Office of Research Integrity, Compliance and Security

International Travel Information for University Employees and Students

K-State travelers going abroad should visit the International Travel and Activities page for information about booking travel through Concur, submitting the required International Travel Registration form, and the On Call Travel Insurance and Assistance Services.

Individuals traveling internationally on university business or with university property are responsible for complying with export control laws and regulations. Export control regulations may restrict or prohibit some travel related activities or destinations, and/or may require licenses for others. The Office of Research Integrity, Compliance and Security (ORICS) can help travelers assess what export control requirements apply to ensure individual and institutional compliance.

Travel Purpose

Research, Fieldwork, Course Instruction, or Related Activities

Activities such as engaging in research, field work or course instruction while outside the United States may be restricted based on content and export control restrictions applicable to the destination country. An exception for information in the public domain may apply to research and instruction if it meets certain criteria. Fundamental research activities and information resulting from fundamental research are not subject to the Export Administration Regulations (EAR). Activities that do not meet the criteria for fundamental research may be subject to export control regulations: an export control review is necessary to determine what export controls apply. Research activity in embargoed or sanctioned countries is severely limited: ORICS must be contacted well in advance of travel to a sanctioned country such as Iran, Cuba, Syria, North Korea and the Crimea, Donetsk and Luhansk regions of Ukraine to conduct any university related business or activity. Reach out to the Office of Research Integrity, Compliance and Security (ORICS) for questions or guidance.

Conferences

Most travel to attend or present at conferences will fall under exclusions to the export control regulations. In general, information that is published and is generally accessible to the public through publication in books or periodicals available in a public library or in bookstores or information that is presented at a conference, meeting, seminar, trade show, or other open gathering, is usually considered to be in the public domain, and not export controlled. Attending or presenting at conferences in sanctioned or embargoed countries may require a specific license: please contact ORICS for guidance.

Travel with Electronic Devices, Data, and Equipment

Travel with export controlled data requires authorization

University employees and students traveling with laptops, cellphones, or other data storage devices and encrypted software must ensure that there is no export controlled information on such devices unless there is a specific license or other authorization in place prior to travel. Anyone intending to travel with or transmit export controlled information outside the U.S. must first consult with ORICS. License exceptions and exemptions may apply, depending on the circumstances. As a best practice, a traveler should travel with a “sanitized” laptop to reduce the risk of unauthorized access to information. Contact ORICS for guidance. See information below about loaner laptops.

Take only the minimum devices required for travel purpose(s)

Employees should travel with the minimum devices, equipment, and data needed to accomplish the travel purpose while outside the United States. Electronic equipment that includes University data or other information should be kept to a minimum—if it is not needed, leave it at home. Employees traveling abroad should be aware of any confidential information on any device they are traveling with. There can be limited to no right to privacy in foreign countries and information may be copied or removed from phones and other devices. If you do not feel you can travel without a laptop, USB or other devices or equipment, a loaner laptop should be taken - see additional information below.

TMP License Exception

Most items, including laptops, tablets, cellphones, and commercial software, may be taken outside the U.S. under a license exception, “Temporary Imports, Exports, Re-exports, and Transfers (In-Country) (“TMP”). The TMP license exception allows the traveler to take K-State property out of the U.S. provided the item is (a) kept under the traveler’s effective control and, (b) brought back to the U.S. within a year of the departure date. The traveler should use the TMP Certification to document application of the TMP license exception. Click link to access the TMP form.

TMP does NOT apply to items or technologies controlled under the International Traffic in Arms Regulations (ITAR). In addition, some equipment such as global positioning systems, thermal imaging cameras, and inertial measurement systems are highly restricted and may require a license even when hand carried. Travelers are advised to contact ORICS for guidance.

K-State employees involved in export controlled research must ensure that there is no export controlled information on electronic devices taken during travel unless a specific license or other authorization is in place to take the information to the travel destination.

Travelling with Personal Equipment

For personal laptops, tablets, cell phones, and commercial software, the Baggage (“BAG”) license exception may apply. Like the TMP, the BAG license exception allows travelers to take certain personal items out of the U.S. provided the item is (i) kept under the traveler’s control and (b) brought back to the U.S. within a year of the departure date. Traveler should use the BAG Certification to document application of the BAG license exception. The traveler is responsible for export controls compliance related to travel with personal items. Click link to access the BAG form.

ITS Loaner Laptop Program

Traveling with a loaner laptop reduces the risk of data and identity theft. K- State Information Technology Services has laptops available to be checked out by faculty or staff who travel to high risk countries.

