Letter to International Travelers
As you will be traveling outside the U.S., I'd like to share some information with you. Traveling out of the country with University-owned items, technology, technical data, software, and encryption code is considered a form of export and is subject to export control regulations, which means you may need to apply for an export license. These regulations also apply to laptops, smart phones, PDAs and digital storage devices, even if you will be bringing them back with you at the end of your trip.
If you are traveling with university-owned, export controlled items, technology, technical data, software or encryption code, the "Export License Exception for Temporary Exports/Reexports (TMP)" may allow you to hand-carry or ship these things out of the U.S. without a license, as long as you adhere to the following stipulations:
1) You ship or hand-carry the items, technology, data or software as "tools of the trade" to conduct University of Nevada, Reno business only;
2) You do not release the items, technology, data or software to anyone not authorized to receive them (this includes even visual inspections);
3) You return the items, technology, data or software to the U.S. no later than 12 months from the date of leaving the U.S. unless they are are consumed or destroyed abroad during the 12-month period;
4) You keep the items, technology, data or software under your "effective control" while abroad (defined as retaining physical possession or keeping it in a secure place such as a hotel safe, a bonded warehouse, or guarded exhibition facility);
5) You take security precautions to protect against unauthorized release of data, technology, and software such as:
a. Use of secure connections when accessing e-mail and other business activities that involve the transmission and use of the software and technology authorized under this license exception,
b. Use of password systems on electronic devices that store the software and technology, and
c. Use of personal firewalls on electronic devices that store the software and technology;
6) You do not ship or hand carry items, technology or software to Iran, Syria, Cuba, North Korea, or Sudan without consulting with the Office of Sponsored Projects in advance.
7) If you have proprietary information provided to the University under a non-disclosure or other confidentiality agreement, you are encouraged to remove all information from your electronic devices prior to foreign travel and not to access proprietary information stored on University servers while out of the U.S.
To utilize the TMP license exception, complete an "Export License Exception (TMP) Certification" form and send me a copy prior to departure.
These exceptions do not apply to EAR satellite or space-related equipment, components, or software; or to any technology associated with high-level encryption products. In addition, they do not apply to anything on the U.S. Munitions List regulated by ITAR. If you need to leave the U.S. with anything that is controlled for export and not covered by the TMP exception, consult Sponsored Projects prior to traveling as you may need to apply for an export license. License applications can take several weeks to process and may be denied.
Exports also include emailing, posting on a website, or any other electronic communication of controlled information or technology. Please keep this in mind when working with foreign collaborators.
U.S. export control regulations are complicated and violations can result in the loss of research contracts, monetary fines, and/or incarceration. If you have any questions about these regulations or any other export control issues, please contact me.
Thank you and safe travels,
Michele Dondanville, Research Compliance Program Manager
(775) 784-6360, firstname.lastname@example.org