--- title: "Gemini Trust Company, LLC · (FinCEN) · United States | Elucidate" description: "Gemini Trust Company, LLC is registered with FinCEN for anti-money-laundering supervision as a in the United States. LEI 254900GBN2V33HKLXO71. Register status, licences, activities and ownership." url: https://elucidate.co/directory/gemini-trust-company-llc-3351168d38ee --- 1. [Directory](https://elucidate.co/directory) 2. [United States](https://elucidate.co/directory/country/us) 3. Gemini Trust Company, LLC United States · Crypto # Gemini Trust Company, LLC Trading as Gemini Exchange, LLC Gemini Trust Company, LLC is a New York limited purpose trust company. The New York State Department of Financial Services (NYDFS) chartered it under the New York Banking Law in October 2015. Gemini Space Station, Inc., which is listed on Nasdaq, owns it indirectly and in full, and the founders Cameron and Tyler Winklevoss control the group. The firm runs the Gemini digital asset exchange and Gemini Custody, and it issues the Gemini Dollar (GUSD) stablecoin. Since May 2025 most US retail accounts have been held by its affiliate Gemini Moonbase, LLC, while the firm keeps New York and Idaho customers and institutional custody clients. Register status Registered for AML supervision in the United States FinCEN AML registration only [2 licences and registrations ↓](https://elucidate.co/directory/gemini-trust-company-llc-3351168d38ee#licences) BIC **No BIC** LEI **[254900GBN2V33HKLXO71](https://search.gleif.org/#/record/254900GBN2V33HKLXO71)** [Licence no. **Not published by the register**](https://elucidate.co/directory/gemini-trust-company-llc-3351168d38ee#licences) ## Licences and registrations Held by Gemini Trust Company, LLC (LEI 254900GBN2V33HKLXO71). 2 entries on 2 of the 22 tracked registers, retrieved 25 September 2026. | Register | Licence | Number | Jurisdiction | Status | Registered | Ends | Activities | Register entry | | --- | --- | --- | --- | --- | --- | --- | --- | --- | | [MSB Registrant Search](https://elucidate.co/directory/register/fincen-msb) FinCEN | —Money Transmitter / Remittance | Not published by the register | [United States](https://elucidate.co/directory/country/us) | Active | 2025-12-22 | — | - Money remittance - Prepaid access | [Search the register ↗](https://www.fincen.gov/msb-registrant-search) | | [Money Services Business Registry](https://elucidate.co/directory/register/fintrac-msb) FINTRAC | Foreign MSB (FMSB)Crypto-Asset Service Provider | M20046728 | [Canada](https://elucidate.co/directory/country/ca) | Active | 2020-06-19 | Renews 2027-02-07 | - Crypto-assets | [Search the register ↗](https://fintrac-canafe.canada.ca/msb-esm/msb-eng) | Trading names on the register: Gemini Exchange, LLC (FINCEN-MSB), GEMINI (FINTRAC-MSB) - Each licence applies in the country of the regulator that granted it. - Registers are tracked in 37 countries. Licences granted elsewhere are not recorded here. ## Swift network Swift’s ISO 9362 BIC directory Holds no BIC in Swift’s directory. Its LEI is not mapped to a BIC in the Swift and GLEIF BIC-to-LEI relationship file. ## Overview Researched 29 Sep 2026 · [Sources](https://elucidate.co/directory/gemini-trust-company-llc-3351168d38ee#overview-sources) Customers Not published Employees Not published Ownership Group subsidiary Firm type Crypto exchange or broker Trades as Gemini - **Standing:** Starting on 21 May 2025, most US Gemini customers were moved from the firm to an affiliate, Gemini Moonbase, LLC, which holds state money transmitter licences. The firm still serves customers in New York and Idaho, US institutional accounts that need a qualified custodian, and Gemini Custody clients. - **Ownership:** Gemini Space Station, Inc. owns the firm indirectly and in full, and according to CoinDesk, Cameron and Tyler Winklevoss hold 94.5% of the parent's voting power. - **Ultimate owner:** Gemini Space Station, Inc., United States - **Head office:** 315 Park Avenue South, 16th Floor, 10010 New York, United States (registered office: 28 Liberty Street, New York, NY 10005, United States) - **Founders:** Cameron Winklevoss · Tyler Winklevoss ### Online - **Websites & references:** [gemini.com ↗](https://www.gemini.com/) [support.gemini.com ↗](https://support.gemini.com/) help centre [status.gemini.com ↗](https://status.gemini.com/) status page [docs.gemini.com ↗](https://docs.gemini.com/rest-api/) developer