CHAPTER IV: SECTION 7 COMPLIANCE WITH U.S. SANCTIONS

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1 REVISED 10/19/12 CHAPTER IV: SECTION 7 COMPLIANCE WITH U.S. SANCTIONS Policies and Procedures of Society of Exploration Geophysicists with respect to Membership, Publishing Activities, and Scholarships with Persons in OFAC Sanctioned Countries In response to the restrictions of the Office of Foreign Assets Control ( OFAC ) with respect to membership rights, publishing activities, and scholarships with persons in OFAC sanctioned countries, Society of Exploration Geophysicists, ( SEG ) has adopted the following policies and procedures: I. Membership Rights A. Balkans, Belarus, Burma, Côte d Ivoire (Ivory Coast), Democratic Republic of the Congo, Iraq, the Former Liberian Regime of Charles Taylor, Lebanon, Libya, North Korea, Somalia, Syria, Yemen, and Zimbabwe. Except as provided in subsection C, SEG may extend full membership to persons in the Balkans, Belarus, Burma, Côte d Ivoire (Ivory Coast), Democratic Republic of the Congo, Iraq, the Former Liberian Regime of Charles Taylor, Lebanon, Libya, North Korea, Somalia, Syria, Yemen, and Zimbabwe except to those persons whose property has been blocked by the U.S. Government. SEG will not provide any benefit or service to such persons. With respect to North Korea, SEG is prohibited from importing into the United States, directly or indirectly, any goods, services, or technology from North Korea. With respect to Syria, SEG is prohibited from exporting or reexporting to Syria any product of the United States (with the exception of information and informational materials). With respect to Burma, SEG may not provide membership benefits to persons in Burma which constitute the exportation of financial services to Burma that are not otherwise permitted under OFAC General License No. 16. B. Iran, Cuba, and Sudan. Except as provided in subsection C, SEG may extend membership to and accept membership dues from persons in Iran, Cuba, and Sudan solely in connection with the receipt of SEG s information and informational materials, such as SEG publications. The membership dues charged may not be less than the fair market value of the information and information materials provided. In addition, SEG may sell information and information materials to persons in Iran, Cuba, and Sudan provided that the fee charged for these materials is not less than fair market value of the materials provided. To the best of its knowledge and ability, SEG will not provide membership benefits or services to members in Iran, Cuba, or Sudan that are prohibited by OFAC regulations, which may include professional certification, professional certification exams, and credit card services. In addition, SEG will not form or provide support to chapters, special interest groups or colleges in Iran, Cuba, or Sudan. SEG may apply for a specific license from OFAC to define the membership benefits that may be provided to members in Iran, Cuba, and Sudan.

2 C. SDN List. SEG may not extend membership to persons listed on OFAC s list of Specially Designated Nationals or SDN list. SEG will regularly review the SDN list to ensure it is not providing membership rights to such persons. II. Educational Activities A. Licenses. SEG will obtain specific licenses issued by OFAC to sponsor educational conferences (including expositions), forums, workshops and seminars that would permit persons in OFAC-sanctioned countries to attend, participate in or present scholarly papers and that are scheduled more than six (6) months after the latest date of this Policy. With respect to all other such educational conferences (including expositions), forums, workshops and seminars as to which no license is obtained, the following provisions of this Part II shall apply. 1 B. Balkans, Belarus, Burma, Côte d Ivoire (Ivory Coast), Democratic Republic of the Congo, Iraq, Lebanon, Libya, the Former Liberian Regime of Charles Taylor, North Korea, Somalia, Syria, Yemen, and Zimbabwe. With the exception of persons whose property has been blocked by the U.S. Government and except as provided in subsection C, SEG may allow persons in the Balkans, Belarus, Burma, Côte d Ivoire (Ivory Coast), Democratic Republic of the Congo, Iraq, the Former Liberian Regime of Charles Taylor, Lebanon, Libya, North Korea, Somalia, Syria, Yemen, and Zimbabwe to attend, participate in, and present scholarly papers at educational conferences (including expositions), forums, workshops and seminars. This would include persons affiliated with academic institutions and governmental entities. References to the "Balkans" shall mean the following countries: Slovenia; Croatia, Yugoslavia, Albania, Bulgaria, Romania, Bosnia-Herzegovina, Moldova, Albania and Macedonia. C. Iran, Sudan, and Cuba. Except as provided in subsection D, SEG may allow persons in Iran, Sudan, and Cuba to attend, participate in, and present scholarly papers at educational conferences (including expositions), forums, workshops and seminars that it sponsors. This would include persons affiliated with academic institutions but would exclude persons affiliated with the governments of these countries as well as any political subdivision, agency, or instrumentality thereof and would exclude companies listed in an OFAC publication that are identified as "Persons Determined to be the Government of Iran" as defined in 31 C.F.R. Part In the absence of a specific license issued by OFAC, SEG will not sponsor conferences or events at conferences that are organized or co-organized by the Government of Iran, Cuba, or Sudan or persons in Iran, Cuba, or Sudan. 1 This provision is based on a verbal conversation with an OFAC employee on August 2, 2012 that suggested that all such SEG-sponsored events be licensed in advance but such comment has not been supported by OFAC regulations or publications. SEG will continue to monitor OFAC publications and regulations to determine whether the OFAC employee's interpretation is correct and will modify this Policy immediately upon determining that this Policy conflicts with OFAC regulations. 2

