Prohibited and Restricted
Countries and Territories

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.

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.

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.

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: