- Partner agreements specify referral compensation per engagement.
- Compensation is paid by Elegasea, not by the principal.
- All partner economics are disclosed to the principal at intake.
ELEGASEA
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PARTNER COMPLIANCE BRIEF
What Compliance Needs to Know.
A factual disclosure document for advisor compliance teams evaluating the Elegasea Partner Network.
Last reviewed: 2026-05-02
AT A GLANCE
- Entity
- Elegasea LLC, Delaware
- Regulatory Status
- Private membership & concierge network. Not a broker-dealer or RIA.
- Partner Compensation
- Disclosed as referral fees, structured per partner agreement. 1099-NEC issued annually for US partners.
- Data Handling
- US-East AWS isolated tenancy. EU data residency available. CCPA + GDPR-aligned.
- Conflicts Posture
- Partner attribution is contractual. Clients remain attached to referring advisor.
PARTNER ECONOMICS
How partner economics work.
Documented service-provider compensation. No client-facing fees. No gifts. No tipping.
- US-resident partners receive 1099-NEC for compensation ≥$600/year.
- Non-US partners are responsible for their own tax compliance under their jurisdiction.
- W-9 collected at partner onboarding.
- Elegasea does not provide investment advice.
- Partners do not provide investment advice through Elegasea.
- Asset transactions (yacht, real estate, aviation acquisition) run through licensed and regulated operators.
ANTI-TIPPING & FINRA
For FINRA-registered advisors: Elegasea referral economics are not gifts and not entertainment. They are documented service-provider compensation paid by the platform, disclosed to the principal at intake, and reportable as 1099-NEC income. Elegasea does not require, request, or accept compensation from the principal flowing to the partner.
Partner-to-Elegasea referral compensation is structured to be compliant with FINRA Rule 3220 (Influencing or Rewarding Employees of Others) gifting limits when the referral compensation is documented as service compensation rather than gift.
This document is informational. It does not constitute legal advice. Each advisor should review with their own compliance officer.
DATA & PRIVACY
Where principal data lives — and how it leaves.
Where client data lives.
Elegasea principal and partner data is stored in US-East AWS regions with isolated tenancy. EU data residency is available upon request for European principals. We do not share principal data with operators except on a per-engagement, per-asset basis with explicit consent.
Right to be forgotten.
Members and partners may request full data deletion at any time via corporate@elegasea.com. We honor GDPR Article 17 and CCPA equivalents within 30 days.
Audit trail.
All asset access, room views, and concierge interactions are logged with timestamp, partner attribution, and principal consent record. Partners and principals can request a full audit trail of any engagement.
FOR COMPLIANCE TEAMS
Download a one-page version for internal review.
We've prepared a single-page PDF of this brief, formatted for compliance review. Bring it to your team.
CONTACT COMPLIANCE
- Mailing
- Elegasea LLC
Available upon request via compliance inquiry
Delaware, USA - Response Time
- We respond to advisor compliance inquiries within 1 business day.