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International Travel Safety and Compliance Policy (Interim)

Policy Information

PDF version
Effective Date: 
September 13, 2012
Policy Number: 
Bus-401
Responsible Unit: 
Office of Global Initiatives / Risk Management
Phone: 
(520) 621-1900

Purpose and Summary

The University of Arizona supports and encourages international travel and collaborations, and recognizes that a global perspective is essential to its academic mission. To this end, the UA has established a broad global presence through programs involving international study, research, partnerships, faculty-led trips, and student opportunities for study abroad and student exchange. The UA endeavors to balance the value of participation in international activities against the potential risks to its students and employees, and to ensure institutional compliance with applicable regulatory programs.

This policy establishes UA requirements for international travel with the goal of maximizing personal safety as well as compliance with applicable regulations. Among the purposes served by this policy are

  • Provision of information, resources, and guidance to UA travelers to maximize their safety and health while traveling abroad
  • Facilitation of immediate access to data on the location of UA international travelers and ability to communicate rapidly with UA travelers to verify well-being and to provide instructions or guidance if needed
  • Evaluation of applicability of state and federal regulatory requirements in advance of international travel to provide direction on compliance and avoid potential penalties, including imprisonment and severe fines

Scope

This policy applies to all University of Arizona (UA) faculty, staff, students, and volunteers who travel internationally as part of University of Arizona research, education, service, or employment.

International travel applicable to this policy includes, but is not limited to, travel in the course and scope of UA employment; travel within the scope of a UA-sponsored research grant or contract; travel that is eligible for UA-approved course credit as well as travel under UA auspices for non-credit experiences; and student or volunteer travel under the direction or supervision of UA faculty or staff.

Students who take a leave of absence from UA enrollment to travel either on their own or through non-UA study abroad programs are not subject to this policy.

Compliance with this policy is necessary to

  • Receive reimbursement for travel expenses, if eligible
  • Be covered by applicable insurance programs during international travel
  • Receive UA academic credit for international coursework, if eligible
  • Receive available University assistance in the event of an emergency during your international travel
  • Avoid significant personal fines and potential prison sentences, internationally
  • Avoid disciplinary action and/or limitations on future UA travel
  • Adhere to related applicable UA, state, and federal policies

Policy

1. Required Action in Advance of Travel

  1. Employee Travel Authorization: UA employee travel and funding must be authorized in advance by the traveler’s department in accordance with established UA travel policies and procedures, outlined in Financial Services Manual, Chapter 14. The first step is completion of a Travel Authorization Form by the traveler’s home department.
  2. Travel Registration: UA will implement systems and procedures for registration of international travel information. Such information may be used in the event of an emergency to locate travelers and communicate emergency information. All UA travelers are required to follow UA procedures for travel registration in advance of travel.
  3. Laptop Computers and Other Equipment: For all destinations outside the United States, software; information (data, technology, schematics, etc.); and equipment (including laptops, cell phones, etc.); or service (including gratis conference presentations) should be vetted prior to travel for possible export control issues. Generally, laptops and other devices that contain only Operating Software, Web Browsers, and Software such as Microsoft Office and Adobe have no export control license restrictions unless travel is to a restricted/embargoed country. See the University’s Export Controls website for guidance and/or contact the University’s Export Control Officer (see Appendix B) for guidance well in advance of committing to the trip. A federally issued export license or documented license exception may be needed prior to travel outside the United States, depending on the proposed destination, the equipment or materials to be taken to or from the foreign locale, the nature of the project or activity associated with the travel, and individuals and organizations to be contacted. This requirement applies whether or not an individual is working on an export-controlled project (see Section 3).
  4. Travel Warning Areas: All UA travel by employees and students to countries and/or areas designated as "Travel Warning Areas" requires advance review and approval as described in Section 2 below.
  5. Travel to Sanctioned or Embargoed Countries: Certain countries, such as Iran, Cuba, Syria, Libya, Sudan, and North Korea, are sanctioned or embargoed. The Export Control Office maintains an up-to-date list of the sanctioned/embargoed countries. All UA employees, regardless of the nature of the proposed professional activities and possible professional contacts in these countries, must coordinate proposed travel to any restricted/embargoed country through the Export Control Office and must be licensed by the appropriate government agency in advance of Travel Authorization.
  6. Student Travel: Student travel as part of a UA program must be authorized in advance as follows, depending on the type of travel:
    1. Participation in study-abroad programs for UA academic credit requires registration through the Office of Study Abroad and Student Exchange (OSASE).
    2. Faculty-led student study/travel abroad (non-Travel Warning Country/Area) requires approval of the faculty member’s Department Head, the College Dean, and the OSASE Director.
  7. Export Control Regulations: Export controls and their applicability must be evaluated during the planning process for international travel (see Section 3 below).
  8. Defense Base Act Insurance: UA international travel by employees (not applicable to students or volunteers) under a federal agency service contract or for work performed on U.S. military bases abroad must be evaluated to determine if Defense Base Act (DBA) insurance coverage is required (see Section 4 below).
  9. In-Country Local Regulations and Laws: For all UA-related international travel by students and employees, particularly if local research is planned, principal investigators are responsible for obtaining, in advance of any research activity on foreign soil, all special visas and/or permits that may be required, and are encouraged to contact the local embassy for assistance if any concerns arise during the trip. Travelers are required to comply with applicable laws and regulations imposed by or relevant in the country to be visited. Failure to comply with the laws of a foreign country can result in arrest, jail, and prosecution by foreign governments. The UA may have limited ability to intervene or assist in the event of arrest abroad, and UA costs incurred for legal counsel, fines, etc., will be the responsibility of the traveler’s home department.
  10. Policy Non-compliance: Failure to submit required international travel information and obtain applicable reviews, approvals, permits, and licenses in advance of the trip may result in having the trip designated as non-UA-authorized, which may result in disciplinary action, non-reimbursement of travel expenses, ineligibility for UA insurance during the trip, and limitations on future travel. Noncompliance with U.S. and foreign regulations may also result in severe penalties, including criminal prosecution, attorneys’ fees, personal fines, and jail.

