EU sanctions programs
Sanction programs are distinct from export control of dual-use items or export control of military items. The sanction laws impact University’s activities as follows:
- Transfer of any item, funds or other economic resources to, or for the benefit of, a designated individual or organization is prohibited. Generally, sanction designation (most notably designation on EU Consolidated Financial Sanctions List) entails extensive prohibition to engage in economic activities with a designated party. Person, groups and entities on the EU Consolidated Financial Sanctions List can be viewed on . Prohibitions apply equally to persons and entities that are not themselves designated but are owned (50% or more) or controlled by designated parties, such as subsidiaries of designated parent companies, and to those acting on behalf of designated parties, such as employees of designated universities and research institutions.
- Export of items to or for use in a sanctioned or embargo country is prohibited without a prior authorization provided that items contemplated for export are included in the product coverage of relevant sanctions program. Depending on the country, the product coverage may be very extensive, prohibiting the export of most or even all items of potential relevance in Aalto. Please note that, in general, it will not be possible to receive export license for dual-use items to any recipient or end-user in a country subject to arms embargo. Many sanction programs also prohibit provisions of technical assistance to sanctioned items which, again, may include essential all items of relevance in Aalto. Depending on sanctions program, prohibition of technical assistance may also be more extensive under sanctions program than under EU Dual-Use Regulation as, for example, de-control notes of in the public domain and basic scientific information may not be applicable. For visualization and other information on the sanctions adopted by the EU against various countries please revert to and .
- Some sanction programs prohibit also provision of other services in relation to a sanctioned item. In such sanction programs, prohibition of other services is an additional restriction to prohibition of technical assistance. Typically, the notion of other services is comprehensive so it is intended to catch most activities related to goods falling under product coverage of sanctions.
- Sanction programs typically entail express provision that prohibits anyone from participating, knowingly and intentionally, in activities the object or effect of which is to circumvent prohibitions of the respective sanction program.
University and members of Aalto community need to identify and comply with any sanction program that may be relevant to the activity undertaken or contemplated to be undertaken at University. This obligation to identify and be aware of restrictions imposed in EU sanction programs is particularly important for such research activities where collaboration partner is affiliated with university or other institution in a sanctioned or embargo country. Conduct of research collaboration with such partner without due regard to the restrictions imposed in the relevant sanction program is not responsible behavior.