University of Arizona International Travel Policies
Travel to Embargoed and Sanctioned Countries
NO UNIVERSITY OF ARIZONA TRAVEL IS PERMITTED TO SYRIA. MOST ACTIVITIES IN IRAN WILL REQUIRE AN OFAC LICENSE AND APPROVAL CAN TAKE MORE THAN A YEAR TO RECEIVE. 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.
On February 16, 2016, the Senior Vice President for Academic Affairs and Provost issued a memorandum to all University of Arizona Campus Colleagues regarding travel to Iran.
License Needed for Online Courses Taken Abroad 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. In addition, there may be licensing requirements for software and other items.
Restrictions on Use of Duo 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 (license or license exception). 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. As stated above, UA does not permit business travel to Syria. There is an OFAC General License, "D-1", 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 UA traveler and sent to the University Export Control Program for signature (firstname.lastname@example.org). The fully signed copy will be returned to the traveler 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. It is the responsibility of the traveler to know the status of official travel prior to departure.
The following are steps that the Traveler and the College/Department/unit should follow to complete the travel authorization process. The procedures can vary from unit to unit.
- Complete the Travel Authorization Form, as required by the Financial Services Office and submit to your College/Unit Accounting Office.
- Register your travel itinerary in the University International Travel Registry, sponsored by the Office of Global Initiatives.
- Your accounting department will review the questionnaire and conduct a Visual Compliance Restricted Party Screening (RPS) on the entities listed on the Travel Authorization Form.
- If all export control questions are checked “NO”, and there are no RPS “HITS”, the Export Control Program does not need to be contacted. Proceed to step number 10. If a “YES” is checked and/or there is an RPS “HIT” (match to the party being screened), continue with steps 6-10.
- ONLY if “YES” is checked on any of the travel questionnaire’s export control questions, and/or RPS resulted in a “HIT”, should the documents listed above be e-mailed to the Export Control Program at email@example.com for an export control determination. Export Control Program approval is required if a “YES” is checked or there is an RPS “HIT”.
- The Export Control Program will contact the traveler to make a license determination (i.e., does the TMP or BAG exception apply, is an ITAR license required, or no license required). NOTE: TMP/BAG is not automatically needed and is not applicable to ITAR data and equipment. The Export Control Program will make all license exception determinations.
- The Export Control Program will inform the Accounting Office and traveler whether or not a license or license exception needed. If a license exception IS required, the Export Control Program will e-mail traveler the appropriate exception form to complete and sign. The traveler will email the completed and signed form back to the Export Control Program for signature.
- The Export Control Program signs and sends the completed copy of the exception form to the traveler and Accounting Department Export Liaison. Please keep in mind an ITAR license approval may take at least two months to process.
- Once any required license or license exceptions are in place, the Export Control Program approves the travel in the University Travel Registry System.
- Note: This step is specific to the College of Optical Science and may not be applicable to other colleges or departments. Accounting Department will forward all required travel documents to the Financial Services Office once steps 1through 10 have been completed.
License Exceptions Forms
TMP License Exception Form
If a Department of Commerce license is required, this form should be used in lieu of a license (applicable for most countries) if the traveler is taking the University of Arizona owned equipment, such as a laptop. This exception is not applicable for anything ITAR controlled (a license from State would be required). Instructions can be found on the form.
BAG License Exception Form
If a Department of 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). Instructions can be found on the form.
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 as detailed on the form.