The one thing that says not CX to me is the indent in the outside of the R chainstay is in the wrong place. It seems to be placed for a small chainring, like a touring bike.

When a CX bike had chain guards on both sides of the ring (though not all did of course), the indent had to clear the inner chain guard, which is bigger than the chainring. Needing a chainstay indent much further from the BB end.

Well, with fender eyes, make that two things.