Marketplace How It Works About Fees
Sign In Join the Beta
Compliance & Legal

Compliance by
architecture.

VaultRunner is designed so that compliance is not a layer added on top of the platform. It is the platform. Every structural decision, from payment routing to metal custody, reinforces the regulatory framework under which VaultRunner operates.

Effective Date: March 20, 2026 Last Updated: March 20, 2026
Classification AML Policy Identity Verification Privacy Terms of Service Tax Reporting Disputes
01

Platform
Classification.

Marketplace Facilitator — Not a Dealer, Broker-Dealer, or Money Transmitter

VaultRunner LLC is a Wyoming limited liability company that operates as a technology-enabled marketplace facilitator. The platform connects verified buyers and sellers of physical precious metals stored at COMEX-approved third-party depositories. VaultRunner earns revenue solely through facilitation fees charged when a transaction completes successfully.

VaultRunner does not take custody of metals or funds at any point in a transaction. This is not a policy choice made for convenience. It is a structural architecture that defines how the platform is classified under federal and state regulatory frameworks.

Structural Architecture
Zero-Custody Model
Buyer payments are routed exclusively through a licensed, regulated third-party escrow provider. Metal remains at the depository and title transfers at the vault level. VaultRunner issues transfer instructions only after the escrow provider confirms that funds are secured. At no point does VaultRunner hold, control, or have access to buyer funds or seller metals.

Payment Processing

All buyer payments flow through a licensed, regulated internet escrow provider. The escrow provider holds funds on behalf of the buyer until the depository confirms that title to the metal has been transferred. Funds are released to the seller only after the buyer acknowledges receipt of the re-titled metal in their depository account. VaultRunner has zero access to buyer funds at any stage of the transaction.

Metal Custody

Metal listed on VaultRunner is pre-authenticated and physically present at a nationally regulated, COMEX-approved partner depository before any listing goes live. When a sale completes, VaultRunner transmits a transfer instruction to the depository directing them to re-title the metal from the seller's account to the buyer's account. The metal itself does not move. VaultRunner never takes physical possession or legal custody of any precious metal.

Regulatory Framework

VaultRunner's zero-custody architecture is designed so that payments flow between buyer and seller through an independent, licensed escrow provider, and metal custody remains with independent, regulated depositories. This structural separation is central to VaultRunner's position that the platform does not engage in the transmission of money, does not act as a dealer buying and selling metals from its own inventory, and does not function as a broker-dealer of securities.

VaultRunner maintains ongoing review of its regulatory posture as the platform evolves and as federal and state guidance develops. The platform's compliance approach is supported by its operational architecture and is subject to review by qualified legal counsel.

02

Anti-Money
Laundering Policy.

Transaction Monitoring & Reporting Procedures

VaultRunner maintains anti-money laundering procedures consistent with its classification as a marketplace facilitator and with the requirements applicable to platforms operating in the precious metals sector. These procedures are active from the platform's first transaction.

Core Commitment
Compliance Is Not Optional
VaultRunner's AML program is designed to detect, deter, and report suspicious activity. The platform cooperates fully with law enforcement and regulatory authorities when required by applicable law. Users who attempt to use the platform for illicit purposes will be removed and reported.

Transaction Monitoring

The platform monitors all transactions for patterns consistent with money laundering, structuring, or other suspicious activity. Monitoring criteria include but are not limited to: unusual transaction size relative to account history, rapid sequential transactions, transactions structured to avoid reporting thresholds, and activity inconsistent with the user's stated purpose.

Suspicious Activity Reporting

When the platform identifies activity that meets applicable reporting criteria, VaultRunner files reports with the appropriate regulatory authorities in accordance with federal law. The platform does not notify users when a report has been filed.

Recordkeeping

VaultRunner maintains records of all transactions, identity verification documents, and monitoring activity for the periods required by applicable law. Records are stored securely and are accessible to authorized regulatory or law enforcement personnel upon lawful request.

