- Due to a lack of appropriate legislation, the government has been searching for ways to exclude scientists from risky countries for 15 years. Robbert Dijkgraaf, the minister of Education, Culture and Science, has initiated a legislative process to enable a broad screening of researchers
- Safety measures for knowledge security at universities have been introduced over the past decades without sufficient legal justification
- Excluding researchers based on their nationality is not allowed. Nevertheless, some scientists in sensitive fields exclude researchers from Iran and China
- Until now, only researchers working in nuclear and missile technology have been scrutinized, but the list of sensitive fields will expand in 2025. Non-military technology will also be included
- Researchers from Iran are currently being excluded based on regulations originally intended for the export of goods
The Dutch government is working on new policies to better protect "sensitive knowledge" at universities. Legislation is being drafted to screen students and researchers from outside the EU before they are allowed to conduct research in so-called “sensitive fields”. However, this is quite a challenge because people cannot be screened or banned from universities without due cause. What can we learn from previous attempts to safeguard sensitive technology at universities?
In this article
2007-2008: 'Zealous professors'
In early 2007, officials at the Dutch Ministry of Foreign Affairs faced a difficult issue: they wanted to prevent Iran from obtaining crucial technology for their nuclear program through Dutch universities. At that time, there were significant international concerns about the possibility that Iran was working on a nuclear weapon, and as a result, the ministry would prefer to exclude students and researchers from Iran, particularly if they were involved in nuclear technology (source). There was, however, one problem: the Netherlands cannot simply refuse residence permits for foreign students or researchers. If someone poses a demonstrable threat to national security, the Dutch Immigration and Naturalization Service (IND) can deny entry into the country to that person. But categorically excluding Iranian researchers is not allowed.
The ministry's struggle is evident from a secret document from the US embassy in The Hague, in which Michael Gallagher, the American Charge d’Affaires at the U.S. Embassy in Hague, reports on a conversation with a senior Dutch Foreign Affairs official about how to deal with Iranian students who want to study in the Netherlands. In the report he stated:
The Dutch official] said the Dutch are facing increased numbers of Iranian students interested in studying at Dutch technical universities. According to Dutch visa legislation, rejected visa applicants are entitled to appeal their cases -- more often than not, "zealous" university professors take up these students' cases on behalf of the students. [The Dutch official] said that while it was very easy to reject a visa under the sanctions resolution for an Iranian student intending to study nuclear physics, it was "more of a stretch" to reject a student interested in biological/chemical studies or higher mathematics -- in these cases, Dutch judges are more inclined to overturn the visa rejection. She added that Dutch intelligence services simply lack the resources or manpower to track Iranian students and their studies once they arrive in the Netherlands.
The Dutch official indicated that refusing Iranian students who want to study nuclear physics here is feasible, but that it is difficult to prevent people from studying other subjects such as higher mathematics, chemistry or biology. Additionally, the American deputy ambassador noted that the official complains about zealous professors who help students appeal their rejected residency permits.
The report makes it clear that the ministry wants to intervene more forcefully than is legally allowed. However, the concerns at the ministry are so great that the then-Minister of Foreign Affairs, Maxime Verhagen, together with his colleague Ronald Plasterk, then-Minister of Education, Culture, and Science, chose to take preemptive action. Two months after the conversation between the Dutch civil servant and the American deputy ambassador, the two ministers wrote a joint letter to universities and colleges to warn them. They asked for ‘vigilance’ and ‘great restraint’ in admitting Iranian students (source).
The legal basis for this request had not yet been established, as secret documents from the American embassy from that time revealed (source). However, officials of the Ministry of Foreign Affairs hoped to find a legal basis for excluding students in the UN Security Council resolutions against Iran. Anticipating official regulations, the University of Twente (UT) and the Technical University of Eindhoven promptly decided to exclude all Iranian students (link to NRC article series from early 2008).
Six months later, the regulation was finalized and officially announced in the Staatscourant (source) and Iranian nationals were prohibited from accessing locations such as the nuclear reactor in Petten and the research reactor in Delft, and Iranian students and researchers were only granted access to sensitive studies after receiving clearance from the intelligence services (source).
