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I think it is but I don't know that CCP has ever made a direct ruling one way or the other.
No, you're trying to twist the rules to make it seem as though it's perfectly fine to do so (like so many other people do and get away with since the rule isn't enforced like it should be).
Players can trade items in their inventories, this would include games, on Steam. Unless ISK or PLEX is also an item in your steam inventory, it goes against the rules. You're also ignoring CCP's EULA (which the store page indicates the existince of a third-party EULA in addition to the Steam Subscriber Agreement).
What you want to try and do is a form of RMT, however you want to try and word it.
https://community.eveonline.com/support/policies/eve-eula-en/
Section 6 B
B. Selling Items and Objects
You may not transfer, sell or auction, or buy or accept any offer to transfer, sell or auction (or offer to do any of the foregoing), any content appearing within the Game environment, including without limitation characters, character attributes, items, currency, and objects, other than via a permitted Character Transfer as described in section 3 above. You may not encourage or induce any other person to participate in such a prohibited transaction. You may not use, transfer or assign any game assets for games of chance operated by third parties. The buying, selling or auctioning (or any attempt at doing so) of characters, character attributes, items, currency, or objects, whether through online auctions, newsgroups, postings on message boards or any other means is prohibited by the EULA and a violation of CCP's proprietary rights in the Game.
I know there are still some Steam inventory PLEXs floating about and if that’s what you want to trade, I’d believe you to be in the right. However, ISK can’t be traded through the inventory and as such is still against the EVE EULA and banable.
How dense are you?
How about this, I'm going to take up your offer, I will use an alternate EVE account and hope my main won't be banned either, and I'll report both of us after the deal is done and we'll see if it's RMT or not straight from the devs' own words and actions. If you are that sure of yourself, there shouldn't be any problem, right?