureau of Industry and Security (BIS) License can take up to eight weeks to process once submitted. Thus, planning ahead is essential.

   Before you leave the U.S., remove anything from your electronic devices that constitutes a trade secret, proprietary information, export-controlled technical data, limited distribution, or any other information that is deemed confidential, sensitive or protected. Consult with your department IT administrator or OESRC to determine effective wiping solutions for this data. If your computer contains information from a Technology Control Plan restricted project, OESRC’s Information Systems Security Officer should be consulted to ensure the data has been removed from the computer using approved software (e.g., Eraser).
    

2. Fill out a Temporary Export Certification before you travel internationally! You can do this easily online!

   The TMP Certification does not apply to any equipment, components, technical data or software specifically designed for military, space, or intelligence applications or otherwise controlled under the International Traffic in Arms Regulations (ITAR). In these cases, please contact OESRC at 1-6642 or oesrc@vt.edu.
    

3. Click, download and read the Best Practices for Academics Traveling Overseas document provided by the FBI.
    
4. View country information. The Department of State (DoS) provides very valuable information on every country in the world. You will find information on the location of the U.S. embassy and any consular offices; whether you need a visa; crime and security information; health and medical conditions; drug penalties; and localized hot spots. Please refer to:
   http://travel.state.gov/travel/cis_pa_tw/cis/cis_4965.html
    
5. Remember: If you don’t need it – don’t take it with you!!

International Travel Tips

Presentations and discussions must be limited to topics that are not related to controlled commodities, software, or technology unless that information is already published or otherwise already in the public domain.

Verify that your technology or information falls into one or more of the following categories prior to travelling:

• Research which qualifies for the fundamental research exclusion
• Published information
• Publicly available software
• Educational information
• Patent applications

Do not take any commodities, software, or technology that falls into one of the following categories:

• Classified or Export Controlled
• Limited Distribution, Proprietary, Confidential, or Sensitive
• Specifically designed or modified for military, space or intelligence applications
• Data or information received under a Non-Disclosure Agreement
• Data or analyses that result from a project for which there are contractual constraints on the dissemination of the research results
• Computer software received with restrictions on export to or on access by non-US Persons

Maintain effective control of any Virginia Tech items or equipment in your possession. This means you either retain physical possession of the item or you secure the item in such an environment as a locked car trunk, a hotel safe, or a locked or guarded meeting or conference facility. Avoid using other computers to log into a Virginia Tech network or website. Consider any information or electronic component that leaves your possession and visual control for more than two minutes likely compromised (copied, downloaded). If your Virginia Tech laptop or data storage device are lost or stolen during your trip, you must report the loss to the OESRC as soon as possible.

Restricted Parties

Restricted Party Screening (RPS) is an essential component of export compliance. RPS determines if the individuals and companies with whom you desire to do business are on any government issued restricted, blocked, or denied party lists. Request a restricted party screening for entities and individuals with whom you will be doing business!

During your travel, if you are contacted by one of these entities or individuals, please record as much information as you can about the incident and contact this office at oesrc@vt.edu or 1-6642.

International Travel Warnings and Alerts (from the Department of State)

Travel Warnings are issued when long-term, protracted conditions that make a country dangerous or unstable lead the State Department to recommend that Americans avoid or consider the risk of travel to that country. A Travel Warning is also issued when the U.S. Government's ability to assist American citizens is constrained due to the closure of an embassy or consulate or because of a drawdown of its staff.
For Countries with current Travel Warnings, please see: http://travel.state.gov/travel/cis_pa_tw/tw/tw_1764.html

Travel Alerts are issued to disseminate information about short-term conditions, either transnational or within a particular country, that pose significant risks to the security of U.S. citizens. Natural disasters, terrorist attacks, coups, anniversaries of terrorist events, election-related demonstrations or violence, and high-profile events such as international conferences or regional sports events are examples of conditions that might generate a Travel Alert.
For Countries with current Travel Alerts, please see: http://travel.state.gov/travel/cis_pa_tw/pa/pa_1766.html

International Travel Advisories

Travel Advisories are provided for Virginia Tech employees traveling overseas. All employees traveling internationally should submit a Travel Estimate and Approval (TEA) Form. Please be sure to provide the country of travel, the travel dates (to and from) and the fund information. OESRC will not return the TEA form, but will copy you on any necessary correspondence/notifications to the traveler (i.e. – Travel Advisory) so you will know that it has been received. Also, from the Controller’s Office website, please refer to: Procedure 20335a: Travel Overview: http://www.co.vt.edu/Procedures/p20335a.html

Travel advisories include up-to-date information on restricted parties and sanction risks in the country to which you are travelling, links to Department of State (DoS) travel warnings or alerts, as well as information concerning your university equipment.

If your office/department does not require you to fill out and submit a TEA form for international travel, you can request a travel advisory from OESRC for the country or countries you will be visiting. Please provide the following:

• Country information
• Dates of travel (to and from)
• Purpose of travel
• Fund information (or how the travel is being paid)
• Names of individuals or entities with whom you will be doing business

International Travel FAQ’s

• View international travel FAQ's