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International Travel

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 (OGSS) and Export Control & International Compliance (ECIC) have collaborated to provide this guidance document to the Northwestern community. Review this webpage and check out this one page Export Controls Travel packing list international-travel/export-controlled-travel-packing-list.pdf

Visit the Office of Global Safety and Security website and Review 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.

Determine if you are traveling to an OFAC Sanctioned Country.

Contact the ECIC Office and register your travel if you plan to travel to the following countries: Belarus, Cuba, Iran, North Korea, Russia, Syria, and certain Regions of Ukraine (Crimea, Donetsk, Luhansk). 

Depending on your destination(s), travel to an embargoed/sanctioned country may require prior authorization in the form of a license from the U.S. Treasury’s Office of Foreign Assets Control (OFAC). OFAC administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals, and issues both civil and criminal penalties for non-compliance.

No University equipment should be taken without prior approval and no University business should be conducted without prior authorization. Most activities involving comprehensively sanctioned countries (even remotely) will require a license.

Heavily sanctioned countries or areas change over time. The ECIC website maintains an up-to-date list of sanctioned countries and additional resources on OFAC sanctions programs. A complete list of OFAC sanctions programs is available on OFAC's website. Contact the ECIC for assistance.

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. 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.

Determine if you are traveling to a military end-use country. 

Contact the ECIC Office if you plan to travel to the following countries: Belarus, Burma, Cambodia, China, Iraq, Russia and Venezuela.

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 or subject to special export controls. The designated countries change over time (currently Belarus, Burma, Cambodia, China, Russia and Venezuela). Iraq is also considered a country subject to special controls under export control regulations.

Contact the ECIC to conduct restricted party screenings and an a licensing determination for the items you plan to take with you.

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 or filling out a TMP Form.

Please review the following steps:

  • Travel with a clean/loaner laptop is required for OFAC countries and highly recommended for MEU countries.
  • Complete the Temporary (TMP) license exception form (TMP Form) when hand-carrying items abroad for University business.
  • Complete the Consumer Communication Devices form (CCD form) if you are traveling to Cuba, Russia, or Belarus and bringing basic consumer electronics/software. See 15 CFR 740.19(b) for a list of eligible items.  
  • Reach out to the ECIC office regardless of country if you plan to travel with any University equipment other than a regular laptop/cell phone/tablet (ex. camera, scanner, chips, electronic devices, protective equipment), material or substance (ex. biological or chemical samples) or high levels of encryption (encryption software, including applications, or devices), military or space-related items or technology, or any controlled data or software (source code, object code, confidential or restricted technical data). 
Clean/Loaner Laptop

Traveling with a clean/loaner laptop is required for OFAC countries and highly recommended for MEU countries. A “clean” laptop does not include proprietary or sensitive information, including unpublished information that might be subject to confidentiality restrictions. 

How do I request a clean laptop? The campus community can request a loaner laptop from NUIT here. Feinberg personnel can submit a request to FSM Loaner Laptop Request. Note: your individual school may require or encourage a clean/loaner laptop for all international travel regardless of country. Learn more here and see IT travel tips.

See Guidance on Taking “Devices” Outside the United States 

Complete the international travel exception forms prior to your travel.
  • TMP Form: International travelers should complete the Temporary (TMP) license exception when bringing items abroad for University Business. Relevant items include, but are not limited to, laptops and other mass market electronic devices, including "clean"/loaner devices (smartphones, tablets, etc.), equipment, software, and technology. The TMP exception form is used for University-owned items when traveling on University business. The TMP form may NOT be used to bring items to embargoed and sanctioned countries.  Travel to these countries requires review/approval from the ECIC office. 
  • CCD Form: International travelers to Cuba, Russia, or Belarus should complete the CCD form when bringing items abroad for University Business. Eligible items are basic consumer electronics/software, including consumer computers, tablets, and peripherals, mobile phones, batteries, chargers. See 15 CFR 740.19(b) for a list of eligible items. Travel to Cuba, Russia, or Belarus (and other heavily sanctioned or embargoed countries) on University business requires review/approval from the ECIC office. 

Note: Some items may need an export control license rather than the TMP or CDC exceptions, so please plan accordingly and reach out to the ECIC for assistance. For example, if you are carrying substances or materials (e.g., biologics, chemicals, etc.), high levels of encryption, or space-related technology, please contact the ECIC for an export control review.

  • TMP Form - University-owned electronic devices, equipment, software for university business abroad
  • CCD form - Any consumer communication devices for university business in Cuba, Russia, or Belarus

Confirm with whom will you collaborate, associate, or do business with on  your travels.

 Before travel, foreign parties may be screened using the Restricted Party Screenings tool to avoid collaborating with a prohibited party. The ECIC team can assist with conducting screenings.

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 (Reference International Travel Handout):
  • 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.

Contact Information if you Experience Issues at the U.S. Port of Entry

Administrative matters & legal immigration questions should be directed to an immigration attorney. For the purposes of notifying the appropriate University officials, if possible, contact Northwestern Police at (847) 491-3456. 

Note: The Northwestern University Police Department (NUPD) is available 24/7 at (847) 491-3456, including weekends and holidays. Please describe the situation to the dispatcher, who will notify the appropriate University officials. 

Contact the ECIC office during regular business hours for export control-related questions.

 

If you have any questions, please contact:

Export Controls & International Compliance  or  Office of Global Safety & Security

Please also report anything that gives you pause from your trip. Safe Travels!