OFAC Compliance Policy

Policy Regarding Benefits to Members in Sanctioned or Embargoed Countries

The Office of Foreign Assets Control (OFAC) of the US Department of the Treasury administers and enforces economic and trade sanctions based on US foreign policy and national security goals.

SME complies with all applicable sanction laws, including those of the United States (US) and European Union (EU), which prohibit personnel and nationals of certain countries (including even US nationals living abroad) from providing or assisting in the provision of certain services to individuals “ordinarily resident in” an embargoed or sanctioned country.(1)

SME’s policy is to provide to members residing in embargoed or sanctioned countries only those membership benefits that either (i) contain or relate to publicly available information or informational materials, or (ii) are otherwise authorized under applicable sanction laws, including regulations administered by the US Treasury Department's Office of Foreign Assets Control (“OFAC”), licenses, exemptions and interpretations issued pursuant thereto.

The list below indicates which membership benefits believed to be permitted under applicable sanction laws as well as those benefits that SME believes may not be offered to individuals “ordinarily resident in” an embargoed or sanctioned country under those laws.

 

Permitted Services and Benefits

There are a number of services/benefits that may be provided to SME members in embargoed or sanctioned countries (e.g., Iran, North Korea, Russia and Syria) because these activities relate to the provision of publicly available informational materials and thus are not limited by applicable US and/or EU sanction laws. These permitted services/benefits include:

  • SME membership

  • Geographic section membership in non-sanctioned countries

  • OneMine.org access (limited to information already in the public domain)

  • Individual membership queries

  • Individual membership benefits for publications, published technical papers and publicly available information

  • Attendance at SME meetings, conferences, and workshops (cannot be an exhibitor and cannot participate in meetings or other activities that could result in the dissemination of information not already in the public domain)

  • SME books and periodicals (print and electronic)

  • Information on SME’s website, www.smenet.org

  • Information on SME Foundation, Minerals Education Coalition and education outreach to pre-university students

  • Attendance verification

 

Unavailable Services and Benefits

Some services and benefits that SME generally provides to its members may not be provided to SME members “ordinarily resident in” sanctioned or embargoed countries. These prohibited services and benefits include:

  • Section support

  • Student Chapter support

  • Funding of any type, including all:

    • Section rebates

    • Scholarship programs

    • Grant and Fellowship programs

  • All awards and/or cash prizes

  • Membership recruitment contests

  • Membership development appreciation awards

  • OneMine.org rebates or payments

  • Participation in or service on SME Committees, the Board of Directors and Divisions

  • Membership in SME organizing committees for technical conferences

  • Interactive training (training that is expanded beyond previously prepared information)

  • Programs involving the receipt of individually tailored information or advice such as mentoring programs

  • International or regional student paper contests

  • SME student design contests

  • Distinguished Lecturer Program

  • Student Chapter awards

  • Regional awards

  • International awards

  • Section awards

  • eMentoring program

  • Certification program

  • Insurance programs

  • Krumb Lecturer Program

  • Volunteer appreciation gift

  • Organizing, supporting or sanctioning SME conferences in embargoed countries


Additional information on US and EU laws regarding this issue may be found at https://www.treasury.gov/resource-center/sanctions/Pages/default.aspx and http://eeas.europa.eu/cfsp/sanctions/docs/measures_en.pdf

For any questions regarding this policy or SME's membership benefits generally, please contact Melanie Penoyar-Perez, SME Director of Operations at penoyer-perez@smenet.org.

(1) Under US law, "Ordinarily Resident In" generally includes:

  • Individuals, regardless of nationality, residing in an embargoed country

  • Individuals holding an embargoed country passport and a non-permanent visa (student, visitor, temporary, business) for any country outside the US

  • Individuals holding an embargoed country passport and a non-permanent visa (visitor, temporary, business) for the US