Reporting requirement for embargoed countries
The Rectorate of the University of Münster has decided to introduce a general requirement that any cooperation with embargoed states must be reported. This will take effect from 1 January 2024. Accordingly, the Finance and Controlling Department is to be informed when academics want to enter into a cooperation with any of more than 30 countries on which the EU has imposed an embargo for foreign or security policy reasons – for example Yemen, Myanmar or North Korea.
The resolution states that the embargoes serve “in particular to prevent the infringement of human rights and the spread of military goods in the embargoed states concerned”. The embargoes regulate restrictions, authorisation requirements and prohibitions as regards collaboration with sanctioned persons and institutions as well as the exchange of certain goods and the knowledge associated with them. Depending on the objective, the measures stipulated in the embargoes vary greatly – from arms embargoes and other import and export restrictions to a ban on financial assistance.
The aim of the reporting requirement is to provide support for academics in the necessary assessments and to give them advice on the implementation of, and compliance with, embargo measures, as well as on submitting to the Federal Office of Economic Affairs and Export Control the relevant applications for approval (if required). The reporting requirement for University staff covers cooperation agreements such as contracts with academics, institutions or companies based in the embargoed state; supplying goods to an embargoed state; PhD projects; stays in Münster undertaken by (visiting) academics from an embargoed state; stays undertaken in an embargoed state by University staff; talks and lectures; joint publications; and research projects with partners from industry. In such cases, academics are required to report any relevant issues to their Faculty Office, which will in turn inform the University administration.
However, not all academics are affected equally by the new regulations. While there is a reporting requirement in the life and natural sciences for each of the embargoed states mentioned, the humanities and social sciences are only required to provide notification in the case of Russia, Iran and Iraq – for the last of these, solely in connection with cultural goods. “This reporting requirement means that we can ensure that each and every piece of research undertaken at the University of Münster complies with German and European law,” says Ingo Schlonzak, the Head of Finance and Controlling. “Also, in this way, we can provide advice to academics which is precisely relevant to each individual case and, in doing so, also help them to carry out their research in the uncertain circumstances resulting from embargoes.”
As processing and assessment procedures still have to be established, the Finance Department points out that a sufficient time buffer should be taken into account when planning any cooperation or activities with embargoed states. Just how fast the relevant regulations can change is shown by the war of aggression against Ukraine, which turned Russia into an embargoed state within a very short space of time. For this reason, the regulations are being continually revised and adapted.
Author: André Bednarz
This article was first published in the University newspaper ‘wissen|leben’, No. 8, 13 December 2023