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), the enhancement of cyber security and the counteraction of 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

Export control and sanctions

An important aspect of responsible internationalisation is to comply with export control regulations and sanctions. The relevant regulations are the 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 threats. 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 regulations apply to all Aalto activities. In EU funding the emphasis is on compliance with dual-use regulations. 

The regulations apply to certain products or items, certain countries, certain end users, or certain end usages. They also apply 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 for Foreign Affairs serves as the national competent authority for export control in Finland.

European Union guidance: 

US legislation to consider 

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


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

Export outside EU

applies to all products and services in the EU export control list

exporting of physical products

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

export on memory sticks or computer drives

oral transfer of information to audiences outside the EU 

Export, re-export outside Finland 

applies to the EU defence items and some sensitive dual-use items (see EU lists above) and the US defence items in their export control lists (ITAR) and the US export control list of dual-use items (EAR)

applies to any export or transfer outside Finland ( -physical, transfer vial email, memory sticks description of restricted items on phone to persons outside Finland etc.) 

Transfer in Finland to people who are not Finnish citizens, export or re-export

applies to defence items in US export control list (ITAR) and US export control list dual use items (EAR) cases where, for example, a Finnish citizen provides access to technical information covered by the EAR to a person who is not a Finnish citizen (this counts as export)  

the regulations are stricter for ITAR items than for EAR items, for example, for the purposes of EAR citizenships is defined as person’s latest citizenship or permanent residency, whereas for the purposes of in ITAR, citizenship covers all citizenships and  permanent residencies of a person. 

Technical support

applies to EU regulations on dual-use items transfer of any technical support, service guidelines or knowledge and skills related to items covered by dual-use regulations outside the EU or to a non-EU nationals in the EU

Do not hesitate to ask for help! Please find below the first contact points in each school:

School of Chemical Engineering

School of Electrical Engineering

School of Engineering

School of Science

Other, Legal and Research Services

Kristiina Kemetter

Ella Bingham

Ella Bingham

Head of Research Services
U901 Research Services
Annukka Jyrämä

Annukka Jyrämä

U901 Research Services

Training on Export Control

This training is for Aalto users only and requires identification. The course and its materials can be found also from Workday learning.

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Export control fundamentals (external link)

Aalto University is committed to - and expects its staff and students to be committed to - carry out all activities in compliance with the export control and sanctions regulations. It is the responsibility of each community member to pay attention to and abide by the restrictions (e.g export controls and economic sanctions) applicable to their own field of science or work.

ONLY INTERNAL FOR AALTO; requires identification

Photo by Mari Kaarni

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

Kaksi henkilöä kampuksella.

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

Aalto University

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

For personnel – highlights and support for your work
This service is provided by:

Legal Services

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