The University of Arizona

International Engagement

Export Control

export@arizona.edu

Kay Ellis
Director and
Empowered Official
ellisk@arizona.edu
(520) 626-2437

Laura Provencher
Analyst
lprovenc@arizona.edu
(520) 626-5865

Amy Weber
Analyst
amyweber@arizona.edu
520-621-0348

Andrew Garcia
Student Associate
ralphgarcia@arizona.edu

Street Address
1618 E. Helen Street
Tucson, AZ 85721

Mailing Address
PO Box 210409
Tucson, AZ 85721

 

International Travel Policies & FAQ

Interim Policy for International Travel Safety and Compliance

Export Control - International Travel & Activities

FAQs - International Travel

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.