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Travel Internationally

Guidance for International Travel

The Office of University Compliance and Integrity (UCI) and the ORED-Research Integrity Office (RIO) review all proposed international travel plans. As of January 1, 2022, all FIU faculty, staff, students, and other personnel traveling abroad on FIU-sponsored trips, or for any international travel on behalf of FIU, are required to read and acknowledge their understanding of this Guidance for International Travel. This Guidance includes essential information about complying with “Foreign Influence”, Export Controls, and OFAC trade sanctions.

Foreign Influence Concerns Related to International Travel

The term “Foreign Influence” is generally used to characterize a situation where an international entity positions itself to gain access to the university’s Intellectual Property (IP) and/or export-controlled information; or to covertly influence or steer the course of federally-funded research in a manner that benefits said foreign entity. Foreign Influence may involve facilitating research efforts (in the U.S. or abroad) so as to provide the foreign entity with direct visibility into research activities in an incidental or even “supportive” manner, though nonetheless outside the scope of intended collaboration.

FIU’s international travelers may encounter unintended foreign influence situations while traveling abroad that may not be readily apparent.  For example, foreign influence may occur when as a foreign party offers to pay for international travel, lodging, and expenses with the objective of ultimately obtaining unauthorized research information; or, when a foreign party offers to provide in-kind laboratory research support in exchange for on-site consulting or advice.  Likewise, proposed engagements by foreign parties who the U.S. Government identifies as a Restricted Party are a per se indicator of potential Foreign Influence concerns.

Foreign Influence is a global risk.  This has been recognized by both Federal research-sponsoring agencies and State of Florida legislation, citing numerous countries of concern including but not limited to People’s Republic of China, the Russian Federation, the Islamic Republic of Iran, the Democratic People’s Republic of Korea, the Republic of Cuba, the Venezuelan regime of Nicholas Maduro, or the Syrian Arab Republic.

Export Regulations and International Travel

Export Control regulations apply to key aspects of international travel, including:

  • Travel to and/or engagements with parties located in Sanctioned and Restricted countries
  • Activities that may facilitate the export of technical data
  • Exports of items, equipment, materials, and/or biologics before or during travel
  • Activities which qualify as a “defense service” under the State Department’s ITAR regulations.

In the case that an export license or authorization is required to export a physical item related to your proposed international travel (e.g., hand-carried equipment or materials, or controlled materials), our Export Office will work with you to obtain such a license and/or adjust your travel plans to preclude license requirements. Likewise, in the event that your proposed travel activity constitutes a defense service in relation to a foreign government or defense agency, we will coordinate the appropriate licensing and compliance measures.

  • Where Are You Going?

    While export controls apply to all countries, travel and other activities to/with OFAC-sanctioned countries (currently Cuba, Iran, Syria, or North Korea) is prohibited in most cases without a license or authorization. Likewise, most exports to these countries require licenses. The Export Office can work with travelers to determine compliance requirements, and early notification will help facilitate travel objectives. Please contact the Export Office as soon as you anticipate travel to a sanctioned country.

  • Activities and Interactions

    While most activities abroad do not require an export license (except with respect to OFAC-sanctioned countries), it is important for travelers to be aware of the following export control concerns:

    Restricted and Prohibited Entities:

    There are a number of individuals and entities around the world that are subject to special restrictions. For many of these entities, ALL exports of even basic items (e.g., promotional materials, office supplies, etc.) require an export license. Likewise, OFAC regulations prohibit the University from providing material or financial assistance to any blocked or sanctioned individual or entity.The TA is designed to identify parties who require Restricted Party Screening and refer the names to our Export Control Office for quick screening and analysis. In the event that a party is restricted, the traveler will be notified through the TA review process. If you would like assistance in determining whether a potential international partner is a Restricted Party, please contact the Export Office. Additionally, more information on Restricted Parties can be found in the Restricted Parties section of this website.

