Policy on Travel to High-Risk or Sanctioned Destinations
Policy Number: 613Safety and Security
The permanent link for this policy is: https://policies.northeastern.edu/policy613/
I. Purpose and Scope
Northeastern University is committed to the health, safety and security of all members of the university community. As a global institution, our community members undertake travel for many reasons such as teaching, research, academics, consulting, service, athletics, cocurricular activities, experiential learning and business purposes intended to advance the mission of the university.
This policy establishes requirements, standards, and expectations associated with university travel to high-risk and/or sanctioned destinations, as defined below, and outlines institutional support designed to reduce personal and institution risk and further the university’s global mission.
This policy applies to all high-risk university travel, as defined in this policy, by staff, administrators, students, and faculty to high-risk and/or sanctioned destinations, regardless of funding source.
This policy does not apply to personal travel (except to the extent that personal travel is a side trip, as defined below).
II. Definitions
For purposes of this policy,
A. University Travel
Means academic, business, extra- or co-curricular travel that is part of a university program or project, authorized by, at the request of, funded, coordinated, or administered by Northeastern University. Such travel may include but is not limited to teaching, study, research, consulting, conference attendance, co-op, service, administrative work, field studies, volunteer work, performances, athletic contests, and trips in connection with a university recognized student organization, academic or administrative unit, such as Advancement events, and Admissions outreach.
The commute to an employee’s primary work site , travel within the region of the employee’s primary work site (including travel to or between campus locations during the employee’s normal workday with no overnight stay or international border crossing), or personal side trips or personal business in which employees may engage in conjunction with university travel is not covered by this policy.
Travel within a student’s home campus (including travel to or from their home campus during a day in which the student has classes), or personal side trips in conjunction with university travel is not covered by this policy.
B. University Travelers or Travelers
Refers to Northeastern students, faculty and/or staff on university travel.
C. High-Risk Destinations
Refers to geographic locations that pose health, safety and security concerns. The university uses the following authorities’ risk ratings to determine which areas are considered high-risk:
1. Current U.S. Department of State Travel Advisory Level 3 (“Reconsider Travel”), Level 4 (“Do Not Travel”), or labeled with the caveat “Reconsider Travel”, or “Do Not Travel” within the narrative of the advisory; Government of Canada Travel Advice and Advisories level 3 (“Avoid non-essential travel”) and level 4 (“Avoid all travel”), or labeled with the similar caveats within the narrative of the advisory; or, if labeled with the similar caveats “Advise against all travel” and “Advise against all but essential travel” within the UK Foreign Commonwealth and Development Office (FCDO) advisory.
2. Centers for Disease Control and Prevention or Public Health Agency of Canada Travel Heath Notice Travel Notice Warning Level 3,
3. The university’s global travel support provider’s list of countries related as either HIGH (risk level 4) or EXTREME (risk level 5), and
4. Those destinations subject to comprehensive U.S., U.K., and/or Canadian sanctions.
The university reserves the right in its sole discretion to designate other locations as “high-risk.”
D. Approver
Refers to the appropriate university person or office to authorize travel to high-risk destinations.
• For staff – The staff member’s Vice President/Senior Vice President/Senior Vice Chancellor or their designee.
• For faculty – The faculty member’s dean or Dean’s designee;
• For students and faculty leading student programs – The director of the office overseeing the university-sponsored program (e.g., GEO, co-op, etc.)
E. Sanctioned Countries and Entities
1. For Individuals Based on the United States Who Are In University Travel
There are countries and entities subject to United States trade or economic restrictions. These lists are administered by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC), the U.S. Department of Commerce through its Bureau of Industry and Security Lists of Parties of Concern, and The International Traffic in Arms Regulations (ITAR) found on the U.S. Department of State Directorate of Defense Trade Controls website.
2. For Individuals Based in Canada Who Are In University Travel
In addition to the U.S. sanctions referenced in the preceding paragraph, there are countries and entities subject to Canadian trade or economic restrictions. These lists are administered through the Global Affairs Canada and the Department of Justice Canada. A list of applicable sanctions and restrictions can be found here: https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/current-actuelles.aspx?lang=eng.
3. For Individuals Based in the United Kingdom Who are In University Travel
In addition to the sanctions referenced in the preceding paragraph, there are countries and entities subject to United Kingdom trade or economic restrictions. These lists are administered through the HM Treasury’s Office for Financial Sanctions Implementation (OFSI) https://www.gov.uk/government/publications/the-uk-sanctions-list.
