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And OP trading / selling / buying CD keys on Steam is not allowed whatsoever. You can give one to a close friend though.
As the games in question are associated with an account and an account can not be transferred between parties, yes, it is covered in the SSA (as you stated).
If we are talking about unassociated game keys, then it is just a matter of trading out-side the established trading system and at your own risk. In this case, Valve just won't help if someone gets scammed.