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• Purpose
• Responsibilities
• Questions, Definitions, and References
• Policy
• Procedure
• Records and Forms

I. Purpose

To ensure that SAO-affiliated persons who are traveling overseas bring proper documentation for equipment and secure their laptops and mobile devices in advance. This is to prevent issues of customs duties and loss of proprietary, sensitive or export-controlled data and the violation of export control regulations.

II. Responsibilities

Export Compliance Officer (ECO)
• Traveler
• Accountable Property Officer (APO)
• Manager of Computation Facility (CF)

III. Questions, Definitions, and References

Address all questions related to this procedure to Natascha Finnerty at 617-496-7557 or nfinnerty@cfa.harvard.edu.

Definitions

Automated Export System (AES)

Data system used by Bureau of Census to record exports and calculate trade balance statistics.

Electronic Export Information (EEI)

Required filing made of export to Bureau of Census by the exporter or shipping company.

References

• SD 931 Use of Computers, Telecommunication Devices and Networks
• SI OIG Management Advisory Regarding Portable Computer Encryption (M-13-01)
• Export License Procedures

IV. Policy

SAO's data policy is for the traveler to use disk encryption on computers or remove all export-controlled, proprietary, and/or sensitive data off laptops and mobile devices and activate security features on smart phones prior to taking them out of the country. Delete sensitive emails from smart phones. Travelers should not use laptops that store export-controlled, proprietary, or sensitive information without disk encryption.

V. Procedure

1. Upon request, the Manager of Computation Facility provides secure flash drives called "Iron Keys" to store and transport any data that needs to be secured. Additionally, the ITAR regulations permit overseas travelers to dial remotely into a secure network for restricted files but must leave the files on the server.

2. The traveler should contact the APO four weeks or more before travel to complete the appropriate property form, especially if other instruments or supplies are being hand carried, to review if there are any export license issues. See Export License procedure for items other than mobile devices.

3. The traveler should complete the export checklist (Form ECP-2) with as much information as s/he can, and send it to the ECO also a month before the travel date. If certain information is the same as on the property form, then it does not need to be repeated if the traveler provides the property form. If only mobile communication and computing devices are carried, one week in advance is acceptable.

4. Then the traveler can prepare a pro forma invoice. Travelers may take laptops and other items as "tools of the trade." "Tools of the trade" items that are needed for your job and stay in your possession regardless of value, do not need to be reported in the Automated Export System. Therefore, the person preparing the commercial invoice indicates "No EEI* required per 30.37 b of the Foreign Trade Regulations" on the invoice if the laptop is valued at more than $2500 and is staying in his/her possession and will be returned to the US. The Export Commodity control Number (ECCN) is 4A994 and license designation is NLR (no license required).

5. The traveler should have a pro forma invoice with him/her that lists the laptop, value, serial number and origin so that s/he can show it when s/he returns and US Customs will not question if it was bought overseas (and charge duty) and what data is on it.

6. If laptops are under SAO control, laptops should have Computrace security software and disk encryption installed by CF.

7. If the traveler is hand carrying items that are not returning and they are valued at more than $2500, these items need to be declared in the Automated Export System. Contact the APO for information about how to do this. Any items or instruments should be checked against the Commerce Control List and US Munitions List to determine if an export license may be required. Please list such equipment on the Export checklist for the ECO to review.

8. Travelers need to ensure any items being brought along do not violate Transportation Security Administration (TSA) regulations regarding hazardous material, magnetic items, liquids, flammable items or weapons.