docs [investors.gemini.com ↗](https://investors.gemini.com/) investor relations site of parent Gemini Space Station, Inc. [Wikipedia ↗](https://en.wikipedia.org/wiki/Gemini_\(company\)) group article - **Official social accounts:** None found - **Apps:** [App Store ↗](https://itunes.apple.com/us/app/gemini-buy-sell-crypto/id1408914447) · [Google Play ↗](https://play.google.com/store/apps/details?id=com.gemini.android.app) Sources · 19 pages consulted 1. [support.gemini.com/hc/en-us/articles/36190266508315-Moonbase-account-entity-changes-FAQ](https://support.gemini.com/hc/en-us/articles/36190266508315-Moonbase-account-entity-changes-FAQ) 2. [gemini.com/legal/gemini-trust-user-agreement](https://www.gemini.com/legal/gemini-trust-user-agreement) 3. [gemini.com/trust-center](https://www.gemini.com/trust-center) 4. [support.gemini.com/hc/en-us/articles/205823016-Are-my-funds-insured](https://support.gemini.com/hc/en-us/articles/205823016-Are-my-funds-insured) 5. [gemini.com/dollar](https://www.gemini.com/dollar) 6. [dfs.ny.gov/reports\_and\_publications/press\_releases/pr1510051](https://www.dfs.ny.gov/reports_and_publications/press_releases/pr1510051) 7. [dfs.ny.gov/reports\_and\_publications/press\_releases/pr202402282](https://www.dfs.ny.gov/reports_and_publications/press_releases/pr202402282) 8. [cftc.gov/PressRoom/PressReleases/9031-25](https://www.cftc.gov/PressRoom/PressReleases/9031-25) 9. [cftc.gov/PressRoom/PressReleases/9236-26](https://www.cftc.gov/PressRoom/PressReleases/9236-26) 10. [sec.gov/enforcement-litigation/litigation-releases/lr-26465](https://www.sec.gov/enforcement-litigation/litigation-releases/lr-26465) 11. [ag.ny.gov/press-release/2024/attorney-general-james-recovers-50-million-crypto-firm-gemini-defraude](https://ag.ny.gov/press-release/2024/attorney-general-james-recovers-50-million-crypto-firm-gemini-defrauded) 12. [sec.gov/Archives/edgar/data/2055592/000205559226000040/gemi-20260430.htm](https://www.sec.gov/Archives/edgar/data/2055592/000205559226000040/gemi-20260430.htm) 13. [sec.gov/Archives/edgar/data/2055592/000205559226000065/exhibit322q22026.htm](https://www.sec.gov/Archives/edgar/data/2055592/000205559226000065/exhibit322q22026.htm) 14. [investors.gemini.com/corporate-governance/management-team](https://investors.gemini.com/corporate-governance/management-team) 15. [lei.bloomberg.com/leis/view/254900GBN2V33HKLXO71](https://lei.bloomberg.com/leis/view/254900GBN2V33HKLXO71) 16. [coindesk.com/business/2026/02/17/gemini-stock-plunges-after-it-parts-ways-with-coo-cfo-and-chief-legal](https://www.coindesk.com/business/2026/02/17/gemini-stock-plunges-after-it-parts-ways-with-coo-cfo-and-chief-legal-officer-months-after-ipo) 17. [coindesk.com/business/2026/09/20/gemini-s-stock-is-down-80-from-its-ipo-that-s-reviving-takeover-specu](https://www.coindesk.com/business/2026/09/20/gemini-s-stock-is-down-80-from-its-ipo-that-s-reviving-takeover-speculation) 18. [bankingdive.com/news/gemini-cfo-coo-clo-exit-abruptly-crypto-winter-winklevoss-ipo-chen-meade-beard-stoja](https://www.bankingdive.com/news/gemini-cfo-coo-clo-exit-abruptly-crypto-winter-winklevoss-ipo-chen-meade-beard-stojanovic-freedman/812404/) 19. [en.wikipedia.org/wiki/Gemini\_(company)](https://en.wikipedia.org/wiki/Gemini_\(company\)) ## Authorisation Researched 29 Sep 2026 · [Sources](https://elucidate.co/directory/gemini-trust-company-llc-3351168d38ee#overview-sources) - **Operates under:** Its own licences The NYDFS charters the firm as a limited purpose trust company with fiduciary powers and authorises it to conduct virtual currency business. It is also registered with FinCEN as a money services business and holds state money transmitter licences, including in Tennessee. | Authority | Licence or registration | Number | Held | Status | Source | | --- | --- | --- | --- | --- | --- | | New York State Department of Financial Services United States | Limited purpose trust company charter under the New York Banking Law (virtual currency business) | — | In its own name | Active | [dfs.ny.gov ↗](https://www.dfs.ny.gov/reports_and_publications/press_releases/pr1510051) | | US state regulators (NMLS) United States | Money transmitter licences (including Tennessee; number of states not confirmed) | 1518126 | In its own name | Active | [gemini.com ↗](https://www.gemini.com/trust-center) | | Financial Crimes Enforcement Network (FinCEN) United