Responsible internationalisation – Export control and sanctions compliance at Aalto University

Aalto University aims for responsible internationalisation. Aalto complies with international export control and sanction regulations, which limit or prohibit exporting of certain items or technology. These regulations aim at the non-proliferation of research outcomes that can be used as weapons of mass destruction (WMDs), to enhance cyber security and counter act any violations of human rights. Aalto aims to promote responsible export of Finnish technology. Export control and sanctions are not a ban on research, but one must be more careful than usual. Technology being under export control means that the technology can have unwanted uses in wrong hands: military use in arms embargo countries, WMD, or human rights violations.
A laptop and papers on a table.
Photo: Aalto University / Anni Hanen-Kajander

An important aspect of responsible internationalisation is to comply with export control regulations and sanctions. The relevant regulations are Finnish National, EU and US export regulations (EAR and ITAR) and EU and US sanctions. 

What's new: Sanctions on Russia and Belarus regarding the Ukraine war, please see here

Export control Sanctions
Export controls restrict the transfer of high technology to foreign destinations with the aim of preventing conflict, human rights abuses, weapons of mass destruction and terrorism or cyber security. Sanctions are legal measures that restrict or interrupt, for example, economic or commercial activities with targeted regimes or groups.
Technology Dual-use item
Specific information necessary for the development, production or use of goods. This information takes the form of technical data or technical assistance Items, including software and technology, which can be used for both civil and military purposes and includes items which can be used for the design, development, production or use of nuclear, chemical or biological weapons or their means of delivery, including all items which can be used for both non-explosive uses and assisting in any way in the manufacture of nuclear weapons or other nuclear explosive devices


Export controls apply to transmission, sharing or transfer of regulated items -- such as research outcomes, knowledge created, or courses offered with content under regulations -- to foreign countries, persons or entities. The controls also apply to information and software. Violations of these regulations may lead to criminal or monetary penalties or to reputation problems. These regulations are based on international control arrangements put in place to curtail terrorism and to support human rights. The importance of export control and dual use has grown and the national and international regulations have been updated recently.  The regulatoins apply to all Aalto activities, in EU Grants they are mainly referred under dual-use regulations. 

The regulation applies to certain products or items, certain countries, certain end users, or certain end usages. It also applies to knowledge in general, for example publications and teaching. Typically, export controls and sanctions focus on:

  • Items and their components that have been designed for military use (weapons).
  • Dual-use items, i.e. non-military items that can be modified to be used for military purposes.
  • items related to cyber security or espionage
  • Sanctions imposed on countries and their citizens and other entities.


How export control may affect you

Export control applies to several university activities. In the following we will look in more detail into some of them.

More information:

The Ministry of Foreign Affairs serves as the national competent authority for export control in Finland.

European Union guidance:

USA legislation to be considered

  • Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR)



Summary: what is meant by export or transfer in EU and US legislations

Export outside EU

applies to all products and services in EU expert control list

exporting physical products

virtual transfer of products/services; email; information transfer, uploading to cloud services with access from abroad 

export via memory stick or in computer drives

oral transfer of information to outside EU audience

Export, re-export outside Finland 

apllies to EU defence items, some sensitive EU dual use items (see EU lists above) US defence itesm in export control lists ITAR) and US export control list dual use items (EAR)

applies to any export or transfer outside Finland ( physical, trasfer vial emails, memory sticks description of items under restrictions in phone to person outside Finland etc.) 


Transfer in Finland to people with non Finnish nationalities, export or re-export

applies to defense items in US export control list (ITAR) and US export control list dual use items (EAR)

for example a Finn provides access to technical information under EAR regulations to non-Finn (deemed export) 

the regulations are more strict for ITAR than to items in EAR, for example in EAR the nationality is defined through last nationality/permanent residency whereas in ITAR the nationality is defined through all named nationalities and permanent residencies of a person. 

Technical support

applies to EU regulations on dual use items 

any technical support, service guidelines or knowledge and skills transfer of items under dual use regulations outside EU or to a non EU nationals in  EU



Do not hesitate to ask for help, please find below the first contact points by schools:

School of Chemical Engineering

School of Electrical Engineering

School of Engineering

Timo Linnoinen

Senior Legal Counsel

School of Science

Other, Legal and Research Services

Without responsibility in internationalization our Purpose, Values and Code of Conduct are at risk 

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Code of Conduct - Values into practice

The Aalto University Code of Conduct is one way of putting our values and way of working — the foundation of our community culture — into practice

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How to make an ethics self-assessment in research projects - Aalto support and guidelines

Here we provide support, links and tips on how to work your way through the EU Grants: How to complete your ethics self-assessment – document

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