International Travel

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Policy Number: 852

Policy Suffix:

I. General Policy

Rice University is an international university with faculty, staff, and students from around the world actively participating in study abroad offerings, international research, and collaborations. It is university policy that all Rice-related international travel must be registered and carried out safely to protect the health, safety, security, and well-being of the Rice community.

This policy applies to all faculty, staff, students, and visitors who are traveling outside of the United States and whose travel is:

funded in part or in full by Rice funds (including research funds);
a component of the Rice curriculum or earning academic credit toward a Rice degree;
part of a Rice-sponsored team, group, club, or organization; or
representing the university or otherwise on behalf of the university.

Examples of such activities include study abroad, student club trips, conference presentations or attendance, field trips, internships, or trips to conduct research outside the United States. Personal travel that does not meet one of these four criteria is not subject to this policy.

II. Roles and Responsibilities

The International Operations Committee (IOC) provides general administrative oversight and support for the university’s international activities. The committee is convened by the Vice President for Global Strategy; it should have representation from administrative and academic units supporting global programs. The IOC determines the criteria for a country or region to be classified as an Elevated Risk for Rice-related travel and may approve or prohibit Rice-related travel to certain countries or regions where the risk cannot be mitigated.

The Office of Research Security and Export Controls (RSEC) is responsible for ensuring international travel complies with export control requirements and regulations/policy pertaining to research conducted, utilized, or supported internationally. RSEC will also ensure that international travelers to designated "countries of concern" receive the appropriate pre- and post-travel briefings on counterintelligence risks.

The Office of Information Security (ISO) has responsibility for data protection. The Chief Information Security Officer (CISO) is the GDPR Data Protection Officer and the HIPAA Security Officer.

The Office of Risk Management oversees a program designed to assist individuals traveling internationally with unexpected health, medical, or security assistance. These services are currently provided by International SOS. Generally, registration with International SOS is sufficient to meet this policy’s insurance requirements. In the event of larger-scale international incidents requiring coordination across multiple individuals or departments, the Office of Emergency Management will assume responsibility for leading and managing the response efforts.

III. Elaboration of Policy

The university maintains an international travel registration page at https://travelregistry.rice.edu. Registration is required for all international travel covered by Policy 852. The registration process is designed to identify travel to locations that are at an Elevated Risk, as this travel may have additional requirements, as described below.

Additionally, registration with Rice’s global safety and security provider is required for all international travel covered by Policy 852.

A. Travel to Elevated Risk Locations

Elevated Risk locations are countries, or regions within a country, where the university has determined there is an elevated risk due to security, health, corruption, sanctions/embargoes, and/or counterintelligence concerns. Generally, a location’s risk is based on:

travel advisories from the US State Department (a country/region within a country at Level 3 or 4 is presumed to be Elevated Risk);
location-specific warnings from the Centers for Disease Control and Prevention (CDC) or the World Health Organization (WHO);
corruption rankings by Transparency International;
US sanctions, embargoes, or restrictions that apply to the location or entity;
counterintelligence concerns regarding the location; or
exclusions from the Rice University-provided international travel insurance coverage or the global safety and security provider’s ability to respond in an emergency.

Rice University will not pay for or reimburse travel to a country with an elevated risk unless the appropriate procedures (as outlined below and in the chart) have been followed. Additionally, if the Elevated Risk cannot be appropriately mitigated, a location may be designated as “prohibited” for university-funded or reimbursed travel. If travel costs for Rice business purposes have been incurred before a university or government decision to prohibit travel, those costs will be eligible for reimbursement.

a. Elevated Risk – Health & Security

Rice University will designate a country or region as an Elevated Risk for Health & Security based on:

current warnings about travel to that location issued by the US State Department (a country/region of a country at Level 3 or 4 is deemed as Elevated Risk);
location-specific Travel Health Notices from the Centers for Disease Control and Prevention (CDC); or
location-specific Ongoing Emergencies and recent Disease Outbreaks from the World Health Organization (WHO).

Faculty and staff travel to a country or region at Elevated Risk for Health & Security does not require approval; however, the faculty or staff traveler is required to review information about the nature of the risk and sign an informed consent and release to travel to that country.

In the case of undergraduate and graduate students, travel to such countries is prohibited unless approved by the IOC. The IOC may approve student international travel to countries that are at Elevated Risk for Health & Security only when there are compelling circumstances or unique facts that justify the travel (for example, if a student is from that country).

b. Elevated Risk – Corruption

Rice University uses Transparency International’s annual Corruption Perceptions Index, which scores and ranks countries based on their perceived level of corruption. Countries with scores of 60 or below are designated as Elevated Risk for Corruption.