States | Money services business registration (money transmitter, prepaid access) | — | In its own name | Active | — | | Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) Canada | Foreign money services business registration (crypto-asset services) | M20046728 | In its own name | Active | — | Licences and registrations the research found, at home and abroad, as the firm and its regulators publish them. The Licences and registrations card shows the entries on the registers the directory tracks. ## Partners and safeguarding Researched 29 Sep 2026 · [Sources](https://elucidate.co/directory/gemini-trust-company-llc-3351168d38ee#overview-sources) - **Safeguarding:** Deposits at a partner bankAccording to the firm, customers' US dollars may be held at Western Alliance Bank, Cross River Bank, Customers Bank and State Street Bank, and may be eligible for FDIC pass-through insurance. [support.gemini.com ↗](https://support.gemini.com/hc/en-us/articles/205823016-Are-my-funds-insured) - **Crypto-asset custody:** Held by the firmThe firm holds customers' crypto-assets itself, keeping most of them in offline cold storage, and its insurance covers theft from its online hot wallet. BPM LLP attests the GUSD reserves each month. [support.gemini.com ↗](https://support.gemini.com/hc/en-us/articles/205823016-Are-my-funds-insured) - **Deposit-holding bank:** Western Alliance Bank United States [support.gemini.com ↗](https://support.gemini.com/hc/en-us/articles/205823016-Are-my-funds-insured) - **Deposit-holding bank:** Cross River Bank United States [support.gemini.com ↗](https://support.gemini.com/hc/en-us/articles/205823016-Are-my-funds-insured) - **Deposit-holding bank:** Customers Bank United States [support.gemini.com ↗](https://support.gemini.com/hc/en-us/articles/205823016-Are-my-funds-insured) - **Deposit-holding bank:** State Street Bank and Trust Company United States [gemini.com ↗](https://www.gemini.com/dollar) - **Deposit-holding bank:** Goldman Sachs United States [gemini.com ↗](https://www.gemini.com/dollar) Banks and regulated firms the firm says hold its customers’ money, issue its cards, sponsor its accounts or settle its payments, as it discloses them in its terms and notices. ## Products and markets Researched 29 Sep 2026 · [Sources](https://elucidate.co/directory/gemini-trust-company-llc-3351168d38ee#overview-sources) - Crypto trading - Crypto custody - Stablecoin - Crypto on- and off-ramp The firm runs the Gemini exchange and custody for digital assets and issues the GUSD dollar stablecoin. Its retail customers are now mainly in New York and Idaho, and its institutional custody clients are in the US. The firm serves US customers under its New York trust charter and state licences, and FINTRAC also lists it as a foreign money services business in Canada. - **Sells to:** Consumers · Enterprises · Financial institutions - **Serves customers in:** United States ## Leadership Researched 29 Sep 2026 · [Sources](https://elucidate.co/directory/gemini-trust-company-llc-3351168d38ee#overview-sources) - **Chief executive:** Tyler Winklevoss Co-Founder and Chief Executive Officer (Gemini Space Station, Inc.) Confirmed 29 Sep 2026 · [investors.gemini.com ↗](https://investors.gemini.com/corporate-governance/management-team) - **Founder:** Cameron Winklevoss Co-Founder and President (Gemini Space Station, Inc.) Confirmed 29 Sep 2026 · [sec.gov ↗](https://www.sec.gov/Archives/edgar/data/2055592/000205559226000040/gemi-20260430.htm) - **Chief financial officer:** Danijela Stojanovic Interim Chief Financial Officer (Gemini Space Station, Inc.) Confirmed 29 Sep 2026 · [sec.gov ↗](https://www.sec.gov/Archives/edgar/data/2055592/000205559226000065/exhibit322q22026.htm) - **Executive:** Kate Freedman Interim General Counsel (Gemini Space Station, Inc.) Confirmed 29 Sep 2026 · [investors.gemini.com ↗](https://investors.gemini.com/corporate-governance/management-team) - **Executive:** Maria Filipakis Member of the board of managers of Gemini Trust Company, LLC Confirmed 29 Sep 2026 · [sec.gov ↗](https://www.sec.gov/Archives/edgar/data/2055592/000205559226000040/gemi-20260430.htm) ## Recent events 5 enforcement or investigation items Researched 29 Sep 2026 · [Sources](https://elucidate.co/directory/gemini-trust-company-llc-3351168d38ee#overview-sources) 1. May 2026 Enforcement The CFTC joined the firm in asking the court to vacate the January 2025 