Export Compliance

6 FBI Tips for Students to Avoid Export Compliance Mishaps

The undeniable value of international collaboration places universities and other research facilities at high risk of breeching deemed export laws. Joint research projects, training programs and other cooperative activities necessitate the exchange of data, shared experiment results, and inter-campus visitation. These activities open the door to a host of violations surrounding licensing errors and omissions, as well as the risk of receiving visitors whose name may exist on a Restricted or Denied Party List.

Fortunately, most vulnerable facilities maintain robust deemed export compliance programs to protect their controlled goods and technology. That’s a good thing, because the U.S. government is paying attention. The Federal Bureau of Investigation (FBI) is very interested in universities and research institutions, and they’re not limiting their attention to the activities that occur on U.S. soil. Their focus for the next twelve months is on Study Abroad programs that, while highly enriching, can be a threat to safety and security for young travelers and for the institutions they represent.

Many American universities have partner schools in locations around the world. The ones in China are of particular concern to FBI agents, perhaps due in part to an American student whose semester in Shanghai led to a chain of events that ended with a four-year sentence for espionage in a federal detention center. To make a long story short, the young man was paid by Chinese intelligence agents to take the US State Department test and try to join the CIA so that he could divulge secrets to the Chinese. It all began innocently enough with a job writing online articles. Unfortunately the hiring company was a front for a Chinese intelligence agency.

The FBI’s latest literature about Study Abroad programs is a brochure that outlines existing threats to students and the precautions they can take to avoid turning an invaluable learning experience into a disaster. The risks are the same as for adults travelling for business or research purposes, and the advice is similar. To highlight just a few:

1. Obtain pre-travel country risk assessments for the country/countries being visited. There could be specific issues you need to be aware of.

2. Do not leave electronic devices unattended. That means laptops are not checked baggage. Shield passwords and avoid Wi-Fi networks (in some countries these networks are controlled by security services).

3. Use up-to-date protections for antivirus, spyware, security patches and firewalls. Do not use thumb drives given to you while abroad, as they could be compromised.

4. Sanitize your laptop, telephone and PDA prior to travel. Ensure no sensitive contact, research, or personal data is on them.

5. If your device is stolen, report it immediately to the US Embassy or Consulate.

6. Avoid illegal, improper or indiscreet actions. As the hapless American student discovered in Shanghai, if something sounds too good to be true, it probably is. When in doubt, report uncomfortable situations to U.S. authorities.

The above advice is a good start to preparing for that big overseas adventure, but it’s not a comprehensive list. Additional travel security tips and country threat information are available from the FBI upon request. If you or someone you care about is about to embark on a Study Abroad program, do your research, and ensure the trip memorable for the right reasons.