Northwestern students, faculty, and staff traveling internationally on behalf of Northwestern for academic, research or other purposes need to follow a series of steps. The Offices of Global Safety and Security and Export Control & International Compliance have collaborated to provide this guidance document to the Northwestern community.
Visit the Office of Global Safety and Security website and the Export Controls & International Compliance Travel Guidance.
The Office of Global Safety and Security (OGSS) supports Northwestern travelers abroad – students (graduate and undergraduate), faculty and staff. Post-pandemic, Northwestern launched an International Travel Registry, where all non-study abroad students must disclose their University-sponsored travel at least two weeks prior to departure. (Study abroad students’ travel details are automatically transferred to the registry 30 days prior to the start of their program). Trip leaders are also required to register their travel when taking students abroad.
Register Travel to OFAC Sanctioned Countries
In addition, employees (faculty and staff regardless of citizenship) are highly encouraged to register their official travel to comprehensively sanctioned countries. The Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals. OFAC issues both civil and criminal penalties for non-compliance. While comprehensively sanctioned countries change over time, currently they are Belarus, Cuba, Iran, North Korea, Russia, Syria, and certain Regions of Ukraine. The Export Controls & International Compliance (ECIC) website maintains an up-to-date list of sanctioned countries. Reference memo from the Office for Research.
The Travel Registry provides important pre-departure health and safety resources and monitors travelers’ destinations during their trips, which allows OGSS to reach out and offer support in a timely manner in the event of a serious threat to travelers’ health or safety, such as a natural disaster or a terror attack.
Some locations considered higher risk require additional disclosures. See the “disclosures” section on OGSS’s evacuation page. Additionally, OGSS recommends that you check the relevant State Department Travel Advisory for general safety information.
Contact Information if you Experience Issues at the U.S. Port of Entry
The Northwestern University Police Department (NUPD) is available 24/7 at (847) 491-3456, including weekends and holidays, for international student/scholar EMERGENCIES ONLY, such as: issues at the port of entry to the U.S., detention by authorities at the airport, serious health issues, or victim of a crime.
NOTE: Administrative matters & immigration questions are NOT emergencies and should not be directed to the NU Police Department. Please contact OISS during regular business hours for immigration questions and the ECIC for export control-related questions..
Determine what equipment, materials, data, or software you plan to take.
The U.S. government has export restrictions on certain items. Consult with Export Controls & International Compliance (ECIC) to determine if your equipment, materials, data, or software are subject to these restrictions. If restrictions apply, the ECIC team can provide guidance on appropriate next steps, such as applying for an export license.
Traveling with a “clean” laptop is recommended. A “clean” laptop does not include proprietary or sensitive information, including unpublished information that might be subject to confidentiality restrictions. Contact your department IT team or NUIT for assistance.
Complete the international travel exemption forms prior to your travel.
International travelers should complete the Temporary (TMP) or Baggage (BAG) license exception when hand-carrying any items abroad for University business. Relevant items include, but are not limited to, laptops and other electronic devices (smartphones, tablets, etc.), equipment, software, technology, substances, materials, etc. The TMP exception form is used for University-owned items, and the BAG form is for personal items taken when traveling on University business. Note some items may need an export control license rather than the TMP or BAG exemption so please plan accordingly and reach out to the ECIC for assistance.
Determine if you are traveling to a sanctioned country.
Depending on your destination(s), authorization from the U.S. Treasury’s Office of Foreign Assets Control (OFAC) may be required. Travel to an embargoed/sanctioned country (such as Iran and Cuba) may require prior authorization in the form of a license. No University equipment should be taken without prior approval and no University business should be conducted without prior authorization. Most activities involving heavily sanctioned countries (even remotely) will require a license. The most highly sanctioned countries or areas change over time but currently include Cuba, Iran, North Korea, Russia, Syria, and Crimea, Donetsk and Luhansk. Contact the ECIC for assistance.
Determine if you are traveling to a military end-use country.
Depending on your destination, the U.S. Commerce Department’s requirement for authorization to "export" even basic equipment (such as laptops, cell phones, etc.) may apply if the country is a designated military-end user. The designated countries change over time (currently Belarus, Burma, Cambodia, China, Russia and Venezuela). Contact the ECIC for assistance.
Confirm with whom will you collaborate, associate, or do business with on your travels.
Take steps to safeguard your research.
- The research at Northwestern is innovative and often of high value even if it is not subject to export control restrictions. The following steps can help you protect your research and fufill your compliance obligations:
- Use University processes (Buffett, COI, INVO, Sponsored Research, etc.) to engage with collaborators – avoid side deals;
- Complete and update federal agency and Northwestern disclosures;
- Limit what you take abroad;
- Keep information in your possession or locked in a secure location;
- Use the Northwestern VPN (where allowed; some countries ban the use of VPN software);
- Encrypt your device; and
- Ask questions. The ECIC and OGSS teams are here to assist you.
Additionally, to assist researchers in navigating international partnerships and avoiding inadvertent issues, the Office for Research maintains a webpage with guidance on Improper Foreign Interference.
If you are receiving federal funding, affiliations with talent programs must be disclosed. Individuals receiving federal funding cannot be “malign” foreign talent program members. Here is a link to the definition of a malign talent program.
If you have any questions, please contact:
Please also report anything that gives you pause from your trip. Safe Travels!