VASPCheck

VASP Compliance Summary — Gemini

Gemini Trust Company, LLC · Custodian · United States

Exported 2026-08-25

Data reviewed 2026-08-04

Overview

Compliance snapshot

Overall regulatory statusAuthorized

EU MiCA statusMiCA application pending

NYDFS limited-purpose trust charter — qualified custodian status
MiCA CASP application pending with the Maltese regulator
Trustpilot 3.6/5 · 3,900 reviews
Earn programme settlement completed in 2024

Medium concern

New York trust charter gives strong US custody standing, but the closed Earn lending programme produced significant investor litigation and settlements.

Authorizations

Licenses & registrations

Jurisdiction	Regulator	Authorization	Status	Reference	Granted
United States (NY)	New York State Department of Financial Services NYDFS · https://www.dfs.ny.gov/virtual_currency_businesses	Limited-purpose trust charter	Authorized	NY-TC-2015-0007	2015-10-05
United States	Financial Crimes Enforcement Network FinCEN · https://www.fincen.gov/msb-registrant-search	MSB registration	Registered	31000-1131-5540	2016-02-19
Malta	Malta Financial Services Authority MFSA · https://www.mfsa.mt/financial-services-register/	MiCA CASP authorization	Pending	APP-MT-2025-0142	2025-09-11
United Kingdom	Financial Conduct Authority FCA · https://register.fca.org.uk	Cryptoasset firm registration (AML)	Registered	FRN 900988	2020-09-24

Reputation

Reputation scores

Trustpilot-style score3.6 / 5

Reviews3,900

App Store4.3

Google Play3.8

12-month trendup

Press sentiment (12m)+3 / ~4 / −3

Media

Recent press

Date	Source	Headline & summary	Sentiment
2026-06-30	Bloomberg	Custodian wins mandates from asset managers Trust-charter status was cited as the deciding factor by two managers.	Positive
2026-03-27	Reuters	Firm files for EU authorization The application targets an EU passport for custody and trading services.	Neutral
2025-12-12	Financial Times	Legacy lending claims finally closed Remaining distributions to former Earn users were completed.	Neutral
2025-10-02	CoinDesk	Fee cuts target institutional custody Custody pricing was reduced for large mandates.	Positive

Risk events

Incidents & enforcement

Date	Type	Amount	Description
2024-02-28	Enforcement	USD 1,100,000,000	Settlement with the New York regulator requiring return of assets to Earn programme customers.
2023-01-12	Enforcement	—	US securities regulator charged the Earn lending programme as an unregistered offering.

Profile

Key facts

Founded2014

Websitegemini.com

Fiat currenciesUSD, GBP, EUR

Proof of reservesYes

Custody modelQualified custody under a New York trust charter

Legal entitiesGemini Trust Company, LLC (US) · Gemini Europe Ltd (UK) · Gemini Intergalactic EU Artemis Ltd (MT)

Gemini

AuthorizedMiCA application pendingESMA register

Gemini Trust Company, LLC

Custodian🇺🇸 United States Founded 2014gemini.com

Visit website

Last reviewed

2026-08-04

Compliance snapshot

NYDFS limited-purpose trust charter — qualified custodian status
MiCA CASP application pending with the Maltese regulator
Trustpilot 3.6/5 · 3,900 reviews
Earn programme settlement completed in 2024

Overall concern

Medium concern

New York trust charter gives strong US custody standing, but the closed Earn lending programme produced significant investor litigation and settlements.

Regulatory

Licenses & registrations

Jurisdiction	Regulator	Authorization	Status	Reference	Granted
🇺🇸 United States (NY)	New York State Department of Financial ServicesNYDFS	Limited-purpose trust charter	Authorized	NY-TC-2015-0007	2015-10-05
🇺🇸 United States	Financial Crimes Enforcement NetworkFinCEN	MSB registration	Registered	31000-1131-5540	2016-02-19
🇲🇹 Malta	Malta Financial Services AuthorityMFSA	MiCA CASP authorization	Pending	APP-MT-2025-0142	2025-09-11
🇬🇧 United Kingdom	Financial Conduct AuthorityFCA	Cryptoasset firm registration (AML)	Registered	FRN 900988	2020-09-24

🇺🇸 United States (NY)
Authorized
Limited-purpose trust charter
New York State Department of Financial ServicesNYDFS
NY-TC-2015-00072015-10-05
Verify at source
🇺🇸 United States
Registered
MSB registration
Financial Crimes Enforcement NetworkFinCEN
31000-1131-55402016-02-19
Verify at source
🇲🇹 Malta
Pending
MiCA CASP authorization
Malta Financial Services AuthorityMFSA
APP-MT-2025-01422025-09-11
Verify at source
🇬🇧 United Kingdom
Registered
Cryptoasset firm registration (AML)
Financial Conduct AuthorityFCA
FRN 9009882020-09-24
Verify at source

User signals

Reputation

Trustpilot-style score

3.6/ 5

3.6

3,900 reviews

Improving (12m)

App ratings

App Store: 4.3
Google Play: 3.8

Press sentiment (12m)

Positive3

Neutral4

Negative3

Media

Recent press

2026-06-30
Custodian wins mandates from asset managersPositive
Bloomberg — Trust-charter status was cited as the deciding factor by two managers.
2026-03-27
Firm files for EU authorizationNeutral
Reuters — The application targets an EU passport for custody and trading services.
2025-12-12
Legacy lending claims finally closedNeutral
Financial Times — Remaining distributions to former Earn users were completed.
2025-10-02
Fee cuts target institutional custodyPositive
CoinDesk — Custody pricing was reduced for large mandates.

History

Incidents & enforcement

2024-02-28EnforcementUSD 1,100,000,000
Settlement with the New York regulator requiring return of assets to Earn programme customers.
2023-01-12Enforcement
US securities regulator charged the Earn lending programme as an unregistered offering.