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Export Control

International Travel at Florida Atlantic University

Florida Atlantic University (FAU) faculty, staff, and students travel frequently as part of FAU related research, education, service, and employment. When an FAU employee travels internationally on behalf of the University, there are five (5) main factors to consider. These factors include the destination, the purpose, the planned interactions, the items, software, technology, or information taken, and the length of the travel. Each one of these factors must be considered when requesting international travel as they may present export control concerns for the traveler and for FAU.

Prior to departure, each FAU employee must be aware of the potential restrictions that relate to their travel plans. Anything an individual takes out of the U.S. is considered an export. This includes physical items, such as laptops and cell phones, but it also includes the data that is contained on the electronic devices. For example, if the traveler’s electronic device contains any International Traffic in Arms Regulations (ITAR) items, software, technology, or information, the traveler must have an export control license simply to take that electronic device out of the U.S. In addition, if that traveler intends to provide access to the electronic device to foreign persons, or present the ITAR controlled information at a conference while abroad, the traveler will require an export control license to do so in order to avoid violating federal law.

When applicable, each individual that is traveling on behalf of FAU must submit an “International Travel Review Request Form” as far in advance of the date of departure as possible to assist in the following:

  • Determining whether the country of destination is listed as an embargoed or sanctioned country under the Office of Foreign Assets Control (OFAC);
  • Determining whether the foreign persons and entities that the traveler will be interacting with are listed as “denied persons” under the Office of Foreign Assets Control (OFAC);
  • Determining whether the travel or export require an export control license;
  • Determining if the travel or export qualifies for an export control license exception;
  • Determining if the destination has local laws and regulations which require compliance by the traveler; and
  • Determining if the actions while abroad require an export control license.


In general, international travel to attend a conference does not require a license. However, if the individual traveling on behalf of FAU is presenting at the conference there are additional concerns to consider. Information presented at conferences must be limited to topics that are not export controlled otherwise the individual must obtain an export control license, which can take several months to be reviewed, approved, and provided. Open seminars are usually not problematic unless they take place in an embargoed or sanctioned country or restricted parties are in attendance. The individuals traveling on behalf of FAU to present at a conference are advised to consider the following:
  • Be aware of what you are sharing. Under the circumstances, providing any information subject to ITAR is a violation of export control regulations. This includes information provided in your presentation as well in casual conversation with those in attendance.
  • Prior to departure, analyze the information and materials that you plan to present or discuss while abroad. This review process will assist the individual traveling abroad to limit the materials to information that has already been published. If there is any uncertainty in regards to what the traveler may or may not be permitted to present, it is suggested that the traveler contact FAU’s Export Control Officer.

If an FAU employee’s international travel requires an export control license, there may be an exception to the regulation requiring the license. An export control license exception is an authorization that allows an individual to export or re-export, under specific conditions, items that would otherwise require an export control license. In particular, there are two export control license exceptions that occur often when an FAU employee travels abroad.

“Temporary Exports” (TMP) Export Control License Exception

Individuals traveling abroad with FAU property or information may qualify for the “Temporary Export” (TMP) exception. The qualifications for the TMP exception include, but are not limited to:

  1. The item, information, technology, or software is being shipped or hand-carried abroad
  2. The item, information, technology, or software will return to the United States within 12 months of its export
  3. The item, information, technology, or software is not being shipped or hand-carried to any of the following countries: Cuba, Iran, Libya, North Korea, Sudan, or Syria
  4. The item, information, technology, or software will be used only as either a “tool of trade” to conduct FAU business, for exhibition and/or demonstration, or for inspection, testing, calibration, and/or repair.
    • If the item or software is for inspection, testing, calibration, or repair, the item or software will be shipped or hand-carried to a country other than Albania, Armenia, Azerbaijan Belarus, Cambodia, China, Georgia, Iraq, Kazakhstan, Kyrgyzstan, Laos, Libya, Macao, Moldova, Mongolia, Russia, Tajikistan, Turkmenistan, Ukraine, Uzbekistan, or Vietnam.
  5. The item, information, technology, or software will remain under the “effective control” of the traveler while the abroad.
  6. The encryption code incorporated in the item or on the software is limited to that available through retail purchase

NOTE:The Temporary Export (TMP) exception does not apply to any of the following:

  1. EAR satellite or space-related equipment, components or software
  2. Encryption items controlled under ECCN 5E002
  3. TItems subject to the International Traffic in Arms Regulations (ITAR)

“Baggage” (BAG) Export Control License Exception

Individuals traveling abroad with personal property or information may qualify for the “Baggage” (BAG) exception. The qualifications for the BAG exception include, but are not limited to:

  1. The item, technology, or software is personally owned by the traveler
  2. The item, information, technology, or software will not be shipped abroad as unaccompanied baggage
  3. TThe item, information, technology, or software is not being shipped or hand-carried to any of the following countries: Cuba, Iran, Libya, North Korea, Sudan, or Syria
  4. The item, information, technology, or software is being used only for appropriate personal use
  5. The item, information, technology, or software is not intended for sale or other disposal
  6. The item, information, technology, or software will be returned to the U.S.
  7. The item, information, technology, or software will remain under the “effective control” of the traveler while abroad

If the FAU traveler qualifies for either the “Temporary Export” (TMP) license exception or the “Baggage” (BAG) license exception, they must complete and submit the Single-Use Export Control License Exemption Certification prior to their scheduled date of departure. The Export Control License Exemption Certifications can be found on the Export Control Forms page.

If the traveler’s equipment does not qualify for the “Temporary Export” (TMP) exemption or the “Baggage” (BAG) exemption, FAU will not authorize the travel and equipment without certifying that the traveler has either an export license or the traveler is not required to obtain an export license due to an exclusion or exception. The following list of equipment requires an export license or other government approval for export:

  • University-owned scientific equipment (other than a sanitized laptop computer, PDA or electronic storage device)
  • Data or information received under an obligation of confidentiality.
  • Data or analyses that result from a project for which there are contractual constraints on the dissemination of the research results
  • Computer software received with restrictions on export to or on access by foreign nationals.
  • Devices or equipment received with restrictions on export to or on access by foreign nationals.
  • Private information about research subjects
  • Devices, systems or software that was specifically designed or modified for military or space applications.
  • Classified information

Under FAU’s travel policy and procedures, all travelers must have a Spend Authorization (SA) established in the Travel and Expense Module and routed through the dean or director level, Division of Research (if applicable), with final approval from the Provost Office. Prior to departure, each traveler is required to review, sign and return the Travel Release of Liability form to the Provost Office.
Expense/Travel Policy and Procedures
Alerts and Warnings
Export Administration Regulation Downloadable Files
Sanctioned Destinations
Release of Liability, Waiver of Claims, Express Assumption of Risks, and Hold Harmless Agreement

Prior to traveling abroad, FAU must verify that the individual traveling is not interacting with foreign persons, entities, or countries whose U.S. export privileges have been restricted or barred. For more information on FAU’s Restricted Party Screening process, please visit the “Restricted Party Screening (RPS)” page.

For questions or concerns regarding export control requirements for international travel, please contact FAU’s Export Control Officer.



 Last Modified 11/16/17