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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.
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. You may refer to this Quick Guide to provide you with an overview of the international travel screening and reporting process.
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 China, Russia, Venezuela, Cuba, Iran, Syria and North Korea.
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.
Completion of the TA:
It is essential for travelers to complete the TA as thoroughly as possible when submitting the request, as this will expediate review and approval of your TA.
For more information on Foreign Influence, the following resources are available:
- The FIU Office of University Compliance and Integrity
- The Office of Research and Economic Development
- Export Control-Foreign Influence Webpage
- ORED’s “Guidance Regarding Foreign Influence and Research”
For detailed Guidance on Export Controls, see the information below and on other sections of this Export Controls website.
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.
- Traveling to Cuba? Please review our Special Information for travel to Cuba
- Traveling to Iran? Please review our Special Information for travel to Iran
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?