F. Side Trips
Personal travel connected to a university travel itinerary (i.e., either immediately before, during or immediately after university travel) that is paid for entirely by the personal funds of a faculty, staff administrator or student.
G. Global Safety and Security Assessment Committee (GSSAC)
The standing committee charged by senior leadership to assess travel-related risks; review and recommend travel policies and protocols; develop and initiate a coordinated emergency response strategy for various risk event categories; monitor changing travel conditions; oversee travel-tracking requirements and reporting; review travel insurance and support services; evaluate and decide on petitions for travel to “High Risk” destinations; and recommend travel safety training requirements.
III. Policy
A. General Policy Statement
1. In general, university travel to high-risk or sanctioned countries is not permitted. All university travel to high-risk and/or sanctioned destinations requires prior approval from the applicable approver a minimum of two weeks in advance of the travel and in accordance with this policy. In the case of travel to sanctioned country, the university may be required to procure a government license or authorization in advance of the planned travel.
2. The university recognizes that on rare occasions there might be compelling reasons to consider allowing a program to proceed if it involves travel to a high-risk or sanctioned location.
3. All employees regardless of physical location are, at a minimum, obligated to comply with U.S. Export Control regulations while on university travel.
4. All travelers proposing to undertake university travel to high-risk and/or sanctioned destinations must comply with the applicable provisions set forth in this policy. Exception Petitions can be accessed through the University Travel website.
5. Students failing to comply with the requirements of this policy may be prevented from traveling, may not receive credit for the course/program, and/or may be excluded from participating in other university global programs.
B. Authorization
1. The university requires all students, faculty and staff to obtain prior authorization to travel to high-risk or sanctioned destinations. Travel to sanctioned destinations requires the approval of both GSSAC and the Export Control Officer.
2. Authorization
a. Individual student travelers requesting to engage in university travel to a country appearing on the university’s High-Risk Country List must complete and submit an Individual Petition for High-Risk Student Travel and obtain written approval from the Global Safety & Security Assessment Committee (GSSAC), unless one of the following exceptions applies:
• The destination is the student’s home country;
• The program is an approved group* or cohort program (examples include the Dialogues of Civilization, Semester In, Three Seas, Alternative Spring Break, club/sport travel)
b. If one of the above exceptions applies, the student must complete an Acknowledgement of Risk for Students.
3. Authorization for Faculty and Staff Traveling to High-Risk or Sanctioned Destinations
a. All faculty and staff members conducting university travel must complete an Acknowledgment of Risk for Faculty and Staff Travel, regardless of destination.
b. If the trip itinerary includes a destination on the High-Risk Country List, the faculty and staff member must obtain advanced authorization to travel from their designated approver prior to submitting the Acknowledgment of Risk for Faculty and Staff Travel.
c. Faculty or Research Staff Using External Funds for University Travel must obtain approval from the funding agency a minimum of two weeks in advance of travel. University travel in connection with externally sponsored research and other activities must follow the guidelines on the NU Travel Checklist posted by the office of Northeastern University Research Enterprise Services (NU-RES). In addition, there may be other restrictions when using external funds.
4. University Rights
The university reserves the right to restrict, deny, or postpone any university travel program or activity if the risk of travel may pose an undue risk to the health, safety, or well-being of the traveler or others.
C. Registration of University Travel
As set forth in the Policy Requiring Registration of University Travel, all university travel must be registered in the university’s travel registry in advance of travel.
In addition, if a petition for travel to a high-risk international destination(s) is approved, travelers should enroll with the U.S. State Department at https://step.state.gov/step/ , Global Affairs Canada at: https://travel.gc.ca/travelling/registration or the equivalent citizen services from the traveler’s country of citizenship. Travelers should visit https://globalsafety.northeastern.edu/global-safety-support-network prior to departure.
Registration should be completed at least 48 hours in advance of travel. Travel booked through one of the university’s travel management vendors will automatically be added to the travel registry. Questions about registration may be directed to the contacts noted below.
D. Prerequisites for Trave lto U.S., U.K., or Canada Sanctioned Destinations & Interacting with Sanctioned Entities
All travelers wishing to travel to countries or engage in business with entities subject to the administration and enforcement of their respective campus’ (U.S., U.K. or Canadian) economic embargoes and trade sanctions must submit the proposed trip to GSSAC and provide the appropriate U.S., U.K. or Canadian Government approval documentation.