    Research & Academic Presentations During Travel:

    Presenters must ensure that all research and academic information in their presentation is publicly available, eligible for publication/dissemination, and/or non-proprietary. Many presenters find it helpful to confirm that these criteria are satisfied prior to travel so that any necessary adjustments can be made in a timely manner. If there are any questions about whether material is eligible for dissemination during international travel, please contact the Export Control Office.

    Field Work Abroad:

    In most cases, fundamental research conducted outside the U.S. will qualify for FIU’s Fundamental Research Exclusion. However, ITAR defense-controlled research cannot be conducted internationally without an export license, even if it otherwise qualifies as fundamental research when conducted at FIU or elsewhere in the U.S. Before conducting sponsored research internationally, including field work abroad, researchers should confirm that the work is not export restricted. Please contact our Export Control Office with questions, or if your work abroad involves any of the following:

    • Exporting items in advance of travel (instruments, materials, software, controlled technical data)
    • Providing payments of any kind to a foreign person, entity, or institution
    • Purchasing or obtaining items or materials from international sources
    • Importing samples to the U.S. from a foreign destination
    • Working with a foreign government and/or military.
  • What Are You Taking With You?

    Items taken to an international destination are considered “exports” under U.S. export control regulations, even when such items return to the U.S. with the traveler.  As such, some items may require an export license or authorization to be hand-carried or baggage-packed in the course of international travel.  Failure to obtain an export license or authorization in these cases may result in Customs detention or delays, significant fines or penalties, and/or inability to enter the foreign destination. 

    To aid in completing the export control portion of the TA, travelers are encouraged to preview the following questions in relation to items that may be exported during international travel:

    1. Will you be transporting (either through carry-on luggage or checked bags) laboratory instruments, tools, samples, raw materials, or prototypes for any reason (including, but not limited to, for your own research, a collaborative purpose, or to give to someone)?
    2. Will you be traveling with a portable electronic device that contains or stores proprietary export-controlled data, FIU confidential or proprietary data as defined by law or FIU policy, or data which is associated with an export-restricted research project or instrument that you have been or are working on currently (even if such data has nothing to do with the purpose of your immediate travel)?
    3. Will you be transporting any device that incorporates specialized scientific software (not including typical operational software such as Microsoft Office, Adobe, etc.) or software programs utilizing specialized cryptographic functionality (not including routine commercial laptop cryptographic protection)?
    4. Will you be providing any specific training or technical assistance to another individual, entity, or governmental institution (or representatives) beyond scientific collaboration in fundamental research?

Florida State Requirements:

In addition to federal Export Control and OFAC trade sanction compliance, Florida State legislation requires screening and pre-approval for all international travel and foreign activities, as well as institutional and individual disclosure of certain travel-related activities and expenses.  As part of the TA (and in addition to the export control questions), the University asks travelers to disclose:

  • Proposed engagements with an institution or organization with whom FIU does NOT currently have a formal, signed partnership agreement (e.g., inter-institutional agreement, educational exchange, research collaboration agreement, business, or service contract);
  • Receipt of any payments or honoraria, directly (i.e., paid directly to you) or on your behalf (i.e., to cover some or all of your expenses) by an international entity or person, including travel, food, or lodging at any time related to your travel;
  • Travel to any foreign country other than the destination entered in the TA (other than a connecting flight where you do not leave the airport).

The answers to these queries are intended to proactively identify foreign influence concerns. It is essential for travelers to complete the TA as thoroughly as possible when  submitting the request, as this will expedite review and approval of your TA.

Mandatory Use of The Travel Authorization (TA) Request Process For International Travel Approval

Pursuant to Florida State legislation (HB 7017/ F.S. 1010.36), the University has expanded its travel authorization process to require screening and pre-approval for all international travel and foreign activities. All international travelers must now complete a Travel Authorization request (TA), which includes a Foreign Travel questionnaire, specific disclosure requirements regarding travel expenses, and the traveler’s Acknowledgement certifying that they have read this Guidance. 

It is essential for travelers to complete the TA as thoroughly as possible when submitting the request, as this will expedite review and approval of your TA.  Travelers may not incur any travel- related expenses or proceed with their trip unless and until the TAR is fully approved.

