1.1. Escrowfy GmbH, operating under the Oxen Finance brand (“Oxen”, “we”, “our”), is committed to complying with all applicable international sanctions regimes, anti-money laundering laws, and counter-terrorism financing regulations. As part of this commitment, we maintain a risk-based approach to jurisdictional exposure that determines the countries and territories from which we will accept clients, process transactions, or provide services.
1.2. This policy sets out the countries and territories that are prohibited (no services of any kind) or restricted (services subject to enhanced due diligence and prior approval) in connection with the use of the Oxen Finance platform.
1.3. This policy is informed by, and must be read in conjunction with, the following sanctions regimes and regulatory frameworks:
• Swiss State Secretariat for Economic Affairs (SECO) sanctions ordinances;
• European Union restrictive measures (EU Sanctions Consolidated List);
• United Kingdom Office of Financial Sanctions Implementation (OFSI) sanctions;
• United States Office of Foreign Assets Control (OFAC) sanctions programs;
• United Nations Security Council (UNSC) sanctions resolutions;
• Financial Action Task Force (FATF) High-Risk Jurisdictions and Jurisdictions under Increased Monitoring;
• Abu Dhabi Global Market (ADGM) and UAE Central Bank sanctions requirements.
1.4. This list is reviewed and updated on a quarterly basis, or immediately upon changes to any of the sanctions regimes or FATF publications referenced herein. The most current version of this policy is always available at oxen.finance/prohibited-countries.
We classify jurisdictions into three risk tiers:
Oxen Finance does not provide any services to, does not accept any clients from, and does not process any transactions involving the following countries and territories. This prohibition applies to natural persons who are nationals or residents of, and legal entities that are incorporated, domiciled, or operating in, the jurisdictions listed below.
The following jurisdictions are subject to comprehensive sanctionsby one or more of SECO, EU, OFAC, OFSI, and/or UNSC:
The following jurisdictions are prohibited due to active armed conflict, UNSC targeted sanctions, and/or the absence of any viable financial infrastructure for conducting meaningful due diligence:
Important: This list is not exhaustive. We reserve the right to decline or terminate a business relationship with any person or entity in any jurisdiction where we determine, at our sole discretion, that the provision of services would be unlawful, would expose us to unacceptable risk, or would be inconsistent with our regulatory obligations.
Services may be available to clients from the following jurisdictions, subject to the successful completion of Enhanced Due Diligence (EDD), senior management approval, and ongoing enhanced monitoring. Onboarding of clients from restricted jurisdictions requires prior written approval from the Chief Compliance Officer.
As of 13 February 2026, the following jurisdictions are on the FATF grey list. Where a jurisdiction is also subject to domestic cryptocurrency restrictions, services are limited to fiat payment facilitation only (see Section 5.1 for details).
The following jurisdictions are classified as restricted due to elevated risk factors, including but not limited to partial sanctions, sectoral restrictions, inadequate AML/CTF frameworks, opacity of beneficial ownership, or elevated corruption indices:
For clients from restricted jurisdictions, the following enhanced measures must be applied in addition to our standard KYC/KYB procedures:
• Prior written approval from the Chief Compliance Officer (CCO) before onboarding;
• Enhanced source of funds and source of wealth verification, including documentary evidence;
• Identification of the purpose and intended nature of the business relationship, with supporting documentation;
• Enhanced screening against all applicable sanctions lists (SECO, EU, OFAC, OFSI, UNSC), PEP databases, and adverse media;
• Increased frequency of periodic reviews (minimum every 6 months, rather than the standard review cycle);
• Enhanced transaction monitoring with lower thresholds and additional alert triggers;
• Documentation of the risk assessment and rationale for accepting the client, retained in the client file;
• Notification to the compliance team of any material changes in the client’s circumstances, activity patterns, or risk profile.
The following restricted jurisdictions impose domestic legal restrictions on cryptocurrency activities. Clients from these jurisdictions are eligible for fiat-based services only. All cryptocurrency-related services are unavailable, regardless of where the transaction originates or terminates.
These service limitations reflect applicable domestic laws and regulations in the relevant jurisdictions. Clients from these jurisdictions will be informed of the applicable service limitations during onboarding and must acknowledge them in writing before account activation.
6.1. In addition to client-level restrictions, Oxen Finance does not process any transactions (incoming or outgoing) where the counterparty, beneficiary, originator, or any intermediary is located in a prohibited jurisdiction, regardless of the client’s own jurisdiction.
6.2. Transactions involving restricted jurisdictions are subject to enhanced scrutiny, including manual review by the compliance team before processing.
6.3. Where a transaction involves a cryptocurrency wallet address associated with, or having exposure to, a prohibited jurisdiction (as identified through blockchain analytics tools), the transaction will be blocked and the client’s account may be suspended pending investigation.
7.1. Any client who provides false, misleading, or incomplete information regarding their nationality, country of residence, domicile, or place of incorporation in order to circumvent this policy may be subject to:
• Immediate suspension and/or termination of all accounts and services;
• Freezing of all funds and assets held on the Platform;
• Reporting to relevant regulatory authorities, financial intelligence units (including MROS), and law enforcement agencies;
• Legal action to recover any losses, costs, or damages incurred by Escrowfy GmbH.
7.2. Use of VPNs, proxy services, or other technical means to mask your true location in order to access services in contravention of this policy constitutes a material breach of our Terms of Use and General Terms and Conditions.
8.1. This policy is reviewed on a quarterly basis and updated promptly following:
• Publication of new or amended SECO, EU, UK, US, or UNSC sanctions;
• FATF Plenary updates to the blacklist or grey list (published in February, June, and October each year);
• Changes in domestic legislation or regulatory guidance in jurisdictions relevant to our operations;
• Material changes to our risk appetite, banking partner requirements, or business strategy.
8.2. The most current version of this policy is always available at oxen.finance/prohibited-countries. Clients are responsible for reviewing this policy periodically. Material changes will be notified to existing clients.
If you have questions about whether your jurisdiction is eligible for Oxen Finance services, or if you believe your jurisdiction has been classified incorrectly, please contact:
