AML / KYC Policy

Document information

1. Purpose and statement of commitment

Marriage4Life Consulting AS (“the Firm”) is a professional services firm registered in Norway providing legal and advisory consulting connected to marriage-related processes, including document verification, prenuptial and marriage agreements, contract drafting, and structured advisory consultations.

The Firm is committed to preventing its services from being used for money laundering, terrorist financing, sanctions evasion, fraud, or any other form of financial crime. This policy sets out the standards and procedures the Firm applies to identify its clients, assess and manage financial crime risk, and meet its legal and ethical obligations.

This policy has been adopted by the Board and applies on a mandatory basis to all directors, employees, consultants, and professionals engaged by the Firm, across all offices and all onboarding channels.

2. Regulatory framework

The Firm's programme is designed to be consistent with the following frameworks:

The Norwegian Anti-Money Laundering Act of 1 June 2018 No. 23 (hvitvaskingsloven) and associated regulations.

The EU Anti-Money Laundering Directives as implemented in EEA law.

The UK Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as amended, in respect of UK-facing activity.

The Financial Action Task Force (FATF) Recommendations.

Applicable financial sanctions regimes, including those administered by the UN Security Council, the UK Office of Financial Sanctions Implementation (OFSI/HMT), the US Office of Foreign Assets Control (OFAC), the EU, and Norwegian authorities.

Where the Firm's activities are not themselves within the mandatory scope of a given regime, the Firm applies these standards voluntarily as a matter of best practice and risk management.

3. Scope

This policy applies to all client relationships and engagements of the Firm, including fixed-price packages, standalone consultations, and tailored engagements, regardless of value, client location, or onboarding channel (in person, video, telephone, or online).

4. Governance and responsibilities

The Board of Directors holds ultimate responsibility for this policy and for the Firm's financial crime risk appetite. The Board approves this policy and each revision, and receives a compliance report at least annually covering screening outcomes, escalations, suspicious activity reports, and training completion.

The role of Money Laundering Reporting Officer (MLRO) and Compliance Officer is held by Bilal Akhtar. The MLRO is responsible for implementing and maintaining this policy and its supporting procedures; approving high-risk client relationships, including all relationships requiring enhanced due diligence; receiving and assessing internal reports of suspicious activity and making external reports where required; maintaining the Firm's business-wide risk assessment and screening arrangements; and ensuring staff and engaged professionals receive appropriate training.

All personnel are responsible for following this policy and for escalating concerns to the Compliance Officer without delay. No client may be onboarded, and no service delivered, in contravention of this policy.

5. Business-wide risk assessment

The Firm maintains a business-wide assessment of its money laundering and terrorist financing risk, summarised below, which is reviewed at least annually and upon any material change to the Firm's services, markets, or client base.

6. Client due diligence (CDD)

The Firm applies client due diligence before any engagement is confirmed and before any professional work is performed. No services are delivered to unverified clients. Standard CDD comprises: identification of the client (full legal name, date of birth, nationality, and residential address); verification of identity using a valid government-issued photographic identity document (passport or national identity card); screening against sanctions and politically exposed person (PEP) lists as set out in section 8; and understanding the purpose and intended nature of the engagement, recorded in the written terms of engagement signed by the client.

Where the client acts on behalf of another person, the Firm identifies and verifies that person and the basis of the authority before proceeding. The Firm does not accept engagements where the identity of the true client cannot be established.

Where a client cannot be satisfactorily identified, declines to provide required documentation, or provides documentation the Firm believes to be false, the Firm will not establish the relationship and will terminate any existing engagement. The Firm will consider whether a report to the relevant authority is required. Engagements may be terminated without refund of work already performed where falsified documents or materially false information are provided, in accordance with the Firm's Terms of Service.

7. Identity verification procedures

Identity verification is conducted through both electronic and manual processes, applied consistently regardless of onboarding channel.

Electronic verification: clients submit a government-issued identity document together with a live photograph (selfie). The document is checked for authenticity and validity, and the live image is matched to the document photograph (liveness confirmation).

Manual verification: where electronic verification is not used or is inconclusive, identity documents are reviewed by trained personnel, and in-person or video presentation of the original document may be required.

In-person onboarding: original documents are inspected at the Firm's offices and copies retained on file.

Verification must be completed before service delivery begins. Where verification cannot be completed, the engagement is declined or paused, and the matter is escalated to the Compliance Officer where the circumstances give rise to suspicion.

8. Sanctions and PEP screening

All clients are screened at onboarding against the following lists, and re-screened periodically and upon any material change to the engagement: UK HM Treasury / OFSI Consolidated List of Financial Sanctions Targets; United Nations Security Council Consolidated List; US OFAC Specially Designated Nationals and Blocked Persons List; EU Consolidated List of Persons, Groups and Entities Subject to Financial Sanctions; and recognised politically exposed persons (PEP) databases.