3 D. SDN List. SEG may not allow persons listed on OFAC s list of Specially Designated Nationals or SDN list to attend and participate in educational conferences (including expositions), forums, workshops and seminars. III. Publishing Activities A. Balkans, Belarus, Côte d Ivoire (Ivory Coast), Democratic Republic of the Congo, Iraq, Lebanon, Libya, the Former Liberian Regime of Charles Taylor, North Korea, Somalia, Syria, Yemen, and Zimbabwe. Except as provided in subsection C, SEG may engage in publishing activities with persons in Balkans, Belarus, Côte d Ivoire (Ivory Coast), Democratic Republic of the Congo, Iraq, Lebanon, Libya, the Former Liberian Regime of Charles Taylor, North Korea, Somalia, Syria, Yemen, and Zimbabwe except with those persons whose property has been blocked by the U.S. Government. SEG will not engage in any publishing activities with such persons. With respect to North Korea, SEG is prohibited from importing products of North Korean origin into the United States either directly or through third countries without a license from OFAC. With respect to Syria, SEG is prohibited from exporting or reexporting to Syria any product of the United States (with the exception of information and informational materials). B. Iran, Sudan, Cuba, and Burma. In accordance with Iranian Transactions Regulations , Sudanese Sanctions Regulations , Cuban Assets Control Regulations , and Burmese Sanctions Regulations and except as provided in subsection C, SEG may engage in transactions with persons in Iran, Sudan, Cuba, and Burma, respectively, that are necessary and ordinarily incident to the publishing and marketing of manuscripts, books, journals, and newspapers (collectively written publications ), in paper or electronic format, subject to the restrictions described below. 1. SEG will not engage in transactions involving the following persons: a. With respect to Iran, the Government of Iran, which generally includes the state and the Government of Iran as well as any political subdivision, agency, or instrumentality thereof, including the Central Bank of Islamic Republic of Iran, and any person acting or purporting to act directly or indirectly on behalf of any of the foregoing with respect to the transactions described in this paragraph 1 and paragraph 2 below. However, the term Government of Iran does not include any academic and research institutions and their personnel. b. With respect to Sudan, the Government of Sudan, which generally includes the state and the Government of Sudan, as well as any political subdivision, agency, or instrumentality thereof, including the Central Bank of Sudan, and any person acting or purporting to act directly or indirectly on behalf of any of the foregoing with respect to the transactions described in this paragraph 1 and paragraph 2 below. However, the term Government of Sudan does not include any academic and research institutions and their personnel. 3

