AML & KYC Policy Summary

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:

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:

• Client type (individual, corporate, trust, foundation, complex structure);
• Country of residence, incorporation, and operational jurisdictions (see our Prohibited and Restricted Countries Policy);
• Industry and business activity (see our Prohibited and Restricted Industries Policy);
• PEP status (Politically Exposed Persons, including family members and close associates);
• Expected transaction volume, frequency, and patterns;
• Source of funds and source of wealth transparency;
• Adverse media and public record findings.

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.

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:

• Provide accurate, complete, and truthful information during onboarding and throughout the business relationship;
• Promptly notify us of any changes to your personal information, residential address, corporate structure, beneficial ownership, or business activity;
• Respond to requests for additional information or documentation in a timely manner;
• Not use the platform for money laundering, terrorism financing, sanctions evasion, tax evasion, fraud, or any other illegal purpose;
• Not structure transactions or activity in a way designed to avoid reporting thresholds or circumvent our monitoring controls;
• Not provide false, misleading, or forged documentation;
• Cooperate with our compliance team in connection with any review, investigation, or request for information.

‍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: