Gemini Exchange Review: The Earn Collapse, a $1.1 Billion Refund, and an IPO

In November 2022, Gemini’s “Earn” program — a yield product promising customers 7.4% returns on idle crypto — froze without warning. The lending partner behind it, Genesis Global Capital, had run out of liquidity in the chaos following FTX’s collapse. Roughly $900 million to $1.1 billion in customer funds became inaccessible overnight.

What followed was a genuinely public, bitter fight. Gemini co-founder Cameron Winklevoss published open letters directly attacking Barry Silbert, CEO of Genesis’s parent company Digital Currency Group, accusing him of “bad faith stall tactics.” Regulators piled on: the SEC charged Gemini with selling unregistered securities, and the New York Attorney General sued separately. It took until 2024 for the dust to settle — and by January 2026, the SEC’s case had been dismissed entirely, with affected customers fully repaid. In August 2025, Gemini filed to go public on Nasdaq. This review covers what actually happened, and what Gemini offers today.

Gemini Quick Overview

Category	Detail
Founded	2014, by Cameron and Tyler Winklevoss; launched October 2015
Parent entity	Gemini Space Station Inc.
Headquarters	New York, US; European HQ in Malta (since Jan 2025)
Regulatory status	NYDFS-chartered trust company; MiCA-licensed (EU, Aug 2025)
Cryptocurrencies supported	100+
Standard interface fees	~1.49% transaction fee + ~0.50%–1.00% spread
ActiveTrader fees	0.60% maker / 1.20% taker (base tier)
IPO status	S-1 filed Aug 2025, Nasdaq ticker “GEMI”
Major settlement	$1.1B refund + $37M NYDFS fine (March 2024, Earn-related)

How Gemini Started

Cameron and Tyler Winklevoss — better known publicly for their early legal dispute with Mark Zuckerberg over Facebook’s origins — announced Gemini in June 2013, and the exchange went live on October 25, 2015. Gemini received a Limited Purpose Trust Charter from the New York Department of Financial Services (NYDFS) in October 2015, positioning itself from the outset as a compliance-first, security-focused exchange rather than competing primarily on speed or breadth of token listings.

In May 2016, New York Governor Andrew Cuomo announced Gemini’s approval as the first licensed US-based Ethereum exchange. The company built its early reputation around this regulatory positioning — a deliberate contrast to several offshore exchanges operating with minimal oversight during crypto’s earlier, less regulated years.

The Gemini Earn Program and the Genesis Collapse

This is the single most consequential chapter in Gemini’s history, and any accurate review must address it directly.

In February 2021, Gemini launched Gemini Earn, a yield product offering customers returns as high as 7.4% by lending their crypto to Genesis Global Capital, a cryptocurrency broker. Gemini acted as the promoter and agent for this program, collecting a fee for facilitating it — but the underlying lending relationship and risk sat with Genesis.

The program operated without major incident for over a year. Then, on November 16, 2022, in the immediate aftermath of FTX’s collapse, Genesis froze withdrawals amid a broader liquidity crisis across the crypto lending sector. Gemini Earn customers — who believed they were using a safe, Gemini-branded product — suddenly found their funds inaccessible, with the actual counterparty risk sitting with a company most had never directly interacted with. Read our FTX collapse explained guide for the broader contagion event that triggered this freeze.

The Public Fight: Winklevoss vs. Barry Silbert

What followed was an unusually public and personal dispute, even by crypto industry standards. Cameron Winklevoss published open letters directly addressed to Barry Silbert, CEO of Digital Currency Group (Genesis’s parent company), accusing DCG of “bad faith stall tactics” in resolving the Earn program’s obligations to Gemini’s customers. This was a notably aggressive, public escalation from a counterparty relationship that would typically be negotiated privately.

Regulatory action followed on multiple fronts. On January 12, 2023, the SEC charged Gemini Trust Company with the unregistered offer and sale of securities related to the Earn program. On October 19, 2023, New York Attorney General Letitia James filed a separate lawsuit against Gemini, DCG, and Genesis, alleging Gemini had deceived investors about the risks of the lending arrangement.

The Resolution: Full Repayment and Regulatory Settlements

Genesis filed for bankruptcy and reached a settlement in February 2023, finalised in March 2024, under which Genesis returned assets to investors and paid a $21 million penalty to the SEC.

Separately, on March 1, 2024, Gemini reached its own settlement with the NYDFS, agreeing to refund at least $1.1 billion to Earn users and pay a $37 million fine over allegations of unsafe practices in its Genesis partnership.

