1. When traveling internationally, University Travelers are “exporters” of any tangible items and technical information they take with them and/or share abroad.
  2. Therefore, University Travelers traveling to an International Destination(s) must comply with all export control and sanctions laws, regulations and requirements including, but not limited to, proper handling, transfer, access, storage, control, and release of export-controlled commodities, hardware, software, information, technology, and technical data.
  3. Export Control review is required for all University Travel to or through International Destinations, High Risk Destinations and Elevated Cyber Security Risk Destinations. Export Control approval is required for travel to High-Risk Destinations and Elevated Cyber Security Risk Destinations.
  4. Campus Export Control Review and Approval Processes.
    1. Campuses / UMPO shall implement export control review and approval processes for all international University Travel conducted by their respective University Traveler(s).
    2. Campus Export Control Review Process will determine, document and communicate applicable licensing or documentation requirements related to:
      1. Office of Foreign Assets Control (OFAC) regulations (for travel to a sanctioned destination).
      2. Department of Commerce Export Administration Regulations (EAR).
      3. Department of State International Traffic in Arms Regulations (ITAR).
    3. At a minimum, international University Travelers must disclose the following information to campus export control offices for review and consideration.  This disclosure may be accomplished through the process for obtaining pre-travel authorization for Travel. 
      1. Purpose and details of Travel.
      2. Travel itinerary including dates, locations and modes of travel.
      3. University Traveler details (citizenship / passport / employment / student)).
      4. List of any University equipment and materials the Traveler will bring on Travel, such as data, technology, software, specimens, and samples.
    4. Campuses may require additional information disclosure(s) depending on the purpose, destination and scope of the trip, such as the individuals and entities with whom the Traveler will interact.
    5. Campuses/UMPO will establish required timeframes for their respective Travelers’ submission of information for export control review and compliance.
      1. Campus export control review will be conducted prior to the Traveler’s departure, and, for Travel to High-Risk Destinations or Elevated Cyber Security Destinations, prior to a Campus Travel Risk Approver approving or denying Travel.
      2. Campus export control approval, if required, must be obtained by the Traveler prior to departure.
  5. Export Control Review and Approval Process may be embedded in the Campus Travel Risk Review Protocol (see Section 1.09).Export Control requirements apply to University Devices and/or Data that are brought on Personal Travel to International Destinations, High-Risk Destinations and Elevated Cyber Security Risk Destinations.
  6. Campuses will provide international University Travelers educational and awareness training or resources on export control and sanctions as needed to maintain compliance with regulations. Training and resources may include, but not necessarily be limited to:
    1. Export controls and sanctions programs awareness.
    2. Information on “Tools of the Trade” (TMP) and “Baggage” (BAG) license exceptions.
    3. Timeframes and expectations for obtaining applicable export license(s).
    4. Restricted-Party Screening of Individuals and Entities with whom University Travelers will be meeting, communicating and collaborating while abroad.
    5. Cybersecurity requirements.
  7. University Travelers are responsible for making determinations about applicability “Tools of the Trade” (TMP) and “Baggage” (BAG) license exceptions but may request assistance from Campus export control personnel with these determinations.