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KripZen
C

Rating report

Gemini

Grade C, 2.7 out of 5

Gemini is a New York-chartered trust company available in all 50 states with $100m of disclosed custody insurance, but publishes no exchange-wide proof of reserves and paid a $37m NYDFS penalty in 2024 over its collapsed Earn programme.

By Safety Desk. Facts checked against official sources on .

Findings, check by check

Every KripZen grade comes from the same five weighted checks. Here is how Gemini scores on each.

  1. Proof of reserves 30%

    No exchange-wide proof-of-reserves programme was found. Gemini holds SOC 1 Type 2 and SOC 2 Type 2 reports, with Deloitte & Touche involved, but those are controls audits rather than reserve attestations.

    What “Proof of reserves” means

    Not disclosed

  2. Custody 25%

    Cold/hot storage split is not disclosed; we could not confirm it from a primary source.

    What “Custody” means

    Partial or unaudited

  3. Regulation 20%

    New York limited-purpose trust company charter granted in September 2015, operating in all 50 states; the February 2024 NYDFS consent order over the Gemini Earn programme carried a $37m penalty and more than $1.1bn committed back to users, alongside a $50m New York Attorney General recovery.

    What “Regulation” means

    Disclosed

  4. Insurance 15%

    Gemini Custody discloses $100m of insurance cover and Gemini operates an in-house Bermuda captive insurer; the cover is scoped to the custody product and we could not confirm it extends to retail exchange balances.

    Partial or unaudited

  5. Incident history 10%

    No confirmed breach of Gemini's own systems found in our research; the Earn programme's collapse was a lending-counterparty failure at Genesis, not an attack on the exchange.

    Disclosed

The weights are the same for every exchange. Read the full methodology

Licences and registrations

The 2 entries we could confirm for Gemini on a regulator’s register or the exchange’s own legal pages. A licence in one country does not mean the service is open to you.

RegulatorLicence or registrationRegister number
NYDFSUnited StatesNew York limited liability trust company charter (fiduciary/qualified custodian) Gemini Trust Company, LLCNMLS 1518126
State regulators (money transmitter licences, ~40 states/DC/PR)United StatesMoney transmitter licences Gemini Moonbase, LLC (Trust Co. licences listed per state)Moonbase NMLS 2403509

Fees, products and reach

Spot fees (base tier)
0.6% maker, 1.2% takerActiveTrader/API fee schedule, lowest-volume tier (>= $0 30-day volume); page states effective Sept 1, 2026. Stablecoin pairs 0.00-0.01%. Simple/app buy-sell spreads not covered.
Proof of reserves
Not found
Products
Spot, Futures, Staking, Card purchases

Base-tier fees from the exchange’s own fee page. Your real cost depends on order type, volume tier and spread; try your numbers in the Exchange Fee Calculator

Our Gemini review

Gemini is chartered as a New York trust company — a heavier regulatory standard than almost anything else in this corpus carries — and it publishes no exchange-wide proof of reserves at all. A C is what happens when the strongest possible regulator relationship sits next to a blank where the reserve evidence should be.

What checks out

The New York limited-purpose trust company charter was granted in September 2015, and Gemini operates in all 50 states on the back of it. That is a banking-style supervision regime, not a money-services registration. We found no confirmed breach of Gemini's own systems; the collapse of the Earn programme was a lending-counterparty failure at Genesis, not an attack on the exchange.

Where the evidence stops

There is no exchange-wide proof-of-reserves programme. Gemini holds SOC 1 Type 2 and SOC 2 Type 2 reports with Deloitte & Touche involved, but those are controls audits — they test whether processes work, not whether the coins are there. The cold/hot storage split is not disclosed. Gemini Custody discloses $100m of insurance cover and the company operates an in-house Bermuda captive insurer, but that cover is scoped to the custody product and we could not confirm it extends to retail exchange balances. The February 2024 NYDFS consent order over Gemini Earn carried a $37m penalty and more than $1.1bn committed back to users, alongside a $50m recovery by the New York Attorney General.

How to read the grade

A trust charter is the strongest supervisory relationship on this page, and Earn is proof that supervision does not make every product on a platform safe. Read the C as: well-regulated at the entity level, unproven at the balance level.

Sources

Every fact on this page comes from one of these official pages, checked on October 20, 2026.

  1. gemini.com/trust-center
  2. gemini.com/legal%20(footer%20product%20list:%20Perpetuals,%20Staking,%20Margin%20Trading,%20Credit%20Card);%20trust-center%20(PCI%20DSS:%20accepts%20debit%20cards)
  3. gemini.com/fees/active-trader-fee-schedule
  4. gemini.com/areas-of-availability

Where to go next

Other exchanges we've graded

How to read these grades: each is derived from published, checkable disclosures — proof-of-reserves attestations, public regulatory registers, disclosed insurance funds and the documented incident record — using the weighted rubric below. Where an exchange does not disclose something, we mark it unverified rather than assume it. These are not audits and not investment advice; they reflect what was published as of our last review. Cryptocurrency investments carry risk, including loss of principal. Nothing on KripZen is financial advice — always do your own research before buying, trading or moving funds.