Gemini review: licences, terms and gambling clause
Can you deposit to a casino from Gemini?
Gemini's gambling clause: not verified, because its binding document could not be read. Its terms let it freeze or suspend an account without prior notice. 1 registration is confirmed in an issuing register. 6 points are not verified. 2 primary-source incidents are recorded. KYC rules: no data in this entry.
Documents last checked Reviewed by CryptoGuardz Register Desk, editorial desk
Disclosure: CryptoGuardz has no commercial relationship with Gemini, earns nothing if you open an account there, and has not contacted the company or given it notice of this entry. Every statement below is either a verbatim quote from a document Gemini publishes or a statement about a public register, and both carry the date they were read. Corrections go to the corrections page.
1. What this means for you
Consequences first, in the conditional, each one produced by a clause in a document Gemini publishes itself. Every line links to that clause, quoted in full and dated.
- Your account can be frozen without notice if Gemini decides it should be The suspension clause is discretionary and its list of grounds closes with a catch-all that swallows the list. The clause is quoted in full below.
- Your withdrawal can be suspended if Gemini decides an incident on the platform requires it The withdrawal clause sets no maximum duration and no external test for when an incident is resolved.
- You are probably not covered by the authorisation you can see if you are outside the European Economic Area The confirmed authorisation is held by the European entity named on it, and the entity that contracts with a user elsewhere is a different company.
2. What this entry records, and what it does not
This register publishes no number for an exchange. The payout score on the casino register has five defined components and a published arithmetic; no equivalent instrument exists here, and inventing one to fill the space would be a measurement nobody made. What follows instead is a field-by-field account of what was read, where it was read and when.
| Binding terms | Read in full 6 clauses captured verbatim across 5 topics, retrieved 2026-10-08 |
|---|---|
| Contracting entity | Gemini Trust Company, LLCJurisdiction New York, United States (limited purpose trust company) · no company number stated |
| Registration check | 1 confirmed in the issuing authority's own registerESMA interim MiCA register, published CSV, read 2026-10-08 |
| Proof of reserves | Not disclosed |
| Insolvency outcome | Stated in the terms Quoted in section 7 |
| Withdrawal test | Not measuredNo first-party deposit or withdrawal has been run against this exchange. It would require funding an account, which this register has not done. Until it has, nothing here is a measurement of how fast the exchange pays. |
| On-chain reserve verification | Not measuredNo independent reconstruction of the Merkle tree or of the exchange's wallet holdings has been attempted. |
3. What we could not verify
Every entry carries this section. The gaps are published because a reader deserves the limits of the check as well as its results.
- The Dispute Resolution, governing law and arbitration sections of both Gemini agreements. They did not appear in the retrieved text after two passes, so no arbitration or jurisdiction clause is recorded.
- Whether either agreement contains a gambling clause. The retrieved text contained none of gambling, gaming, lottery, casino, betting, wager or sweepstakes, but the retrieved text is incomplete.
- The FinCEN MSB registration. msb.fincen.gov is disallowed by robots.txt to the retrieval tool.
- State money transmitter licences. No state register was read.
- Any EU or UK authorisation. The ESMA CASP register file was served truncated at 81,166 characters (ending at the DEBLOCK SAS row) on two attempts, so absence from it cannot be asserted. The FCA register returned a JavaScript error page on two attempts.
- A company number for Gemini Trust Company, LLC or Gemini Moonbase, LLC. Neither agreement gives one.
4. Who you are contracting with
The counterparty named in the binding document, not the brand on the website. This is the company a claim would be brought against and whose insolvency estate a user would be a creditor of.
| Named counterparty | Gemini Trust Company, LLCsource · retrieved 2026-10-08 |
|---|---|
| Jurisdiction of incorporation | New York, United States (limited purpose trust company) |
| Company number | Not disclosedNo company number appears in the binding document, so the entity cannot be looked up in any companies register from that document alone. |
gemini.com/legal/user-agreement splits US users between two counterparties: "Residents of ID, LA, NY, OH, TX are subject to the terms of the Gemini Trust Company, LLC User Agreement." Residents of a longer list of states, beginning AL, AK, AZ, AR, CA, "are subject to the Gemini Moonbase, LLC User Agreement." The selection page footer gives "Gemini Trust Company, LLC NMLS #1518126. Gemini Moonbase, LLC NMLS #2403509." An NMLS number is a licensing system identifier, not a company number, so the number field is left empty.
The Gemini Trust Company agreement describes its counterparty as "Gemini Trust Company, LLC, a New York limited purpose trust company". The Moonbase agreement opens: "Welcome! Thanks for visiting and using our digital asset platform operated by Gemini Moonbase, LLC, a Delaware limited liability company headquartered in Florida ." The Moonbase agreement was read as dated August 21, 2026. No last-updated date was visible in the retrieved text of the Trust Company agreement.
The clauses below are from the Gemini Trust Company agreement unless stated. Most US users outside the five listed states contract with Gemini Moonbase, LLC, which is not a NYDFS trust company and does not appear in the NYDFS list of regulated virtual currency entities.
Both agreements were retrieved as text of about 138,000 and 136,000 characters and read in two passes each. In the Trust Company text the last section heading reached was "Proprietary Rights and Limitations on Use". No Dispute Resolution, governing law or arbitration section appeared in the retrieved text of either agreement, although the Trust Company introduction says the agreement contains one. The retrieved text is therefore treated as incomplete.
5. Registrations, claimed and confirmed
1 of the registrations Gemini claims was found in the issuing authority's own public register. A confirmed registration covers the entity named on it and nothing else. The one confirmed licence is the NYDFS trust charter of Gemini Trust Company, LLC. Users in most US states contract with Gemini Moonbase, LLC, which is not on the NYDFS list. The ESMA MiCA register of authorised providers could not be read in full (see unverified), so no EU authorisation is recorded for or against Gemini.
| Authority | Kind | Confirmed | What it covers |
|---|---|---|---|
| New York State Department of Financial Services (NYDFS), limited purpose trust charter under the New York Banking Law | authorisation | yes | Confirmed. The NYDFS page listing regulated virtual currency entities, read 8 October 2026, carries the row: Gemini Trust Company, LLC, Limited Purpose Trust Charter, date granted 2015-10. A NYDFS press release of 28 February 2024 states: "Gemini was chartered as a limited purpose trust company and authorized to engage in virtual currency business by the Department in 2015." It covers Gemini Trust Company, LLC only, not Gemini Moonbase, LLC, which is not listed. |
| Financial Crimes Enforcement Network (FinCEN), money services business registration | authorisation | no | The Trust Company agreement refers to "Money Service Business" regulations under FinCEN. A FinCEN MSB registration is an anti-money-laundering registration, not a licence to operate an exchange. Not confirmed: msb.fincen.gov is disallowed to this register's retrieval tool by the site's robots.txt, so the MSB registrant search was not run. |
| US state money transmitter licences (various states), as listed by Gemini | authorisation | no | Gemini's Trust Center lists money transmitter licences or statutory equivalents in a series of US states and territories, notes that its Tennessee money transmitter licence does not cover virtual currency transmission, and lists a Nevada foreign independent trust company licence. Not confirmed: no state register was read for this entry. Recorded as claimed and unconfirmed. |
| European Securities and Markets Authority (MiCA register of non-compliant entities) | adverse listing | not listed | Negative check. The official ESMA register of non-compliant entities providing crypto-asset services was retrieved on 8 October 2026 (173 data rows, ending with a complete row) and searched. The string Gemini does not appear in it. |
6. Proof of reserves
Gemini publishes a proof of reserves and says an outside party performs it, but the public page names nobody, so it is not counted as independently signed. It says nothing about what the exchange owes.
| Signer | No dataNo signer is named on the public page. |
|---|---|
| Standard | Not disclosed |
| As of | No dataNo as-of date could be read from the page at retrieval. |
| Covers liabilities | noNothing in the exercise addresses borrowings, loan obligations, off-chain claims, or whether the set of user balances in the tree is complete. |
| Page | gemini.comretrieved 2026-10-08 |
The Gemini Trust Center lists audited financial statements (December 2019 to December 2025, plus June 2024) and SOC 1 Type 2 and SOC 2 Type 2 examinations, which the page attributes to Deloitte. None of these is a proof of reserves, and none is presented as one. No proof of reserves or reserve attestation was found on the page.
The page asserts, without an attestation attached: "Gemini is a full-reserve exchange and custodian." and "This means that all customer funds held on Gemini are held 1:1 and available for withdrawal at any time." These are recorded as Gemini's own claims, not as facts.
