Gemini Review 2026: Fees, Earn Fallout and Safety

Gemini has spent much of its history positioning regulation and custody controls as reasons to choose the exchange. That case is still relevant in 2026, but it now comes with two important qualifications.

The first is cost. Gemini's ActiveTrader pricing is expensive for low-volume users: the base spot tier charges 0.60% for maker orders and 1.20% for taker orders. A trader needs meaningful volume or a qualifying asset balance before those rates fall substantially.

The second is Gemini Earn.

Earn was not a wallet hack. Customers voluntarily entered a yield product in which their crypto was lent to Genesis Global Capital. When Genesis suspended withdrawals in November 2022 and later entered bankruptcy, Gemini Earn users lost access to their assets for roughly 18 months.

The eventual outcome was unusually strong. By June 2024, users had received 100% of the digital assets owed to them in kind. But the recovery does not erase the underlying failure: New York regulators found that Gemini had not adequately assessed and monitored Genesis before exposing customers to it.

That distinction is central to evaluating Gemini today.

A regulated exchange can have strong custody controls while offering a separate product with very different counterparty risk.

Gemini's U.S. structure is more complicated than it used to be

Gemini is often described simply as a New York trust company.

That is no longer accurate for every U.S. retail customer.

Gemini Trust Company, LLC remains a New York limited-purpose trust company regulated by the New York State Department of Financial Services. It continues to serve New York customers, certain other accounts and institutional customers requiring qualified-custodian services.

But beginning in May 2025, Gemini started migrating many U.S. retail customers to a separate company:

Gemini Moonbase, LLC

Moonbase is a Florida-based entity registered with FinCEN as a money services business and licensed as a money transmitter in the states where it operates.

The customer-facing Gemini platform can look almost identical after the migration, but the legal relationship is different.

That means a 2026 Gemini review should not assume every American customer receives the same New York trust-company framework.

Before relying on Gemini's regulatory status, check the legal entity named in the current account agreement.

New York regulation still matters

For customers served by Gemini Trust Company, NYDFS supervision remains one of Gemini's distinguishing features.

Gemini Trust Company has held a New York limited-purpose trust charter since 2015.

That framework subjects it to requirements involving areas such as:

• capitalization;
• cybersecurity;
• compliance;
• custody;
• anti-money-laundering controls;
• consumer protection;
• regulatory examinations.

For institutional clients, Gemini Custody also remains under Gemini Trust Company rather than Moonbase.

This provides more identifiable regulatory structure than a centralized exchange operating entirely through an offshore company.

But the Earn episode showed why the scope of that regulation matters.

The question is not only:

Is Gemini regulated？

It is also:

What Gemini product am I using, which entity provides it, and where do my assets go after I enter that product？

ActiveTrader is expensive at the entry level

Gemini's current ActiveTrader spot fee schedule starts at:

Fees continue falling for much larger trading volumes.

The important part for an ordinary retail trader is the first line.

A 1.20% taker fee is substantial.

For a $5,000 market order:

$5,000 × 1.20% = $60

A $5,000 maker trade at 0.60% costs:

$5,000 × 0.60% = $30

If the same user later sells $5,000 as a taker, the nominal round-trip trading fee would reach:

$120

That calculation does not include spread, price movement or withdrawal costs.

For an occasional trader, the fee structure can therefore matter more than Gemini's regulatory advantages.

Volume changes the comparison quickly

Gemini becomes much more competitive once a user reaches higher fee tiers.

At $25,000 of qualifying volume, the fee falls to 0.25% maker and 0.50% taker.

At $1 million, it reaches 0.05% maker and 0.10% taker.

This creates a very different experience for two users trading on the same exchange.

A low-volume investor purchasing crypto occasionally can pay several times the commission of an active trader or institution.

Gemini also allows certain asset balances to qualify customers for some fee levels, so the current account tier should be checked directly rather than inferred from trading volume alone.

The fee tier is recalculated regularly as the qualifying volume or balance changes.

Stablecoin pairs are priced differently

Gemini applies special pricing to selected stablecoin markets.

Current stablecoin pairs such as GUSD/USD, USDC/GUSD and other designated stablecoin markets can trade at substantially lower rates than ordinary spot cryptocurrencies.

This is another reason a single statement such as “Gemini charges 1.20%” is incomplete.

The base ActiveTrader rate applies to ordinary spot trading at the lowest tier.

Stablecoin markets, derivatives and other products can have separate schedules.

Users should evaluate the exact pair rather than transferring one fee figure across the entire platform.

