POTENTIAL FOR FORFEITURE OF ELECTRONICS IN CERTAIN MIDDLE EASTERN COUNTRIES
As you may be aware the Trump administration levied a restriction on electronics to be carried on board from certain airports in the following cities and countries in the Middle East:
Kuwait City, Kuwait
Riyadh and Jeddah, Saudi Arabia;
Dubai, United Arab Emirates
Travelers may also experience issues in the above listed airports when in transit, if required to clear customs in that country.
FD Associates has learned of a situation that occurred recently where in transit U.S. Travelers at the Abu Dhabi airport clearing U.A.E. Customs were required to forfeit all electronics when travelling to the United States. This includes laptops, ipads, tablets, cell phones, and batteries from e-cigarettes. It is not clear if this action of forfeiture was in connection with the U.S. Restriction on electronic carry on items on flights bound to the United States from the above countries.
As exporters might travel with electronics that store ITAR or EAR controlled data on them, although both sets of export regulations provide exemptions for travelers and their personal use of such data, there is no exemption for the forfeiture of your electronic device to a foreign government. The forfeiture is an export.
Should you be required to forfeit your electronics with export controlled or government data on your devices, you have an obligation to notify DOS, BIS and/or DOD of any controlled or government owned data or hardware forfeited. It is our understanding that DOD has recommended persons subject to forfeiture of government owned or issued electronics destroy the electronics before forfeiting.
Travel routes should be carefully planned for future travel and arrangements to store your electronic devices with shipped luggage is recommended if your travel includes any of these destinations assuming that the forfeiture only applies to carryon items and not checked luggage as well. We recommend all travelers with U.S. Government issued electronics verify with their customer the protocol to be used if encountering such a situation.