Sanctions are restrictive measures imposed by countries, groups of countries, or international organisations to influence or penalise entities, individuals, or governments.

They are non-military measures used to maintain international peace, security, and human rights, and to combat illegal activities like terrorism or drug trafficking. Sanctions are often based on decisions by the United Nations, other international organisations, or EU legislation.

Sanctions can take various forms, including financial, political, transport, and social restrictions. Financial sanctions limit the rights of persons subject to international sanctions to manage, use and dispose of money, securities, objects, other property and property rights; financial sanctions also restrict payments to entities subject to international sanctions; etc.

As a licensed payment institution, Montonio is committed to ensuring compliance with sanctions regulations. This means we must verify that our customers are not sanctioned individuals or entities and that our services are not used for transactions involving sanctioned parties.

Similarly, all banks and financial institutions involved in the payment chain are required to take the same precautions. However, the responsibility doesn’t end with financial institutions—merchants must also ensure they comply with international sanctions. This includes avoiding transactions with sanctioned individuals and adhering to trade and sector-specific restrictions.

By law, Montonio is required to check merchants’ transactions against international sanctions lists—a process known as transaction screening. This obligation applies if the store has activated the Bank Payment Refunds service.

If the Bank Payment Refunds service is enabled, Montonio must verify the payer’s details to ensure they are not on sanctions lists. This screening happens automatically when the payment reaches our bank. However, it’s important to note that payments are not screened at the time the order is placed but rather when the funds are received, which may sometimes take a bit of time.

If a potential sanctions match is detected during automatic screening, Montonio receives an alert. This can occur when the payer’s name is similar to that of a sanctioned person or entity. For example, in our region, common Slavic names like Alexandr Popov or Jelena Ivanova are frequently flagged during checks.

When this happens, Montonio is required to request additional information about the payer from the merchant. This may include details such as the payer's full name, date of birth, citizenship, residency, or place of birth.

If the merchant doesn’t usually collect such information from payers, they will need to reach out to the payer to obtain the necessary details.

If the payer does not provide the requested information, Montonio—or the bank requiring the details—is legally prohibited from confirming the payment. In such cases, we recommend holding off on shipping the product until the matter is resolved, if possible.

Banks often handle this type of information exchange directly between themselves, without involving the parties to the transaction. As a result, they don’t always need to reach out to customers for additional details.

While most EU banks are already prohibited from serving sanctioned individuals or entities, Montonio, as a payment institution, is legally required to conduct its own sanctions screening. We cannot rely solely on banks to fulfill this obligation.

The requirements outlined above are based on the Money Laundering and Terrorist Financing Prevention laws and International Sanctions laws of Lithuania and Estonia. For more information, you can visit the websites of local regulatory authorities, such as Ministries of Foreign Affairs, Financial Intelligence Units, or Central Banks. Below are some useful resources:

Additionally, OpenSanctions provides a comprehensive open database of international sanctions, persons of interest, and politically exposed persons.