Compliance · Albert Connect
Version 1.0
6 October 2026
Reviewed every year
What Albert Connect does, what it does not do, and who carries the regulated payment activity.
Albert Connect Company is a marketplace operator, not a payment entity. Everything that is a regulated payment activity is delegated to its payment provider, Tazapay.
01 · Purpose and scope
This document describes the procedures Albert Connect Company ("Albert") applies to know who uses its marketplace, to keep a record of what is traded on it, and to detect and escalate suspicious activity. It applies to every partner account, every listing and every deal on Albert Connect, and to every member of Albert's team.
Albert is not a bank, a money services business, a money transmitter or any other financial institution, and this document is not a regulated anti-money laundering program of the kind required of such institutions. It is the set of controls that a marketplace operator of our size applies to its own platform.
02 · What Albert is
Albert Connect is a closed, business-to-business marketplace for concierges and luxury service professionals. A partner posts what a client needs, or what they have to offer; other partners answer with a price; the two agree in writing. Albert earns a service fee of 3% of the value of a deal concluded on the platform.
Albert Connect Company is not a payment entity. It is not a bank, a payment institution, a money services business, a money transmitter, an escrow agent or a wallet provider, and it holds no licence of that kind. Everything that is a regulated payment activity is delegated to its payment provider, Tazapay.
What Albert does
Operates the marketplace software: accounts, listings, offers, agreements between two professionals.
Reviews and approves every partner before they can trade, and can suspend an account.
Keeps the written record of each deal: listing, offers, agreement, quote, invoices.
Invoices and collects its own 3% service fee.
Monitors activity on the platform for the warning signs listed in section 6 and escalates them.
What Albert does not do
It does not sell the service. Albert is an intermediary between two professionals, never the seller, and has no relationship with the partners' end clients.
It does not open, hold or operate accounts, balances or wallets for partners or for their clients.
It does not receive, hold, safeguard or transmit partners' or clients' funds in its own name or in its own bank accounts.
It does not carry out currency exchange, cross-border transfers or payouts itself.
It does not perform regulated customer due diligence, sanctions screening or transaction monitoring on payments: the payment provider does.
03 · Payments
Who does what
Payments between partners are collected, held, converted and paid out by Tazapay, a licensed third-party payment provider, under its own licences and in its own name. Tazapay applies its own customer due diligence (KYC for individuals, KYB for companies), sanctions screening and transaction monitoring to every payer and payee, and decides whether a payment or a payout may proceed. Albert sends Tazapay the details of an agreed deal and follows its decisions.
Verification before payout
A partner cannot receive a payout until Tazapay has verified their identity and, for a company, its ownership.
Tazapay's licences
Tazapay US Corp. is registered as a Money Services Business with the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of the Treasury, and Tazapay Pte. Ltd. holds a Major Payment Institution licence from the Monetary Authority of Singapore. The current list is published by Tazapay at tazapay.com/licenses.
04 · Onboarding of partners
Closed network
Nobody can trade on Albert Connect without an approved account. There are no anonymous or guest accounts for trading.
Application
Each applicant states who they are, their company, their role, their city and country, and a contact number.
Human review
Every application is read and decided by a member of Albert's team. Who may approve which kind of application is fixed by role in the system and enforced by it, not left to the reviewer.
Terms of Use
Before using the marketplace, each partner accepts the Albert Connect Terms of Use. The version accepted, the date and the account are recorded. When a new version is published, every partner must accept it again before continuing. The Terms set out what may and may not be traded and require partners to act lawfully in their own jurisdiction.
Professional profile
Each partner completes a professional card (activity, places covered, what they can provide) before taking part in a deal.
Bank details
A partner who wants to be paid records bank details in their own name or their company's name.
05 · Records of activity
Every step of a deal is written and kept: the listing, each offer and counter-offer with its amounts, the agreement between the two partners, the quote, and the invoices, each numbered. Amounts used for documents and fees are read from the agreed terms held by the system, not from what a user's device sends. Changes to requests are logged. These records are kept for at least five years after the end of the relationship with a partner.
06 · Monitoring
Designated team members with an oversight role can see all listings, offers and deals. Listings pass an automated content check when they are posted. Partners can report or block another partner from within the product, and reports are reviewed by the team. The team treats the following as warning signs that call for a review of the account and of the deal:
A deal whose price bears no relation to the service described, or a service that cannot plausibly be delivered.
A request to pay or be paid by a third party unrelated to the deal, or in a country unrelated to either partner.
Repeated deals between the same two accounts with no visible service, or deals cancelled and re-created at different amounts.
A partner who refuses to say who they are, who gives information that does not match, or who appears to act for somebody else without saying so.
Pressure to move a payment off the record, to split it without reason, or to use cash or crypto-assets.
A link to a person, entity or country subject to sanctions.
07 · Sanctions and escalation
Albert does not knowingly admit or keep as a partner any person or entity that is subject to United States, United Nations, European Union or United Kingdom sanctions, or that is resident in a comprehensively sanctioned country or territory. The country of each applicant is recorded at application and checked by the reviewer. Screening of payers and payees against sanctions lists is performed by the payment provider on every payment it processes.
Report
Any team member who notices a warning sign reports it to the compliance lead the same day.
Review and suspend
The compliance lead reviews the account and the deal, and may suspend the account immediately. A suspended account cannot post, answer or conclude deals.
Payment provider
Where a payment through the payment provider is concerned, Albert informs the provider and follows its instructions.
Authorities
Albert cooperates with lawful requests from competent authorities and keeps a written record of each review and of its outcome.
08 · Team and document
Access to partner data and to oversight functions is granted by role and limited to those who need it. Every team member with such access reads this document when they join and after each revision.
Company
Albert Connect Company, a Delaware corporation (file number 10768163), 131 Continental Dr, Suite 305, Newark, Delaware 19713, United States.
Compliance lead
Arthur Dimeglio, Co-Founder and Chief Technology Officer.
Approved by
Romain Sihou, Co-Founder and Chief Executive Officer.
Version
1.0, 6 October 2026. Reviewed at least once a year, and whenever the payment arrangements or the business model change.
Questions
Through the contact form.