consent order, saying the complaint should not have been filed. [cftc.gov ↗](https://www.cftc.gov/PressRoom/PressReleases/9236-26) 2. Feb 2026 Leadership The parent company parted ways with its COO, CFO and chief legal officer and named an interim CFO and an interim general counsel. [coindesk.com ↗](https://www.coindesk.com/business/2026/02/17/gemini-stock-plunges-after-it-parts-ways-with-coo-cfo-and-chief-legal-officer-months-after-ipo) 3. Jan 2026 Enforcement The SEC and the firm filed a joint stipulation dismissing, with prejudice, the SEC's 2023 case over the Gemini Earn programme. [sec.gov ↗](https://www.sec.gov/enforcement-litigation/litigation-releases/lr-26465) 4. Sep 2025 Other The parent company, Gemini Space Station, Inc., began trading on Nasdaq on 12 September 2025. [bankingdive.com ↗](https://www.bankingdive.com/news/gemini-cfo-coo-clo-exit-abruptly-crypto-winter-winklevoss-ipo-chen-meade-beard-stojanovic-freedman/812404/) 5. May 2025 Other The group began moving most US customers from the firm to its affiliate Gemini Moonbase, LLC, a licensed money transmitter. [support.gemini.com ↗](https://support.gemini.com/hc/en-us/articles/36190266508315-Moonbase-account-entity-changes-FAQ) 6. Jan 2025 Enforcement A CFTC consent order required the firm to pay USD 5 million over statements made in 2017 about a bitcoin futures contract. [cftc.gov ↗](https://www.cftc.gov/PressRoom/PressReleases/9031-25) 7. Jun 2024 Enforcement The firm settled the New York Attorney General's Earn lawsuit, returning about USD 50 million in digital assets and accepting a New York lending ban. [ag.ny.gov ↗](https://ag.ny.gov/press-release/2024/attorney-general-james-recovers-50-million-crypto-firm-gemini-defrauded) 8. Feb 2024 Enforcement The NYDFS fined the firm USD 37 million for compliance failures, and the firm committed to returning at least USD 1.1 billion to Earn customers. [dfs.ny.gov ↗](https://www.dfs.ny.gov/reports_and_publications/press_releases/pr202402282) Compliance-relevant events of the last three years, newest first: fines and enforcement, investigations, security incidents, licence changes, funding rounds, acquisitions and leadership changes. Each links to its source. ## Identifiers - **Licence no. · FINTRAC-MSB:** M20046728 - **BIC:** Holds no BIC in Swift’s directory - **LEI:** [254900GBN2V33HKLXO71 ↗](https://search.gleif.org/#/record/254900GBN2V33HKLXO71) - **How the LEI was matched:** Matched by Elucidate to GLEIF on name, country and address - **Elucidate firm ID:** 3351168d38ee - **Merged register entry:** 0a8fc6c075f3 · FINTRAC-MSB ## Profile - **Type:** Crypto · Money service business - **Regulation:** AML registration only - **Main licence class:** Money Transmitter / Remittance - **Activities:** - Money remittance - Prepaid access - **Licensed in:** [United States](https://elucidate.co/directory/country/us) · North America - **First registered:** 2025-12-22 Types come from Swift’s BIC classification, the licences on the 22 tracked registers, and the ECB and FSB bank lists. Most banks outside the euro area appear as financial institutions, because their supervisors’ registers are not tracked yet. ## Ownership and group GLEIF relationship records GLEIF’s relationship records name no parent for this LEI, and no group page is published for it. ## Addresses - **Address on the register:** 315 Park Avenue South, 16th Floor, New York, 10010 - **Country:** United States ## ISO 20022 identification As an agent in a Swift cross-border payment message (CBPR+) This institution holds no BIC. A CBPR+ message identifies it by name and postal address, and may add its LEI or a clearing code. - **Identified by:** Name and postal address, with its LEI - **Postal address:** Hybrid: town, postcode and country in their own elements, the rest in one address line ```xml 254900GBN2V33HKLXO71 Gemini Trust Company, LLC 10010 New York US 315 Park Avenue South, 16th Floor ``` CBPR+ identifies the instructing and instructed agents by BIC only. An institution without a BIC can be the debtor, creditor or an intermediary agent. The values are as published by the register. Check them against your own records before use. ## Related institutions ### Other crypto institutions in the United States - [ALT 5 Sigma Canada Inc. · trading as Alt 5 Pay, Alt 5 Pro No BIC Crypto Money service business AML registration only United States · Registered with FinCEN · 31000302468893 (FINCEN-MSB) · also on FINTRAC-MSB · LEI 549300VLBPOXFH1EV814](https://elucidate.co/directory/alt-5-sigma-canada-inc-8d60fef9f3f4) - [Bullish (GI) Limited No BIC Crypto Money service business AML registration only United States · Registered with FinCEN (FINCEN-MSB) · also on FINTRAC-MSB · LEI 254900NYNV3R8ASG1O69](https://elucidate.co/directory/bullish-gi-limited-ab5828389a0f) - [CoinZoom, Inc. · trading as CoinZoom No BIC Crypto Money service business AML registration only United States · Registered with FinCEN (FINCEN-MSB) · also on FINTRAC-MSB · LEI 254900OSN89KBJJMZH17](https://elucidate.co/directory/coinzoom-inc-01b348b3ef91) - [Delos Financial LTD. No BIC Crypto Money service business AML registration only United States · Registered with FinCEN (FINCEN-MSB) · also on FINTRAC-MSB · LEI 254900MKNSV3FZIVV850](https://elucidate.co/directory/delos-financial-ltd-ea8ba73e52ef) - [Flexa Inc. No BIC Crypto Money service business AML registration only United States · Registered with FinCEN (FINCEN-MSB) · also on FINTRAC-MSB · LEI 254900EFVI0G2XW4AP93](https://elucidate.co/directory/flexa-inc-0f11f48b41b5) - [Flumen Pay LLC No BIC Crypto Money service business AML registration only United States · Registered with FinCEN (FINCEN-MSB) · also on FINTRAC-MSB · LEI 984500007987393A9E81](https://elucidate.co/directory/flumen-pay-llc-d500e1541b61) - [Pionex Inc No BIC Crypto Money service business AML registration only United States · Registered with FinCEN (FINCEN-MSB) · also on FINTRAC-MSB · LEI 254900YVFF6J3358DK80](https://elucidate.co/directory/pionex-inc-597a3ecb3379) - [Stillman Digital inc. No BIC Crypto Money service business AML registration only United States · Registered with FinCEN (FINCEN-MSB) · also on FINTRAC-MSB · LEI 254900SBGEOWIZPTA157](https://elucidate.co/directory/stillman-digital-inc-798a7476d554) [See all →](https://elucidate.co/directory/search?type=crypto&cc=US) [Other entries on FINCEN-MSB →](https://elucidate.co/directory/register/fincen-msb) Sources & method Register entries come from the public registers of financial regulators, standardised into one taxonomy. LEIs are matched through GLEIF, and a BIC is linked only through a shared LEI. An institution missing from these registers is not necessarily unregulated. Register entries are not matched against the OFAC or EU sanctions lists. Where the legal entity also holds a BIC, the matches for that BIC are on its page. Always screen against the official lists. An institution is one entry in the directory: a BIC8 in Swift’s directory, or a firm on a tracked register that holds no BIC. Licences held by an institution with a BIC are shown on its page. [Read the methodology →](https://elucidate.co/directory/methodology) Registers for this page - **MSB Registrant Search**—Financial Crimes Enforcement Network (FinCEN) · [source ↗](https://www.fincen.gov/msb-registrant-search) as at 24 September 2026 - **Money Services Business Registry**—Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) · [source ↗](https://fintrac-canafe.canada.ca/msb-esm/msb-eng) as at 25 September 2026 - **Overview, authorisation, partners, products, leadership and events**—researched per institution by an AI model with web search, from the firm's own website, terms and filings, regulators' registers and notices, company registers and news. Licences, partners, figures, people and events link to their source, and each card shows the research date. AI research can be wrong or out of date, so check key facts at the source. ## Assess the financial crime risk behind a licence A licence records what an institution is authorised to do; it does not assess it. The [Elucidate FinCrime Index (EFI)](https://elucidate.co/ratings) is an independent score of the financial crime risk of banks and payment institutions. [Book a demo](https://elucidate.co/demo-request) Licence and registration data are drawn from the public registers of the regulators named on each page and shown for information only; the official register is always the authority. LEIs and ownership are from GLEIF. Directory and gpi data are drawn from SWIFT's public sources. SWIFT, Swift gpi and UETR are trademarks of S.W.I.F.T. SC, Avenue Adèle 1, 1310 La Hulpe, Belgium. Elucidate is not affiliated with, endorsed by or sponsored by SWIFT or any regulator named here. Elucidate does not provide payment or other financial services.