End-use and end-user control
While vast majority of end-uses and end-users relevant to activities carried out in University are legitimate, export control and sanctions compliance requires exporters to understand the end-use and end-users of items they export to ensure that breach of law does not occur. Thus, it is the responsibility of anyone who exports controlled items or provides technical assistance in University to be vigilant for end-users whose intent is to procure or divert items to prohibited purposes (such as strengthening of undesired military capabilities) or prohibited destinations (such as countries under sanctions or embargo);
- End-users whose intent is to procure or divert items to prohibited purposes (such as strengthening of undesired military capabilities) or prohibited destinations (such as countries under sanctions or embargo);
- End-users that are designated on relevant sanctions or restricted party lists and
- End-uses that are illegal such as proliferation of WMDs or their means of delivery, destabilizing accumulation of conventional weapons, internal repression or violations of human rights and international humanitarian law.
Particular attention needs to be paid to collaborators who are new to University and for which knowledge is incomplete and inconsistent.
Being vigilant for signs of suspicious enquiries or collaborations is an integral part of controls for end-use and end-user, as well as of controls for catch-all and cyber-surveillance situations. Non-exhaustive list of behavior that may be of concern can be found in the list of red flags.
If one or more red flags listed in these internet pages apply to your research activity there is a strong indication for further scrutiny.
University conducts investigations under prospective partner screening (PPS) and know your partner (KYP) processes on its current and prospective partners in accordance with practices in force from time to time. However, please note that partners involved in non-institutional or informal collaboration carried out by a member of Aalto community will typically not be subject to such investigations by University as University will not be in contractual relationship with such partners. Therefore, heightened vigilance for end-use and end-user control is needed from any member of Aalto community who engages in non-institutional or informal collaboration. Please note that breach of export control or sanction laws does not depend on the type of collaboration and also non-institutional or informal collaboration may cause breach.
Any member of Aalto community is obliged to bring to University’s attention all relevant information available to the said member of Aalto community about the end-use or end-user concerns, if any, pertaining to actual or prospective collaborator with whom the said member of Aalto community conducts or contemplates to conduct collaboration. Please contact the Aalto University support organization for export control and sanctions mattersfor information on notifications of concerns and breaches of export control and sanction laws.