1.1. Escrowfy GmbH, operating under the Oxen Finance brand (“Oxen”, “we”, “our”), is committed to the highest standards of anti-money laundering (AML), counter-terrorism financing (CTF), and counter-proliferation financing (CPF) compliance. We have zero tolerance for money laundering, terrorism financing, sanctions evasion, and any form of financial crime.
1.2. This document is a public summary of our AML/KYC framework. It is intended to help our clients and prospective clients understand why we collect certain information, how we use it, and what obligations arise for both parties. Our full internal AML/CTF/CPF Policy and related procedures are confidential and are not published.
1.3. This summary should be read in conjunction with our Privacy Policy (OXN-POL-PRIV-001), Prohibited and Restricted Countries Policy (OXN-POL-JRP-001), Prohibited and Restricted Industries Policy (OXN-POL-IND-001), and General Terms and Conditions.
2.1. Escrowfy GmbH is a member of the VQF Self-Regulatory Organisation (SRO) under membership number 101009, operating as a financial intermediary within the meaning of the Swiss Anti-Money Laundering Act (AMLA/GwG). We are subject to the supervisory oversight of the VQF and, indirectly, the Swiss Financial Market Supervisory Authority (FINMA).
2.2. Our AML/KYC framework is designed to comply with the following laws, regulations, and international standards:
We are legally required to verify the identity of every client before establishing a business relationship or processing transactions. This is not optional — it is a legal obligation imposed on all regulated financial intermediaries.
Important: We may request additional documentation beyond what is listed above, depending on your risk profile, jurisdiction, business activity, or the nature of your transactions. This is a normal part of the compliance process and does not imply suspicion.
4.1. We apply a risk-based approach to client due diligence, as required by the FATF Recommendations and all applicable AML legislation. This means that the level of due diligence applied to each client is proportionate to the assessed risk of the client relationship.
4.2. Risk is assessed based on multiple factors, including but not limited to:
4.3. Clients assessed as presenting elevated risk are subject to Enhanced Due Diligence (EDD), which may include additional documentation requirements, senior management approval, more frequent periodic reviews, and enhanced transaction monitoring.
5.1. All clients, beneficial owners, directors, authorised signatories, and counterparties are screened against international sanctions lists and Politically Exposed Persons (PEP) databases at the point of onboarding, and on an ongoing basis throughout the business relationship.
5.2. The sanctions lists we screen against include, but are not limited to:
5.3. If you, a beneficial owner, director, or counterparty of yours appears on a sanctions list, we are legally required to freeze funds, block transactions, and report to the relevant authorities. We may not be able to inform you before taking such action.5.4. PEP status does not automatically disqualify you from using our services. However, PEPs and their close associates are subject to Enhanced Due Diligence, including verification of source of wealth and senior management approval.
6.1. Our obligations do not end at onboarding. We conduct ongoing monitoring of all client relationships and transactions throughout the duration of the business relationship. This includes:
6.2. If our monitoring identifies activity that is inconsistent with your profile, we may contact you to request clarification or additional documentation. We may also temporarily suspend transaction processing pending the outcome of our review.
7.1. Where we have reasonable grounds to suspect that a transaction or business relationship involves the proceeds of crime, terrorism financing, or sanctions evasion, we are legally obligated to file a Suspicious Activity Report (SAR) with the Swiss Money Laundering Reporting Office (MROS), or the relevant financial intelligence unit in the applicable jurisdiction.
7.2. Tipping off: We are prohibited by law from informing you that a SAR has been filed or that your activity is under investigation. If we are unable to explain the reason for a delay, account restriction, or request for information, it may be because we are legally prevented from doing so.
7.3. Filing a SAR is a legal obligation, not an accusation. It does not mean that you are suspected of criminal activity. It means that we have identified activity that, by law, we are required to report to the authorities for further assessment.
By using the Oxen Finance platform, you agree to:
Failure to comply with these obligations may result in: delay or refusal of onboarding; suspension of services; freezing of funds; termination of the business relationship; and/or reporting to the relevant authorities.
9.1. We reserve the right to take the following actions where required by law, regulation, or our internal compliance obligations:
9.2. Where we take any of the above actions, we will inform you of the action and the reason, unless we are legally prohibited from doing so (e.g., because a SAR has been filed or because disclosure would constitute tipping off under applicable law).
9.3. In the event of account closure, any remaining funds (to the extent not frozen by legal requirement) will be returned to the client’s verified bank account, subject to any applicable deductions for outstanding fees or charges. Crypto-assets will be transferred to the client’s verified external wallet, subject to the same conditions.
10.1. We are legally required to retain all KYC/KYB documentation, transaction records, risk assessments, screening results, and SAR-related records for a minimum of 10 years from the date of termination of the business relationship, in accordance with Swiss AMLA Art. 7.
10.2. This retention obligation applies regardless of your data protection rights (e.g., right to erasure under GDPR or nFADP). Where a data subject request conflicts with a legal retention obligation, the legal obligation prevails. For more information, please refer to our Privacy Policy (Section 7).
11.1. Escrowfy GmbH maintains a dedicated compliance function responsible for the implementation, oversight, and continuous improvement of our AML/CTF/CPF framework. The compliance function is headed by the Chief Compliance Officer (CCO) and operates independently of revenue-generating business lines.
11.2. All staff with client-facing or compliance-relevant roles receive mandatory AML/CTF training upon joining and at least annually thereafter, covering applicable legislation, typologies and red flags, internal procedures, sanctions obligations, and SAR reporting.
11.3. Our AML/CTF framework is subject to periodic independent review by external auditors or consultants, and to examination by the VQF SRO.
12.1. In accordance with FATF Recommendation 16 and applicable implementations (including the EU Transfer of Funds Regulation and Swiss AMLO provisions), we collect and transmit originator and beneficiary information for all wire transfers and virtual asset transfers processed through the Oxen Finance platform.
12.2. For crypto-asset transfers, we comply with the Travel Rule by collecting the required originator and beneficiary data and transmitting it to the counterparty VASP, where technically feasible and required by law.
12.3. We may decline to process a transfer if the required Travel Rule information cannot be obtained from or transmitted to the counterparty.
13.1. We update this summary as necessary to reflect changes in applicable law, regulation, or our internal procedures. Material changes will be notified to clients and published on our website.
13.2. The most current version is available at oxen.finance/aml-kyc.
For questions about our AML/KYC requirements, or if you need assistance with the verification process:
