Export Control Menu
International Travel and Export Compliance
International travel is an important part of advancing Penn State’s mission of generating and disseminating knowledge around the globe. At the same time, international travel can present risks that must be mitigated to prevent issues like unauthorized transfers of controlled items, technology, technical data, and information. Our office, often in conjunction with the Global Safety office, reviews travel to avoid creating unnecessary barriers while still complying with federal U.S. export control laws and regulations in accordance with the University’s TR01 and TR02 travel policies. Below, you will find information regarding international travel and export controls.
Restricted International Travel Activities
Your international travel activities are generally permissible, provided you do not engage in any of the following restricted actions:
- Restricted Research: Engaging in non-fundamental, proprietary, export-controlled, or classified research.
- Controlled Items: Transporting export-controlled hardware, software, or technical data without an active federal license and/or exemption/exception.
- Restricted Parties: Interacting or collaborating with individuals or entities on a federal restricted party list.
- Sanctioned Destinations: Traveling to a comprehensively sanctioned or embargoed country without official authorization from the Office of Foreign Assets Control (OFAC).
Secure Approval and/or a License
When traveling abroad, everyday devices such as computers, smartphones, watches, or even tablets are subject to U.S. export control regulations, especially if they contain encryption or specific types of software. This is also true for items typically used in research such as lab equipment, biological samples, chemicals, or unpublished data.
Depending on the destination and type of items or data, the U.S. government may require an export license from the appropriate federal agency (e.g., the Department of Commerce, the Department of State, and/or the Department of Treasury) before these items can be taken abroad. This process can take several weeks to months (or longer) to secure a license. To determine whether your item requires an export license, please contact the Office of Export Compliance.
Taking Certain Items Abroad
When traveling abroad, everyday devices such as computers, smartphones, watches, or even tablets are subject to U.S. export control regulations, especially if they contain encryption or specific types of software. This is also true for items typically used in research such as lab equipment, biological samples, chemicals, or unpublished data.
Depending on the destination and type of items or data, the U.S. government may require an export license from the appropriate federal agency (e.g., the Department of Commerce, the Department of State, and/or the Department of Treasury) before these items can be taken abroad. This process can take several weeks to months (or longer) to secure a license. To determine whether your item requires an export license, please contact the Office of Export Compliance.
Items That Need Review/Approval Before Departure
The following items should not be taken abroad without the Office of Export Compliance’s approval:
- Devices, equipment, and software that may be export-controlled
- Unpublished research data
- Confidential or proprietary information
- Research results that are restricted by a sponsor for national security or proprietary reasons
- Devices, software, or technology that have military or space applications
*Please note that faculty and staff traveling abroad are strongly encouraged to request a clean loaner laptop from their departmental IT unit to secure sensitive information and ensure compliance with Penn State Global’s travel guidelines for electronic devices and technology abroad.
Hand carrying research samples
Do not hand carry research samples abroad without first securing approval from the Office of Export Compliance. This not only applies to hand carrying samples outside of the U.S. but also into the U.S.
While hand carrying research samples might seem more convenient than shipping them, it presents severe risks to the traveler and Penn State:
- Confiscation of the samples
- Border detainment
- Travel delays
- Revocation of travel visas for foreign nationals
Traveling to Sanctioned and Embargoed Countries
The U.S. Department of the Treasury has sanctioned and/or embargoed the following countries (this list is subject to change). Travel to or collaboration with entities in the following regions requires prior federal authorization from the Office of Foreign Assets Control (OFAC):
· Iran
· Russia
· Cuba
· North Korea
· Venezuela
· Belarus
· Ukraine (Crimea, Donetsk, and Luhansk regions)
Securing an OFAC specific license is a strict federal process that can take over a year to obtain but may not be granted. Please contact the Office of Export Compliance as soon as you begin planning your international travel.
OFAC Authorization Types
- General License: Pre-authorizes certain activities that would otherwise be prohibited, requiring no formal OFAC application.
- Specific License: Required for any activity not covered by a general license, requiring an explicit application to OFAC.
The Office of Export Compliance will determine what type of license is applicable for your destination and activity to ensure compliance with federal regulatory requirements.
Register Your Travel in the GSN
You must submit your international travel registration through the Global Safety Network (GSN) prior to departure per University Policy TR01. The Office of Export Compliance and the Research Security office reviews GSN international travel submissions to assess any export compliance and research security concerns.
International travel registration includes University affiliated travel, outside business activities and Third-Party Paid Travel. Don’t forget to log travel for research, teaching, administrative, or service activities conducted under the auspices of Penn State. This includes travel that is:
- Funded, reimbursed, coordinated, or otherwise facilitated by Penn State
- Charged to Sponsored Research funds
- Self-funded or sponsored by a host institution but related to university duties or programs.
Other Considerations
Did You Know? The Foreign Corrupt Practices Act
The Foreign Corrupt Practices Act (FCPA) makes it illegal for U.S. persons to pay, offer, promise, or authorize anything of value (cash, gifts, offers, services, etc.) to a foreign government official in exchange for obtaining or retaining business.
Practical example: You cannot pay a customs official to expedite clearance of your items or waive a routine luggage inspection.
Key Takaways
- You must register your travel through the GSN before your departure per University Policy TR01.
- Please reach out to the Office of Export Compliance if you have any questions before your travel.
- The Office of Export Compliance assists travelers with applying for and obtaining export licenses when necessary; however, a license can take several months to over a year to secure (and in some cases, may not be granted, depending on the item, destination, and activity, etc.).
- If you don’t need it, don’t take it with you!
Questions?
Contact the Export Compliance team: export@psu.edu
Office for Research Protections
Address
200 Innovation Blvd.
Suite 110
University Park, PA 16802
The Office for Research Protections (ORP) ensures that research at the University is conducted in accordance with federal, state, and local regulations and guidelines that protect human participants, animals, students, and personnel involved with research.