Gemini Mode is not the same as ActiveTrader

Gemini's simple retail interface and ActiveTrader use different pricing structures.

ActiveTrader exposes a central limit order book and explicit maker/taker fees.

Gemini's simplified purchase experience prioritizes convenience and uses a different fee model that can include a convenience charge and spread.

That means a retail customer should not assume the simpler interface is cheaper simply because it requires fewer steps.

The useful comparison is the final amount of crypto received for the same amount of dollars.

For a larger purchase:

• check the Gemini Mode quote;
• open the equivalent ActiveTrader market;
• inspect the order book;
• calculate the applicable maker or taker fee;
• compare the final amount received.

For low-volume users, ActiveTrader's base fee is already high enough that neither route should be assumed inexpensive without checking.

Funding method can matter as much as the trading fee

U.S. customers can use several funding methods.

Gemini currently lists ACH deposits and withdrawals as free.

USD wire deposits are also free from Gemini's side, while a USD wire withdrawal carries a $25 platform fee.

Debit-card funding is much more expensive. The current platform charge is 3.49% of the purchase amount before applicable trading costs.

For example:

$5,000 × 3.49% = $174.50

That funding charge alone is larger than many complete trading transactions on lower-fee exchanges.

PayPal funding also carries a percentage charge.

For someone using Gemini regularly, the choice between ACH and an instant payment method can therefore have a larger effect on total cost than optimizing between two nearby trading tiers.

What Gemini Earn actually was

Gemini Earn launched as a way for customers to generate yield on cryptocurrency held through Gemini.

But the assets were not simply sitting in Gemini's normal custody system earning interest.

Under the Earn structure, customer crypto was lent to Genesis Global Capital, a lending company within Digital Currency Group.

That created a different risk relationship.

A customer using ordinary Gemini custody was exposed primarily to Gemini's custody and operational controls.

An Earn customer was additionally exposed to Genesis as a borrower.

That distinction became critical in 2022.

Genesis suspended withdrawals in November 2022

On November 16, 2022, Genesis Global Capital suspended redemptions and new loan originations.

The suspension followed severe stress across the crypto lending industry and came shortly after the collapse of FTX.

Gemini Earn customers could no longer retrieve the assets they had lent through the program.

Genesis Global Capital subsequently filed for bankruptcy protection in January 2023.

For Earn users, the problem was therefore not that someone compromised Gemini's private keys.

It was that the counterparty holding their loaned assets could no longer return them.

This is why Earn should be classified as a counterparty and credit-risk failure, not a Gemini exchange-wallet hack.

NYDFS found Gemini's Genesis oversight inadequate

The regulatory findings are an important part of the Earn history.

In February 2024, NYDFS entered into a consent order with Gemini Trust Company.

The regulator found deficiencies in Gemini's management of the Earn relationship, including inadequate due diligence and monitoring of Genesis.

Among the problems identified by NYDFS was Gemini's failure to obtain enough information about Genesis's financial condition and loan portfolio to properly evaluate the counterparty.

The regulator also cited broader compliance deficiencies.

Gemini agreed to pay a $37 million civil monetary penalty.

It also committed resources toward returning customer assets through the Genesis bankruptcy process.

For users evaluating yield products, this is arguably more informative than the final recovery percentage.

The failure was not simply:

Genesis collapsed.

The regulatory finding was that Gemini should have done more before and during the relationship to understand the risk Genesis represented to Earn customers.

Earn users ultimately received 100% of their crypto back

The final recovery was much better than initially appeared likely.

On May 29, 2024, Gemini distributed approximately $2.18 billion in digital assets to Earn users.

That initial distribution represented approximately 97% of the assets owed.

Crucially, the assets were returned in kind.

A user owed one bitcoin did not receive only the dollar value of that bitcoin at the November 2022 bankruptcy-era price.

The user received bitcoin.

That distinction became extremely valuable because many crypto prices increased substantially during the period when the assets were locked.

On June 20, 2024, Gemini distributed the remaining approximately 3%.

Earn users therefore ultimately received:

100% of the digital assets owed to them in kind.

That is an unusually strong recovery for customers caught in a major crypto bankruptcy.

It does not change the fact that users lost access for roughly 18 months.

A 100% recovery does not mean Earn was safe

Outcome and risk should not be confused.

Suppose two borrowers each default.

One creditor eventually recovers everything after a long bankruptcy.

Another recovers only 30%.

The first loan did not retroactively become risk-free.

