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. 

International Travel Compliance Summary

Export control and research security requirements may vary depending on travel destination, your planned activities abroad, the items you plan to bring with you, and whether you will receive funding. The table below is a summarized reference of compliance steps. Please find additional details and guidance about each of these topics below. 

Export Control Review Required 

Travel to Sanctioned or Embargoed Countries

Depending on your destination(s), travel to a comprehensively or heavily embargoed country may require prior authorization in the form of a license from the U.S. Treasury’s Office of Foreign Assets Control (OFAC) or a documented exemption from the Northwestern ECIC team. 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.

A complete list of OFAC sanctions programs is available on OFAC's website. Contact the ECIC for assistance.

Activities with other High-Risk Countries

Burma (Myanmar), Cambodia, China (including Hong Kong and Macau), Nicaragua, Iraq, Venezuela. 

Activities in high-risk countries require additional due-diligence in the form of restricted party screenings, foreign talent recruitment program screening, sponsored-required disclosures, or sponsor-required approvals in some instances, and strong protection for your data and devices. ECIC can help run screenings and review activities for compliance. 

Visit our Research Security website to learn more about navigating international partnerships and avoiding inadvertent issues related to foreign influence or foreign components. 

• Accepting money or in-kind support from certain international sources is one of the criteria used by the federal government in evaluating research security risks and may impact future funding opportunities.
• If you are collaborating or receiving support (of any kind – monetary or non-monetary including honorariums) from a designated country of concern (China including Hong Kong and Macau, Iran, North Korea, or Russia) review our Research Security page and reach out to the ECIC team at exportcontrols@northwestern.edu.
• If you are receiving federal funding, affiliations with talent programs must be disclosed. Individuals receiving federal funding cannot be “malign” foreign talent recruitment program members. Here is a link to the definition of a malign talent program.

High-risk countries or areas change over time. The ECIC website maintains an up-to-date list and additional resources.  

Restricted Party Screenings

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

Bringing controlled research equipment or samples anywhere

The U.S. government has export restrictions on certain items. Depending on the items you bring, the destination, and your planned activities abroad, the items you bring may require a license from the Bureau of Industry and Security (BIS). 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.

Reach out to the ECIC team regardless of country if you plan to travel with any University equipment other than a standard laptop/cell phone/tablet with basic consumer software (ex. camera, scanner, chips, electronic devices, protective equipment), material or substance (ex. biological or chemical samples) or high levels of encryption (encryption software, including custom 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). 

Any items listed on the Commerce Control List (CCL) are considered high-risk for compliance. Search your item in BIS Interactive CCL or reach to the ECIC team at exportcontrols@northwestern.edu for a review. 

Clean/Loaner Laptop

NUIT  Travel Standard for Technology and Endpoint Devices requires traveling with a clean/loaner laptop for heavily sanctioned countries. Clean laptops are highly-recommended for travel to China and other military end-use or regulated countries listed above. 

A “clean” laptop is one that does not include proprietary or sensitive information, including unpublished information that might be subject to confidentiality restrictions. 

How do I request a clean laptop? Travelers may contact their local IT support or Northwestern IT for information on what “clean loaner laptops” are available to them, as well as any potential costs of using the service. Feinberg personnel can submit a request to FSM Loaner Laptop Request. Note: Your 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 

Export Travel Forms

• TMP Form - University-owned equipment or software for university business abroad. Use this flow chart to determine if you must submit a TMP form.
  • TMP Form: International travelers should complete the Temporary (TMP) license exception when bringing NU-owned items beyond a standard laptop with basic consumer software abroad for university-related activities. 
  • The TMP form may NOT be used to bring items to sanctioned  or embargoed countries or regions.  Travel to these countries or regions for university-related activities requires review/approval from the ECIC team. 

• CCD form - University consumer communication devices for university business in Belarus, Cuba, Russia, or Syria. 
  • CCD Form: International travelers to Belarus, Cuba, Russia, or Syria 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 Belarus, Cuba, Russia, or Syria (and other sanctioned or embargoed countries) on university-related activities requires approval from the ECIC team. 

Note: Some items may need an export control license rather than the TMP or CCD 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.

International Travel Registration

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. 

• All non-study abroad students must disclose their University-related travel at least two weeks prior to departure.
• Faculty and staff are highly encouraged to register their travel for the following countries: Belarus, Cuba, Russia, Syria, Iran, North Korea, and Crimea, Donetsk, Luhansk regions of Ukraine.
• Students studying abroad do not need to register. Student 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. 

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.

Find additional resources in the Office of the Provost Travel and Immigration page.

Take steps to safeguard your research 

• Use University processes (Buffett, COI, INVO, Sponsored Research, etc.) to engage with collaborators – avoid side deals;
• 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.
• Review NU guidance to protect your research, your personal information, and electronic devices: 
  • NUIT Protect your Research 
  • NUIT Stay Secure During Travel 
  • Guidance on taking devices outside the US 
  • Global Safety’s Travel Security Guidance 
  • GeoBlue insurance. Contact Julie Friend with questions. 
  • NSF Secure Center Travel resource  

Issues at the U.S. Port of Entry

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

Administrative matters & legal immigration questions should be directed to an immigration attorney. Additional resources are available in the Office of the Provost Travel and Immigration page.

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. 

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!