Gemini is a centralized cryptocurrency exchange and custodian based in New York. The legal entity is Gemini Trust Company, LLC, a New York State limited purpose trust company. The New York State Department of Financial Services licenses the company.
Gemini serves retail customers and institutions in more than 60 countries. It charges trading fees, transfer fees on some rails, and a separate fee for Gemini Custody. Customer fiat on the exchange is held apart from the company’s operating accounts.
How is Gemini structured as a regulated trust company?
Gemini Trust Company, LLC, NMLS 1518126, is chartered as a limited purpose trust company under New York Banking Law. The New York State Department of Financial Services licenses it as a fiduciary and qualified custodian. Customer fiat and digital assets are held in accounts segregated from Gemini’s corporate funds.
Gemini states that it holds those customer assets 1:1 and does not use them unless the customer directs a transaction. NYDFS requires capital in excess of customer deposits. The company reports material changes in that capital to the NYDFS.
How does the Gemini trading engine operate in practice?
The Gemini trading engine offers two interfaces for digital asset orders. Gemini mode is the retail interface on the website and in the mobile app. Instant orders, recurring orders, and crypto-to-crypto converts are quoted with a spread included in the price.
The order fee and that spread can vary by payment method, order size, market conditions, jurisdiction, and asset. The trade review screen shows both before the customer confirms the order. Gemini states that it may retain excess spread from the transaction.
The ActiveTrader terminal provides direct interface access to the exchange’s centralized limit order book. Active traders can view real-time market depth and place limit, market, and stop-loss orders. Limit orders are posted to the public ledger and execute when matching liquidity becomes available.
This matching ledger settles transactions internally, updating database balances without initiating immediate on-chain settlement.
The exchange issues the Gemini dollar, an ERC-20 token on Ethereum called GUSD that the NYDFS has regulated since 2018. Customers can redeem 1 GUSD for 1 U.S. dollar on the platform. Converting U.S. dollars to GUSD on Gemini is free.
Permitted reserve assets include deposits at FDIC-insured banks, government money market funds, and U.S. Treasury bills maturing within three months. The February 27, 2026 reserves report listed 44,560,165.87 GUSD in circulation and a reserve of the same amount. That report presented the reserve as cash deposits at U.S. regulated institutions, after settlement-timing adjustments.
The Gemini dollar page says BPM LLP publishes a monthly reserve attestation.
What fees and transaction costs does Gemini charge?
Gemini posts separate Gemini fee schedules for Gemini mode, ActiveTrader, transfers, derivatives, and custody. The Gemini mode schedule, dated February 15, 2026, does not publish a fixed percentage. The fee and spread are set when the order is placed and shown on the review screen before confirmation.
ActiveTrader and API orders follow a maker-taker schedule dated September 1, 2026. The tier uses trailing 30-day spot and derivatives volume, excluding stablecoin pairs, or total asset balance in U.S. dollars. If volume and balance point at different tiers, the lower fee applies.
Tiers are recalculated each day at about 2:00 a.m. UTC. Fees are charged in the quote currency, and cancelling an unmatched maker order is free. A partial fill pays the taker rate on the immediate match and the maker rate on the amount that rests.
The September 1, 2026 ActiveTrader spot tiers are below. A row applies when volume or balance meets that row’s minimum. Asset balance does not qualify a tier on rows marked n/a.
| Minimum 30-day volume | Minimum asset balance | Maker fee | Taker fee |
|---|---|---|---|
| $0 | $0 | 0.600% | 1.200% |
| $10,000 | $1,000,000 | 0.400% | 0.800% |
| $25,000 | $5,000,000 | 0.250% | 0.500% |
| $75,000 | $15,000,000 | 0.125% | 0.250% |
| $250,000 | $25,000,000 | 0.075% | 0.150% |
| $500,000 | n/a | 0.060% | 0.125% |
| $1,000,000 | n/a | 0.050% | 0.100% |
| $5,000,000 | n/a | 0.040% | 0.085% |
| $10,000,000 | n/a | 0.025% | 0.065% |
| $20,000,000 | n/a | 0.010% | 0.050% |
| $50,000,000 | n/a | 0.000% | 0.035% |
| $100,000,000 | n/a | 0.000% | 0.025% |
| $250,000,000 | n/a | 0.000% | 0.020% |
RLUSD/USD, USDC/GUSD, and GUSD/USD charge 0.00% to makers and 0.00% to takers. Other stablecoin pairs charge 0.00% to makers and 0.01% to takers. The derivatives schedule on the same page charges 0.02% maker and 0.07% taker at $0 volume, in GUSD.