The same logic applies to Gemini Earn.

The eventual recovery was favorable, but users still experienced:

• loss of liquidity;
• bankruptcy exposure;
• legal uncertainty;
• inability to access assets;
• uncertainty about the eventual recovery amount and timing.

A customer who needed those assets during the lockup could not treat them as available merely because they would eventually be returned.

This is the most important lesson from Earn for evaluating future crypto yield products.

Custody and lending need to be separated

The Earn episode makes one question especially useful:

Does this product keep my crypto in custody, or does it transfer/lend my assets to someone else？

Those are very different arrangements.

With custody, the central questions include:

• who controls the keys;
• how assets are segregated;
• whether assets can be lent or pledged;
• what legal claim the customer has.

With lending, users also need to understand:

• who the borrower is;
• whether title transfers;
• collateral;
• borrower leverage;
• rehypothecation;
• credit quality;
• what happens after default.

A familiar exchange interface can make two products look similar even when the underlying legal and economic risks are completely different.

Gemini Earn is one of the clearest examples.

Gemini Custody is a different product again

Gemini Custody is primarily an institutional custody service and remains tied to Gemini Trust Company.

It should not be treated as identical to ordinary retail exchange balances or to the former Earn program.

Gemini Custody uses controls designed around institutional asset storage, including offline key management and role-based access processes.

Gemini also describes insurance arrangements covering certain custody risks.

Insurance language requires care.

Insurance does not automatically mean every crypto loss will be reimbursed.

Coverage depends on:

• the insured event;
• policy limits;
• exclusions;
• custody structure;
• circumstances of the loss.

A statement that Gemini carries insurance is therefore not equivalent to saying that every Gemini account is fully insured.

Crypto is not FDIC insured

Gemini's regulatory status does not convert cryptocurrency into an insured bank deposit.

Bitcoin, ether and other crypto balances are not FDIC-insured simply because the customer uses a regulated U.S. exchange.

Fiat dollars may be handled differently depending on the account and banking arrangement.

Where Gemini holds eligible USD through banking partners, pass-through FDIC treatment can depend on the exact structure and whether applicable requirements are satisfied.

Users should therefore separate:

USD held through banking arrangements

from

crypto held on the exchange.

The protections are not the same.

Gemini has avoided a major disclosed central-wallet theft

Gemini's core exchange security history is stronger than several exchanges founded during the same period.

There has not been a widely disclosed large-scale theft from Gemini's main exchange wallets comparable with some major historical exchange hacks.

That is relevant.

But security should not be reduced to whether private keys have been stolen.

Gemini users have still been affected by third-party data-security incidents.

In December 2022, Gemini disclosed that a third-party vendor incident exposed customer email addresses and partial phone numbers.

Gemini said its own account systems were not compromised and that customer funds remained secure.

The significance of that incident was primarily phishing risk.

An attacker does not need a private key database if leaked customer information can be used to create convincing account-recovery or support scams.

Third-party risk appeared again in 2024

Gemini's public-company disclosures later described another third-party service-provider incident in 2024 involving a provider connected with one of its ACH banking partners.

The episode affected information associated with approximately 15,000 users.

Again, this was not reported as a theft from Gemini crypto wallets.

But it illustrates a broader point.

An exchange's security perimeter includes more than its own matching engine and cold wallets.

It can also include:

• payment processors;
• banks;
• identity providers;
• customer-support systems;
• cloud providers;
• analytics vendors.

A platform can have strong internal security and still inherit risk through external providers.

Hardware-backed authentication is worth using

Gemini supports several account-security options, including:

• passkeys;
• hardware security keys;
• authenticator-based two-factor authentication;
• approved withdrawal addresses;
• device and account monitoring.

For an account holding a meaningful balance, hardware-backed authentication provides stronger protection than relying only on SMS.

Users should also secure the email address connected to Gemini.

A strong exchange password provides limited protection if an attacker can take control of the customer's email and intercept recovery messages.

Approved withdrawal addresses can add friction to unauthorized transfers by restricting where assets can be sent.

Withdrawal holds do not always mean a crypto problem

Gemini supports ACH funding, and customers can sometimes trade with deposited funds before the banking transfer has fully settled.

That does not necessarily mean the resulting crypto can be withdrawn immediately.

Gemini can place a temporary hold until the original bank transfer clears.

Users sometimes interpret this as a crypto-withdrawal failure when it is actually settlement risk on the fiat deposit.

