How to read these grades: each is derived from published, checkable disclosures — proof-of-reserves attestations, public regulatory registers, disclosed insurance funds and the documented incident record — using the weighted rubric below. Where an exchange does not disclose something, we mark it unverified rather than assume it. These are not audits and not investment advice; they reflect what was published as of our last review.
Gemini
Gemini is a New York-chartered trust company available in all 50 states with $100m of disclosed custody insurance, but publishes no exchange-wide proof of reserves and paid a $37m NYDFS penalty in 2024 over its collapsed Earn programme.
BySafety DeskSenior Exchange Safety Editor
Our Gemini review
Gemini is chartered as a New York trust company — a heavier regulatory standard than almost anything else in this corpus carries — and it publishes no exchange-wide proof of reserves at all. A C is what happens when the strongest possible regulator relationship sits next to a blank where the reserve evidence should be.
What checks out
The New York limited-purpose trust company charter was granted in September 2015, and Gemini operates in all 50 states on the back of it. That is a banking-style supervision regime, not a money-services registration. We found no confirmed breach of Gemini's own systems; the collapse of the Earn programme was a lending-counterparty failure at Genesis, not an attack on the exchange.
Where the evidence stops
There is no exchange-wide proof-of-reserves programme. Gemini holds SOC 1 Type 2 and SOC 2 Type 2 reports with Deloitte & Touche involved, but those are controls audits — they test whether processes work, not whether the coins are there. The cold/hot storage split is not disclosed. Gemini Custody discloses $100m of insurance cover and the company operates an in-house Bermuda captive insurer, but that cover is scoped to the custody product and we could not confirm it extends to retail exchange balances. The February 2024 NYDFS consent order over Gemini Earn carried a $37m penalty and more than $1.1bn committed back to users, alongside a $50m recovery by the New York Attorney General.
How to read the grade
A trust charter is the strongest supervisory relationship on this page, and Earn is proof that supervision does not make every product on a platform safe. Read the C as: well-regulated at the entity level, unproven at the balance level.
Grade breakdown
Every KripZen grade comes from the same five weighted checks. Here is how Gemini scores on each.
- Proof of reservesWeight 30%
No exchange-wide proof-of-reserves programme was found. Gemini holds SOC 1 Type 2 and SOC 2 Type 2 reports, with Deloitte & Touche involved, but those are controls audits rather than reserve attestations.
What this means → does not meet this factor - CustodyWeight 25%
Cold/hot storage split is not disclosed; we could not confirm it from a primary source.
What this means → partial or unverified - RegulationWeight 20%
New York limited-purpose trust company charter granted in September 2015, operating in all 50 states; the February 2024 NYDFS consent order over the Gemini Earn programme carried a $37m penalty and more than $1.1bn committed back to users, alongside a $50m New York Attorney General recovery.
What this means → meets this factor - InsuranceWeight 15%
Gemini Custody discloses $100m of insurance cover and Gemini operates an in-house Bermuda captive insurer; the cover is scoped to the custody product and we could not confirm it extends to retail exchange balances.
partial or unverified - Incident historyWeight 10%
No confirmed breach of Gemini's own systems found in our research; the Earn programme's collapse was a lending-counterparty failure at Genesis, not an attack on the exchange.
meets this factor