International Travel Safety and Compliance Policy (Interim)

The University of Arizona is committed to encouraging and supporting international travel and collaboration. A global perspective and engagement are essential to the UA's academic mission. This policy addresses UA international travel which includes, but is not limited to, international study, research, partnerships, collaboration, presentations, trainings, recruitment, tours, and experiential learning. 

This policy establishes UA requirements for international travel intended to maximize safety and ensure compliance with applicable regulations. This policy:

• Establishes administrative requirements regarding official international travel;
• Centralizes information, resources, and guidance to UA travelers to promote health and safety while abroad;
• Provides resources to rapidly locate, contact, and assist UA international travelers; and
• Addresses institutional responsibilities to maintain compliance with state and federal regulatory requirements.

This policy applies to official UA travel outside the United States by faculty, staff, students, program participants, and Designated Campus Colleagues (DCCs, including DCC Volunteers), regardless of travel funding source.

Defense Base Act Insurance: UA employees traveling abroad under a federal service contract or performing work on a U.S. military installation abroad are required to arrange for Defense Base Act (DBA) insurance prior to departure.

Elevated Risk: Moderate, high, or extreme risk. For criteria designating elevated risk, click here.

Elevated Risk Area: A country, region, or location identified by the International Travel Safety Oversight Committee (ITSOC) due to conditions that may include and are not limited to: rates of crime, terrorist activity, political instability, natural disaster, state of emergency, health hazards, or other hazards to travelers.  These locations may have a Travel Warning or Travel Alert issued by the Centers for Disease Control and Prevention or ratings of moderate, high, or extreme risk from the U.S. Department of State or other sources. 

• Elevated Risk Travel: Determined based on destination(s); travel activities; or travel type. ITSOC will oversee determinations of travel risk. 

Export Control: An “export” is (1) An actual shipment or transmission out of the U.S., including the sending or taking of an export controlled item out of the U.S. in any manner; (2) Releasing or otherwise transferring technical data, technology or source code to a foreign person in the U.S. (a “deemed export”).  In addition to an actual shipment, an export can occur through visual inspection, phone or in-person exchanges, via email transmissions or other means. There are also regulations that include restrictions on providing “anything of value” including professional presentations and professional advice/consulting to individuals/entities in certain sanctioned countries. Prior government approval in the form of an export license may be required and must be in place prior to the export.

International Travel: Travel to any destination(s) outside the United States or its territories. This includes travel originating from outside the United States, and within and to other countries.

International Travel Safety Oversight Committee (ITSOC): Comprised of advisory and liaison members and standing members selected to represent specific university functions and areas of responsibility; the Committee provides oversight and review concerning the security of international travel.

Official Travel: Authorized travel that includes any of the following:

• In the course and scope of UA employment, authorization, or representation;
• On behalf of a UA sponsored project, research grant, or contract;
• Financed through UA by funding, scholarship, sponsorship, or financial aid;
• UA approved travel, while enrolled as a UA student to meet a course or degree requirement;
• Directed, coordinated, or supervised by UA employees for any traveler;
• Involving the use of a UA vehicle.

Travel or study abroad opportunities advertised or promoted by UA units are not considered official UA travel unless one or more of the above criteria are met.

UA Traveler: A student, employee, or DCC (including DCC Volunteers) on Official Travel.

1. The University of Arizona will have centralized registration systems in place with requirements for all Official Travel.
2. The centralized registration systems will facilitate:
   1. Preparation of travelers
   2. Timely locating of travelers
   3. Communication and assistance in an emergency.

3. All UA Travelers are required to comply with all procedures referenced in this policy.
4. Official Travel requires appropriate authorization. Information regarding required pre-departure authorization is available here.
5. The International Travel Safety Oversight Committee is appointed by the Provost or designee to provide oversight of Official Travel.
6. Employees supervising, overseeing, advising, organizing, or accompanying students or community members internationally must be familiar with and able to appropriately advise on requirements and procedures regarding Official Travel.
7. UA Travelers cannot be required to visit an Elevated-Risk Area or participate in Elevated Risk Travel as a requirement of employment, academic activity, research, or other UA program.
8. All UA Travelers to an Elevated Risk Area or participating in Elevated Risk Travel shall be at least 18 years of age prior to departure.
9. The Provost is authorized to prohibit or restrict Official Travel in any country or region that poses an unacceptable institutional risk.
10. Exceptions to this policy require ITSOC review and written approval from the Provost.

1. Risk Management Services will oversee travel insurance coverage for official UA Travelers. This includes coordination regarding Federal Defense Base Act requirements.
2. Arizona International will coordinate with the appropriate entities for all required student travel oversight, international Clery reporting, and insurance coverage.
3. The Arizona International Study Abroad and Student Exchange will oversee the development, implementation, management, and related policies and procedures for UA study abroad programs.
4. The office of the University Export Control Program (UECP) is responsible for the institutional management and oversight of Export Control compliance, including applying for government approvals related to Export Controlled activities.

Travelers are expected to coordinate with UECP for review and potential licensing. Trip or Program Leads are expected to verify that all travelers under UA supervision follow Export Control regulations. UA volunteers and DCCs traveling independently are responsible for coordinating with UECP for any possible Export Control review and licensing. If a license is required, the license must be in place prior to the export.

5. Arizona International Travel provides centralized oversight in coordination with Study Abroad and Student Exchange and other applicable units regarding: international risk assessment; review processing; traveler preparation; international incident management; and International Emergency Support.
6. Financial Services Office (FSO) will process reimbursements of authorized Official Travel.
7. Departments and/or Principal Investigators advising, coordinating, or directing Official Travel are responsible for verifying that all required special visas and/or permits are obtained for travel.
8. All UA employees involved in the oversight, advising, or planning of Official Travel must be able to appropriately advise travelers of requirements and procedures regarding Official Travel to facilitate accurate advising and safe planning.
9. UA Travelers, Trip, and Program Leads are responsible for obtaining and/or verifying appropriate travel documents, visas, permits, or any other authorization required for entry and activity in all travel destinations. Similarly, UA Travelers are responsible for compliance with applicable U.S. regulations governing their travel as well as those of any destination country.
10. Campus groups offering Faculty-Led Tours must follow UA policies and procedures.
11. The UA does not provide insurance coverage to persons not on Official Travel.
12. Costs incurred for legal counsel, fines, etc., for travel violating this policy may be the responsibility of the traveler or the traveler’s home unit, department, school, or college.
13. Failure to comply with applicable UA policies governing international travel or the decision of the Provost will result in an unauthorized designation. Consequences may include, but are not limited to: disciplinary action, non-reimbursement of travel expenses, ineligibility for UA academic credit, ineligibility for insurance coverage, limited or no emergency support, limitations on future travel, financial penalties to the sponsoring department, or designation of the trip as outside the course and scope of employment. Noncompliance with U.S. and foreign regulations may also result in severe penalties, including criminal prosecution, attorneys’ fees, personal fines, and incarceration.