About AIST


Commerce Prohibition Policy for OFAC Sanctioned Countries - Back to Governance Policies

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 July 2019.

Policy

Status: July 2021

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 2021.

A. 

The Association for Iron & Steel Technology (AIST) will halt all business transactions with the following “Comprehensive” Countries:

Comprehensive
Crimea Region of Ukraine
Cuba
Iran
North Korea
Syria

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 business transactions with the following “Limited/Targeted” Countries.

Limited/Targeted Sanctions
Balkans
Belarus
Burundi
Burma
Central African Republic
Darfur Region of Sudan
Democratic Republic of the Congo
Iraq
Lebanon
Libya
Mali
Nicaragua
Somalia
South Sudan
Ukraine/Russia
Venezuela
Yemen
Zimbabwe

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 list (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 refund any money paid and deny participation in AIST, citing the ban by OFAC.

Specially Designated Nationals and Blocked Persons (SDN List) List — OFAC maintains various sanctions lists that may have different prohibitions associated with them. Several 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 SDN List 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.

C.

The OFAC and Limited/Targeted Sanctions lists will be reviewed annually by Member Services prior to invoicing, August timeframe.