2008-2012: Iranian researchers revolt
From the moment the ministry warned about Iranian students and researchers, Iranian scientists in the Netherlands noticed that something had changed. For example, physics professor Nasser Kalantar was suddenly denied access to the Petten nuclear reactor. Kalantar, who had been in the Netherlands for over twenty years and holds the Dutch nationality, called it discrimination. He was not the only one. Iranian researchers wrote letters to the newspaper, and the newly formed action group ‘Iranian Students’ handed a petition with 4,000 signatures to Minister Plasterk.
Nevertheless, the Iranians got no response. Professor Kalantar saw no other option and, along with two other Iranian-Dutch researchers, initiated a lawsuit against the Dutch State. They argued that the regulation violated the principle of equality as formulated in Article 1 of the Constitution, and restricted their right to education. Furthermore, they argued that the regulation was stigmatizing and unnecessarily hurtful.
What followed was series of legal battles. The Hague court ruled in favor of the Iranian researchers and struck down the sanctions regulation. According to the administrative court, there is "no objective and reasonable justification" for making distinctions based on nationality. Thus, the regulation is in violation of the prohibition of discrimination (source). The State appealed this verdict and the Iranian researchers won again (source). Only when the Supreme Court ruled in favor of the Iranian researchers – by then it was already 2012 – did the State accept the verdict (source).
Since the court invalidated the regulation, researchers and students could no longer be screened or excluded based on nationality. From that moment on, all scientists who wanted access to knowledge that could contribute to the development of a nuclear bomb or ballistic missile had to be individually screened.
The Iranian researchers requested the State to apologize "for denying them access to certain buildings and (parts of) master programs solely on the grounds of their Iranian nationality". But these apologies were not forthcoming, even after repeated requests from ombudsman Brenninkmeijer (source).
The State claimed to have acted in good faith and was under the impression that the distinction made was justified.
March 14, 2019: 'We are going to screen Iranian students'
The ruling of the Supreme Court in 2012 made clear that excluding students and researchers based on their nationality was not allowed. Therefore, it is at least confusing when, seven years later, Stef Blok – then Minister of Foreign Affairs – expressed his concerns about the Iranian ballistic missile program in the NOS news and announced: 'with immediate effect, we will screen students and scientists from Iran who are studying sensitive subjects and we will investigate for which other countries this should happen in the future’ (source).
Professor Nasser Kalantar – whose trust in the Dutch legal system had just been restored after the ruling of the Supreme Court – saw this on TV and was dumbfounded about this sudden reverse in policy: 'Either those people are stupid, or they have no memory or whatever. I really don't know what's going on, except: power politics, power play, power games...'
Ton van den Brandt, chairman of the Dutch Lawyers' Committee for Human Rights, expressed his concerns on behalf of the Committee in a letter to Minister Blok. He wrote: 'Recent media reports and your letter to the chairman of the Lower House suggest that distinctions will be made again on the basis of nationality in selecting and monitoring students and researchers for certain studies.' He reminds Blok of 'the judgments of the court, the appellate court, and the Supreme Court' and wondered "if history is repeating itself again.'
Blok responded reassuringly: 'The task force will carry out this assessment in a careful and non-discriminatory manner. That means that all students and researchers – regardless of their origin or nationality, and not exclusively students and researchers from Iran – (...) will be assessed for involvement in the Iranian ballistic missile program.' Kalantar, however, was not reassured. He said the ministry immediately replied: 'that was not what we meant'... What was not meant? This cannot have been said unconsciously!’
Besides this regulation, another part of history was repeating itself again too: just like eleven years earlier, the minister announced a measure without pre-existing legal basis. Blok himself acknowledged this in a letter to Parliament: the cabinet was still exploring the possibilities (source).
While some ministry officials were still searching for a legal basis for the minister's plans, other officials were already implementing the measures. The Ministry of Education, Culture and Science drew up a new list of high-risk subject groups and screened researchers. Researchers had to fill out lengthy questionnaires with personal data (source) and sent them to the ministry. However, due to the regulation not yet being finalised, it took Iranian researchers over nine months to find out whether they could stay or not.
'They really suffered mentally from that', said Ton van den Boogaard, Professor of Non-Linear Solid Mechanics at the University of Twente, whose research group is on the high-risk subject group list. Van den Boogaard: 'Three-quarters of a year of uncertainty about their own future, and at the same time working 120%, as is usual for us... that's not possible. It kept haunting them.'
Iranian researchers who were affected by the screenings did not dare to respond by name, for fear of being associated with espionage. But various sources described the personal dramas that resulted from the ministry's radio silence: contracts were not renewed due to the uncertain outcome, and people became overwrought with fear of losing their residency permits.
