Domestic and International Travel Restrictions

We can help, so please talk with us well in advance of your trip (8-12 months) in case you need an export license.

If you are taking or shipping anything else including but not limited to the following, we need to evaluate your equipment to determine if you need an export license from the U.S. Department of Commerce:

• Non-public technical data;
• Other electronic devices not covered above;
• Technical instrumentation; 
• Chemicals;
• Biological materials/samples; or
• Safety equipment

Payments for equipment, supplies, sub-awards and contracts need to be screened when going to persons, institutions, businesses and organizations external to the university and outside the United States. This prevents prohibited parties from receiving money and helps protect against financial gain by an embargoed country.

Although accounts payable staffer generally screens financial institutions, occasionally they will contact you or the export control office with questions before paying vendors, contractors or suppliers. In order to minimize these situations, we encourage you to: 

1. Use suppliers that have incorporated in the U.S. 
2. Purchase through the U.S. branch of the company or institution.
   • e.g., purchase through Oxford University Press USA rather than the parent office in the United Kingdom.
     
   • If you have questions or concerns, do a quick Internet search on your prospective company combined with the words “export control.” This should help turn up any news stories about the company/person, including possible violations. 
   • If there are violations, the U.S. Department of Commerce likely has restricted them and we recommend you find another supplier.
   • When you are traveling and not able to use the university purchasing /payment system, pay with a credit card. It creates a better payment trail and provides third party protection because the credit card company and its financial institution will handle the payments to a foreign entity.

Some non–U.S. workers may face additional export controls due to International Traffic in Arms Regulations (ITAR) and the Commerce Control List (CCL), restricting their access to materials or technology. The restrictions depend on two main factors - nationality of the person and classification of the materials.

• For example: a non–U.S. researcher, depending on his/her country of origin, may need an export license in order to access materials because of research interests in biotoxins, aviation technology or cryptography.
• Individuals from select countries may need export licenses even for access to common consumer electronics like laptop computers/tablets. When restrictions apply, the hiring department can develop a Technology Control Plan (TCP) that will prevent violations and allow the individual to begin work. However, there may be costs involved with developing and implementing a TCP, a waiting period for federal export licenses and the possibility that a license might not be granted.

Researchers come to UB for several reasons. They are consultants, collaborators, visiting scholars and members of delegations. They might visit laboratories, present at conferences/lectures/seminars, attend athletic or arts events, and volunteer in hospitals or on campus.

• Some of these visitors will engage in activities that require an export license, and for these, we need to practice due diligence by reviewing the guests and their plans. You need to check their names against government restricted lists as well as to provide an export license for those who might need one.
• If someone will have access to a research laboratory that normally is not open to the public (i.e., you lock the doors at night), you must clear all members of the group before they visit the lab. This is particularly important if the lab has a Technology Control Plan in place. 
• Please check with the university's export control office well in advance of the visit, so we can address any issues in a timely fashion. Alternatively, your departmental export control liaison can clear your visitors if there are procedures in place prior to the visit. Your departmental export control liaison or chair can work with the export control office to set up this process.

UB's export control office reminds you to consider compliance costs and be sensitive to potential public policy ramifications when considering the hiring of foreign nationals. 

In 2011, the Department of Homeland Security's U.S Citizenship & Immigration Services (USCIS) changed the visa application as regards controlled research, equipment and access to controlled information. Those changes don't prevent the hiring of non-U.S. personnel unless someone is on a government restricted list.