PPDM Association Sanction Policy

Approved by the PPDM Board of Directors August, 2019
Reviewed by Legal Committee Sept 21, 2022

The PPDM Association, incorporated in Alberta Canada, has both individuals and corporations or other agencies and organizations as members. PPDM must comply with all applicable sanction laws, particularly those of Canada. PPDM also endeavors to follow US and European Union sanction laws which prohibit PPDM staff from providing or assisting in the provision of certain services to individuals who are citizens of, or who are “ordinarily resident in” an embargoed or sanctioned country. It should be noted that not all sanctions relate to the dissemination of information or information standards, and only those sanctions that are relevant to the work of the PPDM Association are considered.

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

For example, PPDM may provide to members residing in embargoed or sanctioned countries only those membership benefits related to information or informational materials or that are otherwise authorized under applicable sanction laws, including regulations administered by the Government of Canada (Special Economic Measures Act, the United Nations Act, Justice for Victims of Corrupt Foreign Officials Act), the US Treasury Department's Office of Foreign Assets Control (“OFAC”), and other acts as relevant, including licenses, and interpretations issued pursuant thereto.

Under Canadian law, PPDM standards and best practices may be included under the definition of Technical Data (technical data includes blueprints, technical drawings, photographic imagery, computer software, models, formulas, engineering designs and specifications, technical and operating manuals and any technical information or know-how. (données techniques)).

This document is intended to educate PPDM staff and members about economic sanctions laws that are applicable to PPDM activities, and to serve as a basic guide to assist PPDM and its members in conducting PPDM activities in conformity with these laws. In addition, PPDM will cooperate with its international association and professional society counterparts to ensure that any joint activities are in compliance with applicable U.S. and European Union sanctions laws.

Overarching guidelines
  • Governments such as the Government of Canada, The U.S. Department of Treasury Office of Foreign Assets Control (“OFAC”) administer and enforce economic sanctions programs against countries and specific individuals who have been specially designated or blocked. Although regulations and requirements vary by country, as a practical matter, absent specific permission from Treasury in the form of a specific license, transactions with PPDM members and prospective members may be are limited to dissemination of “information and informational materials.” Note that this list of countries may change without notice should the relevant authorities change their rules.
  • Depending on the country involved, agencies or departments or any other corporate entities that are controlled by the sanctioned government may not become members of the PPDM Association. PPDM uses sites such as these as a general reference:
  • PPDM may provide many individual membership benefits and services to persons in a country that is subject to non-comprehensive sanctions; however, PPDM may not provide any benefits or services to persons who appear on lists such as the OFAC SDN list and also not to persons on the Sectoral Sanctions Identifications List (“SSIL list”) related to Russia/Ukraine sanctions.
  • There are a number of services/benefits that may be provided to PPDM members in countries sanctioned by Canada, the US and/or the EU because these activities relate to the provision of informational materials and thus are not limited by applicable sanction laws.
  • Dues or fees may not be paid by or through a bank controlled by a sanctioned government.
The list below indicates which membership benefits are permitted under, versus those benefits which PPDM may not offer in order to comply with, applicable sanction laws.

Benefits to Corporations or Regulatory Agencies

Permitted services / benefits are limited to dissemination of “information and informational materials.” Accordingly, PPDM may provide members and prospective members in Sanctioned Countries with certain membership benefits if these activities relate to the provision of information and information materials as outlined below.

a. Allowed Benefits
These permitted services/benefits include

  • Corporate entities or regulatory agencies who are registered in a sanctioned or embargoed country may not obtain corporate membership benefits.
  • Services and benefits may be available to individuals as described in this policy

b. Prohibited services/benefits to corporations or regulatory agencies include: 
There are services/benefits that may not be provided to PPDM members in countries sanctioned by the US and/or the EU because there are persons involved in providing these services who may be prohibited by US or EU laws.
  • Corporate entities or regulatory agencies who are registered in a sanctioned or embargoed country may not become voting, associate, honorary or contributing members of the PPDM Association.
  • Cannot be an exhibitor or sponsor of PPDM events or other activities in any country.
  • Cannot participate in organizing or supporting any PPDM conferences in embargoed countries.
  • Regional Leadership Teams may not be formed within Sanctioned or Embargoed countries.
  • Cannot receive PPDM training within the Sanctioned or Embargoed Country and cannot receive training that is expanded beyond previously prepared information.
  • Cannot participate in any mentoring or interactive professional development program.

Benefits to Individuals

c. Allowed Benefits
Requests for access will be reviewed on a case by case basis. PPDM’s ruling on any such request will be binding. Because of the complexity associated with granting benefits to sanctioned individuals, PPDM rulings are generally aligned with a cautious approach.

Based on sanction rules for an Individual’s country of citizenship or residence, permitted services/benefits may include:
  • Individual membership queries
  • PPDM Associate (Individual) membership
  • Registration as a Guest on the PPDM Association website, and any access to information materials generally accessible to such Guests.
  • Foundations subscriptions
  • Use of Individual membership pricing for attendance at PPDM events or public training.
  • Individual membership level access to the PPDM website provided the individual is a current Individual member in good standing.
  • Individual membership level access to any PPDM publications, published technical papers and informational matter.
  • Attendance at PPDM meetings, conferences, and workshops
  • Attendance registration verification
  • Participation in scheduled public training sessions, provided these are not expanded beyond materials or information normally presented during each class, and provided fees for participation have been paid in full.

d. Prohibited services/benefits to individuals include:
There are services/benefits that may not be provided to PPDM members in countries sanctioned by the US and/or the EU because there are persons involved in providing these services who may be prohibited by US or EU laws.
  • Cannot be an exhibitor or sponsor of PPDM events or other activities in any country
  • PPDM Staff cannot prepare letters of invitation for any PPDM activity to sanctioned individuals
  • Cannot participate in organizing or supporting any PPDM conferences in embargoed countries
  • Cannot be provided with funding of any type, including:
    • Free or discounted membership fees.
    • Membership recruitment contests.
  • Cannot participate in any development or organizational activity including but not limited to:
    • PPDM Association Board of Directors.
    • PPDM Committee or Work group.
    • Regional Leadership Teams.
  • Regional Leadership Teams may not be formed within Sanctioned countries
  • Training that is expanded beyond previously prepared information
    • Any mentoring or interactive professional development program.
  • PPDM Programs such as, but not limited to:
    • PPDM Contests, such as the Foundations Photo contest.
    • Student awards.
    • Volunteer of the Month awards.
    • Other award programs as devised from time to time.
    • Certification program.
    • Volunteer appreciation recognition or gift.
Additional information on laws regarding this issue may be found online. Below are some relevant laws