International Travel
UH encourages and supports its faculty, staff and students to participate in university-related activities abroad. International travel on behalf of UH may be subject to export control regulations due to the technology, software, and/or technical data being taken out of the U.S. Special considerations may also apply based on the travel destination and purpose for travel. All UH faculty, staff, students, and other personnel traveling abroad on UH-sponsored trips, or for any international travel on behalf of UH, are required to complete an International Travel Export Control Form (Sharepoint) prior to submitting their Concur travel authorization request.
The following should be considered when planning international travel and/or research collaborations to ensure compliance with export control laws and regulations as well as university research security measures.
Foreign Influence Concerns
Since 2018, Congress and all major federal agencies sponsoring research have expressed concerns about the impact of undue foreign influence on federally funded research in the U.S. The term “foreign influence” in higher education is generally used to describe situations in which a foreign government, entity or individual positions itself to divert a university’s intellectual property to said foreign government, entity or individual; or to covertly influence or steer the course of federally-funded research in a manner that benefits said foreign government, entity or individual. Foreign Influence may involve facilitating research efforts (in the U.S. or abroad) to provide the foreign entity with direct visibility into research activities in an incidental or even “supportive” manner, though nonetheless outside the scope of the intended collaboration.
UH’s international travelers may encounter unintended foreign influence situations while traveling abroad. For example, foreign influence may occur when a foreign organization offers to pay for international travel, lodging, and expenses with the illicit objective of obtaining unauthorized research information; or when a foreign entity offers to provide in-kind laboratory research support in exchange for on-site consulting or advice. Likewise, proposed collaborations with or engagements by foreign parties that the U.S. government identifies as a Restricted Party are an automatic indicator of potential Foreign Influence concerns.
Foreign Influence is a global risk. Foreign influence may occur in any country, however, the U.S. government has identified countries of concern related to undue foreign influence. These countries include China, Iran, Russia, North Korea, Syria, and Venezuela. Travel to these countries may require extra measures to secure technology, data and information.
It is essential for travelers to complete the International Travel Export Control form as thoroughly as possible to expedite review and approval of the travel request.
Travel to OFAC-sanctioned Countries
While export controls apply to all countries, travel and other activities to/with OFAC-sanctioned countries (currently Cuba, Iran, Syria, North Korea and certain regions of Ukraine) is prohibited in most cases without a license or authorization. Likewise, most exports to these countries require licenses. The Export Control Officer (exportcontrol@uh.edu) can work with travelers to determine compliance requirements for travel to these countries. Early notification helps facilitate travel objectives. Please contact the Export Office as soon as possible if you anticipate travel to a sanctioned country.
Additional information on travel to Cuba.
Other countries with notable sanctions and end-user restrictions include: Balkans, Belarus, Burma (Myanmar), Central African Republic, China, Democratic Republic of the Congo, Ethiopia, Hong Kong, Iraq, Lebanon, Libya, Venezuela, Yemen, and Zimbabwe. Layovers in foreign countries also count as a destination for export control purposes. Please be aware that restrictions may exist for a layover location, even though it is not your final destination.
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) 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 International Travel Export Control form 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 export control review process. If you need assistance in determining if a potential international partner is a Restricted Party, please contact the Export Control Officer.
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 before travel to make any necessary adjustments in a timely manner. If there are any questions about whether material is eligible for dissemination during international travel, please contact the Export Control Officer.
Field Work Abroad
In most cases, fundamental research conducted outside the U.S. qualifies for UH’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 UH 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 Officer 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 during 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.
When 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 Control Office will work with you to obtain a license and/or adjust your travel plans to preclude license requirements.