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International Travel with Encryption

Because encryption products may be used for illegal purposes, the United States and many other countries may ban or severely regulate the import, export, and use of encryption products. By taking your encrypted laptop to certain countries without prior authorization, you could be violating U.S. export law or the import regulations of the country to which you are traveling, which may result in confiscation of your laptop, in fines, or in other penalties.

Over the past fifteen years, a group of nations negotiated a set of rules attempting to facilitate traveling with encryption software known as the "Wassenaar Arrangement."  One of its provisions allows a traveler to freely enter a participating country with an encrypted device under a "personal use exemption" as long as the traveler does not create, enhance, share, sell or otherwise distribute the encryption technology while visiting. 
 
The countries that support the personal use exemption include:  Argentina, Australia, Austria, Belgium, Bulgaria, Canada, Croatia, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Japan, Latvia, Lithuania, Luxembourg, Malta, Mexico, Netherlands, New Zealand, Norway, Poland, Portugal, Republic of Korea, Romania, Slovakia, Slovenia, South Africa, Spain, Sweden, Switzerland, Turkey, United Kingdom and the United States.
 
Although the Russian Federation and the Ukraine agreed to many of the Wassenaar Arrangement's provisions, they currently do not  permit personal use exemptions.
 
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  •  The encryption functionality within McAfee's Data Protection Suite, has been granted an “ENC/Unrestricted” license exception with the U.S. Department of Commerce. 

     
    Dell/Credant encryption falls under §742.15(b) of the U.S. Export Administration Regulations (EAR) ("Encryption registration required, with classification request or self-classification report, for mass market encryption commodities, software and components with encryption exceeding 64 bits.")  It is categorized as Mass Market with an Export Control Classification Number (ECCN) of 5D992.  Dell/Credant's Encryption Registration Number (ERN) is R100449."
     
    In both cases, this exception allows us to transport or ship a University-owned or personally-owned computer that has one of our approved encryption products installed to any country as long as the computer remains under our effective control, EXCEPT for the following countries defined in the Department of Commerce’s Export Administration Regulations:
    • Cuba,
    • Iran,
    • North Korea,
    • Sudan, and
    • Syria.
    If you must travel to one of the five embargoed countries, you may be able to obtain the appropriate export license, but the process can take, on average, about ninety days for review.  The Department of Commerce’s Bureau of Industry and Security and the Office of Foreign Assets Control (OFAC) within Dept. of Treasury accept applications for licenses to export encryption products and technologies.

    If you cannot obtain an export license, see the section below regarding your options if you cannot satisfy encryption export or import controls.

  • The following nations, including two Wassenaar signatories indicated by an asterisk (*), do not recognize a "personal use exemption".  Before traveling to these countries with an encrypted laptop, you will need to apply to their specified governmental agency for an import license:
    • Belarus - a license issued by the Belarus Ministry of Foreign Affairs or the State Center for Information Security of the Security Council is required.
    • Burma (Myanmar) - a license is required, but licensing regime documentation is unavailable. Contact the US State Department for further information.
    • China - a permit issued by the Beijing Office of State Encryption Administrative Bureau is required. You can either apply for the permit on your own, or contact our McAfee or Dell/Credant authorized distributor.
    • Hungary - an International Import Certificate is required. Contact the US State Department for further information.
    • Iran - a license issued by Iran's Supreme Council for Cultural Revolution is required.
    • Israel - a license from the Director-General of the Ministry of Defense is required.  For information regarding applicable laws, policies and forms, please visit the following website: http://www.mod.gov.il/pages/encryption/preface.asp.
    • Kazakhstan - a license issued by Kazakhstan's Licensing Commission of the Committee of National Security is required.
    • Moldova - a license issued by Moldova's Ministry of National Security is required
    • Morocco - a license is required, but licensing regime documentation is unavailable. Contact the US State Department for further information.
    • *Russia - licenses issued by both the Federal Security Service (Federal'naya Sluzhba Bezopasnosti - "FSB") and the Ministry of Economic Development and Trade are required. License applications should be submitted by an entity officially registered in Russia. This would normally be the company that is seeking to bring an encryption product into Russia. 
    • Saudi Arabia  - it has been reported that the use of encryption is generally banned, but research has provided inconsistent information.  Contact the US State Department for further information.
    • Tunisia - a license isued by Tunisia's National Agency for Electronic Certification (ANCE) is required. 
    • *Ukraine - a license issued by the Department of Special Telecommunication Systems and Protection of Information of the Security Service of Ukraine (SBU) is required.
    Since laws can change at any time, please check with the US State Department before travelling internationally to ensure that you have the most up-to-date information.  Additional information about international encryption controls can be found at the following websites:

    http://www.wassenaar.org/introduction/index.html 

  • If you are not able to meet the import or export requirements for a country you are about to visit, we recommend you remove the encryption software from your laptop prior to traveling. NOTE your laptop must be scanned by a member of the Information Security Office or ITAC to ensure no confidential University information resides on the laptop's hard drive. Any confidential information found on your laptop must be removed before your laptop is decrypted.

Additional Resources 

IT Assistance Center (ITAC)
itac@txstate.edu
512.245.ITAC (4822)

Information Security Office
infosecurity@txstate.edu
512.245.4225