Commerce Prohibition Policy for OFAC Sanctioned Countries
Status: July 2019
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 (EC) in July 2019.
The Association for Iron & Steel Technology (AIST) will halt all business transactions with the following “Comprehensive” Countries:
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.
AIST will investigate prior to allowing business transactions with the following “Limited/Targeted” Countries.
Central African Republic
Darfur Region of Sudan1
Democratic Republic of the Congo
1Sudan was removed completely from the sanction lists effective 12 October 2017, pursuant to Executive Order 13761 and its amended Executive Order 13804. However, the Darfur Region of Sudan and South Sudan are not affected by these executive orders. These regions are still sanctioned.
2On 27 November 2018, Nicaragua was added to the Limited/Targeted Sanctions list as part of Executive Order 13851.
Potential or current members/customers — If an individual is from one of the countries with Limited/Targeted Sanctions, we will search the Specially Designated Nationals and Blocked Persons (SDN) List for the name of the applicant, or for the 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.
Specially 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 6,300 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 site, 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.
The OFAC and Limited/Targeted Sanctions lists will be reviewed annually by Member Services prior to invoicing, August timeframe.