International Travel and the Exportation of University Property
Foreign travel destination laws and restrictions are also an ever-changing set of federal regulations. All Radford University employees, staff, and students are subject to U.S. export and sanctions regulations. Penalties for failure to comply with current US foreign export laws and policies can be significant and should be avoided.
- The physical export outside of the United States of university commodities, software, or technology is subject to control under U.S. export control laws and regulations.
- In most cases, university employees may temporarily export common items, software, and technology subject to the Export Administration Regulations (EAR) outside of the United States under a “No License Required (NLR)” declaration, so long as this property is not exported to a sanctioned country (Cuba, Iran, Syria, Sudan, Peoples Republic of [North Korea], and the Crimea Region of the Ukraine/Russia).
- However, any export of technology, even temporarily, is subject to U.S. export control regulations and, in some cases, the host country’s import regulations. This can apply even to laptops and other widely available technologies. Additionally, certain entities have been placed on “restricted-party” lists that could prohibit us from doing business with them.
- The Research Compliance Office Export Control DOES NOT require notification for the temporary export to a non-sanctioned country of commercially available laptops, tablets, and/or cell phones with standard commercially available software because no license is required.
- For export of ANY OTHER types of university commodities, software, or technology, please contact email@example.com prior to your travel to ensure no export license is required.
- Published information, fundamental research, open-source software, and other information in the public domain are not subject to these regulations and may be discussed and shared freely.
- We recommend that you do not export confidential/proprietary technical data as it may be subject to export control and may require an export license or other government approval.
- Contact Radford IT Security for information about taking a loaner laptop on your international travel.
Please help us comply with current law by contacting the Radford University Research Compliance Office promptly if you are considering such activities or otherwise intend to do business with a foreign entity.
If you or any Radford University equipment assigned to you (including laptops, cell phones, and other electronics) are planning to travel to a foreign destination for 12 months or less, please complete the Word version of the Radford University International Travel and Temporary Export (TMP) Certification Form and submit to the Research Compliance Office.
Please submit the form as soon as possible, at least four (4) weeks in advance of your anticipated travel date, preferably in the early planning phase of your trip, so that we may process your submission and return it to you sufficiently in advance of your departure.
You will receive an emailed response that includes travel advisories and restricted party screening information specific to your travel destination(s) within 1-2 weeks of submission.
Your assistance in helping to keep Radford University in compliance with federal regulations is most appreciated. Completing this form four weeks prior to your anticipated departure date, allows us to adequately review your travel form in this ever-changing regulatory climate.
International Travel Tips & Guidance:
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 traveling:
- Research that qualifies as fundamental research
- Published information
- Publicly available software
- Educational information
Do not take any commodities, software, or technology that fall into one of the following categories:
- Classified, Controlled Unclassified, or Export Controlled
- Limited Distribution, Proprietary, Confidential, or Sensitive
- Specifically designed for military, intelligence, space, encryption software, or nuclear-related applications
- Data or information received under a Non-Disclosure Agreement
- Data or information that results from a project with contractual constraints on the dissemination of the research results
- Computer software received with restrictions on export to or on access by non-US Person
If you and/or your electronic equipment are leaving the country for greater than 12 months, please contact the Research Compliance Office promptly and directly.
If the equipment is encrypted (including laptop software), might have military applications, or is otherwise "high tech" beyond normal office "Tools of Trade" applications, please contact the Research Compliance Office promptly and directly.
Any computers or laptops that contain non-commercial, special purpose, or encryption software may be considered to have military applications or to be otherwise "high tech" beyond normal office "Tools of the Trade", export-controlled and require special considerations to export outside the United States. Radford University IT Security has information to consider prior to travel regarding laptop computers, tablets, and securing data. If a loaner machine is needed for travel, please complete the Radford University IT Computer Request Form and submit it to IT Support services at firstname.lastname@example.org.