Export control and sanctions - scope and definitions
Compliance with export control and sanction laws applies to all members of the Aalto community. Export control and sanctions legislation that University and members of the Aalto community are obliged to comply with depends on the subject matter. In most cases, the relevant legislation is national or issued by the institutions of the EU. When applicable, also compliance with export controls and sanctions issued by the United States is necessary.
Members of the Aalto community
All members of the Aalto community are under the obligation to comply with the export control and sanction laws. Members of the Aalto community entail any University employee irrespective of employee group or organizational status (including academic staff and support staff), any professor emeritus/emerita (if agreement on a professor emeritus/emerita position is valid), any student enrolled in any program at University (including undergraduate and postgraduate studies) and any visiting researcher and student (whenever such visiting person is affiliated with University on account of the visit). Nationality or place of origin of a member of the Aalto community are irrelevant for the above-mentioned obligation to comply.
Legislation
- Export control of dual-use items meaning legal measures intended to contribute to international peace and security, and to prevent proliferation of weapons of mass destruction (WMD) and their delivery systems, strengthening of undesired military capabilities or commissioning of internal repression and other violations of human rights;
- Export control of military items (items specially designed or modified for military use) meaning legal measures intended to reach similar policy objectives as the export control of dual-use items;
- Sanctions (also known as restrictive measures) meaning legal measures intended to bring about a change in bad or harmful policies or activities by targeting countries, organisations and individuals responsible for such policies or activities.
Definitions for key terms
| Annex I | Annex I, as amended from time to time, of the EU Dual-Use Regulation (Regulation (EU) 2021/821) |
| Catch-all control | Control imposed on actual or intended use of an item, in its entirety or in part, (i) in connection with development, handling, operation, maintenance, storage, detection, identification or dissemination of weapons of mass destruction (WMD) (whether chemical, biological or nuclear) or nuclear explosive devices, (ii) for development, production, maintenance or storage of WMD鈥檚 delivery systems (such as ballistic missiles, cruise missiles or drones), (iii) for a military end-use in a country subject to arms-embargo (such as development, maintenance or production of military items), or (iv) for use as parts or components of military items exported from EU member state without or in violation of authorization. |
| Controlled items | Any dual-use items (whether listed or non-listed), military items or items included in the product coverage of any sanction program relevant to activity undertaken at the University |
| Cyber-surveillance items | Dual-use items specially designed to enable the covert surveillance of natural persons by monitoring, extracting, collecting or analysing data from information and telecommunication systems. |
| Dual-use items | Items which can be used for both civilian and military purposes. Dual-use items controlled by the EU are listed in Annex I, or they are non-listed. Non-listed dual-use items relate to catch-all control and cyber-surveillance items. Dual-use items controlled by Finland are listed in the national control list. Please see the latest version of the Annex I and the national control list Control lists | Aalto University |
| Military items | Items specially designed or modified for military use. Please see the latest version of the list of military items here Control lists | Aalto University |
| National control list | List of dual-use items controlled by Finland. The national control list is effective as of 15 September 2024 and it includes items in the following disciplines: quantum technologies, manufacturing technologies for advanced semiconductors and material technologies. |
| Technology | Specific information necessary for the development, production or use of goods (i.e. tangible items). This information may take the form of technical assistance1 (such as instructions, skills, training, working knowledge, consulting services and may involve transfer of technical data) or technical data (blueprints, plans, diagrams, models, formulae, tables, engineering designs and specifications, manuals and instructions written on or recorded on other media or devices such as read-only memories). |
| 1 Please note that the term technical assistance has two meanings in the EU Dual-Use Regulation. The definition given here relates to Annex I of the Regulation which specifies what technology (i.e., what specific technical information related to listed dual-use item) is considered itself a listed dual-use item under the Regulation and therefore subject to an export license requirement for transmission to recipients outside the EU. Provision of technical assistance under EU Dual-Use Regulation addresses a different use of the term "technical assistance鈥 that primarily relates to the provision of technical services and other technical support, and that does not necessarily involve the disclosure or transmission of information outside the EU. |