But that was not the only adverse consequence of the sluggish bureaucracy. Leaders of high-risk subject groups, such as Van den Boogaard, also concluded that it became an 'objective risk' for them to hire Iranians: if you have to wait for months before you find out whether an applicant has passed the screening, filling vacancies becomes very complicated. That is why various scientists at, among others, Delft University of Technology, the University of Twente, and Eindhoven University of Technology, consequently stated that they would no longer hire Iranians because of the bureaucratic obstacles.
The screening, introduced by Stef Blok, which was supposed to take place in a 'careful and non-discriminatory manner', in practice lead to the exclusion of researchers based on their nationality.
The knowledge embargo on Iran was introduced with great urgency in 2019, resulting in personal dramas for individual researchers. Was this justified because national security was at stake?
In the item of the NOS News on March 14, 2019, Minister Blok said that he was introducing the measure because the government is “increasingly concerned about the Iranian missile program”. But there does not seem to be a concrete threat to national security. Blok stated that he had no reason to believe that sensitive knowledge had already been leaked to Iran. Blok stated that: 'We have not been given any reason by our intelligence services to be concerned at the moment'.
The government's concerns about the Iranian missile program were not unrealistic, especially since US President Donald Trump had withdrawn from the nuclear agreement with Iran a year earlier. 'This created a new situation', said non-proliferation expert Frederik Voute. Iran hinted that they were also no longer bound by the agreement because of Trump's departure. Voute stated that: 'Maybe the government reacted to that. But maybe it was an offering to the US'.
That American pressure played a role seemed likely to Voute: 'The United States is a very important partner for the Netherlands. Especially under Mark Rutte, attempts have been made to tighten the bonds very closely and the Netherlands has always stayed a little in the shadow of the US. (...) I have rarely seen minister Stef Blok not following the same line as the Americans. So I can very well imagine that he said at the ministry, 'How strict we can be towards Iran? We need to keep a watchful eye. What do we have in our arsenal?' That announcement was a statement to the outside world. Something the minister could show off with.'
Was national security really at stake? Or was it mainly the pressure from America that prompted Blok to introduce the new regulation without proper consideration? And even then, was it lawful for some individual scientists to be put on hold for more than a year due to a hastily introduced regulation?
The answers to those questions remain unanswered to this day.
In 2007 and 2017, the Netherlands also imposed sanctions on North Korea following the nuclear tests carried out by the country in respectively 2006 and 2016, and the sanctions imposed on the country by the UN Security Council and EU.
Due to North Korea's nuclear program, the Netherlands also imposed a knowledge embargo in 2014, as can be read in an evaluation commissioned by the ministry of OCW (source). From that moment on, students and researchers who wanted to work on nuclear and missile technology at TU Delft must first be screened by the ministry. Only if these researchers receive an exemption from the ministry - similar to a Declaration of No Objection, which is preceded by the security screening by intelligence services, could they be admitted.
Fall 2019: Minister Blok finds a loophole
The measure announced by Stef Blok in 2019 – generally referred to as the 'Knowledge Embargo Iran' – appeared not only to violate the prohibition of discrimination, but is also peculiar for another reason. The plan was notably specific: the regulation was only directed at Iran, and specifically at the Iranian missile program. This was peculiar, because… aren't there other countries in the world that are interested in sensitive technology from the Netherlands? China, for example.
The short answer to that question is that the government had to make do with what it had. For example, Danny Pronk, an expert in security and modern weapons technology, said: 'Those measures regarding Iran and Iranian scientists could be implemented because there are all kinds of international regulations to limit the Iranian ballistic missile program. They provide the international legal basis to be able to take such measures. Those aren’t available for most major powers like China.'
The international regulation on which Blok based his new plans, is a European sanction regulation against Iran from 2012 (EU Sanctions Regulation Iran (2012/267, link). This sanction regulation prohibited 1) the export of technology that can be used in ballistic missiles to Iran and 2) the financial support of people or organizations in Iran involved in the construction of ballistic missiles.
The use of this sanction regulation was at least confusing, because the regulation is concerned with the export of goods and not the admission of persons. In a letter to the Dutch parliament, Minister Blok acknowledged that the use of the sanction regulation was not immediately obvious, but he argued that it could nevertheless be used to keep unwanted scientists out: 'Although this regulation was not drawn up with higher education in mind, it provides points of reference for closer scrutiny of students and researchers in specific studies and research groups who may be connected to the Iranian ballistic missile program.'
