Controls on the export of dual-use items are administered by my Department in accordance with Regulation (EU) 2021/821 of the European Parliament and of the Council setting up a Union regime for the control of exports, brokering, technical assistance, transit and transfer of dual-use items. Annex I of Regulation (EU) 2021/821 lists all of the dual use items, software and technology that are controlled, however alumina is not listed and is therefore not a controlled item.
My Department also has responsibility - policy, administration and enforcement - for certain elements of trade sanctions, primarily dual use and military goods.
"Aughinish" is not subject to sanctions by the EU, nor has it been proposed by the EU for sanctions. In addition, alumina is not a sanctioned good therefore its export to other countries, including Russia, or to Russian linked entities, is not restricted.