Other withdrawal delays can result from:

• security reviews;
• newly added withdrawal addresses;
• account changes;
• compliance checks;
• blockchain congestion;
• wallet maintenance.

Before sending money needed on a strict deadline, understand whether the funding method introduces a settlement hold.

Crypto withdrawal fees are dynamic

Gemini no longer relies on one simple fixed crypto withdrawal fee across every asset.

Withdrawal charges can be dynamic based on the blockchain and network conditions.

The fee is displayed before the transfer is submitted.

For most assets, Gemini also applies a withdrawal minimum of approximately $10 worth of the asset or the relevant blockchain dust threshold, whichever is greater.

This matters for smaller positions.

A customer purchasing a small amount with the intention of moving it immediately to self-custody should check the withdrawal cost before placing the trade.

The correct sequence is:

• check the trading fee;
• check the expected execution price;
• check the withdrawal minimum;
• inspect the current network fee;
• then decide whether the purchase size makes sense.

Asset selection is broader than it once was, but still selective

Gemini now advertises more than 100 ActiveTrader pairs across more than 70 cryptocurrencies.

That is substantially broader than Gemini's early product lineup.

It is still not designed around the enormous long-tail catalogs seen on some offshore exchanges.

For many U.S. users, that can be either a limitation or an advantage.

A trader searching for newly launched microcaps may frequently find the desired asset missing.

A customer primarily interested in BTC, ETH, stablecoins and other established markets may care more about USD access, custody controls and regulatory structure than the total listing count.

Availability should still be checked market by market.

Listing on a regulated exchange does not mean a cryptocurrency is guaranteed to retain value.

GUSD should be evaluated separately from the exchange

Gemini Dollar, or GUSD, is Gemini's U.S.-dollar-backed stablecoin.

Because Gemini Trust Company is involved in the product and its reserve structure, GUSD has a different regulatory context from many offshore-issued stablecoins.

But holding GUSD is not the same economic exposure as holding a cash balance at a bank.

Users still need to understand:

• issuer risk;
• reserve structure;
• redemption mechanics;
• liquidity;
• regulatory changes.

Special low-fee Gemini trading pairs can make GUSD efficient to trade without automatically making it the appropriate stablecoin for every portfolio.

Trading cost and asset risk are separate decisions.

Gemini became a public company in 2025

Gemini's corporate structure also changed after the Earn period.

Gemini Space Station, Inc. completed its IPO in September 2025, and its Class A shares began trading on Nasdaq under the ticker GEMI.

The public-company structure creates additional financial disclosure requirements.

Gemini now files quarterly and annual reports with the SEC covering areas including its financial condition, legal risks and business performance.

That does not directly protect customer crypto.

But it does give users and institutional counterparties more information about the broader company than was available when Gemini was privately held.

Gemini is becoming more U.S.-focused

In February 2026, Gemini announced plans to wind down operations in the United Kingdom, European Union, other European jurisdictions and Australia as part of a restructuring.

The company said its business would continue operating in the United States and Singapore.

That makes geographic availability increasingly important when reading older Gemini reviews.

A product, regulatory entity or funding method described in an older European Gemini article may no longer represent the platform's current strategic footprint.

For a 2026 retail user, Gemini is increasingly a U.S.-centered platform rather than a globally uniform exchange.

Where Gemini is strongest

Gemini's strongest case is not low-cost retail trading.

At the lowest ActiveTrader tier, its 0.60% maker and 1.20% taker rates make that argument difficult.

Its clearer advantages are elsewhere:

• established U.S. regulatory infrastructure;
• New York trust-company custody for applicable accounts;
• institutional custody products;
• USD banking;
• strong account-security tools;
• a long operating history without a major disclosed central-wallet theft;
• public-company disclosures.

Those characteristics can matter to institutions and users who place significant weight on custody and regulatory structure.

They need to be weighed against the actual transaction cost.

A highly regulated venue can still be unnecessarily expensive for a user making frequent small trades.

What Earn should change about the way Gemini is evaluated

Gemini Earn is the most important event in the company's history for understanding product risk.

It demonstrated that the Gemini brand alone does not tell a customer what happens to their assets.

Three products carrying the Gemini name can represent three very different relationships:

Exchange trading: assets are held and traded through the exchange.

Custody: assets are stored under a custody arrangement.

Earn: assets were lent to a third-party borrower.

The interface may have been familiar in all three cases.

The underlying risk was not.

That lesson remains relevant even though Earn itself has ended.

Whenever Gemini or any other exchange offers staking, lending or another yield product, users should identify precisely where the return comes from.