According to Blok the sanction regulation prohibits the provision of "technical assistance (…) with respect to this [missile] technology (...) for use in Iran." His reasoning was as follows: knowledge is transferred in education and applied research at universities. If a student from Iran acquires knowledge about missiles here, then returns to Iran, and uses his knowledge acquired in the Netherlands to benefit the ballistic missile program, then the Dutch university has provided technical assistance.
The ministry asks the European Commission if it agrees with this reasoning. After a few months of waiting, in the summer of 2019, Brussels responded affirmative: 'The Commission takes the view that the provision of higher education and the undertaking of applied research could fall under the notion of 'technical assistance' as provided by the sanctions regulations'. (190805 EC-opinion-technical-assistance-prohibition_.pdf) However, the Commission added that it is up to the national authorities to assess on a case-by-case basis whether there is actually technical assistance as described in the regulation.
From that moment on, the regulation, which was actually aimed at the export of goods, also applied to people. In theory, this meant that researchers who are involved in technology that could be applied to the construction of missiles were now screened for ties to Iran. In practice, the screenings brought so much bureaucracy and uncertainty that many 'high-risk research groups' prefered not to hire Iranian researchers alltogether.
No ballistic missiles have been built at Dutch universities. However, research is being done into technology that can be used in those missiles and other applications. The question is: when is that technology dangerous and when not?
According to Danny Pronk, an expert in security and modern weapon systems, that distinction is 'completely unclear. Except for a few small areas, you can never prove that something has a weapons technology application'. Even ballistic missiles themselves can be used for civilian purposes. Pronk said, 'we use them to put satellites into orbit around the earth that we use for the internet, communication traffic, photos of the earth's surface, to check if the dikes have broken somewhere'. It is, therefore, hardly predictable whether a component will ultimately be used in a weapon or not.
To prevent Dutch universities from inadvertently providing "technical assistance" to the Iranian ballistic missile program, the government uses the Missile Technology Control Regime (MTCR), an export list intended to limit the risks of the spread of technology that can be used in weapons of mass destruction; a list of no less than 81 pages (source). With this list in hand, the Ministry of Education, Culture and Science visited universities in 2019 to determine which research groups should be classified as risk groups.
The ministry then compiled its own list with sensitive research areas and associated research groups. The list of sensitive research areas is public (source), but the ministry does not disclose how many risk groups there are exactly. What we do know is that Delft University of Technology (TU Delft) has the most risk groups, mainly at the Faculty of Aerospace Engineering. Furthermore, the University of Twente has four, Eindhoven University of Technology has three, and the University of Groningen has two research groups in the list.
How risky are all those groups? Opinions differ: group leaders in Aerospace Engineering in many cases agree that the technology they are working on could - theoretically - be used in a nuclear weapon. Many other research group leaders are more critical, for example Professor Ton van den Boogaard, whose group at the University of Twente simulates what happens when you press a shape into a material. This knowledge is useful for mass production, for example in the car industry. Van den Boogaard thinks the link to rocket building is quite a stretch: 'my knowledge isn't really useful for that'.
Antonis Vakis, an expert in tribology at the University of Groningen, also has no idea why his group is on the list. Sure, in the past, he has researched a material that is on the MTCR list. But since then, his group has mainly been working on the 'ocean grazer', an instrument for offshore sustainable energy production. 'I don’t think you could make a case that our fundamental tribology research or the ocean grazer should be in a ballistic missile research exemption process'.
Since 2020, Vakis has been trying to get his group off the list, but without success: his letters to the Ministry of Education, Culture and Science remain unanswered.
Initially, the Ministry of Education, Culture, and Science aimed to prevent 'technical assistance' to Iran's ballistic missile program. However, in the fall of 2020, one and a half year after Minister Blok announced the Knowledge Embargo Iran, the Ministry of Foreign Affairs warned universities of yet another prohibition formulated in the 2012 European sanctions regulation. The ministry cautioned universities that they could no longer collaborate with universities and other organizations on the sanctions list:
It is forbidden to provide assets or economic resources (...) to or for the benefit of these entities. (...) The term 'economic resources' is broadly defined and, in practice, means: anything of value. This means that no goods, services, assets, etc., can be made available to the entity. Receiving goods, services, etc. from such an entity is also not allowed. Scientific collaboration and/or sharing of knowledge with a researcher affiliated with a sanctioned knowledge institution also falls under this category. If an Iranian university is on the European sanctions list, collaboration with that university and/or individuals affiliated with that university is almost certainly not allowed. This is unrelated to the relevant field of study.
