International Activities

• limiting what you take abroad;
• keeping information in your possession or locked in a secure location;
• using a “clean” laptop – with minimal information;
• using the university VPN if you need to access data;
• encrypting your device; and
• screening collaborators in advance.

Yes. See the following link for detailed guidance on purchases and shipping. Depending on the item, export control laws and regulations may require security protocols (such as a TCP) to be in place before the item arrives on campus or is released for use. Items intended to be shipped outside the U.S. must be evaluated and coordinated by Export Control. If a license to export the item is required, Export Control will apply for such government authorizations. A customs broker may need to be involved in international shipments and purchases.

Prior to travel, to avoid collaborating with a prohibited party, foreign parties should be screened using the Restricted Party Screening tool. Export Control or your Department Administrator can assist with conducting screenings. 

Depending on your destination(s), authorization from the U.S. Treasury’s Office of Foreign Assets Control (OFAC) may be required. Travel to an embargoed/sanctioned country (e.g.,  Cuba, Iran) may require prior authorization in the form of a license. If travel to an embargoed country is for personal reasons, no University equipment may be taken, and no University business should be conducted without prior authorization. Most activities involving Iran (even remotely) will require a license.

The purpose of the OFAC regulations is to enforce embargoes and economic sanctions. In general, the OFAC regulations prohibit exports to certain sanctioned/embargoed countries such as Iran, Cuba, Sudan, North Korea, and Syria.

OFAC considers providing anything of value or a service to Iran or the government of Iran would require prior government approval. For example, giving a professional presentation, even if it does not contain materials controlled under ITAR or EAR, is deemed under OFAC to be a “service” and “something of value” provided to the recipient audience. 

In addition to the points listed above there are other considerations which vary by country:

• Attending a conference in Iran (OFAC considers this to be an “import”) or speaking at a conference in Iran (providing a service or something of value) requires a license. An OFAC license for Iran generally takes six to nine months (or longer) to process once submitted.
• Participating in certain online courses abroad requires an OFAC license, if the student is ordinarily a resident of sanctioned country (Cuba, Iran, Syria, or the Crimea Region of the Ukraine).
• Any technical discussions, formal or informal, could require a license and would be prohibited prior to the receipt of the necessary license(s).
• Travel to Cuba has special considerations.  For information on Cuba travel, see http://www.treasury.gov/resource-center/sanctions/Programs/Pages/cuba.aspx.

• The University of Arizona will NOT apply for an OFAC License for activities in or with Syria - no University travel to Syria will be approved. Travel to Iran will be approved on a case-by-case basis and only upon receipt of any required OFAC or other government licenses.

If an employee travels to any sanctioned country on their own time, the individual may not take or send anything university-owned such as equipment, software, technology, or data, or represent the university in any capacity.

Sanctioned Countries are designated by the U.S. Government as having limited or comprehensive trade sanctions and embargoes imposed for reasons of anti-terrorism, non-proliferation, narcotics trafficking, or other reasons. Sanctions are prohibitions on transactions (e.g., financial exchanges, providing or receiving services of value) with designated countries, entities, or individuals.

It depends on the country and the item. The U.S. government has export restrictions on certain items. Consult with Export Control to determine if your equipment, materials, data, or software is subject to these restrictions. Export Control will obtain licenses, exceptions or assist with other requirements to facilitate your travels, if required. Traveling with a “clean” laptop is recommended.

UA faculty, staff, and students traveling internationally on behalf of UA for business, research, or other purposes are required to register well in advance of their departure (travel.arizona.edu). In addition to obtaining UA approval, the traveler may require a license, license exception/exemption, or other guidance to hand-carry items abroad, access data, interact with certain persons, speak at a conference, conduct research, provide training or other services, or engage in other UA related activities.

See the Export Control resource on international activities for additional guidance.