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Sanctions Compliance Policy

Version 1.0, effective 7 August 2026.

This policy explains how Selgeo (Apliteni OÜ; “we”, “us”, “our”) applies sanctions and restricted-territory controls when providing the Selgeo platform to Merchants and Partners. It is intended to support compliance with applicable EU sanctions and related restrictions.

1. Scope

This policy applies to:

  • Merchants registering for or using a Workspace;
  • Partners using a Global Partner Account or joining a Programme;
  • beneficial owners, directors, authorised representatives, and other controlling persons where relevant;
  • any use of the Platform on behalf of, or for the benefit of, another person or organisation.

2. Prohibited users

Selgeo does not knowingly provide the Platform to any person or organisation that:

  • is listed on an applicable sanctions list;
  • is owned or controlled by a sanctioned person or organisation;
  • acts on behalf of, or for the benefit of, a sanctioned person or organisation;
  • provides false, misleading, or incomplete information to avoid sanctions screening;
  • uses the Platform in a way that would cause Selgeo, a Merchant, a Partner, or Stripe to breach sanctions or export-control restrictions.

3. Prohibited territories

Selgeo does not knowingly provide the Platform where this would involve a person, organisation, activity, or transaction located in, registered in, ordinarily resident in, or otherwise connected with a territory subject to comprehensive EU sanctions or an equivalent restriction applicable to Selgeo.

The list of restricted territories may change without prior notice when laws, regulations, or regulator guidance change.

4. Sanctions lists

Selgeo may screen relevant users and related persons against:

  • the EU Consolidated Financial Sanctions List;
  • United Nations Security Council sanctions lists;
  • sanctions or restricted-party lists used by our payment, infrastructure, identity-verification, or compliance providers;
  • other lists that we reasonably determine are necessary to comply with applicable law or provider requirements.

5. When checks may happen

Sanctions checks may be performed:

  • during Merchant registration or onboarding;
  • when a Merchant connects Stripe or enables a live Workspace;
  • when a Partner creates a Global Partner Account, joins a Programme, or receives a payout;
  • when account details, ownership, location, payout data, or risk indicators change;
  • periodically, to reflect updates to sanctions lists;
  • when we receive an alert, provider notice, regulator request, or other risk signal.

6. Potential matches and escalation

If a potential sanctions match is identified, Selgeo may temporarily restrict the relevant account, Workspace, Programme, payout, integration, or support request while the match is reviewed.

The review may include:

  • checking available account, billing, location, ownership, and payout information;
  • requesting additional information or documents from the Merchant or Partner;
  • consulting a legal or compliance reviewer;
  • contacting Stripe or another provider where the issue affects their services;
  • notifying the Estonian Financial Intelligence Unit where the Estonian International Sanctions Act requires it;
  • recording the decision and rationale in an internal compliance log.

7. Account actions

Where Selgeo identifies a confirmed match or an unacceptable sanctions risk, we may:

  • reject onboarding or refuse to provide the Platform;
  • suspend, restrict, or terminate access to the relevant account, Workspace, Programme, or integration;
  • block or delay a payout, export, support action, or other requested operation;
  • disconnect or require revocation of a Stripe integration where continued access would create sanctions risk;
  • notify a Merchant, Partner, provider, regulator, or authority where required or permitted by law;
  • retain records necessary to evidence compliance with legal obligations.

8. Merchant and Partner responsibilities

Merchants and Partners must:

  • provide accurate and up-to-date registration, billing, ownership, tax, and payout information;
  • not use the Platform on behalf of, or for the benefit of, a sanctioned person or organisation;
  • not invite, approve, or pay Partners where doing so would breach sanctions or provider restrictions;
  • notify Selgeo promptly if their sanctions status, ownership, location, or payout eligibility changes;
  • cooperate with reasonable information requests related to sanctions compliance.

9. No obligation to disclose details

Selgeo may be unable to disclose the full reason for a restriction, delay, or termination where disclosure would breach law, provider requirements, regulator expectations, security controls, or an ongoing investigation.

10. Contact

Sanctions-compliance questions or notices should be sent tocontact@selgeo.com.

Version 1.0, effective 7 August 2026. Apliteni OÜ, registry code 14296961, Tornimäe tn 3 // 5 // 7, 10145 Tallinn, Estonia. Contact:contact@selgeo.com.