The recovery process for affected customers ultimately had a genuinely unusual silver lining: distributions were paid in kind rather than in cash — meaning a customer who had lent 1 Bitcoin into Earn received 1 Bitcoin back, not its dollar value at the time of the freeze. Because Bitcoin’s price rose substantially between the November 2022 freeze and the 2024-2025 distribution period, many Earn users ultimately received a 237% recovery relative to the value frozen at the time of suspension — an outcome dramatically better than typical crypto bankruptcy recoveries, which are usually paid in cash at depressed, frozen-date valuations. Read our biggest Bitcoin price crashes guide for context on Bitcoin’s price trajectory across this period.

With customers fully repaid and Genesis’s bankruptcy resolved, the SEC’s case lost much of its practical urgency. On January 23, 2026, the SEC and Gemini filed a stipulation dismissing the lawsuit with prejudice — closing the legal chapter over three years after it began.

The Trump Administration Connection

A separate regulatory matter — a June 2022 CFTC lawsuit alleging Gemini misrepresented its exchange and futures contracts during 2017 regulatory meetings — was also resolved during this period, settled under the second Trump administration with a relatively modest $5 million fine in January 2025.

Wikipedia’s documentation of this period notes that the Winklevoss twins had donated to Donald Trump and entered into business partnerships with his sons, Eric Trump and Donald Trump Jr., prior to this favourable settlement — and reportedly influenced the administration’s CFTC staffing decisions, successfully opposing the appointment of Brian Quintenz to a CFTC role. This sequence of events has drawn scrutiny regarding the relationship between political donations and regulatory outcomes in the crypto industry, though no formal finding of impropriety has been established regarding the settlement itself.

Gemini’s IPO and Current Corporate Structure

In a significant move reflecting renewed confidence following the resolution of its Earn-related legal exposure, Gemini — now operating under the corporate name Gemini Space Station Inc. — filed its S-1 registration with the SEC on August 16, 2025, signalling its intent to go public on the Nasdaq Global Select Market under the ticker symbol GEMI.

Five days later, on August 21, 2025, Gemini also obtained a Markets in Crypto-Assets (MiCA) license from Malta’s Financial Services Authority, granting regulatory approval to operate across all 27 European Union member states — a significant expansion of its formal regulatory footprint beyond its original US base. Read our crypto laws by country guide for more on how MiCA functions across the EU.

In January 2025, Gemini relocated its European headquarters from Dublin, Ireland, to Malta, citing changes in the regulatory landscape.

What Gemini Offers in 2026

Trading platforms: Gemini operates two distinct interfaces — a simplified retail interface for beginners (with higher, dual-component fees) and ActiveTrader, a more advanced platform with TradingView charting integration and significantly lower, tiered maker-taker fees for active traders.

Supported assets: Over 100 cryptocurrencies, including Bitcoin, Ethereum, Solana, Litecoin, Cardano, Polkadot, Avalanche, and the exchange’s own stablecoin, Gemini Dollar (GUSD) — a USD-pegged stablecoin distinct from a typical volatile cryptocurrency. Read our USDT vs USDC guide for how reserve-backed stablecoins like GUSD function structurally.

Gemini Credit Card: Issued by WebBank, offering crypto rewards on everyday purchases — 4% back on gas, EV charging, and transit spending up to $300 monthly, dropping to 1% beyond that threshold, with rewards paid instantly in the cardholder’s chosen cryptocurrency.

Staking: Available for several proof-of-stake assets, with Gemini handling the technical infrastructure and deducting a service fee from rewards. Read our how to stake cryptocurrency guide for how this compares to staking independently.

No lending/interest products: Following the Earn collapse, Gemini has not reinstated any broad interest-bearing or lending product as of 2026 — a notable, deliberate gap reflecting the company’s caution after the Genesis episode.

Derivatives: Limited. Gemini focuses primarily on spot trading; users seeking leveraged futures or options need to look to alternative platforms.

Fees: What You’ll Actually Pay

Interface	Fee Structure
Standard retail interface	~1.49% transaction fee + ~0.50%-1.00% convenience fee (spread)
ActiveTrader (base tier)	0.60% maker / 1.20% taker
ActiveTrader (higher volume tiers)	Decreases significantly with trading volume

The practical takeaway repeated across nearly every independent 2026 review: use ActiveTrader, not the default retail interface, for anything beyond a small, occasional purchase. The standard interface’s combined transaction-fee-plus-spread structure makes it considerably more expensive than competitors’ default rates.

Security Track Record

Gemini has never suffered a platform-level hack resulting in stolen customer crypto — a genuinely strong record over a decade of operation. The exchange maintains SOC 1/2 Type 2 certifications, publishes Proof of Reserves, and stores the substantial majority of customer assets in cold storage.

One notable exception: in late 2022, a third-party vendor incident exposed email addresses and partial phone numbers for approximately 5.7 million users. Core exchange systems and funds were not affected, though some impacted users subsequently faced phishing attempts using the leaked contact information.

Gemini’s Global Footprint Is Shrinking in Some Markets

Despite its EU expansion through the Malta MiCA license, Gemini announced it will cease operating in the United Kingdom effective April 6, 2026, arranging with eToro to onboard eligible UK customers who opt in. The company has also scaled back retail access in the EEA and Australia — a notable contraction even as its US and broader EU regulatory position has strengthened.

Merits and Demerits

Merits:

1. Among the most heavily regulated crypto exchanges in the US, with a NYDFS trust charter
2. Strong, decade-long security track record with no platform-level hack resulting in stolen funds
3. Full resolution and repayment of the Earn program crisis, with many customers actually profiting from the in-kind recovery structure
4. New EU-wide MiCA license significantly expands regulatory reach
5. Pending Nasdaq IPO reflects renewed institutional confidence
6. ActiveTrader offers genuinely competitive fees for active traders

Demerits:

1. Standard retail interface fees are notably expensive relative to competitors
2. The Earn/Genesis episode remains a significant mark on the company’s history, even though fully resolved
3. Scaling back operations in the UK, EEA, and Australia reduces its global accessibility
4. No broad interest or lending products since the Earn suspension
5. Limited derivatives offerings compared to exchanges like Binance or Bitget
6. Narrower cryptocurrency selection than Binance, though broader than some competitors

Should You Use Gemini?

Consider Gemini if: regulatory compliance and custody discipline are your top priorities, you are a US-based user comfortable using ActiveTrader rather than the pricier default interface, or you specifically want exposure to a platform pursuing a Nasdaq listing.

Consider alternatives if: you are based in the UK (given the April 2026 exit), you want the lowest possible fees without navigating a separate trading interface, or you need broad access to interest-bearing crypto products, which Gemini has not reinstated since 2022.

For broader guidance on protecting your holdings regardless of which exchange you choose, read our how to store cryptocurrency safely guide.

FAQs

Is Gemini safe to use in 2026?

Gemini has never suffered a platform-level hack resulting in stolen customer crypto, and maintains strong regulatory compliance through its NYDFS trust charter and new MiCA license. Its main historical issue, the Gemini Earn program’s exposure to Genesis, was fully resolved through a $1.1 billion refund and regulatory settlements completed by 2024-2026.

What happened to Gemini Earn?

Gemini Earn, a crypto lending yield product, froze in November 2022 when its lending partner, Genesis Global Capital, ran out of liquidity following FTX’s collapse. After a lengthy bankruptcy and regulatory process, Gemini settled with the NYDFS in March 2024, refunding at least $1.1 billion to affected users and paying a $37 million fine. Many users received in-kind distributions worth significantly more than their funds were worth at the time of the freeze, due to Bitcoin’s price appreciation.

Is Gemini going public?

Yes. Gemini, operating as Gemini Space Station Inc., filed its S-1 registration with the SEC on August 16, 2025, intending to list on the Nasdaq Global Select Market under the ticker symbol GEMI.

What are Gemini’s fees?

The standard retail interface charges approximately 1.49% in transaction fees plus a 0.50%-1.00% spread. The ActiveTrader interface uses a tiered maker-taker model starting at 0.60% maker and 1.20% taker, decreasing with higher trading volume.

Can I still use Gemini in the UK?

No, not after April 6, 2026. Gemini announced it will cease UK operations on that date, arranging with eToro to onboard eligible customers who opt in to transfer.

Does Gemini still offer Earn or lending products?

No. Following the 2022 Earn suspension and subsequent settlements, Gemini has not reinstated any broad interest-bearing or lending product as of 2026. Current staking products are separate, more conservative, and tied to actual network validation rather than third-party lending.

Final Word

Gemini’s story over the past four years captures something genuinely important about crypto’s institutional maturation: a regulated, security-focused exchange whose core custody operations never failed, brought into a major crisis entirely through a third-party lending partnership it had promoted to its own customers — followed by a public fight, multiple regulatory settlements, and an eventual, unusually favourable resolution for affected users.

By 2026, with the Earn matter fully resolved, the SEC case dismissed, a new EU-wide regulatory license secured, and a Nasdaq IPO filed, Gemini has positioned itself as a case study in regulatory recovery rather than collapse — distinguishing it from exchanges like FTX that failed to survive comparable crises. Whether that institutional resilience justifies its comparatively higher standard-interface fees depends entirely on how much you value regulatory depth and custody discipline over the lowest possible transaction cost.

Disclaimer: This article is for informational purposes only and does not constitute financial advice. Cryptocurrency exchange use carries risk, including third-party counterparty risk as demonstrated by the Gemini Earn program. Always conduct your own research before choosing any platform.