Export Control

Purpose and Scope

U.S. export control laws regulate the transfer of certain equipment, software, technical data, and information to foreign countries, entities, or individuals, including “deemed exports” to foreign nationals within the United States. These regulations are designed to protect national security and support U.S. foreign policy objectives.

The Foreign Travel Security Program establishes the standards and processes to protect university personnel, students, research, data, and institutional assets during international travel conducted on behalf of Colorado State University (CSU).

This program applies to all faculty, staff, students, researchers, contractors, and affiliates who engage in university-sponsored, university-funded, or university-affiliated travel outside the United States, including travel for research, teaching, conferences, collaborations, filed work, or sponsored engagements.

The program supports CSU’s compliance with federal research security requirements, including those outlined in National Security Presidential Memorandum-33 (NSPM-33), as well as U.S. export control laws and regulations.

Program objectives include:

  • Safeguard the health and safety of travelers.
  • Protecting sensitive research, intellectual property, data, information systems, and university equipment.
  • Ensure compliance with U.S. export control laws, sanctions, federal research security requirements, and university policies.
  • Strengthen CSU’s global engagement and international collaboration while mitigating risk.

IMPORTANT: Controlled research may not be performed outside the United States – including travel with devices that may contain research. Please contact Export Controls and Foreign Engagement with any questions regarding travel restrictions.

Export Controls and Foreign Engagement offer country-specific travel briefings. Loaner equipment is available for travel to sanctioned or high-risk countries.

International Travel Registration and Authorization

To support federal research security requirements and institutional risk management, CSU maintains an organizational record of international travel conducted for university purposes.

This applies to all CSU faculty and staff traveling internationally for:

  • University business
  • Research activities
  • Teaching or academic programs
  • Conference attendance
  • International collaborations
  • Sponsored or externally funded travel

must complete a pre-travel authorization and disclosure in Kuali prior to travels.

Travel registration allows the university to:

  • Maintain institutional records of covered international travel
  • Identify export control, sanctions, or research security risks
  • Provide appropriate security guidance
  • Assist travelers in the event of emergencies abroad

Failure to register for international travel may result in travel delays, inability to receive reimbursement, or compliance concerns with federally funded research programs.

Pre-Travel Security Review and Briefings

Employees travelling to a high-risk destination, or travel involving research materials or equipment, must contact the Export Controls and Foreign Engagement team to discuss:

  • Traveling to sanctioned, restricted, or high-risk countries
    • Countries subject to U.S. Comprehensive Sanctions – The highest level of export restrictions.
      • Crimea / Donetsk People’s Republic and Luhansk People’s Republic regions of Ukraine
      • Cuba
      • Iran
      • North Korea
      • Syria
    • Countries subject to U.S. targeted sanctions or other export restrictions.
      • Afghanistan
      • Armenia
      • Azerbaijan
      • Bahrain
      • Belarus
      • Burma
      • Cambodia
      • Central African Republic
      • China (PRC)
      • Congo, Democratic Republic
      • Cote d‘Ivoire
      • Cuba*
      • Cyprus
      • Egypt
      • Eritrea
      • Fiji
      • Georgia
      • Haiti
      • Iran*
      • Iraq
      • Israel
      • Jordan
      • Kazakhstan
      • Kuwait
      • Kyrgyzstan
      • Laos
      • Lebanon
      • Liberia
      • Libya
      • Macao
      • Moldova
      • Mongolia
      • North Korea*
      • Oman
      • Pakistan
      • Qatar
      • Russia
      • Saudi Arabia
      • Somalia
      • South Sudan
      • Sri Lanka
      • Sudan*
      • Syria*
      • Taiwan
      • Tajikistan
      • Turkmenistan
      • Ukraine
      • United Arab Emirates
      • Uzbekistan
      • Venezuela
      • Vietnam
      • Yemen
      • Zimbabwe
  • Laptops, mobile devices, drones, sensors, or research equipment
  • Accessing federally sponsored research data
  • Carrying unpublished research data
  • Transporting biological materials, chemicals, or specialized equipment

When appropriate, travelers may receive country-specific security briefings, which may include guidance on:

  • Personal safety and situational awareness
  • Research security and intellectual property protection
  • Export control restrictions
  • Computer access and cybersecurity risks
  • Foreign intelligence collection risks
  • Research related restrictions
  • Institutional reporting requirements

Electronic Device and Data Security

International travel increases the risk of cyber intrusion, device compromise, and data theft. Travelers should minimize the amount of sensitive data carried abroad.

CSU provides loaner laptops for travel to sanctioned or high-risk destinations.

International travelers must:

  • Use a VPN connection and encryption whenever possible
  • Avoid public WI-FI networks
  • Disable wireless auto-connect features
  • Disable Bluetooth
  • Keep electronic devices in personal possession
  • Use strong passwords and device locking
  • Accessing sensitive research data without authorization

Any loss, theft, or suspected compromise of devices or data must be reported immediately to the Export Controls and Foreign Engagement Office.

Suspicious Activities and Reporting

All faculty and staff should notify the Export Controls and Foreign Engagement teams regarding any suspicious activities that occur before, during or after foreign travel or engagements. All CSU members travelling abroad should:

  • Limit conversations about sensitive research or unpublished research
  • Be wary of unsolicited inquiries or requests for collaboration, data, or technology
  • Avoid sharing controlled or proprietary information
  • Maintain data handling and security requirements

Resources

External Resources

Forms and Templates