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BSA/AML Program

Last updated: February 28, 2025

Bank Secrecy Act and Anti-money Laundering Compliance Program

Welcome! Thanks for visiting Gemini, a digital asset platform operated by Gemini Trust Company, LLC (“GTC”) and Gemini Moonbase, LLC (“Moonbase”) (collectively “we”, “our” or “Gemini”). GTC and Moonbase have each developed a Bank Secrecy Act and Anti-Money Laundering Compliance Program (“BSA/AML Program”) designed to maintain compliance with applicable laws and regulations relating to AML and counter-terrorist financing (CTF). This includes, but is not limited to:
  • Establishing robust internal policies, procedures and controls that combat any attempted use of Gemini for illegal or illicit purposes and that are designed to ensure our customers basic protections under consumer protection laws;
  • Complying with the applicable regulations and guidance set forth by the Financial Crimes Enforcement Network (“FinCEN”);
  • Filing Suspicious Activity Reports (“SARs”);
  • Filing Currency Transaction Reports (“CTRs”);
  • Maintaining comprehensive records of orders and other transfers;
  • Employing a Bank Secrecy Act Officer (“BSAO”) responsible for the implementation and oversight of our BSA/AML Program;
  • Executing Know Your Customer (“KYC”) procedures on all customers;
  • Performing regular, independent audits of our BSA/AML Program;
  • Following record retention requirements; and
  • Implementing a compliance training program for all new and existing employees.

Policies and Procedures

Our BSA/AML Program has been reviewed and approved by our Boards of Managers (the “Boards”). Our BSA/AML Program is regularly reviewed and, if necessary, revised in an effort to comply with applicable rules, regulations and policies. GTC is regulated by the New York State Department of Financial Services (“NYSDFS”) as a trust company. Both GTC and Moonbase comply with applicable BSA/AML requirements under the oversight of relevant state regulatory agencies and the U.S. Department of the Treasury’s FinCEN.

Internal Controls

We have developed robust internal policies, procedures, and controls designed to comply with applicable BSA/AML laws and regulations, some of which are outlined here on this page, including, but not limited to, employee training, our Customer Identification Program (“CIP”), the filing of SARs and CTRs, as well as other reporting requirements and audits.

Training

All of our employees, officers, and Board members receive regular BSA/AML training, as well as position-specific training. They must receive this training at least once every twelve (12) months. New employees receive training within thirty (30) days of their start date. All documentation related to compliance training, including materials, tests, results, attendance and dates are maintained. In addition, our compliance training program is updated as necessary to reflect current laws and regulations.

Bank Secrecy Act Officer

The BSA Officer (“BSAO”) is responsible for coordinating and monitoring day-to-day compliance under our BSA/AML Program. The BSAO is required to report any violations of our BSA/AML Program directly to our CEO and our Board. In addition, the BSAO is responsible for recording and filing SARs, CTRs and performing a BSA/AML Program audit at least annually.

Customer Identification

Our Customer Identification Program (“CIP”) is an important part of our BSA/AML Program. It helps us verify the identities of our customers, detect suspicious activity in a timely manner and prevent fraud.

Account Opening Process

In order to open an account and use Gemini, your identity must be verified, authenticated, and checked against government watchlists, including the Specially Designated Nationals List (“SDN List”) published and updated by the Office of Foreign Assets Control (“OFAC”). Failure to complete any of these steps will result in your inability to use Gemini.
Individual customer — Prior to opening an account for an individual customer, we attempt to collect, verify, and authenticate the following information:
  • Email address;
  • Mobile phone number;
  • Full legal name;
  • Social Security Number (“SSN”) for U.S. persons, or any comparable government-issued identification number for non-U.S. persons;
  • Date of birth (“DOB”);
  • Proof of identity (e.g., driver’s license, passport or government-issued ID);
  • Home address (not a mailing address or P.O. Box); and
  • Additional information or documentation as determined by our Compliance Team.
Non-US customers are required to provide an additional proof of identity (e.g., driver’s license, passport, or government-issued ID) and any additional documentation as required under applicable laws and risk assessments.
If you successfully meet and complete our CIP requirements, then we will provide you with account opening agreements electronically.
Institutional customer — Prior to opening an account for an institutional customer, we attempt to collect, verify, and authenticate the following information:
  • Institution legal name;
  • Employer Identification Number (“EIN”) or any comparable government-issued identification number;
  • Full legal name (of all account signatories and beneficial owners);
  • Email address (of all account signatories);
  • Mobile phone number (of all account signatories);
  • Address (principal place of business and/or other physical location);
  • Proof of legal existence (e.g., state certified articles of incorporation or certificate of formation, unexpired government-issued business license, trust instrument or other comparable legal documents as applicable);
  • Contract information of owners, principals, and executive management (as applicable);
  • Proof of identity (e.g., driver’s license, passport or government-issued ID) for each individual beneficial owner that owns 10% or more, as well as all account signatories; and
  • Identifying information for each entity beneficial owner that owns 10% or more (see individual customer information collected above for more details).

If your institution successfully meets and completes our CIP requirements, we will provide you with account opening agreements electronically.


Suspicious Activity/Currency Transaction Reports Process

We file SARs if we know, suspect or have reason to suspect suspicious activities have occurred by, at or through Gemini. A suspicious transaction is often one that is inconsistent with a customer’s known and legitimate business, personal activities or personal means. We leverage our Compliance Department, which performs transaction monitoring to help identify unusual patterns of customer activity. The BSAO is responsible for the review and investigation of suspicious activity to determine if sufficient information has been collected to justify the filing of a SAR.
In addition, any currency transactions over a determined USD value are to be reported to FinCEN via a CTR filing.
Our BSAO is responsible for maintaining records and supporting documentation of all SARs and CTRs that have been filed.

BSA/AML Program Audit

Gemini’s Internal Audit function is responsible for overseeing the independent assessment of our BSA/AML Program at least annually. The results are presented to our Board.

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