Travel Considerations

Where are you going?

When you travel internationally for MSU-related business purposes, you must register your travel with the MSU Global Travel Registry or ViaTRM. If your destination is a U.S. government comprehensively embargoed country or region, the MSU Global Travel Registry will forward your travel registration to MSU’s Office of Export Control and Trade Sanctions (ECTS) for additional review of your travel and ECTS will reach out to you to discuss your travel plans as needed. The U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) website maintains an up-to-date list of embargoed countries and regions around the world.

Destinations currently subject to the most comprehensive U.S. embargoes include:

Cuba
Iran
North Korea
Syria
The Crimea region as well as the so-called Donetsk People’s Republic (DNR) and Luhansk People’s Republic (LNR) regions of Ukraine

The OFAC comprehensively embargoed countries are heavily sanctioned by the U.S. government and nearly all activities require advance federal authorization (i.e. export license or exemption). MSU’s Office of Export Control and Trade Sanctions (ECTS) will provide additional guidance when you register travel to an embargoed country/region. However, even if you do not need an export license to travel to your destination, you may need an export license or exemption to take certain technologies or information with you.

Military End Use countries

Belarus
Burma
Cambodia
China
Russia
Venezuela

If traveling to a military end-use country: There are heightened export control restrictions when exporting items to military-end users in certain countries. Exporting (even temporarily by hand carrying items or shipping) to a military-end-use country may be an export violation. Taking data that has been previously published or is in the public domain is exempt from the export control regulations. Please consult the section titled "What Are You Taking With You?" if you are taking technology, items, materials, or equipment to a military end-use country.

PLEASE NOTE: If you are planning to travel to Iran for an MSU related business meeting or to attend a conference, you will need to obtain an export license prior to your trip. You should contact MSU’s Office of Export Control and Trade Sanctions (ECTS) at export@msu.edu immediately to allow time to apply for the license.

What is the purpose of your trip?

MSU personnel travel internationally for many reasons, and different export control issues arise depending on the nature of your travel, such as:

Whether attending an international meeting or conference, conducting research abroad, collaborating with an international colleague or entity, or providing other services, MSU travelers must ensure that the data they release is publicly available. The release of export-controlled data or information, without prior authorization or an export license from the relevant federal agency, is an export violation and may expose you and MSU to severe penalties. MSU personnel may share information resulting from Fundamental Research (i.e. research funded without any publication or participation restrictions) conducted in the U.S. However, MSU personnel may not share any data or information that was not generated under the Fundamental Research Exemption without checking in with MSU’s Office of Export Control and Trade Sanctions (ECTS).

You must also ensure that you are not interacting with or providing financial assistance to a sanctioned or specially designated entity, such as persons or entities appearing on the OFAC’s Specially Designated Nationals and Blocked Persons List, or on the BIS’s Denied Person List or the Entity List. It is recommended to know in advance with whom you will be communicating and collaborating, so Restricted Party Screening (RPS) of those persons and entities can be done. MSU’s process for RPS is discussed in more detail below.

With whom are you working?

For MSU personnel traveling internationally to conduct MSU related business, such as research or to attend professional meetings and conferences, it is recommended best practice to know in advance with whom you will be communicating and collaborating so that MSU’s Office of Export Control and Trade Sanctions (ECTS) can complete screening of those persons and entities. For performing Restricted Parties Screening (RPS), MSU’s Office of ECTS has made available to the MSU community a consolidated screening lists tool called Descartes Visual Compliance™. It is a web-based platform for which MSU has an unlimited seat license for distribution across the University as needed. Please provide MSU’s Office of ECTS with the names of any international entities or colleagues so that RPS may be completed prior to your trip. It is important that you include the name of any international entities with which your colleagues are affiliated so that the international entity may be screened as well. For more information about Descartes Visual Compliance™ RPS tool, please contact MSU’s Office of ECTS at export@msu.edu.

What are you taking with you?

Anything taken out of the U.S. may be considered to be an export, including data on laptops and cell phones, materials, equipment, software, and other technologies that may be subject to the U.S. Export Control Regulations. Items subject to the Export Administration Regulations (EAR), depending on where they fall on the Commerce Control List (CCL), may require a license or an applicable License exception. Defense articles or technical data subject to the International Traffic in Arms Regulations (ITAR) are restricted to U.S. Persons and must have a license to be taken out of the U.S. Without an ITAR license, providing technical data about defense articles at international conferences is an export control violation. Accessing export controlled technical data or technology remotely from an international location may also be an export control violation.

When traveling out of the United States, everything you take with you may be considered an “export,” under U.S. export control regulations. This includes tangible items (laptops, cell phones, equipment, samples, prototypes etc.) and intangible products (trainings, know-how, files, data etc.). Some of these exports will require an export license from the government. However, in many situations, you will not need an export license because either (1) the items or data you are taking are not controlled to your destination or sometimes (2) a license exception is available.

The export regulations require the use of a license or of a license exception to be documented in writing. There are two license exceptions that may be utilized under certain circumstances, and they may require the traveler to complete and sign a certification. Please see MSU’s Tools of Trade License Exemption guidance for additional information. MSU’s Office of Export Control and Trade Sanctions (ECTS) is available to assist with export classifications and license determinations.

What do you need to be careful of?

THE FOREIGN CORRUPT PRACTICES ACT

It is illegal for U.S. persons to offer or pay anything of value to a foreign official for the purposes of obtaining, retaining, or furthering business activities, per the federal Foreign Corrupt Practices Act (FCPA) anti-bribery provisions. For example, making payments to custom officials in exchange for their agreeing not to inspect goods or to release goods held at points of entry would violate the FCPA.

Be Aware

Customs officials in any country, including the U.S., may inspect your belongings, including electronic content of computers, phones, tablets, and storage devices. They may take possession of these items for various periods of time—even permanently. It is a best practice to only take items with you that are absolutely needed for your trip.

Some countries also have import regulations that specifically prohibit travelers from bringing into those countries encrypted laptops or other mobile devices. Violations of those countries’ prohibitions could result in confiscation of your device by customs authorities and/or fines or other penalties.

Preventing A Problem While Traveling

You are required to report a stolen or lost device or other IT Security Incident. The MSU Office for Global Health, Safety and Security also provides detailed information on Emergency Assistance for MSU International Travelers.

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