Program Oversight

VaultRunner's AML procedures are reviewed on a regular basis and updated as regulatory guidance, platform operations, or transaction patterns evolve. The platform designates a compliance officer responsible for oversight of the AML program.

03

Identity
Verification.

Know Your Customer (KYC) Requirements

Every user who transacts on VaultRunner must complete identity verification before any purchase or sale. This is a one-time process that protects both buyers and sellers on the platform. You must be at least 18 years of age to create an account and transact on VaultRunner.

What Is Required

Age Requirement
You must be at least 18 years of age. Age is verified during the identity verification process using your government-issued identification and date of birth. Accounts that do not meet this requirement will not be approved.
Full Legal Name
As it appears on government-issued identification.
Date of Birth
Used for identity matching and verification.
Residential Address
Current physical address; P.O. boxes are not accepted as a primary address.
Government ID
A valid, unexpired government-issued photo identification (state driver's license, state ID card, or U.S. passport).
SSN / TIN
Required for tax reporting and identity verification purposes under federal law.

Verification Process

Identity verification is completed during account registration. The platform uses automated identity-matching systems to verify submitted information against authoritative databases. In some cases, manual review may be required. Accounts that cannot be verified are not permitted to transact.

Enhanced Due Diligence

VaultRunner reserves the right to request additional documentation or information from any user when transaction patterns, account characteristics, or regulatory requirements warrant enhanced review. Enhanced due diligence may include, but is not limited to, source-of-funds verification, additional identification documents, or in-person verification.

User Protection
Verification Protects Everyone
Identity verification is not a bureaucratic hurdle. It ensures that every counterparty on the platform is a confirmed, real individual. Buyers know they are purchasing from a verified seller. Sellers know that payment is backed by a verified buyer. The one-time verification process protects the integrity of every transaction on the marketplace.
04

Privacy
Policy.

How VaultRunner Collects, Uses, and Protects Your Information

VaultRunner collects only the information necessary to operate the marketplace, verify user identity, comply with applicable law, and protect the security of the platform. The platform does not sell, rent, or trade personal information to third parties for marketing purposes.

Information Collected

Account information: Name, email address, physical address, date of birth, phone number, government-issued identification, and Social Security Number or Tax Identification Number as required for identity verification and tax reporting.

Transaction information: Records of listings created, purchases made, sale proceeds, escrow references, depository transfer confirmations, and associated timestamps.

Technical information: IP address, browser type, device information, and session data collected automatically when using the platform. This information is used for security monitoring, fraud prevention, and platform improvement.

How Information Is Used

Personal information is used to verify identity, process transactions, facilitate communication between parties to a transaction (where necessary), comply with legal and regulatory requirements, monitor for fraud or suspicious activity, and improve platform functionality. VaultRunner does not use personal information for targeted advertising or sell it to data brokers.

Information Sharing

VaultRunner shares personal information only in the following circumstances:

Escrow provider: Transaction and identity information necessary for the escrow provider to process payments and comply with its own regulatory obligations.

Depository partners: Account and identity information necessary to open depository accounts, process title transfers, and comply with depository regulatory requirements.

Law enforcement and regulators: Information disclosed in response to valid legal process, including subpoenas, court orders, or regulatory examinations, or as otherwise required by applicable law.

Service providers: Limited information shared with providers who perform services on behalf of VaultRunner (such as identity verification providers), subject to contractual obligations regarding confidentiality and use.

Data Security

VaultRunner implements industry-standard security measures to protect personal information. Identity data and sensitive fields (such as Social Security Numbers and government ID images) are encrypted at rest using AES-256 encryption and in transit using TLS 1.3. Access to personal information is restricted through role-based access controls with least-privilege principles, and all access to sensitive data is logged for audit purposes. Multi-factor authentication is required for all personnel accessing systems that contain user PII. The platform maintains continuous security monitoring, incident response procedures, and periodic security assessments appropriate to the sensitivity of the data it holds.

