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Responsible Internationalisation - export control and sanctions

Open exchange of ideas is vital for innovative advancements in science, technology, art and business. In doing that we need to comply with export control and sanctions regulations. This page contains relevant information for all Aaltonians when cooperating internationally.
Responsible internationalisation enables free exhange of ideas for reaching breakthroughs in science, technology, art and business.
Responsible internationalisation enables free exchange of ideas for reaching breakthroughs in science, technology, art, and business.

Members of the Aalto community are encouraged to engage in collaboration with universities and organisations worldwide. However, it is crucial to remain vigilant and comply with export control and sanctions regulations to ensure that our research is not misused by third parties for objectives that contradict our university’s mission or code of conduct. Export control and sanctions laws are in place not to censor research, but to prevent its misuse. The effect of export control and sanction laws varies for individuals based on their fields of research and roles within it. 

What every researcher needs to know

  1. Think ahead – who are your contemplated partners and what are you researching (see Risk matrix below for export control and sanctions for more details)? Some partners and research domains are inherently riskier than others. The higher your risk exposure, the more cautious you need to be.
  2. Know your research activity (see chart on the life span of a research activity).
  3. What is the Technology Readiness Level (TRL) relevant for your research activity (initial, expected and achieved)?
  4. Is your research relevant for controlled performance capabilities or features and if so, does your research benefit from any of the de-controls?
  5. Consult with Aalto’s support organization for advice.
  6. Report any concerns you encounter to your manager, Compliance Officer or via Ethical channel | Aalto University

Application of export control and sanctions laws on Aalto activities

Photo by Mikko Raskinen

Export control and sanctions - scope and definitions

Export control and sanctions legislation that University and members of the Aalto community are obliged to comply with depends on the subject matter.

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Technology readiness levels

Technology Readiness Level (TRL)

Technology Readiness Level (TRL) is a non-discipline specific measurement system with indicators of the maturity level of particular technologies.

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. The aim of export controls is to prevent the misuse of sensitive knowledge and expertise and it is therefore important to understand what is being exported.

Controlled exports

The export of a controlled item from Finland may require an export license.

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Ensure correct interpretation of law before relying on de-controls.

Exemptions from export license requirements (De-controls)

Certain exemptions (de-controls) apply to various activities at the University, removing the need for an export license.

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What is considered technical assistance covers a wide range of activities.

Provision of technical assistance under EU Dual-Use Regulation

The provision of technical assistance related to dual-use items is controlled under the EU Dual-Use Regulation. Required licenses can depend on whether the dual-use items are presumed to be intended for military end-uses or weapons of mass destruction.

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Export control regulation on catch-all and cyber-surveillance situations is more stringent than regulation applicable on dual-use items in general.

Catch-all control and cyber-surveillance items

Regulation on on catch-all and cyber-surveillance situations is more stringent than regulation applicable on dual-use items in general.

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Awareness of the export control and sanctions reguation is important when dealing with end-users or partners, particularly new ones.

End-use and end-user control

As part of adhering to export control and sanctions regulation, vigilance is always important when collaborating with partners, especially for unfamiliar entities or in new collaborations.

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Sanction programs are distinct from export control of dual-use items or export control of military items.

EU sanctions programs

Sanction laws prohibit transferring particular items or resources to certain individuals or organizations, including technical assistance to sanctioned items.

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A man operating a machine

US export control and sanction legislation

Aalto community members managing US regulated items must respect any export restrictions and seek advice if needed.

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Crystal Flowers in Halls of Mirrors -näyttelyn kuva, kuvaaja Mikko Raskinen

Restrictive measures on account of the Russian aggression on Ukraine

On this internal webpage you can find a short summary of the restrictive measures against Russia.

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Item classification seeks to achieve understanding on whether an item within the scope af any relevant control list

Classification and export screening procedures

The classification and export screening procedures serve as a framework to identify and categorize research and innovations, while ensuring compliance with import and export control regulations.

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Decision tree export cdontrol and sanctions

Export control and sanctions - tools and templates for assessment and licensing

Here are some tools and templates for enabling you to assess the situation and a list of people to contact when you need help.

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Publishing an article or giving a presentation may constitute an export of dual-use item

Publishing (including open science) and export controls

In general, publication of an article or giving of a presentation is not problematic from the export control law point of view.

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Photo by Aleksi Poutanen

Control lists

On this page you will find the latest versions of the EU List of Dual-Use Items, Finland's national control list and the Common Military List of the EU.

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