Maker rebates apply at the $50 million and $100 million derivatives volume tiers. Converting U.S. dollars to GUSD is free. Gemini states that redemption on the platform is 1 GUSD for 1 U.S. dollar.
On the January 20, 2026 transfer schedule, ACH deposits and ACH withdrawals are free. Wire deposits are free from Gemini, though the sending bank may charge its own fee. A U.S. dollar wire withdrawal includes a $25 processing fee.
Crypto deposits are free. Crypto withdrawals pay a network fee that Gemini says it does not keep, and the amount is shown before the withdrawal is sent. Debit-card purchases carry a 3.49% fee plus trading fees, and PayPal deposits carry a 2.50% fee plus trading fees.
Exchange balances do not pay a custody fee. The standalone Gemini Custody product, on the October 7, 2026 schedule, charges 0.40% annualized or $30 per month per asset, whichever is higher. Moving crypto from the exchange into Gemini Custody is free, and moving it back to the exchange costs $125 per withdrawal.
On-chain withdrawals from current Custody accounts pass through the network fee. Legacy Custody accounts pay $125 on an administrative withdrawal.
Who is eligible for Gemini and what are the account limits?
Eligibility starts at age 18 in the jurisdictions Gemini supports. The help center states that Gemini is available in all 50 U.S. states and in more than 60 countries. U.S. applicants provide a government-issued photo ID and a Social Security number.
Account limits depend on the payment rail and can differ by account. ACH deposit caps are shown inside the account and reset every 24 business hours, excluding weekends and U.S. federal holidays. ACH withdrawals for U.S. customers are capped at $100,000 per day.
Wire deposits have no maximum for individual or institutional accounts. U.S. dollar wire withdrawals have no stated maximum, and the minimum is $25.01, which includes the $25 fee. Debit-card purchases and PayPal deposits are each capped at $1,000 per day and cannot be used to withdraw fiat.
ACH deposits may be available for trading before they settle. A withdrawal hold stays in place until the ACH clears, which typically takes four to five business days. A password reset places a separate 72-hour hold on withdrawals.
Withdrawal Protection is an optional setting, not a default lock on every new address. When it is on, crypto cannot leave to an address until that address has been in the address book for 7 days. Turning the setting off after it was on starts another 7-day wait before the change takes effect.
What risks and operational tradeoffs does Gemini introduce?
Gemini’s listing rules and its custody model each add a constraint. The trust company charter requires the platform to obtain NYDFS approval before listing new digital assets. As a result, Gemini supports fewer cryptocurrencies than unregulated offshore exchanges or standard domestic brokers.
Holding assets on the exchange means Gemini controls the private keys. If the exchange faces insolvency or a regulatory freeze, access to custody balances can be restricted. Digital assets in custody are not covered by FDIC or SIPC insurance.
Gemini states that crypto in its online hot wallet carries insurance for certain losses, subject to policy limits. U.S. dollar cash in an account may be eligible for FDIC pass-through insurance at an FDIC-insured bank, subject to FDIC limits. The cash portion of GUSD reserves may also be eligible for that pass-through treatment.
The platform’s compliance-first structure can lead to transaction delays during automated security audits. If an account triggers compliance flags, transactions are paused pending manual verification reviews. These compliance holds require users to submit documentation explaining the source of their funds.
Resolving these reviews can take several business days, limiting immediate liquidity access.
Common questions
Is Gemini available in New York State?
Gemini is chartered as a New York trust company, and the help center states that accounts are available in all 50 U.S. states, including New York. The trust company is licensed by the New York State Department of Financial Services.
How do I redeem GUSD for U.S. dollars?
A customer can redeem GUSD for U.S. dollars on Gemini at a stated rate of 1 GUSD to 1 dollar. Gemini says the redemption burns the token and returns the dollars. Converting U.S. dollars into GUSD on the platform is free.
Does Gemini provide tax reporting documents?
Gemini issues Form 1099-DA to U.S. non-exempt accounts that sell a digital asset, and Form 1099-MISC when other exchange income exceeds $600. For 2025 sales, the IRS copy of Form 1099-DA reports proceeds only, and sales outside Gemini are omitted. IRS cost-basis reporting starts for assets bought on Gemini on or after January 1, 2026 and held there until sale.
