UAMS personnel frequently travel abroad as a positive part of their ongoing scholarly efforts. Did you know that when you leave the United States, even temporarily and for any reason (e.g., teaching, research, or to attend a conference), everything you take with you is an export — including electronic devices, software, and data. This is true of any hand-carried items, materials, and devices. Because of this, international travel by UAMS personnel may be subject to Export Control regulations. Under most circumstances international travel is free of export concern; however, there are several factors that may cause heightened restrictions. Those restrictions may require an export license, which may be a time-consuming process. Please plan accordingly.
In order to protect UAMS, your research, and yourself, it is important to consider the following questions:
Where are you going?
While any item or technology that is taken outside the US is subject to export regulations, each country may be subject to different US export control requirements. Some destinations are subject to heightened export controls. The Department of Treasury, Office of Foreign Assets Control (OFAC) broadly regulates and restricts interactions with embargoed countries. These restrictions vary depending on the country and change frequently depending on US economic and political relations. In particular, the following nations are currently subject to the most comprehensive sanctions:
- Cuba
- Iran
- North Korea
- Sudan
- Syria
- Crimea region
- Donetsk region
- Luhansk region
- Sevastopol region
Any interaction with these nations will likely require a license from OFAC. For additional information, see Sanctions Programs and Country Information.
For information on sanctions related to Russia & Belarus, see Department of Commerce Country Guidance here.
Regardless of your foreign destination, please complete the UAMS Travel Form prior to your departure.
What are you taking?
When you travel abroad everything you take with you is considered an export. This applies not only to tangible items but intangible items as well. Some examples may be:
- Laptop and smart devices
- Scientific equipment
- Biological materials
- Chemicals and toxins
- Software
- Research data
- Blueprints, drawings, and schematics containing export controlled technology
- Technology related to encryption
In addition to becoming familiar with applicable export control requirements, UAMS travelers should note that any international travel with an electronic device may result in the disclosure of personal information installed on that device. In some countries, customs officials may examine information contained in devices or seize devices. Instances of laptop seizures have been widely reported in the press. Travel in and out of the U.S. is no exception: Homeland Security personnel may inspect information contained in a traveler’s device, or seize the device. UAMS travelers should therefore consider carefully which devices that they take with them on international trips.
Once outside the United States, you should NOT expect privacy. Your Wi-Fi connections are not secure and your property can be seized and searched by foreign authorities without probable cause. It is recommended that you document any items you plan to take with you to help prove they were in your possession before leaving the United States.
If you are traveling abroad and taking UAMS-owned property, please complete the International Travel form below to assist with this documentation.
What are you doing?
Fortunately, most international travel does not raise any export control concerns. This is in part because no export license is required for the temporary export to a non-sanctioned country of commercially available laptops, tablets, and/or cell phones with standard commercially available software. In other instances, an exclusion or exception to a license requirement maybe available.
If you plan to conduct research abroad, please keep in mind that this does not qualify for the Fundamental Research Exclusions (FRE) and may be subject to export controls. Additionally, this activity may require prior approval from the Vice Chancellor of Research and Innovation. Please complete their intake form found here.
If teaching abroad, limit your content to that of a catalog course; if you are presenting or sharing data, limit it to only that which is published or qualifies for the FRE. The same applies when collaborating abroad and sharing information with your foreign collaborators.
Who you interact with overseas also plays an important role in export compliance. The Office of International Compliance will perform a Restricted Parties Screening (RPS) on people and associated entities you plan to interact to ensure they are not listed on US Government-issued blocked or denied parties lists. Please avoid using abbreviations.
However, in order to assess any potential export control issues associated with your upcoming international trip, please answer the International Travel Form questions carefully. NOTE: Individuals can be held personally liable for exporting controlled items, controlled technical data, or controlled software without a license or license exception. Contact the Office of International Compliance if you have any additional questions.
International Travel Form
Please note: in accordance with the UAMS International Compliance Policy & Guide, UAMS travelers must complete the International Travel Form (available below) prior to international travel.
If the responses are “yes” to any of questions 1-9 in the International Travel Form below, please ensure this form is completed at least 45 days prior to trip commencement in order permit to the Office of International Compliance to review. The Office of International Compliance may contact you for additional information to complete the export review process. In the event a license if required, the Office of International Compliance will submit a license application to the appropriate government agency.
If the response is “yes” to question 10 only, please provide a description of the property to be taken outside the US. In the event additional information is required, the Office of International Compliance will contact you. If an Export License Exception Certification is necessary, the Office of International Compliance will provide it to you for completion prior to your trip.
If you are unable to certify the statements contained on the Export License Exception Certification, contact the Office of International Compliance. In the event a license is required, the Office of International Compliance will submit a license application to the appropriate government agency
When the International Travel Form is completed, you will receive an email. This email is automatically submitted to the UAMS Travel Office, and no further action is necessary on your part. However, if any additional information is required, the Office of International Compliance will contact you.
This form is best used with the Google Chrome browser
This form is only required for work-related travel, not for personal travel.