Data Retention

VaultRunner retains personal information and transaction records for the following periods: account information, identity verification documents, and transaction records are retained for five years after account closure, consistent with Bank Secrecy Act recordkeeping requirements. Technical and session data is retained for 12 months. AML monitoring records are retained for five years from the date of creation. When retention periods expire, data is securely deleted using cryptographic erasure. Users may request information about the data VaultRunner holds about them by contacting privacy@vaultrunner.com.

Your Rights

You may request access to the personal information VaultRunner holds about you, request correction of inaccurate information, or request deletion of your account and associated personal information (subject to legal retention requirements). Requests should be directed to privacy@vaultrunner.com. VaultRunner will respond within 30 days.

Cookies and Tracking

The platform uses essential cookies required for site functionality and security. VaultRunner does not use third-party advertising trackers. Analytics data, when collected, is used exclusively for platform improvement and is not shared with advertising networks.

05

Terms of
Service.

Governing Agreement for Platform Use

By creating an account or using the VaultRunner platform, you agree to the following terms. If you do not agree to these terms, do not use the platform.

Platform Role

VaultRunner operates as a marketplace facilitator. It provides the technology infrastructure that connects buyers and sellers of physical precious metals. VaultRunner is not a party to any transaction between buyers and sellers. The platform does not guarantee the outcome of any transaction, does not set prices, and does not provide investment advice.

Eligibility

Users must be at least 18 years of age, a legal resident of the United States, and capable of entering into a legally binding agreement. Users must successfully complete identity verification before transacting. VaultRunner reserves the right to refuse service to any individual or entity at its sole discretion.

User Obligations

Users agree to provide accurate, complete, and current information during registration and throughout their use of the platform. Users are responsible for maintaining the security of their account credentials. Users agree not to use the platform for any unlawful purpose, including but not limited to money laundering, fraud, tax evasion, or sanctions violations.

Listing Accuracy

Sellers are responsible for ensuring that all listing information is accurate, including metal type, weight, purity, condition, and depository location. VaultRunner verifies that metal is present and authenticated at the depository before a listing goes live, but the seller remains responsible for the accuracy of their listing description.

Fees

VaultRunner charges a facilitation fee of 1.5% to sellers and 0.75% to buyers on completed transactions. Fees are deducted at the time of settlement. The complete fee schedule, including escrow and depository-related costs, is available on the Fee Schedule page. VaultRunner reserves the right to modify its fee schedule with advance notice to registered users.

Transaction Finality

Once a buyer confirms receipt of re-titled metal in their depository account and the escrow provider releases funds to the seller, the transaction is final. VaultRunner does not offer refunds on completed transactions. Disputes arising before transaction completion are handled through the escrow provider's dispute resolution process.

Platform Availability

VaultRunner endeavors to maintain continuous platform availability but does not guarantee uninterrupted access. The platform may be temporarily unavailable for maintenance, updates, or circumstances beyond VaultRunner's control. VaultRunner is not liable for losses resulting from platform downtime.

Limitation of Liability

VaultRunner's aggregate liability arising from or related to any user's use of the platform is limited to the total facilitation fees paid by that user in the twelve (12) months preceding the event giving rise to the claim. VaultRunner is not liable for losses arising from market fluctuations, depository operations, escrow provider actions, user error, or circumstances outside VaultRunner's reasonable control. The platform is provided on an "as is" and "as available" basis without warranties of any kind, express or implied.

Indemnification

You agree to indemnify, defend, and hold harmless VaultRunner LLC, its members, officers, employees, and agents from any claims, damages, losses, or expenses (including reasonable attorneys' fees) arising from your violation of these Terms, your use of the platform, any listing you create or transaction you enter into, or your violation of any applicable law or regulation.

Governing Law

These Terms of Service are governed by the laws of the State of Wyoming. Any disputes arising from use of the platform that are not resolved through the dispute resolution process described below shall be subject to the exclusive jurisdiction of the courts located in Wyoming.