If the return depends on a third-party borrower, it should not be evaluated using the security reputation of the exchange alone.

What to check before using Gemini

For someone evaluating Gemini in 2026, the useful checks are relatively specific.

Identify your Gemini entity.

Do not assume every U.S. account is governed by Gemini Trust Company. Many retail users now contract with Gemini Moonbase.

Check the actual ActiveTrader tier.

Low-volume trading is expensive. Higher tiers are materially cheaper.

Compare Gemini Mode with ActiveTrader.

Simple execution and order-book trading have different cost structures.

Use an efficient funding method.

ACH can be far cheaper than debit-card or PayPal funding.

Distinguish custody from yield.

The Earn experience shows why a product's counterparty structure matters more than the logo on the screen.

Check withdrawal restrictions before funding.

Settlement holds, security controls and dynamic network fees can affect when assets can leave the platform.

Use strong account authentication.

A hardware security key or passkey provides better protection against phishing-driven account takeover.

Gemini's regulatory and custody record gives users substantial information to evaluate.

Its Earn history gives them an equally important reason to read beyond the brand.

Frequently asked questions

Did Gemini Earn users get all their crypto back？

Yes.

Gemini Earn users ultimately received 100% of the digital assets owed to them in kind.

Approximately 97% was distributed on May 29, 2024, with the remaining approximately 3% made available on June 20, 2024.

How much did Gemini Earn users receive？

The initial May 2024 distribution was worth approximately $2.18 billion at then-current crypto prices.

Because users received the same type and quantity of crypto they were owed rather than only the bankruptcy-era dollar value, they also retained the benefit of price appreciation during the lockup period.

Was Gemini Earn hacked？

No.

The Earn failure was primarily a counterparty and credit-risk event.

Earn assets were lent to Genesis Global Capital. When Genesis suspended withdrawals and later entered bankruptcy, Earn customers lost access to the assets.

This was different from an attacker stealing crypto from Gemini's exchange wallets.

Did regulators penalize Gemini over Earn？

Yes.

In February 2024, NYDFS imposed a $37 million civil monetary penalty on Gemini Trust Company and documented failures involving the Earn program and Gemini's oversight of Genesis.

The regulator also secured commitments connected with restoring Earn customer assets.

What are Gemini ActiveTrader fees in 2026？

The current base spot tier charges 0.60% maker and 1.20% taker.

At $10,000 of qualifying volume, the rates fall to 0.40% maker and 0.80% taker. At $25,000 they fall to 0.25% and 0.50%.

Higher-volume tiers continue to reduce the rates.

Why is Gemini expensive for small traders？

A low-volume customer begins at the highest ActiveTrader fee tier.

For example, a $5,000 taker order at 1.20% generates a $60 trading fee before spread or withdrawal costs.

Users should compare this with their expected trading frequency rather than evaluating Gemini solely on regulatory reputation.

Is every U.S. Gemini account held by Gemini Trust Company？

No.

Many U.S. retail accounts were migrated beginning in 2025 to Gemini Moonbase, LLC, a separate money-transmitter entity.

Gemini Trust Company continues to serve New York customers, certain other accounts and institutional custody clients.

Users should check the legal entity listed in their own agreement.

Is Gemini regulated in New York？

Gemini Trust Company, LLC is a New York limited-purpose trust company regulated by the New York State Department of Financial Services.

That status applies to Gemini Trust Company and the services it provides. It should not automatically be extended to every Gemini affiliate or product.

Has Gemini been hacked？

Gemini has not publicly disclosed a major theft from its central exchange wallets comparable with several well-known exchange hacks.

However, third-party data incidents have exposed customer information and increased phishing risk.

An absence of a large wallet theft does not eliminate account or vendor-security risk.

Is crypto held on Gemini FDIC insured？

Crypto assets are not FDIC-insured bank deposits.

USD balances may have different protections depending on how funds are held and whether applicable pass-through insurance requirements are met.

Users should not apply bank-deposit protections to BTC, ETH or other crypto balances.

Does Gemini charge for crypto withdrawals？

Gemini uses dynamic or asset-specific crypto withdrawal fees that can change with the selected blockchain and network conditions.

The applicable fee is displayed before the withdrawal is confirmed.

Is Gemini still available in Europe？

Gemini announced in February 2026 that it would wind down operations in the UK, EU, other European jurisdictions and Australia as part of a restructuring.

Its continuing core operating markets include the United States and Singapore.