4 c. With respect to Cuba, the "Government of Cuba" includes the state and the Government of Cuba, as well as any political subdivision, agency, or instrumentality thereof, including the Central Bank of Cuba; any person occupying the positions identified below as a prohibited official of the Government of Cuba or a prohibited member of the Cuban Communist Party; employees of the Ministry of Justice; and any person acting or purporting to act directly or indirectly on behalf of any of the foregoing with respect to the transactions described in this paragraph 1 and paragraph 2 below. For the purposes of this paragraph, the term "Government of Cuba" does not include any academic and research institutions and their personnel. For the purposes of this paragraph, the term "prohibited official of the Government of Cuba" means: Ministers and Vice-ministers, members of the Council of State, and the Council of Ministers; members and employees of the National Assembly of People's Power; members of any provincial assembly; local sector chiefs of the Committees for the Defense of the Revolution; Director Generals and sub- Director Generals and higher of all Cuban ministries and state agencies; employees of the Ministry of the Interior (MININT); employees of the Ministry of Defense (MINFAR); secretaries and first secretaries of the Confederation of Labor of Cuba (CTC) and its component unions; chief editors, editors and deputy editors of Cuban state-run media organizations and programs, including newspapers, television, and radio; and members and employees of the Supreme Court (Tribuno Supremo Nacional). For purposes of this paragraph, the term "prohibited members of the Cuban Communist Party" means: members of the Politburo; the Central Committee; Department Heads of the Central Committee; employees of the Central Committee; and secretary and first secretary of the provincial Party central committees. d. With respect to Burma, the State Peace and Development Council of Burma or the Union Solidarity and Development Association of Burma, any successor entity to any of the foregoing entities, or any person, other than personnel of academic and research institutions, acting or purporting to act directly or indirectly on behalf of the foregoing entities with respect to the transactions described in this paragraph 1 and paragraph 2 below. 2. SEG may engage in the following activities unless such activities are limited by the restrictions set forth in paragraphs 3 or 4 below: a. Commissioning and making advance payments for identifiable written publications not yet in existence, to the extent consistent with industry practice; b. Collaborating on the creation and enhancement of written publications; 4

5 c. Augmenting written publications through the addition of items such as photographs, artwork, translation, explanatory text, and, for a written publication in electronic format, the addition of embedded software necessary for reading, browsing, navigating, or searching the written publication; d. With respect to Burma and Cuba only, exporting embedded software necessary for reading, browsing, navigating, or searching a written publication in electronic format, provided that, to the extent a license is required under the Export Administration Regulations, 15 CFR parts 730 through 774 (the "EAR"), the exportation is licensed or otherwise authorized by the Department of Commerce under the provisions of the EAR; e. With respect to Iran and Sudan only, exporting embedded software necessary for reading, browsing, navigating, or searching a written publication in electronic format, provided that the software is classified as "EAR 99" under the EAR, or is not subject to the EAR; f. Substantive editing of written publications; g. Payment of royalties for written publications; h. Creating or undertaking a marketing campaign to promote a written publication; and i. Other transactions necessary and ordinarily incident to the publishing and marketing of written publications as described above in paragraph 1 and this paragraph SEG will not engage in transactions that involve the provision of goods or services to Iran, Sudan, or Cuba, or the exportation or reexportation of financial services from the United States to Burma, that are not necessary and ordinarily incident to the publishing and marketing of written publications, including but not limited to: a. Providing or receiving individualized or customized services (including, but not limited to, accounting, legal, design, or consulting services) other than those that are necessary and ordinarily incident to the publishing and marketing of written publications, even though such services are delivered through the use of information and informational materials; b. Creating or undertaking a marketing campaign for any person with respect to any service or product other than a written publication or for the benefit of the Governments of Iran, Sudan, or Cuba or the State Peace and 5

