Although US and UK sanctions are not legally binding on individuals and businesses in Lithuania, financial institutions may choose to comply with them in the course of their business activities.
Financial institutions make such decisions after assessing the potential risks involved. For example, they may process international payments, maintain correspondent banking relationships with banks in the United States or the United Kingdom, use financial services provided by those banks, or process payments in US dollars or British pounds sterling. In some cases, financial institutions may also be required to comply with certain legal requirements of foreign jurisdictions or with contractual obligations arising from their cooperation with foreign banks
For these reasons, a financial institution may refuse to process a payment if it considers that the payment does not comply with its sanctions policies or risk management framework. Such a decision does not necessarily mean that the payment breaches sanctions that are legally binding in Lithuania. Rather, it may indicate that the payment does not meet additional requirements established by the financial institution to manage legal, financial or reputational risks.
If a financial institution refuses to process a payment, it must inform the customer of its decision and explain the reasons for the refusal, unless otherwise provided by law. Customers are therefore entitled to know why their payment was not processed.
According to Lietuvos bankas, financial institutions have not adopted a common approach to the implementation of OFAC sanctions. Therefore, if you have questions about whether a particular financial institution applies OFAC sanctions, you should contact that institution directly. A list of financial market participants is available here.