1.1. Escrowfy GmbH, operating under the Oxen Finance brand (“Oxen”, “we”, “our”), adopts a risk-based approach to the types of businesses and industries it serves. Certain industries present inherently elevated risks of money laundering, terrorist financing, sanctions evasion, regulatory non-compliance, or reputational harm. This policy sets out the industries and business activities that are prohibited or restricted across the Oxen Finance platform.
1.2. This policy applies to all prospective and existing clients, whether natural persons or legal entities, and extends to the ultimate beneficial owners, directors, and authorised representatives of such clients.
1.3. This policy is informed by the requirements of the Swiss Anti-Money Laundering Act (AMLA/GwG), VQF SRO regulations, EU Anti-Money Laundering Directives, UK Money Laundering Regulations, ADGM AML Rules, FATF Recommendations, and the internal risk appetite of Escrowfy GmbH and its banking partners.
1.4. This policy should be read in conjunction with our Prohibited and Restricted Countries Policy (OXN-POL-JRP-001), General Terms and Conditions, and AML/KYC Policy.
Industries and business activities are classified into two tiers:
Oxen Finance does not provide services to, and will not onboard, any client whose primary or substantial business activity falls within any of the categories listed below. This prohibition is absolute and applies regardless of the jurisdiction in which the client operates.
The following industries are lawful but present elevated regulatory, compliance, reputational, or operational risk. Clients operating in these sectors may be considered for onboarding subject to successful completion of Enhanced Due Diligence (EDD), verification of all required licences and authorisations, written approval from the Chief Compliance Officer (CCO), and ongoing enhanced monitoring.
Onboarding of clients in restricted industries requires a documented risk assessment retained in the client file. The assessment must be reviewed and approved by the CCO before account activation.
For all clients operating in restricted industries, the following additional measures apply beyond standard KYC/KYB procedures:
Prior written approval from the Chief Compliance Officer (CCO) before onboarding. The CCO may escalate to the Board where the risk assessment warrants it.
Verification of all licences, authorisations, and registrations required for the client’s business activity in its jurisdiction of operation. Licence copies must be retained in the client file and verified against the issuing authority’s public register where available.
Enhanced source of funds and source of wealth documentation, including audited financial statements where available, bank statements, and evidence of legitimate business revenue.
Adverse media screening covering the client, its directors, UBOs, and key personnel, with particular focus on regulatory enforcement actions, fraud allegations, and sanctions-related reporting.
Documented risk assessment setting out the specific risks identified, the mitigating factors, and the rationale for accepting the client. This assessment must be signed off by the CCO.
Increased frequency of periodic reviews: minimum every 6 months for restricted industry clients (compared to the standard 12–24 month cycle).
Enhanced transaction monitoring with sector-specific alert rules and lower thresholds calibrated to the risk profile of the industry.
Ongoing licence monitoring: the compliance team must verify at least annually that the client’s licences remain valid, in good standing, and have not been revoked, suspended, or made subject to enforcement action.
6.1. Where a client’s business spans multiple sectors, the highest-risk classification applies. If any material portion of the client’s revenue, operations, or business purpose falls within a prohibited category, the client will be declined regardless of other activities.
6.2. For clients with mixed activities that include one or more restricted sectors, all restricted-industry EDD requirements apply to the entire client relationship, not only to the restricted activity.
6.3. “Material portion” means, for the purpose of this policy, any activity that constitutes 10% or more of the client’s revenue, assets under management, transaction volume, or operational focus, or any activity that is the stated primary purpose of the business relationship with Oxen Finance.
7.1. Clients who fail to disclose, or who misrepresent, the nature of their business activities in order to circumvent this policy may be subject to:
7.2. Where a client’s business activity changes after onboarding such that it falls within a prohibited or restricted category, the client must notify Oxen Finance immediately. Failure to do so constitutes a material breach of the General Terms and Conditions.
8.1. This policy is reviewed on a semi-annual basis and updated as necessary following:
Changes in applicable law, regulation, or regulatory guidance;
Updates to banking partner or payment scheme (Visa/Mastercard) acceptability policies;
Changes to the FATF Recommendations or typology reports;
Material changes to our risk appetite or business strategy;
Regulatory enforcement actions or industry developments affecting sector risk.
8.2. The most current version of this policy is available at oxen.finance/prohibited-industries.
