International Travel Acknowledgement of UF Directives/Policies

As responsible stewards of UF resources, all UF Travelers who plan to travel internationally on university business on or after January 1, 2022, must read and acknowledge all applicable UF regulations, policies, and directives.

Why was this step added?

The state of Florida has mandated preapproval and screening programs for international travel for all state agencies that receive $10 million or more in state funds.

The acknowledgement in UF GO covers the following policies/directives:

UF Policy on Export Control

UF Policy on Export Control – U.S. export control laws govern the transfer of technology, information, and commodities overseas or to a foreign national within the US. Depending upon your destination, what you intend to bring with you, or your planned activities, you may need to obtain a license or other authorization from the U.S. government before your trip. For more information, visit the Export Controls website.

UF Directive on International Travel

UF Directive on International Travel – A Travel Authorization (TA) for official university business must be entered into the Travel and Expense Module of myUFL for all foreign travel. Additional information regarding expenses incurred during foreign travel, creating foreign travel expense reports, and paying visiting travelers can be found here.

Taking UF Assets Abroad

Taking UF Assets Abroad – If you are traveling with any UF-owned property, including your UF laptop, you should submit a Foreign Travel Request and receive pre-approval from UF Asset Management via the myAssets Portal. The Foreign Travel Request is required to comply with government regulations and U.S. export laws regarding foreign travel with property.

UF Policy on Intellectual Property

UF Policy on Intellectual Property – University personnel are required to disclose promptly all their inventions, even those the creator believes to be unrelated to his or her university duties and not involving the use of university support. Contact UF Innovate Tech Licensing for guidance on disclosing, ownership, commercialization, patent, copyright or trademark strategy.

Additional Guidance on International Travel

Does the destination matter?

When planning your travel, it is important to note that the State of Florida has a unique law that prohibits the use of any state funds in support of travel to countries designated as state sponsors of terrorism. Currently, the U.S. Department of State has designated Cuba, Iran, North Korea, and Syria as state sponsors of terrorism. As such, you cannot use any UF funds to support your travel to those destinations, including UF Foundation, gift, start-up, or sponsored research funds.

In addition to Florida law, the U.S. Office of Foreign Assets Control (OFAC) administers trade sanctions programs, which may impact your ability to travel to or perform certain activities in various sanctioned countries.

The countries of most concern are those countries subject to OFAC’s comprehensive sanctions: Cuba, Iran, North Korea, Syria, and the Crimea region. Most interactions with those countries will require a license from the U.S. government. Before you travel to or plan collaborations with any of the comprehensively sanctioned countries, contact UF RISC to determine whether your planned travel or activity requires a license.

What can I bring on my trip?

Each time you leave the U.S. and bring items with you, even temporarily, you have engaged in an export of those items. In most cases, bringing items with you when you travel does not require any prior authorization. However, especially when traveling on university business, you may need to export an item or technology to a location that would require a license or other authorization (i.e., license exception). Remember, only the UF Export Control Officer within UF RISC is authorized to make the determination about whether an item is subject to export control laws. Contact UF RISC to help you determine whether what you are taking on your trip is subject to the export control regulations.

Rules of Thumb for Traveling with Equipment or Software:

Do not take the following items on an international trip without first consulting UF RISC:

• UF-owned equipment or software (other than UF-owned laptops, tablets, which can be submitted via the myAssets Portal with UF RISC consultation);
• Equipment, software, or data that you received with restrictions on its export or on access by foreign persons;
• Data or analyses that resulted from research that did not qualify as fundamental research (i.e., research that was subject to publication or foreign person access restrictions);
• Equipment, systems, or software that were specifically designed or modified for military or space applications;
• ITAR-controlled articles or technical data (including software); and
• Classified information.

Plan ahead! Getting an export license from the U.S. government may take several months, so contact the UR RISC as soon as possible to begin your export review.

Items that Generally Will Not Require a License:

Laptops, Tablets, Cell Phones – You likely will not need a license to take most low-tech, commercially available items with you during travel to most countries except the comprehensively sanctioned countries (Cuba, Iran, North Korea, Syria, and the Crimea region). For travel to or through comprehensively sanctioned countries, an export license will likely be required, even for common items like laptops and cell phones. (See more information on Cuba and Iran, below)

Note that both the laptop itself and all software and data stored on it are subject to export control regulations. In general, laptops cannot contain anything other than standard, off-the-shelf software, and basic encryption in order to export them without a license. Additionally, you must remove any export controlled or proprietary data from your laptop before traveling.

Activities with Iran

OFAC maintains a comprehensive sanctions program against Iran pursuant to the Iranian Transactions and Sanctions Regulations (ITSR), among other rules, executive orders, and policies. Additionally, the U.S. Department of State has designated Iran as a state sponsor of terrorism. These regulations and designations place significant restrictions on the interactions the UF community can have with Iran. Additionally, Florida law prohibits the use of any university funds in support of travel to Iran.

In general, the following restrictions apply to all UF activities with Iran:

• UF personnel are restricted from using any UF funds to support travel expenses for travel to Iran (includes UF Foundation, gift, start-up, college/departmental, or sponsored research funds);
• S. persons may not attendor present at a conference in Iran without an OFAC license.
• This license requirement applies regardless of the topic of the conference and regardless of whether the information presented is within the public domain.
• It can take up to six months or more to obtain an OFAC license for Iran. Plan ahead!
• Please Contract the Export Control Officer as soon as possible if you would like to engage in activities with Iran.

Activities with Cuba

On 11 January 2021, the US Department of State reinstated Cuba on the list of “state sponsors of terrorism” (see: https://www.state.gov/u-s-announces-designation-of-cuba-as-a-state-sponsor-of-terrorism/).

Consequently, and as was the case before Cuba was removed from that list by the Obama Administration in 2014, pursuant to Florida Statute 112.061.3(e). no state funds may be used to travel to Cuba at this time.

RISC will update their page on International Travel and Shipping as new information becomes available.

Resources

For more information about international engagements, please visit International Engagement and Collaborations. If you have questions about engagements while abroad, reach out to UF RISC.

For general travel related questions, please contact the UF Travel Team.

Before planning any trip abroad, be sure to check the U.S. Department of State Travel Advisories for your intended destination.

For information on health and travel notices, including vaccines and medications, visit CDC Travel Recommendations.

If going abroad for more than 30 days, a remote work location agreement may be required. Visit UF HR for more information.