Looks interesting to me.
I didnt understand what the word "doesn't hold your funds" means, if your platform supports/acts_as escrow, it need to manage/control that funds.
What is the address/located of that company?
Basically, it's not centralised that is an exchange doesn't have total control over customers funds. If it is a multi-signature wallet, the transaction needs to be signed by both the parties. But again, in case of any unforeseen circumstances, the exchange can still hold the funds if they can't release it. Still better than the existing exchanges.