Below, we provide bullet-pointed examples pertaining to some of the key questions raised in the Foreign Travel Questionnaire. The answers to these queries are intended to proactively identify foreign influence concerns:

Cybersecurity Guidance for International Travel

In preparation for travel, one thing we often forget and overlook is cybersecurity. However, the risk for loss, theft and unauthorized access of devices and sensitive information increases when traveling. The purpose of this guide is to assist with cybersecurity measures that can be taken before, during and after travel to minimize these risks.

General Travel Guidelines

  • Before Travel
    •  Plan to take only the necessary devices, data (work, personal and sensitive data) and documents(including credit cards). Less is best.
    •  Consider using a device solely for travel with only the data, applications and services needed. If a device solely for travel cannot be used, back up data.
    • Remove all sensitive and personal data, including clearing browser history, cookies, cache, autofilled data, saved passwords and disabling “remember me” features.
    • Enable Two Factor Authentication (2FA) for all accounts, especially those that may be accessed during travel.
    • Submit a request with the Division of IT (DoIT) or designated IT Administrator (ITA) to install any needed programs and applications prior to travel.
    •  Ensure the device is up to date and all operating system (OS), antivirus, application and program updates are installed.
    • Verify the device is encrypted, and firewall, screen locks and timeout/screensaver functions are implemented.
    • Implement a strong password to log into the device.
    • If an external storage device is needed, it should be encrypted and approved by the IT Security Office.
    • Consider using RFID blocking products to protect credit cards and passport.
  • During Travel
    • Keep device with you. Do not leave device unattended or in unsecure locations, such as at the hotel, including in the safe.
    • Always lock the device screen when not in use for a short/temporary time period.
    • Shut down device when not in use for a prolonged time period. Do not put in sleep mode or simply close the laptop.
    • Do not allow others to use the device.
    • Refrain from accessing any sensitive information, if possible.
    • Do not connect to any unknown public/Wifi networks, especially when accessing sensitive information or resources. Only use secure networks, such as the hotel Wifi, in addition to VPN.
    • Always use FIU VPN, if possible, especially when accessing sensitive information or any FIU resources, including Office365 and MyFIU/PantherSoft.
    • Use OneDrive for data storage rather than storing on device.
    • Do not download or store any sensitive information on the device, including from MyFIU/PantherSoft.
    • Do not use personal phone to access FIU resources, especially without VPN.
    • Only use trusted external storage devices, such as USB drive/flash drive/external hard drive, that are owned by you. If you are provided with an external storage device while abroad, refrain
      from connecting it to your laptop/mobile device until it can be scanned for malicious applications to ensure safe use.
    • If the device has a USB power cord, do not use public charging stations, such as at the airport, mall or hotel, to charge it, but rather always use your own power cord and an electrical outlet.
    • Do not use any public computer to access personal and sensitive resources, including FIU resources.
    • Do not use any public or untrusted computer for anything that requires you to enter passwords.
    • Do not install updates or unknown software via unknown network or public Wifi. Updates and software installation should take place when on VPN. Beware of security warnings and pop ups from browser.
    • If you receive Duo (Two Factor Authentication/2FA) prompts that were not initiated by you, deny the request, reset your password and notify the IT Security Office as soon as possible.
    • If you notice any suspicious activity on the laptop, stop using it, disconnect it from Internet access (turn off Wifi and Bluetooth, if applicable) and notify the IT Security Office as soon as possible.
    • If device is lost or stolen, notify the IT Security Office as soon as possible.
    • Be mindful of the information shared on social media, which may provide answers to security questions or knowledge of your whereabouts.
    • Browse the web safely by being mindful of suspicious emails, links, pop ups, malware alerts (not from antivirus) and social engineering tactics. Ensure a secure browsing connection by verifying the website is using https or has a padlock next to the URL/website address when conducting transactions that involve entering passwords, sensitive information or making purchases.
  • After Travel
    • If FIU credentials will be used on the device to access any FIU resources, such as email, Office365 products (including OneDrive, Word, PowerPoint, etc.), reset FIU password upon return.
    • Reset all passwords that may have been used during travel.
    • Scan device for malware.

