International Travel Policies & FAQ
Interim Policy for International Travel Safety and Compliance
Export Control - International Travel & Activities
Embargoed and Sanctioned Countries
No University of Arizona travel is permitted to Syria. Most activities in Iran will require an OFAC license which can take months to process. Activities in embargoed and sanctioned countries may require a license from Commerce, OFAC, or both. There is a presumption of denial for anything ITAR-controlled.
Online Courses in Sanctioned Countries
There are OFAC restrictions related to taking online courses abroad. Licenses to provide a service to sanctioned countries are required under some circumstances. There may also be licensing requirements for software and other items.
OFAC Licenses - Online Courses in Sanctioned Countries
Duo Restricted in Embargoed Countries
The UA agreement with Duo does not allow UA users to access or use Duo's services in a U.S. embargoed country without U.S. government authorization. In addition, there are export control regulations that impact the use of Duo in embargoed countries. Cuba, Syria, and Iran are the comprehensively embargoed countries. There is an OFAC General License D-1 Iran that covers the use of Duo in Iran. No additional paperwork is required.
To access or use Duo's services in Cuba requires signed documentation prior to travel. The Consumer Communications Devices ("CCD") license exception form should be signed by the traveler and sent to Export Control for signature (export@arizona.edu). The form will be returned and should be kept with the traveler during the trip. Documentation must be kept for five years.
Travel Authorization Process
All University of Arizona personnel traveling internationally on University business are required to complete and submit a Travel Authorization form, register each trip in the University International Travel Registry, and receive approval prior to travel.
License Exceptions Forms
License exception forms may be needed when taking items or equipment abroad.
TMP License Exception Form If a Commerce license is required, this form should be used in lieu of a license (applicable for most countries) if the traveler is taking University owned equipment, such as a laptop. This exception is not applicable for anything ITAR controlled; a license from State would be required.
BAG License Exception Form If a Commerce license is required, this form should be used in lieu of a license (applicable for most countries) if the traveler is taking a personal laptop or other equipment that contains University of Arizona project data. This exception is not applicable for anything ITAR controlled; a license from State would be required.
CCD License Exception Form License exception CCD authorizes the export or reexport of commodities and software controlled under the Export Administration Regulations (EAR) to Cuba or Sudan under specific conditions. Only certain commodities and software are authorized.
Accessing Data While Abroad Accessing export-controlled data abroad is considered an export, including opening an encrypted email with ITAR or export controlled data or accessing the data even on the University server through the VPN. University personnel must coordinate in advance with Export Control if they need to access export-controlled data abroad. A license or license exemption is required in most cases. However, there are some countries where a license or license exemption would not be granted.