This policy does not prohibit travel to these countries, but travel must be registered, and faculty and staff will be provided with a copy of Rice Policy 107 on Anti-Bribery and Corruption in advance of travel. Additionally, faculty and staff who travel to these countries must provide an annual certification of compliance with Policy 107.

c. Elevated Risk – Embargoes & Sanctions

When a country or region is listed on a sanctions list maintained by the US Treasury Department’s Office of Foreign Assets Control (OFAC), that country or region will be designated as Elevated Risk due to Embargoes & Sanctions. This designation generally means that travel is prohibited under US law, but there may be circumstances that allow for certain travel or activities (such as if the individual is a citizen of that country, or for certain humanitarian missions).

Travel to countries designated as Elevated Risk due to Embargoes & Sanctions is prohibited for all Rice students, faculty, and staff unless it has been reviewed by the Office of Research Security and Export Controls (RSEC) and approved by the International Operations Committee. If the trip is approved, all travelers must receive a pre-trip briefing from RSEC.

d. Elevated Risk – Counterintelligence

The United States intelligence community, including federal funding agencies, has identified certain “countries of concern’’ based on activities that pose significant threats to national security, economic stability, and intellectual property.

Travel to such countries by faculty/staff, and in some cases, graduate and undergraduate students will require pre-and post-travel briefings by the Office of Research Security and Export Controls if the traveler is conducting, performing, or assisting faculty or staff with any federally funded research, the traveler must receive pre- and post-travel counterintelligence briefings even if traveling on non-federally funded projects.

e. Summary of International Travel Requirements

Type of Travel

Faculty/Staff

Graduate Students

Undergraduate Students

All travel

Must register on Rice’s Travel Registry.

For international travel to locations at Elevated Risk (Health & Security)

May be required to sign an informed consent and release.

Will receive a copy of most recent health risk information from the CDC and/or WHO if applicable.

Prohibited.

Allowed only for compelling circumstances, with approval from IOC.

Must sign an informed consent and release.

Will receive a copy of most recent health risk information from the CDC and/or WHO if applicable.

Prohibited.

Allowed only for compelling circumstances, with approval from IOC.

Student, and in some cases a parent/guardian, must sign an informed consent and release.

Will receive a copy of most recent health risk information from the CDC and/or WHO if applicable.

For international travel to locations at Elevated Risk (Corruption)

Will receive a copy of Rice Policy 107: Anti-Bribery and Corruption.

Must file an annual anti-bribery statement (as part of the annual disclosure process).

No action required.

For international travel to locations at Elevated Risk (Embargoes & Sanctions)

Prohibited.

Exceptions must receive approval from the IOC, in consultation with the Export Control Officer (who will be notified upon registration). If approved, the traveler must receive a pre-trip briefing.

Prohibited.

Exceptions must receive approval from the IOC, in consultation with the Export Control Officer (who will be notified upon registration). If approved, the traveler must receive a pre-trip briefing.

Prohibited.

Exceptions must receive approval from the IOC, in consultation with the Export Control Officer (who will be notified upon registration). If approved, the traveler must receive a pre-trip briefing.

For international travel to locations at Elevated Risk (Counterintelligence)

If the traveler conducts, performs, or assists with any federally funded research, the traveler must receive pre- and post-travel counterintelligence briefings even if traveling on non-federally funded projects.

If the traveler conducts, performs, or assists faculty or staff with any federally funded research, the traveler must receive pre- and post-travel counterintelligence briefings even if traveling on non-federally funded projects.

Failure to follow relevant international travel requirements may result in all expenses being deemed ineligible for reimbursement by Rice University and could result in additional disciplinary actions.

B. Fly America Act

If any portion of international travel will be funded by the US government, individuals must be aware of and adhere to the Fly America Act, a federal regulation that requires the use of US carriers for travel funded by federal grants and contracts. Currently, there are international treaties that allow for use of carriers from the European Union, Australia, Iceland, Japan, Norway, and Switzerland.

Travelers should confirm that their travel complies with all regulations and exceptions listed on the Fly America Act website.

C. Export Controls

Rice faculty, staff, and students should be aware of potential export restrictions when traveling to a foreign country. Export control regulations are very complex and often involve special rules that apply to certain items or technology (including laptops and other electronic devices).

Whether traveling for Rice or for personal reasons, any individuals who plan to travel with Rice-owned electronic devices or to share data or other potentially controlled items or information must contact the Office of Research Security and Export Controls for guidance.