A confirmed sanctions match results in immediate refusal or suspension of the engagement, no movement of funds, and escalation to the Compliance Officer for assessment of reporting obligations to the relevant authorities. Potential matches are resolved before any further work is performed.

A confirmed PEP match does not automatically preclude an engagement but requires senior management approval, establishment of source of wealth and source of funds, and enhanced ongoing monitoring.

9. Enhanced due diligence (EDD)

Enhanced due diligence is applied in the circumstances set out below.

10. Geographic risk

The Firm's primary markets are the United Kingdom, Norway, and Pakistan, with additional clients served internationally. The Firm treats jurisdictions identified by FATF as subject to increased monitoring, and jurisdictions subject to comprehensive sanctions, as higher-risk.

Clients resident in, onboarding from, or paying from higher-risk jurisdictions are subject to enhanced due diligence regardless of engagement value. The Firm does not enter into engagements with clients in jurisdictions subject to comprehensive international sanctions.

For the avoidance of doubt: all engagements at or above GBP 1,000 (or equivalent), and all clients connected to higher-risk jurisdictions including Pakistan irrespective of value, are subject to enhanced due diligence. Given the Firm's package pricing, this means the substantial majority of package engagements are subject to EDD as standard.

11. Source of funds

For all engagements subject to enhanced due diligence, the client provides a written confirmation of the source of the funds used to pay for the engagement (for example, salary, savings, family support, or business income), supported by documentary evidence where the value, jurisdiction, or circumstances warrant it. Payments that are inconsistent with the stated source of funds are escalated before acceptance.

12. Payment controls

The Firm currently accepts payment by bank transfer and intends to introduce card payments through a regulated payment provider. The following controls apply to all payment methods:

Payments are accepted only from accounts held in the client's own name; third-party payments are declined unless the relationship and rationale are documented and approved by the Compliance Officer.

The Firm does not accept cash.

Refunds are returned only to the original payment method and original payer, in accordance with the Firm's published Refund and Cancellation Policy.

Overpayments and requests to redirect funds to third parties are treated as red flags and escalated.

13. Ongoing monitoring

Client relationships are monitored on an ongoing basis to ensure that activity remains consistent with the Firm's knowledge of the client. Monitoring includes review of engagement scope changes, repeat purchases, payment patterns, and periodic re-screening against sanctions and PEP lists. Identification documents are refreshed where they expire during a continuing relationship or where doubts arise as to their veracity.

Specific transaction monitoring triggers include: payments materially exceeding the contracted package value; multiple payments structured beneath the GBP 1,000 EDD threshold; payments from accounts in names other than the client's; and refund requests submitted unusually quickly after payment. Any triggered concern is escalated to the MLRO before processing continues.

14. Suspicious activity reporting

All personnel must report knowledge or suspicion of money laundering, terrorist financing, or sanctions evasion to the Compliance Officer immediately, using the Firm's internal reporting procedure. The Compliance Officer assesses each internal report and, where the legal threshold is met, submits a report to the relevant authority — in Norway, Økokrim (the Norwegian National Authority for Investigation and Prosecution of Economic and Environmental Crime); in the UK, the National Crime Agency — and to any other competent authority as required.

Personnel must not disclose to a client that a report has been made or is being considered (no tipping off). Where suspicion arises before onboarding is complete, the engagement is not progressed.

15. Record keeping

The Firm retains the following records for a minimum of five years from the end of the client relationship or the completion of the engagement, whichever is later, and for longer where required by law or by professional obligations: identity documents and verification records, including screening results; enhanced due diligence records, including proof of address and source of funds confirmations; signed terms of engagement, deliverables, and case files; payment records, refund records, and related correspondence; and internal and external suspicious activity reports and the analysis supporting them.

Records are stored securely with access restricted to authorised personnel, and are processed in accordance with the Firm's Privacy Policy and applicable data protection law, including the GDPR.

16. Training

All directors, employees, and engaged professionals receive training on this policy at induction and at least annually thereafter, covering identification and verification procedures, sanctions and PEP screening, red flags relevant to the Firm's services, and internal reporting obligations. Training records are maintained by the Compliance Officer.

17. Third-party verification providers

Where the Firm uses external electronic identity verification or sanctions screening providers, the Firm remains fully responsible for compliance with this policy. Providers are assessed for reliability and regulatory standing before use. The Firm retains the underlying verification evidence and does not rely solely on a provider's pass or fail conclusion. Any change of provider is approved by the MLRO.

18. Policy review and approval

This policy is reviewed at least annually by the MLRO and approved by the Board. It is reviewed earlier upon any material change in the Firm's services, client base, payment channels, or the applicable legal and regulatory framework. Breaches of this policy are treated as a serious disciplinary matter and may also constitute a criminal offence under applicable law.

Approved by: Amina Nazir, Managing Director and Chair of the Board, Marriage4Life Consulting AS. Policy Owner / MLRO: Bilal Akhtar. Effective Date: June 2026. Review Date: June 2027.