From this point on, collaboration with students and researchers from these universities was considered indirect economic support for the missile program, even if the researchers in question had nothing to do with missile technology.
University boards complied with the letter and warned their employees that they could no longer collaborate with nine Iranian knowledge institutions. For some institutions on this list, such as the Research Centre for Explosion and Impact and the military Malek Ashtar University, it is quite obvious that collaboration is undesirable. But the list also included internationally renowned universities, such as Sharif University and Shahid Beheshti University. Dutch research groups, especially in high-tech fields, are generally eager to recruit students and researchers who have graduated from these universities.
The reason for the implementation of these additional measures remains unclear. Is the Netherlands genuinely concerned that universities are financially supporting the Iranian missile program by collaborating with individual researchers? Or does the ministry see the regulation mainly as an effective way to safeguard sensitive knowledge? But if the latter is the case, why then exclude all researchers, regardless of their field of study? Danny Pronk, when asked. Stated that: 'It sounds a bit like a discouragement policy. Maybe it is ultimately the intention of the government to discourage Iranian scientists from coming to the Netherlands. Or indeed to discourage Dutch scientific institutions from hiring Iranians'.
Whether it was the implicit intention of the government or not: after the ministry's warning, the University of Twente and Technical University Eindhoven decided to err on the side of caution and not only exclude researchers who were at that time affiliated with a sanctioned institution but also those who have studied there in the past. In September 2020, the UT warned its staff: Because of the sanctions against Iran, it has been decided by the Ministry of Foreign Affairs (BZ) that it is not permitted to appoint employees or guest employees at Dutch universities if they have studied at one of the following Iranian universities. (...) We are very sorry about this, but we have to follow the law and can't hire people that are connected to these universities anymore. We count on your understanding'.
Researchers who were trained at the Iranian Sharif University noticed the change of policy: if they applied for a research position, many of them were almost immediately rejected. Others were invited for an interview and were also offered the job, but were then rejected at the last minute because of the sanctions. A Delft doctoral candidate was told just before her PhD-defense that the collaboration is being terminated (read this article about Daryaa).
After criticism, the UT adjusted its policy in the summer of 2021. From that moment on, the university only excluded people who had active ties with sanctioned universities or who conducted research on military applications. In addition, researchers who had previously studied at a sanctioned university had to declare that they no longer maintain contact with people who are still affiliated with that university.
Since the war in Ukraine, European export sanctions against Russia and Belarus have also been in place. These sanctions have consequences for Russian and Belarusian researchers in the Netherlands as well.
Since the war in Ukraine, European export sanctions against Russia and Belarus have also been in place. These sanctions have consequences for Russian and Belarusian researchers in the Netherlands as well. Similar to the Knowledge Embargo Iran, the aim is to prevent Dutch institutions from providing "technical assistance" regarding technologies on the sanctions list. In the case of Russia, as stated on the website of the Knowledge Security Desk (source), it is 'legally prohibited to allow knowledge transfer' if it involves 'technology that can be used by the Russian defense and security sector, oil refining, aviation, and space industry'. It is up to universities to prevent this. The information from the Knowledge Security Desk does not make it clear what this means for Russian and Belarusian researchers working in the Netherlands in these areas.
Collaboration with Russian knowledge institutions is not formally prohibited, but the government does make an urgent call 'to freeze all institutional and formal collaborations'. However, the Knowledge Security Desk emphasizes that 'informal contacts with individual scientists, teachers, and students from Russia and Belarus can continue'. Russian and Belarusian researchers in the Netherlands can also continue to 'take courses, participate in research, publish, graduate, etc.' as long as the sanctions do not prevent it.
Furthermore, Russian and Belarusian researchers are only actively excluded if they apply for a position in the Netherlands from Russia or Belarus. This distinction has been made in order to not risk unwanted knowledge transfer to Russia and Belarus. Russian and Belarusian researchers who work outside of Russia and Belarus cannot be excluded from an application procedure based on their nationality.