No travel to U.S., U.K. or Canadian sanctioned countries or business interaction with sanctioned entities may be conducted without both applicable U.S. Government, U.K. Government or Canadian Government and GSSAC approval.
For all proposed travel to or involving a sanctioned country or for assistance in determining whether transactions with specific institutions, entities or individuals are prohibited under U.S., U.K., or Canadian sanctions regulations, please contact the Export Control Officer at exportcontrol@northeastern.edu as early as possible in the planning process.
E. Export Controls
For the purposes of export control regulations, when traveling outside of the U.S., U.K., or Canada travelers are considered “exporters” of any tangible items and technical information they take with them and/or share abroad. Depending on the items being transported and the countries being visited, an export license may be required prior to departure. Electronic devices, such as laptops, tablets and cellphones, as well as the data on such devices and the underlying technology and encryption software, may be subject to export controls.
For additional information and guidance on export controls, please refer to the Policy on Export Controls and the Export Control Compliance Manual and/or contact the Export Control Officer at exportcontrol@northeastern.edu.
F. Insurance and Evacuation/Emergency Travel Assistance
Community members on university travel have access to the university’s urgent and emergency insurance policy. Information about health insurance and evacuation/emergency travel assistance can be found on the University Global Safety website.
Individuals who are not on university travel or who are on a side trip are not covered under the university’s urgent/emergency insurance policy.
All travelers undertaking university travel must possess personal health insurance that provides medical coverage for the duration of travel in the destination(s) of travel (including stopovers and travel prior to program start and after program completion).
G. Evacuation/Recall of Travelers
The university reserves the right to require that all university travelers evacuate a given location when, in its sole judgment and discretion, it determines that continued presence in that location may endanger the health, safety or well-being of university travelers or others.
University travelers who fail to heed a university instruction to interrupt or evacuate do so at their own risk, and are on notice that the university may not be able to respond with assistance. Such travelers may forfeit emergency travel insurance coverage, academic credit, tuition payments or expense reimbursement, and may be held responsible for additional expenses incurred by the university due to the individual’s refusal to follow policy. In addition, travelers may be subject to local administrative or law enforcement actions related to the specific local conditions and restrictions.
H. Connectivity
All university travelers must meet the university’s connectivity requirements, which set forth requirements designed to ensure that the university is able to contact travelers quickly when necessary. If applicable, travelers must review their destination’s laws specific to satellite phone use and consult with the NUPD International Safety Office prior to traveling.
When traveling to locations that the university has identified on the University Travel Page as presenting a heightened cybersecurity risk, faculty and staff travelers may not take university-issued electronic devices, and must avail themselves of the loaner device program administered by the Help Desk under the Policy on Computers and Mobile Devices for Travel to Destinations with Heightened Cybersecurity Risk.
I. Side Trips
1. As it pertains to faculty and staff, side trips while on university travel are discouraged.
2. As it pertains to students, side trips while on university travel are not permitted except as permitted in the Side Trip Guidance document found here:
3. The use of university resources for side trips is prohibited.
4. NU discourages side trips to high-risk or sanctioned areas as defined above. If travelers participate in side trips, the traveler must ensure that compliance with this policy and the requirements set forth by their office or program. Travelers on personal side trips must also comply with the requirements set forth on the Northeastern Global Safety and Support Side Trip Guidance website.
IV. Additional Information
Information regarding high-risk destinations can be found on the University Travel website. Trip-specific Assumption of Risk and General Release from Liability Forms may be found on the Global Experience Office and University Travel websites.
No traveler shall be required to travel to a location designated as high-risk as defined in this Policy.
Staff and faculty may also register personal travel in order to have access to travel alerts from our logistics provider and notifications from the university in the event of unforeseen events or emergencies.
V. Contact Information
For questions regarding the administration of this policy or the travel approval process please contact the Global Safety and Support Office at mytravelplans@northeastern.edu or 617-373-2121.
For questions regarding Export Controls and corresponding regulations please contact the Export Control Officer at exportcontrols@northeastern.edu.
For questions regarding and assistance with traveling with electronic devices, please contact the Office of Information Security at ois@northeastern.edu.
For questions regarding insurance abroad, please visit https://globalsafety.northeastern.edu/insurance/ or contact the Risk Services Office at risk@northeastern.edu.
Supersedes
Policy on International Travel
Keywords
Travel Registry; High Risk Travel; Export Control; Sanctions; Cybersecurity; Connectivity
Version History
Last Revision Date: September 8, 2023
Issued: February 4, 2021