2. Travel Warning Areas

  1. Travel Warning Area, for purposes of this policy, a country or region will be designated as a Travel Warning Area if any of the following conditions apply:

    1. A current Travel Warning has been issued by the U.S. State Department.
    2. A current Travel Health Warning has been issued by the U.S. Centers for Disease Control.
    3. Any country or region is designated as restricted for UA travel by the Office of the Provost, based on recommendation from the International Travel Safety Oversight Committee (ITSOC;  see Appendix A).
  2. For Travel Warning Areas the following provisions apply:

    1. The Provost may authorize or restrict UA travel to specific regions within a Travel Warning Country/Area.
    2. No UA student or employee shall be required to travel to a Travel Warning Area.
  3. All UA travel to Travel Warning Countries/Areas requires advance review and approval by the Provost’s Office or designee. The International Travel Safety Oversight Committee (ITSOC) serves as the review body for travel proposals and provides a recommendation to the Provost concerning whether the proposed travel should be approved. See Appendix A to this policy.
  4. Employee Travel to Travel Warning Areas: In addition to Travel Authorization, supplemental information must be submitted that characterizes travel risks, provides justification of travel necessity to their work, acknowledges additional risk of travel, and documents Department Head concurrence and approval. The "Related Information" section includes a Supplemental Travel Authorization (for Travel Warning Areas) that can be used to meet this requirement.
  5. Student and Volunteer Travel to Travel Warning Areas: In addition to Travel Authorization (if applicable), all students and volunteers must submit supplemental information that characterizes travel risks, provides justification of travel necessity to their academic program, acknowledges additional risk of travel, and documents concurrence and approval from their Program Director or Advisor or sponsoring Department Head as applicable. Additionally, students and volunteers must complete and sign an Assumption of Risk and Release form, included in "Related Information."
  6. UA study abroad programming in a Travel Warning Country/Area requires approval from the ITSOC and the Office of the Provost. Information about ITSOC is included in Appendix A.
     

3. Travel Restrictions and Export Controls

  1. The Senior Vice President for Research is authorized to prohibit or restrict UA travel to any country or region that poses an unacceptable risk for Export Control compliance. The primary federal agencies that oversee the administration of export control regulations are the Department of Commerce’s Bureau of Industry and Security (BIS); the Department of State’s Directorate of Defense Trade Controls (DDTC) (for International Traffic in Arms Regulations–ITAR); and the Department of Treasury’s Office of Foreign Assets Control (OFAC).The UA's Export Control Office, which reports to the Senior Vice President for Research, oversees UA compliance with these regulations.
  2. "Export," for purposes of this policy, means sending or taking an article outside the United States in any manner; or disclosing through visual, oral, e-mail, fax, or other means, any export-controlled technical data or information, whether in the United States or abroad.Export Control regulations also include proscriptions on providing “anything of value,” including professional presentations and professional advice/consulting, to certain OFAC-sanctioned countries.

  3. Certain countries, such as Iran, Cuba, Syria, Libya, Sudan, and North Korea, are sanctioned or embargoed. The Export Control Office maintains an up-to-date list of the sanctioned/embargoed countries. Any individual working on an export-controlled project must coordinate proposed travel to any restricted/embargoed country through the Export Control Office and must be licensed by the appropriate government agency in advance of Travel Authorization. The UA Export Control Officer is designated as the UA Liaison to all federal agencies for these licensing issues.
  4. The consequences of violating these regulations can be very severe for the individual and/or organization violating these regulations
  5.  See Appendix B for more information.
     

4. Defense Base Act (DBA) Requirements

  1. "Defense Base Act (DBA)" is a federal requirement governing insurance benefits that employers must provide to employees who travel abroad under the provisions of a federal contract or subcontract (does not include grants). Reference is CFR Title 42, Chp.11, §1651.
  2. For international travel where the UA is a contractor or subcontractor to any agency of the U.S. federal government, or when work will be conducted on any U.S. military base abroad, a requirement for Defense Base Act (DBA) insurance coverage may be applicable. DBA is a specialized form of worker’s compensation insurance that responds to injury, disability, or death of employees working abroad.
  3. These requirements are applicable only to employees, not students or volunteers, and the following provisions apply:
    1. Risk Management Services will provide guidance and training for departments to identify the need for DBA coverage during contract review and project planning.
    2. Scope of work, itinerary, and payroll data must be submitted by the traveler’s home department and approved in order for DBA coverage to be established well in advance of the travel.
  4. DBA premiums are calculated based on payroll data and the number of days abroad. Unless otherwise specified, funding responsibility for DBA insurance premiums will be through Risk Management Services and the State of Arizona.
  5. Failure to obtain DBA coverage when required may result in financial penalties assessed against the UA, which will be the responsibility of the UA employee’s home department.

Appendix A: International Travel Safety Oversight Committee (ITSOC)

Appendix B: Export Controls Overview

Related Information*

Revision History*

Incorporates the interim "Guidelines on Travel to Areas of the World Affected by Infectious Disease Epidemics"

* Please note that sections titled Frequently Asked Questions, Related Information, and Revision History are provided solely for the convenience of users and are not part of the official University policy.

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