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US export control and sanction legislation

Aalto community members managing US controlled items must respect any export restrictions and seek advice if needed. The University's activities fall under US export control regulations in cases where items containing controlled US components are mixed with our products, software or technology, or if our items are directly produced from certain controlled US software or technology.
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Anyone handling controlled US items must be mindful at all times of any US export license limitations and restrictions, and seek advice when necessary.

Members of Aalto community handling controlled US items must be mindful at all times of any US export license limitations and restrictions, and seek advice when necessary. Export control laws of the United States become applicable to University in the following situations:

  • University uses controlled US origin items;
  • Items originating from University incorporate controlled US origin items, or they are bundled with controlled US origin software1;
  • Software originating from University is commingled with controlled US origin software2;
  • Technology originating from University is commingled with controlled US origin technology3;
  • Items originating from University are direct products of specified US origin software or technology (foreign-direct product rule);
  • Items originating from University are direct products of a plant or major component of a plant that itself is a direct product of specified US origin software or technology (foreign-direct product rule).

Although there are exceptions, a US license may be required to transfer items referred to above to anyone in University who is a foreign or dual national, or to anyone outside University (whether in Finland or abroad).  

1 Depending on the threshold value of US origin items.
2 Depending on the threshold value of US origin items.
3 Depending on the threshold value of US origin items.

Generally, all publicly available information and software in publicly available repositories under open-source software (OSS) license terms are not controlled items under US laws, even if originating from the United States. However, when utilizing computer software not under any OSS license terms please make sure to check the applicable license terms as there may be contractual restrictions imposed by the vendor on the use of such computer software. 

US sanctions extend in some cases to making available any US origin or US controlled items (including non-controlled items) to designated entities (or their employees) in Finland or abroad. Persons or entities designated on the US Entity List are subject to individual licensing requirements and policies supplemental to those found elsewhere in the US regulation. These licensing requirements will apply for export, re-export and/or transfer (in-country) of US origin items. US sanction designations can be searched in CSL Search (trade.gov). Prohibitions normally apply equally to persons and entities that are not themselves designated but are owned (50% or more) by designated parties and their representatives.

Support organization for export control and sanctions matters at Aalto University

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