7. Custody, segregation and insolvency
What the binding document says about where your coins sit and what happens to them if the exchange fails, quoted rather than characterised.
Except for Digital Assets held in your segregated Custody Account, Gemini holds your Digital Assets in an omnibus Digital Asset Account.gemini.com
Digital Assets held on your behalf and reflected in the Digital Asset Account and Custody Account of your Gemini Account are not treated as general assets of Gemini.gemini.com
8. Freezing your account
2 clauses, quoted in the order they appear in the document. Read the last one first: it is the ground that swallows the others.
You agree and understand that we have the right to immediately (i) suspend your account and all accounts beneficially owned by you and any members of your household or for which you are a representative or authorized signatory and, in the case of entities, any affiliates (each, a “Related Account”), (ii) freeze/lock the funds and assets in all such accounts, and (iii) suspend your access to Gemini, until a determination has been made, if we suspect, in our sole discretion, you and/or any such accounts to be in violation of:gemini.com
You agree and understand that we have the right to terminate your access to the Gemini Platform and any account at any time and for any reason, including for violation of this User Agreement or applicable law, and that if we do so, your rights and obligations under this User Agreement will continue.gemini.com
9. Suspending withdrawals
In certain situations, Digital Asset withdrawals may be delayed in connection with Downtime, the congestion or disruption of a Digital Asset Network, or for regulatory or administrative purposes.gemini.com
10. Sending funds to a casino from Gemini
Not verified. The document that would contain Gemini's gambling clause could not be retrieved.
None of the words gambling, gaming, lottery, casino, betting, wager or sweepstakes appeared in the retrieved text of either user agreement. The nearest provision is a prohibited activity list covering dark markets, ransomware, mixing services and illegal activity. Recorded as not verified rather than not disclosed because the retrieved text omitted at least the Dispute Resolution section, so a gambling clause elsewhere cannot be ruled out.
11. Which networks Gemini withdraws USDT on
5 USDT networks listed with withdrawals enabled on 2026-10-08, including Avalanche, Ethereum, Solana, Tron, Arbitrum.
Read from Gemini's own support article listing USDT deposit and withdrawal networks. The article states "If you are withdrawing via the API then ETH, USDT and USDC can only be withdrawn on Ethereum." and that multichain ETH and USDC withdrawals "are not available for clients based in the EU & EEA, UK or Singapore." The article shows no last-updated date. USDC networks listed: Avalanche, Ethereum, Optimism, Arbitrum, Base, Solana, Polygon. Source. Which DEXes operate on each of those chains is in the DEX register.
12. Amendment, liquidation, arbitration and governing law
The clauses that decide what the contract can become, what can be done to an open position, and where a dispute would be heard.
Feel free to print and keep a copy of this User Agreement, but please understand that we reserve the right to change any of these terms and conditions at any time.gemini.com
13. Public record
Matters of public record, taken from primary sources and stated with them. They are not scored, because a historical event is not a measurement of how the exchange behaves today, and leaving them out while citing the sources would be worse.
The New York State Department of Financial Services announced that "Gemini Trust Company, LLC has committed to return at least $1.1 billion to Gemini Earn Program customers through the Genesis Global Capital, LLC (GGC) bankruptcy proceeding." The release adds: "Gemini will also pay a $37 million fine to DFS for significant failures that threatened the safety and soundness of the company." and "Despite Gemini's public statements to the contrary, Gemini did not fully vet or sufficiently monitor GGC throughout the life of Earn".
The Commodity Futures Trading Commission announced that the US District Court for the Southern District of New York entered a consent order against Gemini Trust Company LLC, ordering it to pay $5 million. The release states: "The order includes a permanent injunction, and finds Gemini violated the CEA and made materially false or misleading statements or omissions to the Commission." On 27 May 2026 the CFTC announced it had joined Gemini in a motion asking the court to vacate the consent order "as to the prospective provision" (CFTC Press Release 9236-26).
14. Who should avoid Gemini
Anyone outside the European Economic Area who is relying on the authorisation they can see. The confirmed authorisation is held by the European entity named on it and covers that company's clients. A user elsewhere is contracting with a different entity under different terms.
Related entries
Or read the whole exchange register, the same method applied to wallets and to crypto casinos, the clause library at clause watch, or how this register works.