6 Development Council of Burma or the Union Solidarity and Development Association of Burma; c. With respect to Iran, Sudan, or Cuba only, engaging in the exportation or importation of goods other than the exportation of embedded software described in paragraphs 2.d and e above; d. Operating a publishing house, sales outlet or other office in Iran, Sudan, Cuba, or Burma; or e. With respect to Cuba only, engaging in transactions related to travel to, from or within Cuba. Notwithstanding the foregoing, the importation and exportation of information and informational materials, as defined in applicable regulations, is exempt from the prohibitions of this paragraph SEG will not engage in the following activities: a. The use of publishing houses or translators in such countries unless the activity is primarily for the dissemination of written publications in such countries (with respect to Burma, this prohibition is limited to transactions constituting the exportation or reexportation of financial services to Burma); b. With respect to Iran and Sudan only, the exportation from or importation into the United States of services for the development, production, or design of software; c. With respect to Cuba only, transactions for the development, production, or design of software; d. With respect to Burma only, the importation into the United States of any article that is a product of Burma (subject to certain exceptions including an exception for information or informational materials); e. Transactions for the development, production, design, or marketing of technology specifically controlled by the International Traffic in Arms Regulations ( ITAR ), EAR, or the Department of Energy Regulations set forth at 10 C.F.R. Part 810 (with respect to Burma, this prohibition is limited to transactions constituting the exportation or reexportation of financial services to Burma); f. The exportation of information or technology subject to the authorization requirements of 10 CFR Part 810, or Restricted Data as defined in Section 11 y. of the Atomic Energy Act of 1954, as amended, or of other information, data, or technology the release of which is 6

7 controlled under the Atomic Energy Act and regulations therein (with respect to Burma, this prohibition is limited to transactions constituting the exportation or reexportation of financial services to Burma); g. The exportation of any item (including information) subject to the EAR where a U.S. person knows or has reason to know that the item will be used, directly or indirectly, with respect to certain nuclear, missile, chemical, or biological weapons or nuclear-maritime end-uses as set forth in part 744 of the EAR. In addition, U.S. persons are precluded from exporting any item subject to the EAR to certain restricted end-users, as set forth in part 744 of the EAR, as well as certain persons whose export privileges have been denied pursuant to parts 764 or 766 of the EAR, without authorization from the Department of Commerce (with respect to Burma, this prohibition is limited to transactions constituting the exportation or reexportation of financial services to Burma); h. The exportation of information subject to licensing requirements under the ITAR, or exchanges of information subject to regulation by other government agencies (with respect to Burma, this prohibition is limited to transactions constituting the exportation or reexportation of financial services to Burma); or i. With respect to Cuba only, specific licenses may be issued on a case-by-case basis authorizing the travel-related transactions set forth in Section (c) of the Cuban Assets Control Regulations and such additional transactions that are directly incident to attendance of professional meetings that are necessarily and ordinarily incident to the publishing and marketing of written publications. 5. With respect to Iran, SEG may include an electronic search function in a database composed of information that is exempt from the Iranian Transactions Regulations which merely searches and sorts the exempt information in the database. 6. With respect to Iran, SEG may condition publication on the author s transfer of the copyright if such transfer is a standard practice in SEG s industry. C. SDN List. SEG may not engage in publishing activities with persons listed on OFAC s list of Specially Designated Nationals or SDN list. IV. Scholarships A. Balkans, Belarus, Burma, Côte d Ivoire (Ivory Coast), Democratic Republic of the Congo, Iraq, Lebanon, Libya, the Former Liberian Regime of Charles Taylor, North Korea, Somalia, Syria, Yemen, and Zimbabwe. Except as provided in subsection C, SEG may provide scholarships to persons in the Balkans, Belarus, Burma, Côte d Ivoire (Ivory Coast), Democratic Republic of the Congo, Iraq, Lebanon, Libya, the Former Liberian 7

8 Regime of Charles Taylor, North Korea, Somalia, Syria, Yemen, and Zimbabwe except to those persons whose property has been blocked by the U.S. Government. SEG will not provide scholarships to such persons. B. Iran, Sudan, and Cuba. Except as provided in subsection C, SEG may not provide scholarships to persons in Iran, Sudan, or Cuba unless it applies for a specific license from OFAC to allow it to offer scholarships. C. SDN List. SEG may not provide scholarships to persons listed on OFAC s list of Specially Designated Nationals or SDN list. V. Miscellaneous A. SEG shall consult the SDN list referenced throughout these policies in connection with all activities, which can be found at SDN-List/Pages/default.aspx. B. References to persons in a country shall include persons having such country as their place of national origin or citizenship. Accordingly, SEG will be cognizant to a person from a country being temporarily located elsewhere when applying these policies. SEG will regularly monitor this policy statement for compliance with changing United States laws. DATED,

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