Currently, there are two formal regulations in force that allow researchers to be excluded: the North Korea Sanctions Regulation 2017 and the EU-Iran Council Regulation 267/2012. Both regulations apply to researchers involved in nuclear and missile technology. It is peculiar, however, that researchers who apply for an exemption from TU Delft seem to go through a different procedure than researchers from other universities.
When researchers from TU Delft apply for an exemption, they are directly informed by the ministry whether or not they are granted an exemption. Researchers from other universities, though, do not receive an exemption. In their case, the ministry only sends a (non-binding) risk advice to the university. The university is then responsible for deciding whether or not to grant access.
Non-proliferation expert Frederik Voute finds the situation strange: 'I think that if you do a screening, the screening authority should make a decision about it. You shouldn't pass it down. I also think that the people at the university may not be qualified to make a decision about it. You can't really expect these people to do further research or actually decide whether or not to reject this person.'
A partial explanation is that the North-Korea Sanctions Regulation is a Dutch law, and the European sanctions regulation regarding Iran is not. Perhaps, says Voute, it is a loophole. 'They [at the ministry] don't have a law, it's a regulation. So, it's not legally binding.'
Still, it is strange that the government uses different regulations at different universities; that for TU Delft, the state is responsible for the choice of whether or not to exclude researchers in risk groups, and that at other universities, the Board of Directors is responsible for this decision.
2025: A country-neutral screening?
For years, the government has been searching for ways to gain control over the influx of researchers from risk countries, separate from existing sanction regulations. When Minister Blok announced the knowledge embargo on Iran in March 2019, he wrote that ”additional measures are being developed to further tighten supervision of students and researchers from other risk countries”. That, however, has proved to be difficult: four years later the additional measures are still pending.
But that doesn't mean the involved ministries have been idle in the meantime. Slowly but surely, the outlines of a new knowledge security policy are taking shape, as is described in Minister Robbert Dijkgraaf's letters to the House of Representatives of December 23, 2022 (source) and April 5, 2023 (source).
In short, the plan is to screen all individual researchers entering from outside the European Union who want access to risk groups. The main differences with the current regulations are:
- The screening will be 'country-neutral' and will not only focus on knowledge transfer to countries such as Iran or North-Korea. Dijkgraaf states that: 'The approach has a generic character and can be applied to any country outside the European Union where there is a threat to knowledge security, so that we are prepared for developments in the threat assessment'.
- Researchers and students will be screened before they apply for a residence permit. As a result, both the responsibility for screening and the decision will rest with the government. It seems like Dutch and other EU researchers will not have to go through the screening. It is not yet known what will happen to researchers and students from outside the EU who are already in the Netherlands when the regulation comes into force.
- The list of sensitive areas will be considerably longer. While previous regulations primarily focused on nuclear and missile technology, the new policy will cover a much wider range of 'knowledge and technology that could pose risks to national security.' The list will not only consist of military applications of technology; technology that is important for the “economic security” of the Netherlands will also be included. Specific fields within quantum technology, chip technology, artificial intelligence, and biotechnology could, among others, be included. It is not yet clear which areas will be identified as risk areas, as the list is still being developed. In March, the ministry sent a draft list to universities for consultation.
Minister Dijkgraaf hopes that the new law can come into effect on January 1, 2025. The introduction of such a screening has been under discussion since 2020, but its implementation has been delayed because the legal basis for the screening must be created first. The ministry is working on a new law, which makes it possible to screen researchers and students. If the screening shows that there are indications that the person in question poses a threat to national security, this may lead to the rejection of the application for a residence permit, as laid down in the law on treatment of aliens (Vreemdelingenwet 200). 'The screening', writes Dijkgraaf, 'must be regulated by law in a careful manner because this form of screening, regardless of the outcome, interferes negatively with the lives of citizens'.
Meanwhile, universities are not sitting still. Various professors in the current sensitive fields-list are already indicating that, in anticipation of the new legislation, they will not be hiring Chinese researchers for the time being.
For years, the government has been looking for ways to screen researchers from countries such as China and Russia. But as long as Minister Dijkgraaf's new screening framework has not been implemented, there is no legal basis to do so because there are no UN or EU sanctions applicable (source).
In the meantime, informal measures are being taken: the ministry warns against collaborating with Chinese universities on the so-called ASPI list. ASPI, or the Australian Strategy Policy Institute, is an Australian think tank that has conducted extensive research into the intertwining of Chinese universities with the Chinese defense. Using their China Defense Universities Tracker (source), universities can check whether a Chinese university has ties to the Chinese military.