International Travel and Export Compliance

When traveling internationally for university business or with university property, export control restrictions may apply depending on:

Where you are going
What you take with you (i.e., Physical Exports)
The purpose of your trip and who you will engage with

The export compliance team in the Office of Research Compliance (ORC) can help you determine if any export restrictions apply to your destination(s), if any export licenses or documented use of a license exception are needed for physical exports, and provide Restricted Party Screening of foreign colleagues and foreign institutions or other entities you plan to engage with on your trip.

Where are you going?

While travel to most countries doesn’t on its own trigger export control concerns, travel to an Office of Foreign Assets Control (OFAC) Sanctioned Country (external link), including but not limited to Belarus, Cuba, Iran, North Korea, Russia, or Syria, may require the university to secure a license for the travel before your trip. Countries subject to Military End Use Controls, including China, Burma, Cambodia, Nicaragua, or Venezuela, require extra due diligence, and many activities and/or exports there may trigger licensing requirements. Please alert the export compliance team at um.export@maine.edu as early as possible if you plan to travel to a sanctioned country or country subject to Military End Use controls, regardless of your trip’s purpose.

What are you taking with you? (i.e., Physical Exports)

When leaving the country, everything taken with you is considered an export. The physical items, the underlying technology, and any data which may reside on them are all subject to export control regulations, even if the export is temporary.

For the university’s purposes, ORC only needs to know about UMaine-owned equipment, supplies, devices, etc. being taken abroad. (Personal Items? Complete CBP Form 4457 [external link] to register personal items for re-entry to the United States [U.S.]) It is the traveler’s responsibility to ensure that equipment, electronic devices, files, and presentations do not contain any export-controlled technical data or technology, and to coordinate with the export compliance team in ORC to determine if any applicable licensing or filing requirements apply to their export.

ORC’s export compliance team is notified of university international travel that is submitted in Concur, and will reach out to inquire about planned exports. However, travelers with planned exports are also encouraged to review ORC’s guidance on Physical Exports and Export Compliance and Travel with Portable Electronic Devices and proactively contact the export compliance team at um.export@maine.edu well ahead of your trip, especially if you plan to take a large number of items with you, so that there is adequate time to assist you. As noted in the two guidance pages, you will want to ensure you keep copies of export documentation, such as documents for customs, with you when you travel!

Personal Travel with University-Owned Devices

Any time a university-owned device is taken abroad, it is considered to be an export by the university and thus is subject to the same review process. In this scenario, it is the traveler’s responsibility to notify ORC of this export since the travel is personal and isn’t in Concur. Please follow the instructions above and contact um.export@maine.edu if questions arise.

What is the purpose of your trip?

Presenting at international conferences generally doesn’t require export compliance review unless:

You are presenting unpublished, proprietary, and/or export-controlled data or information.
and/or
If the conference you plan to attend or present at is in a sanctioned country or one subject to Military End Use controls (as described above).

If the international conference you are attending is an open conference (i.e., open to members of the public), any information you receive at the conference would typically be considered published or in the public domain, and thus not subject to export controls. Given that, you should avoid presenting, sharing, or discussing any unpublished, proprietary, or export-controlled data or information, and any data or information restricted by non-disclosure agreements (NDAs), confidentiality agreements, or other similar agreements. In other words, you should limit information shared to only that which is already in the public domain to limit the possibility of inadvertently violating U.S. export control regulations.

However, if you plan to present data or information that has not been previously published, if you plan to present at a conference that is not an open conference, and/or if you plan to present at a conference in a sanctioned country or one subject to Military End Use controls, please contact the export compliance team in advance.

Consider Physical Exports and information which may be shared or otherwise released while conducting research abroad, ensure exports are reviewed as needed, and consider international collaborations (see below) to ensure Restricted Party Screening has been conducted. See International Research for additional considerations.

Consider who (both individuals and entities) you plan to engage with while abroad and ensure they are not a restricted party/entity by requesting Restricted Party Screening via email to um.export@maine.edu. (Note: Formal collaborators and their home institutions, i.e., those named in MOUs (Memorandum of Understanding), Research Agreements or other institutional-level agreements, have likely already been screened via ORC’s communications with the Office of Research Administration (ORA) and/or Office of Strategic Partnerships, Innovation, Resources and Engagement (SPIRE), but if you are unsure, you are welcome to request screening).

Providing course instruction, training, or other services abroad may be subject to export control. Prior to engaging in these activities, it is important to consider whether the information to be shared is subject to export control laws and regulations.

Other considerations for international travel

The University of Maine System (UMS) requires travelers to countries with a U.S. State Department Travel Advisory (external link) Level of 3 to receive an exception from UMS Risk and Safety Management. University-funded travel to countries with a Travel Advisory Level of 4 is prohibited.
Work with UMS Risk and Safety Management to ensure the appropriate insurance coverage is in place for your activity and equipment.
If you plan to travel with electronic devices, be sure to review the UMaine Advanced Research Computing, Security, and Information Management (ARCSIM) travel guidance for data security which includes tips for travelers for before, during, and after travel.
Fieldwork? Work with UMS Risk and Safety Management to develop and implement a Fieldwork Safety Plan (Please see: Fieldwork Safety Training Guide [requires @maine.edu account to view]).
NSF-funded trip? You may need to develop & disseminate an off-campus or off-site Safe and Inclusive Working Environment Plan. For more information, see UMS Safe and Inclusive Work Environment Plan.
ASCC-affiliated? (Advanced Structures and Composites Center) Make sure you follow any additional requirements detailed in ASCC’s policies and SOPs (Standard Operating Procedures) – see SOP-22 “Purchasing and Travel” and SOP-42 “International Travel Procedure.”

Resources / Quick Links

Contact

If you have any other questions or concerns about international travel and export compliance, please contact um.export@maine.edu.