Temporary Export Memo Request Portal for International Travel

Industrial Security Contact

Deb Kuidis
Manager of Industrial Security
Facility Security Officer (FSO)

Address
1805 Sigma Chi NE
MSC05: 1665
1 University of New Mexico
Albuquerque, NM 87131

Contact
email: dkuidis@unm.edu
phone: 505-277-2058

 

Audrey Pineda
Export Control Compliance Officer

Address
1805 Sigma Chi NE
MSC05: 1665
1 University of New Mexico
Albuquerque, NM 87131

Contact
email: export@unm.edu
email: pinedaa@unm.edu
phone: 505/277-2968
 

International Travel Requirements

Certain faculty and staff employees who travel out of the country must meet with the Facility Security Officer (FSO) for a briefing, prior to and upon returning from their trip. The pre-and post-trip briefing is required when one or more of the following is true:

  1. The employee has a security clearance and is working on a classified contract.
  2. The employee is working with unclassified but sensitive material which is deemed export controlled under federal regulations.
  3. The employee is traveling to any embargoed country -- currently Cuba, Iran, North Korea, Sudan, Syria and Crimea Region of the Ukraine.

>>> Click here for details on what to do when travelling abroad

Export Control Requirements for International Travels

Doing Research Abroad...

When traveling abroad there are three basic questions that university personnel need to consider when determining if export controls apply to their travel:

  • Where are you going?
  • What are you taking with you?
  • What will you be doing and who will you be interacting with?

Where are you going?

In general, travel to most countries is not a problem. There are exceptions which would include countries that are subject to OFAC Sanctions Programs. If your travel plans include transit to or through one or more of the countries subject to trade sanctions contact The Office of Export Control for assistance in mitigating the risks associated with traveling to countries subject to sanctions and embargoes.

What are you taking with you?...

  • Items and Equipment:

    When taking items abroad (including scientific equipment, computers, cell phones, and GPS units) you need to verify that the items are not export restricted based on your travel destination(s). The Office of Export Control can assist you in the process and provide an official memo of behalf of the institution indicating that your items and/or equipment have been cleared for export. For most low-tech, commercially-obtained items, an export license will NOT be required unless you are traveling to or through a comprehensively sanctioned country (i.e., Cuba, Iran, Syria, Sudan, and North Korea) in which case an export license may be required – even for everyday items such as cell phones and laptop computers. Contact The Office of Export Control for help in determining your export license requirements. It is highly recommended that you register any items/equipment that you will be taking with you with U.S. Customs and Protection (CBP). Registration allows you to prove that you had the items before you left the U.S. and all CBP registered items will be allowed to return to the U.S. duty-free. For additional information see Columbus CBP – Port of Entry and Department of Homeland Security Certificate of Registration- form 4455 or Certificate of Registration for Personal Effects Taken Abroad

What will you be doing and who will you be interacting with...

It is important to ensure that you do not accidentally export restricted information or provide any type of assistance or benefit to a sanctioned or blocked entity. The following are a few things to keep in mind as you plan your travel activities:

  •  Presentations
    When presenting data/information in an international setting (including in the U.S. where the audience may include foreign nationals), you need to ensure that you limit your presentation to only information or data that is published, or is publicly available, or that qualifies as Fundamental Research. Be careful not to include or discuss any proprietary, unpublished, or export-restricted data or information as that may constitute an unauthorized export.
  • Interactions with Foreign Colleagues
    As noted above, you are free to openly discuss any published or publicly available information or information generated as the result of Fundamental Research as long as the recipient is not a sanctioned or specially designated entity. It is important to remember that while the results/information resulting from Fundamental Research are not subject to export controls and can be shared without a license, any items, technology, or software generated under that Fundamental Research would be subject to export controls and may require an export license.
  • Field Work
    Any university research activity done outside the U.S. may not qualify for the Fundamental Research Exclusion and would therefore not be protected from export controls until the work is published or otherwise made publicly available. Before disclosing or sharing information or data resulting from international field work it is important to ensure that the information is not export controlled.

Traveling to an Embargoed or Sanctioned Country...

If you are traveling to a sanctioned country, you are required to obtain a country-specific pre-travel briefing, as well as a post-travel debriefing, from your FSO. Please contact Deb Kuidis to schedule these appointments. Please be aware that international sanctions can be introduced or lifted at any time. You are ultimately responsible for determining if your destination is under sanctions. For further information on sanctions in place by the government of the United States, please refer to the Department of Treasury’s website at http://www.treasury.gov/resource-center/sanctions/Programs/Pages/Programs.aspx. At the time of this writing, the following countries were subject to sanctions:

  • Comprehensive Sanctions Cuba, Iran, Sudan, and Syria
  • Targeted Sanctions The Balkans, Belarus, Cote D’Ivoire (formerly Ivory Coast), Iraq, Lebanon, Liberia, Libya, Myanmar, North Korea, Somalia, Sudan, Yemen, and Zimbabwe

Travel Reporting Requirements...

Certain faculty and staff employees who travel out of the country must meet with the Facility Security Officer (FSO) for a briefing, prior to and upon returning from their trip. The pre-and post-trip briefing is required when one or more of the following is true:

  1. The employee has a security clearance and is working on a classified contract.
  2. The employee is working with unclassified but sensitive material which is deemed export controlled under federal regulations.
  3. The employee is traveling to any embargoed country -- currently Cuba, Iran, North Korea, Sudan, Syria and Crimea Region of the Ukraine.

International Collaboration...

In general, collaborations between university personnel and scholars at foreign institutions or organizations do not require export licenses unless they involve export controlled or restricted research or involve scholars in sanctioned countries. Before engaging in an international collaboration, the university needs to determine if export licenses are required and to verify that the foreign individual and/or organization are not blocked or sanctioned entities.

Obtaining Access to a Virtual Private Nerwork (VPN)...

Employees need to be granted VPN access if they wish to continue using UNM Software and connect to Department Resources while outside of the country.

A computer's VPN connection could be compromised (via a man-in-the-middle attack) to gain unauthorized access to UNM network data and/or enable malicious activity against the UNM network which is a risk to everyone’s personal data and sensitive information/research at UNM.

The danger of compromise to any account lets someone connect to our Data Center's network which is a risk. There are often many national boundaries that internet traffic passes through on its route to UNM from abroad. Avoid connecting to Banner and Banner-related systems until you return. If you must connect, I highly recommend that you change your password upon your return to minimize the likelihood of an unauthorized third party using your NetID and password.