Commerce Prohibition Policy for OFAC Sanctioned Countries
Status: Nov 2016
The purpose of this policy is to provide guidelines for administering any requested commerce from individuals or
groups based in sanctioned countries as designated by the Office of Foreign Assets Control (OFAC), and as further
recommended by the Executive Committee in August 2016.
A. The Association for Iron & Steel Technology (AIST) will halt all business transactions with the following
Crimea Region of Ukraine
Potential Members/Customers – If an individual is from one of the countries with comprehensive sanctions, we
will decline their membership, purchase or conference registration, citing the EC’s decision to prohibit business
with these sanctioned countries.
Existing Members – Current memberships will be allowed to expire at the end of the calendar year; however,
these individuals will not be permitted to make purchases or register for conferences during this time. Their
memberships will not be eligible for renewal.
Material Advantage Student Members – The Material Advantage partners will be informed of AIST’s policy to
effect a holistic change. If the other Material Advantage partners continue to allow student members from OFAC
countries, AIST will remove those members from the AIST database each week during list upload.
B. AIST will investigate prior to allowing business transactions with the following “Limited/Targeted” Countries.
Central African Republic
Cote d'Ivoire (Ivory Coast)
Democratic Republic of the Congo
Potential or Current Members/Customers – If an individual is from one of the countries with Limited/Targeted
Sanctions, we will search the Specialty Designated Nationals and Blocked Persons (SDN) List for the name of
the applicant, or for persons wishing to purchase items or attend conferences.
If the individual is on the list, we will decline their request, citing the ban by OFAC.
Specialty Designated Nationals and Blocked Persons (SDN) List – OFAC maintains various sanctions lists that
may have different prohibitions associated with them. A number of the named individuals and entities are known
to move from country to country and may end up in locations where they would be least expected.
The names are incorporated into OFAC’s list of Specially Designated Nationals and Blocked Persons which
includes more than 6,000 names of companies and individuals who are connected with the sanctions targets.
This is a searchable list on the U.S. Department of the Treasury website, where we can screen individuals prior
to doing business with them.
U.S. citizens are prohibited from dealing with SDNs wherever they are located and all SDN assets are blocked.
C. The OFAC and Limited/Targeted Sanctions lists will be reviewed annually by AIST Member Services Department
prior to invoicing each August.