High Risk Destination Guidelines

There are some countries that are considered high risk destinations. High risk destinations include Foreign Countries of Concern (FCCs) which are designated as The People’s Republic of China, The Russian Federation, The Islamic Republic of Iran, The Democratic People’s Republic of Korea, The Republic of Cuba, The Venezuelan regime of Nicolas Maduro, and The Syrian Arab Republic.  As a result, further steps are recommended in addition to the general travel guidelines.

See General Travel section for additional guidelines

  • Before Travel
    • Follow the requirements of FIU’s International Travel Policy for Employees and Students.
    • Submit a request for a loaner laptop via FIU’s Library.
    • Install any needed applications. If the applications are from Microsoft, plan to use Office365 online.
    • If the travel is for research purposes or will otherwise involve use or access to sensitive data, including student/FERPA, HIPAA, etc., consult the IT Security Office.
    • If 2FA is affected at the destination, consult the IT Security Office for recommendations, which may include obtaining a YubiKey.
    • If the high risk destination restricts access to VPN, plan accordingly by taking the following into consideration:
      • Backup data needed on an encrypted storage device.
      • Delay Internet access, if possible, to when VPN can be used, especially when needing to access sensitive data or FIU resources.
    • If the high risk destination limits Internet connection, consider using cellular network and roaming via a mobile device for a more secure connection, which can also be used for tethering/to hotspot, instead of connecting laptop to unsecure or public Wifi. See Mobile Device section for additional guidelines.
    • Be aware of and follow export controls, encryption and VPN guidelines of the US and/or high risk destination.
  • During Travel
    • Always use FIU VPN, if possible, especially when accessing any FIU resources, including Office365 and MyFIU/PantherSoft. There is a possibility that VPN may not always be accessible due to cut off times of the country.
    • If VPN is not accessible, it is then recommended to store files on device or encrypted external storage device.
    • If device is searched, confiscated, lost or stolen, notify the IT Security Office as soon as possible.
  • After Travel
    • Upon return, refrain from using the device, including not connecting it to FIU’s network or storage devices, etc. It should be returned to FIU’s Library to be wiped.

Mobile Device Guidelines

Like laptops, mobile devices, such as phones and tablets, are often brought along during travel to stay connected. Mobile devices should also be secured and may have specific guidelines in addition to the general travel guidelines.

See General Travel section for additional guidelines.

  • Before Travel
    • Consider using a mobile device solely for travel with only the data and apps needed. If a mobile device solely for travel cannot be used, back up data.
    • Enable 2FA for all accounts, especially those that may be accessed during travel.
    • Install any needed apps prior to travel.
    • Ensure mobile device is up to date by installing all updates for the mobile device and apps installed, including antivirus.
    • Install VPN.
    • Consider encrypting the mobile device.
    • Verify the device has screen lock or strong password and timeout/screensaver functions implemented.
    • Setup “find my device” feature.
    • Remove all sensitive and personal data, including clearing browser history, cookies, cache, autofilled data, saved passwords and disabling “remember me” features.
  • During Travel
    • Do not use personal phone to access FIU resources, especially without VPN.
    • Disable Wifi, GPS and Bluetooth when not in use.
    • Quit all applications and use Wifi to avoid roaming charges when a secure Internet connection is not needed.
    • Be mindful of scanning QR codes and if necessary, ensure it is provided by a trusted or known source.
  • After Travel
    • If FIU credentials will be used on the device to access any FIU resources, such as email,
      Office365 products (including OneDrive, Word, PowerPoint, etc.), reset FIU password upon
      return.
    • Reset all passwords that may have been used during travel.
    • Scan mobile device for malware and/or reset to factory settings.

Questions or Need for Assistance

Contact IT Security at Security@fiu.edu or (305) 348-2284.