Gemini is one of very few crypto businesses that operates as a chartered trust company, supervised by the New York Department of Financial Services. That structure imposes capital requirements, custody rules and examination obligations that ordinary exchanges avoid entirely, and it is the reason institutions use Gemini Custody for assets they cannot leave with an unregulated venue.
What Gemini actually is
A spot exchange with a retail app and a professional ActiveTrader interface, an institutional custody business, the GUSD stablecoin and a credit card product. Its listing policy is conservative, screened against US securities analysis, so coverage is narrower than most competitors. Security engineering is a genuine strength: SOC 1 Type II and SOC 2 Type II examinations, hardware security modules, multi-signature cold storage and insurance on the hot-wallet portion.
Gemini Earn and what it cost
In 2022, Gemini Earn lent customer assets to Genesis, which halted withdrawals when its parent group collapsed. Around $900m of customer assets were frozen, and recovery took until 2024 through bankruptcy proceedings and a settlement with the New York Attorney General, with customers ultimately made whole in kind. The custody and exchange businesses were never the problem — the product was a lending programme marketed alongside them, and many users did not distinguish. It is the clearest example in this list of why a regulated custodian's yield product is not covered by the regulation that makes its custody safe.
Fees and liquidity
The retail app charges a spread plus a flat fee that is expensive on small amounts, while ActiveTrader runs a competitive maker-taker schedule — the same two-tier structure as Coinbase, with the same advice: use the professional interface. Liquidity is modest by comparison with the majors, adequate for BTC and ETH and thin elsewhere. Asset coverage is a few dozen tokens.
Who should use Gemini
US users who want a trust-company counterparty and institutions needing regulated custody with clean audit reports. It is not the venue for active trading or for anything beyond the largest assets, and its yield products deserve the scepticism the Earn episode earned. As a place to buy and hold majors with a supervised custodian, it remains a legitimate choice.