Modifications

VaultRunner reserves the right to modify these Terms of Service at any time. Material changes will be communicated to registered users via email and posted on this page with an updated effective date. Continued use of the platform after modifications constitutes acceptance of the revised terms.

Severability

If any provision of these Terms of Service is found to be unenforceable by a court of competent jurisdiction, the remaining provisions shall continue in full force and effect.

06

Tax
Reporting.

Information Reporting Obligations

VaultRunner provides transaction records to support users in meeting their federal and state tax obligations. VaultRunner does not provide tax advice. Users are responsible for determining and fulfilling their own tax reporting requirements. Consult a qualified tax professional for guidance specific to your situation.

Transaction Records

The platform maintains detailed records of every completed transaction including: date of sale, metal type and quantity, sale price, fees paid, and net proceeds. These records are accessible to users through their account dashboard and can be downloaded for tax preparation purposes.

IRS Reporting (Form 1099-B)

Under IRS rules, certain precious metals transactions are subject to Form 1099-B reporting when they meet specific thresholds defined by the Commodity Futures Trading Commission (CFTC) and IRS Revenue Procedure 92-103. Reporting is required only for transactions that meet or exceed the minimum quantity for a CFTC-approved regulated futures contract in the same metal form. Most fractional coin transactions (such as 1 oz American Gold Eagles or fractional gold coins) do not meet these thresholds and are not reportable.

When a reportable transaction occurs, VaultRunner will issue Form 1099-B to both the seller and the IRS by the deadline required under federal law. Sellers will be notified when a reportable event occurs. VaultRunner aggregates sales by the same user within any 24-hour period for threshold purposes, consistent with IRS requirements.

Cash Reporting (Form 8300)

Federal law requires reporting of cash payments exceeding $10,000 in a single transaction or related transactions within 24 hours. Because all VaultRunner payments are processed through a licensed escrow provider via bank wire or ACH transfer, cash payment obligations are not expected to arise in normal platform operations.

Important
VaultRunner Does Not Provide Tax Advice
Tax treatment of precious metals transactions varies by metal type, holding period, transaction size, and individual circumstances. Precious metals may be subject to the 28% collectibles tax rate or standard capital gains rates depending on your specific situation. VaultRunner provides transaction records only. The platform does not determine cost basis, calculate capital gains, classify holding periods, or advise on reporting obligations. Users should consult a qualified tax professional. The Documents & Tax section of your account provides downloadable transaction records for tax preparation.
07

Dispute
Resolution.

How Disputes Are Handled

Because all payments are held by a licensed, regulated escrow provider until both parties confirm satisfaction, the vast majority of transactions complete without dispute. When issues arise, the following process applies.

Before Transaction Completion

If a dispute arises before the buyer has confirmed receipt of re-titled metal, the escrow provider holds all funds. No metal is transferred and no payment is released until the dispute is resolved. The escrow provider's dispute resolution procedures govern the process, and VaultRunner cooperates fully by providing transaction records and depository confirmation data.

After Transaction Completion

Once the buyer confirms receipt and the escrow provider releases funds, the transaction is final. VaultRunner does not reverse completed transactions. If a user believes a completed transaction involved fraud or misrepresentation, VaultRunner will investigate and, if warranted, take action including account suspension or termination and referral to appropriate authorities.

Platform-Level Disputes

Disputes regarding VaultRunner's platform fees, account status, or policies should be directed to compliance@vaultrunner.com. VaultRunner will respond within five business days. If a dispute cannot be resolved through direct communication within thirty (30) days, the parties agree to pursue resolution through binding arbitration in the State of Wyoming in accordance with the rules of the American Arbitration Association. The arbitrator's award shall be final and binding. Each party shall bear its own costs and attorneys' fees unless the arbitrator determines otherwise.

Contact

For compliance inquiries, privacy requests, or general questions about the policies described on this page:

Entity
VaultRunner LLC, a Wyoming limited liability company

Built to operate
the right way.

VaultRunner is currently in beta development. Register now to be among the first buyers and sellers on the platform when the marketplace opens. Early registrants receive priority access.