Gemini: what the sources say

Regulation, reserves, fees

Reserves note: No exchange-wide proof-of-reserves page found in the searches run. Gemini sponsored a Chainlink Proof of Reserve feed for the wrapped Filecoin (eFIL) token only (2021 blog); that is not an exchange PoR.

Incidents and regulator actions found

Security incidents

• 2022-11 Genesis, the unrelated lender behind Gemini's Earn programme, halted redemptions; Genesis filed for bankruptcy January 2023. About 232,000 Earn users lost access to about $1.05 billion in digital assets. Outcome: Per Gemini's SEC prospectus: global settlement approved 2024-04-19; Earn users received coin-for-coin in-kind recovery (about $2.18 billion distributed 2024-05-29, remainder 2024-06-20). Access was lost for about 18 months, not permanently. source
• 2024-06 (breach 3-7 Jun 2024; notices from 2024-06-26) Breach at a third-party ACH service provider exposed full names, bank account and routing numbers of about 15,000 Gemini customers. Gemini stated no evidence of customer impact beyond this data; other personal data and credentials were reportedly not compromised. Reported by BleepingComputer. Outcome: Affected customers notified by Gemini; no crypto fund loss reported in the article. source

Regulator and court actions

• 2024-02-28 NYDFS: Consent order on safety and soundness issues of the Earn programme and governance/compliance matters. Outcome: Gemini Trust agreed to a $37 million civil monetary penalty, an initial $40 million contribution to Earn users' recovery, and full in-kind recovery. Official or regulator database source
• 2023-01 to 2026-01-23 US SEC: Civil action alleging the Earn programme involved sale of unregistered securities. Outcome: Dismissed with prejudice by stipulation filed 2026-01-23, citing full in-kind return of Earn users' assets. PRESS OR OTHER SOURCE · official text not found source
• 2025-01-13 US CFTC (consent order, S.D.N.Y.): CFTC stated Gemini Trust Company LLC made materially false or misleading statements or omissions to the CFTC in 2017 during self-certification of a bitcoin futures contract. Outcome: USD 5 million civil monetary penalty and permanent injunction. On 2026-05-27 the CFTC and Gemini asked the court to vacate the order (per Bloomberg Law); ruling not reported in the source. Official or regulator database source
• 2026-03-19 Private securities class action (No. 26-cv-02261): Reported by plaintiff law-firm press release: complaint alleges Gemini Space Station and executives failed to disclose material information in IPO documents (class period 2025-09-12 to 2026-02-17). Allegations are the plaintiffs' claims, not established. Outcome: Pending per source; lead-plaintiff deadline 2026-05-18. PRESS OR OTHER SOURCE · official text not found source

What we could not verify

Not verified: exchange-wide proof of reserves; current OAM register entry and legal entity registered; EU-specific fee schedule; exact MFSA grant date (ESMA notification date used); any security incidents beyond Earn/Genesis (none found in sources read).

Facts are as of 9 Oct 2026. We ran a limited number of searches per exchange, so an empty list is not proof that nothing happened. We did not check the Italian OAM register. Items from press or third parties are reports, not findings by an authority. If something here is wrong or out of date, send a correction with a source: corrections policy. Education only, not investment advice.

Sources

1. [1] ESMA interim MiCA CASP register (CSV) accessed 2026-10-09
2. [2] Gemini blog: Gemini receives its MiCA licence (2025-08-20) accessed 2026-10-09
3. [3] Gemini blog: Gemini secures regulatory approvals to operate in Italy and Greece (2022-11-30) accessed 2026-10-09
4. [4] Gemini Space Station, Inc. Form 424B4 (SEC) accessed 2026-10-09
5. [5] Baker McKenzie: The rise and fall of the SEC's case against Gemini (2026-01-27) accessed 2026-10-09
6. [6] Gemini: ActiveTrader fee schedule accessed 2026-10-09
7. [7] Gemini: API fee schedule (it) accessed 2026-10-09
8. [8] Gemini blog: Gemini launches staking and derivatives for EU customers (2025-09-05) accessed 2026-10-09
9. [9] BleepingComputer: Gemini discloses third-party data breach accessed 2026-10-09
10. [10] CFTC press release 9031-25: Gemini Trust Company $5 million accessed 2026-10-09
11. [11] Law-firm notice (BusinessWire) Methvin v. Gemini Space Station accessed 2026-10-09