To reserve a loaner laptop:

  • Request a loaner laptop at least one week prior to travel by calling 785-532-4918.
  • Pick up the loaner laptop from ITS equipment checkout.
  • Upon your return, move any data stored on the laptop to a flash drive or external hard drive.*
  • The laptop will be erased/re-imaged upon return by ITS staff.

Included with the laptop will be a case, charger, and international power adapter. For security reasons, travel laptops have limited software and functionality. The laptop applications and software will include a browser, the Microsoft Office suite, antivirus software, Zoom and access to the VPN.

The loaner laptop program is free to faculty and staff, however, the individual borrowing the laptop will be responsible for replacement costs due to damage, loss, or theft. For additional information, visit the IT Equipment Checkout webpage.

*ITS is not responsible for any lost data.

IT Security Tips While Traveling

  1. Do not travel with any moderate or high-risk data.
  2. Disable features that auto connect your laptop to WiFi or Bluetooth.
  3. Use the virtual private network (VPN) when accessing any university systems.
  4. Avoid public WiFi networks that do not require a login or or password.
  5. Confirm with staff (at your hotel, conference center, host, etc.) the correct name of the network and exact login procedures to ensure that the network is legitimate.
  6. To prevent theft and unauthorized access or loss of sensitive information, never leave equipment—including any USB or external storage devices—unattended in a public place. Keep your devices secured in taxis, at airports, on airplanes, and in your hotel room. Also, be aware that government officials and hotel staff will likely have access to the safe in your hotel room.
  7. If you travel with a mobile phone, do not use the public charging kiosks; that connecting cable may open access to whatever you have stored on the phone.

Additional Export Control Considerations

Travel to Sanctioned and High Risk Countries

The U.S. government maintains comprehensive sanctions and embargoes against certain countries. Comprehensively embargoed countries currently include Cuba, Iran, North Korea, Syria and the Crimea, Donetsk, and Luhansk Regions of Ukraine. Countries considered high risk may vary, but currently include China, Russia, and countries listed as Travel Advisory Level 4 – Do Not Travel by the U.S. Department of State.

Sanction and embargo programs are administered by the Office of Foreign Assets Control (OFAC), Department of Treasury, and generally prohibit importation and exportation of goods and services to and/or from an embargoed country. Travel related activities that are allowable for other destinations might require an export license or other authorization if the travel is to an embargoed destination. For example, while travel to Iran is not prohibited and does not require a license, attending a conference or conducting research in Iran requires a license. Travel to Cuba on the other hand is prohibited, unless authorized by a specific or a general license. The rules are different for each embargoed destination. Please contact ORICS at exportcontrols@k-state.edu, phone 785-532-3224 for guidance prior to travel as soon as you become aware of your impending travel. ORICS will assist with applying for the license when necessary. Licenses can take several months before they are granted, so it is important that the traveler contacts ORICS as soon as possible.

Restricted Party Screening

The U.S. federal government maintains several lists of individuals and entities for which the Government has imposed restrictions related to exports, imports, and services. Additional due diligence is required when dealing with an individual or entity appearing on these lists. Activities involving the individual or entity may be prohibited or restricted. When traveling internationally, it is important to ensure that the individuals and/or entities the traveler is meeting with are not restricted, and that the topics of discussion or other proposed activity are not restricted. Restricted Party Screening will be performed during the export controls compliance review of international travel registration forms.

Additional Information Related to International Travel

Extended Travel – HR and related Legal Considerations

If an individual will be on international travel for longer than two weeks, they should contact Human Resources regarding wage/payment issues. Human Resources can be reached at 785-532-6277.

Department heads and supervisors of international travelers on university business should consult the Office of General Counsel regarding compliance with foreign employment, tax, and registration laws. Advance notice—prior to signing any employment-related documents and/or assigning duties to occur abroad—is critical, preferably 6-8 weeks. Contact OGC at 785-532-5730, or via email attys@k-state.edu.

It is each employee’s responsibility to ensure they are aware of and comply with applicable laws in the foreign country, just as they are responsible for complying with applicable law within the United States.

Remote Work

An employee who is working remotely must reside within the United States to comply with all federal and state laws, filings, or tax requirements. No remote work arrangements are allowed for employees who are international. For additional Information, see the HR remote work website or contact Human Resources at 785-532-6277.

Immunizations

A Travel Consult is available at the Lafene Allergy and Immunization Clinic to assist students, faculty, or staff who are traveling internationally. Find additional information at this link or by calling 785.532.6544.

 

For more information or questions, please contact ORICS at comply@k-state.edu or 785-532-3224.