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Is Gemini safe?

Gemini Trust Company, LLC (parent: Gemini Space Station, Inc., Nasdaq: GEMI) · Last updated Oct 19, 2026
80/100Strong signals

At a glance

80/100 · Strong signals
  • ClarityCheck score80/100 · Strong signals
  • US availabilityAvailable in the US
  • NY BitLicense / trust charterYes (NYDFS list)
  • Proof of reservesAudited filings (no PoR)
In short

NY trust company, US-listed public company, CFTC-designated exchange; 2024 NYDFS and 2025 CFTC penalties. Available across the US, including New York (NY-chartered trust company).

Score breakdown

  • US money-transmission licensing25/25
    FinCEN MSB registration (5) + state licence coverage: broad (20)
  • Higher-tier US oversight20/20
    NYDFS BitLicense/trust charter yes (10); CFTC-registered affiliate yes (5); SEC-registered broker-dealer or SEC-reporting parent yes (5)
  • Reserves & financial transparency10/20
    Audited financials filed with the SEC yes (10); proof of reserves not found (0)
  • Enforcement record (last 5 years)15/25
    Starts at 25. Criminal plea: none found (0); regulatory penalties ≥ $1M: 2 (−5 each, max −15). Dismissed or closed cases don't deduct.
  • Security incidents (last 3 years)10/10
    Starts at 10. Theft of ≥ $100M: none found; disclosed customer-data breach: none found

How the score works →

Custody

Gemini Trust Company is a New York trust company and qualified custodian (per Gemini).

Registrations & licences

4 facts
  1. Official sourceOct 19, 2026 · FinCEN

    Gemini Trust Company, LLC and Gemini Moonbase, LLC appear in FinCEN's MSB registrant list.

    FinCEN MSB Registrant Search (full registrant export) ↗
  2. Company / third-partyOct 19, 2026 · Gemini

    Gemini lists money transmitter licences (or the statutory equivalent) across US states.

    Gemini Trust Center ↗
  3. Official sourceOct 19, 2026 · NYDFS

    NYDFS lists Gemini Trust Company, LLC with a Limited Purpose Trust Charter (2015-10).

    NYDFS: Virtual Currency Businesses, regulated entities list ↗
  4. Official sourceDec 10, 2025 · CFTC

    Gemini Titan, LLC designated a contract market (DCM) by the CFTC on Dec 10, 2025.

    CFTC: DCM filing 44472, Gemini Titan, LLC ↗

EU (MiCA)

1 fact
  1. Official sourceOct 19, 2026 · ESMA

    Gemini Intergalactic EU Ltd (Malta) is an authorised MiCA CASP, notified 21/08/2025.

    ESMA interim MiCA register: authorised crypto-asset service providers (CASPS.csv) ↗

Enforcement & legal history

3 facts
  1. Official sourceFeb 28, 2024 · NYDFS

    NYDFS consent order, Feb 28, 2024: $37 million penalty over the Earn programme. Gemini committed to return at least $1.1 billion to Earn customers.

    NYDFS: Gemini to return at least $1.1 billion to Earn customers ↗
  2. Official sourceJan 6, 2025 · CFTC

    CFTC consent order, Jan 2025: $5 million penalty for misleading statements to the CFTC in 2017.

    CFTC: Gemini Trust ordered to pay $5 million ↗
  3. Official sourceJan 23, 2026 · SEC

    SEC dismissed its Gemini Earn case with prejudice on Jan 23, 2026, citing the full in-kind return of Earn investors' assets.

    SEC Litigation Release 26465 ↗

Reserves & transparency

1 fact
  1. Official sourceOct 19, 2026 · SEC EDGAR

    Public company: files audited annual reports (10-K for 2025) with the SEC. We found no Merkle-tree proof-of-reserves.

    Gemini Space Station 10-K (FY2025) ↗

Gemini questions

Is Gemini safe?

ClarityCheck scores Gemini 80/100 (Strong signals) on public regulatory and transparency signals: NY trust company, US-listed public company, CFTC-designated exchange; 2024 NYDFS and 2025 CFTC penalties. This is not a solvency rating or a guarantee.

Is Gemini available in the US?

Available in the US. Available across the US, including New York (NY-chartered trust company).

Is Gemini licensed in New York?

Yes. NYDFS lists a BitLicense or trust charter for Gemini's entity (checked Oct 19, 2026).

Not legal, financial or investment advice. The CLARITY Act is not law. Facts are from the linked sources as checked on Oct 19, 2026; please tell us if anything is out of date.