International Travel & Collaboration Guidelines

Rowan University faculty and staff travelling out of the country must read the pre-briefing described below or meet with Rowan University Export Control Officer when planning to travel abroad, particularly when the employee:

1. Has security clearance and is working on a classified contract.
2. Working with unclassified but sensitive material which is deemed export controlled under federal regulations.
3. Is traveling to any embargoed country -- currently Cuba, Iran, North Korea, Sudan, Syria and Crimea Region of the Ukraine/Russia
   
   

What should I do before travelling abroad even when not working with classified material?

1. When travelling abroad consider the following to determine whether export control regulations apply:
   1. Where are you going?
   2. What are you taking?
   3. What will you be doing?
   4. With whom you will be interacting?*
2. Complete CITI Export Controls Training - Group 2: Export Controls International Travel Only course
3. Complete the International Travel Checklist found Here

* Certain interactions may be considered as “deemed export”.  According to Export control regulations, deemed export is defined as the release of technology or source code having both military and civilian applications to a foreign national.

Is there a problem for Travelling Abroad?

1. Not all travels abroad are regulated or a problem.  However, be aware that travelling to some foreign countries are subject to Foreign Assets Control (OFAC), Export Administration Regulations (EAR) or International Traffic in Arms Regulations (ITAR), particularly to sanctioned/embargoed countries.   If your travel includes going to or transiting through sanctioned countries such as Cuba, Iran, North Korea, Sudan, Syria and Crimea Region of the Ukraine, please contact the Export Control Officer in the Office of Research Compliance for assistance to mitigate the risks associated with traveling to such embargoed countries.  A specific license will be required before you travel or transit through those countries.
   
   

What am I allowed to take when travelling abroad? What needs to be done before you travel with certain items?

1. Items such as laptops with no encryption, IPhones and IPads, Jump/Flash drive (unencrypted), Android Cell Phones/Tablets, Garmin GPS, Bitlocker encryption and GoPro Camera for routine use do NOT require a license so long as the travel does not include Cuba, Iran, Sudan, Syria or North Korea.
2. Scientific equipment, computers, laptops, PDAs, iPads, drives, digital storage devices, cell phones, and GPS units (they have pre-loaded encryption software subject to regulations)  – Verify that these items are not export-restricted based on your travel destination(s).  The Office of Research Compliance can assist you in the process. An official memo on behalf of the institution indicating that your items and/or equipment have been cleared for export. It is highly recommended that you register when any items/equipment that you will be taking with you. Use Form 4455 to register with U.S. Customs and Protection (CBP). Registration allows you to prove that you had the items before you left the U.S. and all CBP (Customs and Border Protection)-registered items will be allowed to return to the U.S. duty-free.
3. Low-Tech, commercially available items - An export license is NOT required unless you are travelling to or travelling through sanctioned/embargoed countries.  If travel or transit includes sanctioned/embargoed countries, an export control license may be required even for every day or routine carry with items such as cell phones and laptop computers. Contact the Office of Research Compliance at Rowan for help in determining your export license requirements.
4. Sharing, shipping, hand carrying, transmitting or transferring Rowan-developed non-commercial software with no source code or object code when travelling abroad – There may or may not be license exception under Export Control Regulations (EAR).  You must follow the following requirements even when a license is not required: 1) You must keep the item under your control all the time and 2) You must return the item within 12 months or consume or destroy within 12 months. 
5. Items used in the design, development, production, stockpiling or nuclear explosive devices with chemical or biological agents – They may require export control license unless there is no publication restrictions for the data or Non-Disclosure Agreement for the item has no publication restriction.
   
   

What will you be doing abroad?

1. These guidelines are provided to ensure that you do not accidentally export restricted information to foreign nations or nationals.
   1. Presentations:  When presenting data/information in an international setting limit your presentation to only information or data that is published, or is publicly available, or that qualifies as Fundamental Research. Be careful not to include or discuss any proprietary, unpublished, or export-restricted data or information as that may constitute an unauthorized export. 
      • ‘Fundamental research’ means basic and applied research in science and engineering, the results of which ordinarily are published and shared broadly within the scientific community, as distinguished from proprietary research and from industrial development, design, production, and product utilization, the results of which ordinarily are restricted for proprietary or national security reasons.”
   2. Interaction with foreign nationals: You are free to openly discuss any published or publicly available information or information generated as the result of Fundamental Research as long as the recipient is not a sanctioned or specially designated entity. It is important to know that while the results/information resulting from Fundamental Research are not subject to export controls and can be shared without a license, any items, technology, or software generated under that Fundamental Research with publication restriction or protected information would be subject to export controls and may require an export license.
   3. Field work abroad:  Data collected during a field work abroad is not considered as fundamental research until the data is published or made publicly available.  Before publishing or making the data public, make sure that the collected data is not export controlled.
      
      

What must be done when travelling to Sanctioned/embargoed country?

1. If you are traveling to a sanctioned country, you are required to obtain a country-specific pre-travel briefing, as well as a post-travel debriefing, from Rowan’s Export Control Office. Please be aware that international sanctions can be introduced or lifted at any time. You as the traveler, are ultimately responsible for determining if your destination is under sanctions. For further information on sanctions in place by the government of the United States, please refer to the Department of Treasury’s website at http://www.treasury.gov/resource-center/sanctions/Programs/Pages/Programs.aspx.  At the time of this writing, the following countries were subject to sanctions:

Comprehensively embargoed countries:  

OFAC:  Crimea region of Ukraine/Russia, Cuba, Iran, North Korea, Sudan and Syria

EAR: Crimea region of Ukraine/Russia, Cuba, Iran, North Korea and Syria

Targeted Sanction Countries:

OFAC: Libya, Lebanon, Somalia, Belarus, Iraq, Yemen, Myanmar (formerly Burma), Zimbabwe, Balkans, Burundi, Central African Republic, Cuba, Democratic Republic of the Congo, Ethiopia, Hong Kong, Iran, Mali, Nicaragua, Sudan, Syria, Ukraine/Russia, Venezuela

EAR:     Iraq

ITAR (International Traffic in Arms Regulations) prohibited countries:

Afghanistan, Belarus, Central African Republic, Cuba, Cyprus, Eritrea, Iran, Iraq, Lebanon, Libya, North Korea, Syria, Myanmar, China, Haiti, Somalia, Russia, Republic of the Sudan (South Sudan), Yemen, Zimbabwe, Venezuela, Democratic Republic of the Congo.

Are there restrictions for International Collaborations?

In general, collaborations between Rowan University personnel and scholars at foreign institutions or organizations do not require export licenses unless they involve export controlled or restricted research or involve scholars in sanctioned countries.  Before engaging in an international collaboration, contact Export Control Office to determine if export licenses are required and to verify that the foreign individual and/or organization are not blocked or sanctioned entities.

When I travel abroad, can I have access to my department resources through VPN?

Yes.  However, employees need to be granted VPN access by Rowan IT before traveling if they wish to continue using Rowan University Software and connect to Department Resources while outside of the country.  Please Contact Rowan’s Information Resources and Technology Office on using VPN abroad at iso@rowan.edu.