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Top rated: Rabby 8.3
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The most conservative custody setup of any exchange we rate, held by a New York trust company under a regime that is genuinely more demanding than a money-transmitter licence. The price is high: the app is expensive, and since 1 Sep 2026 the ActiveTrader base tier is 0.60% maker / 1.20% taker. In 2026 Gemini is leaving the UK, the EU and Australia while posting heavy losses.
Best for: US users who want the strictest state custody regime and will pay for it
7.1 is the weighted average of the five pillar findings below. Dependable, with trade-offs a reader should know about first.
Custody through a New York limited-purpose trust company, a materially stricter regime than money transmission. SOC audits published. No hack of exchange customer balances on record. The company itself is under strain: a $107.7M net loss in Q2 2026 and a $250M Ripple credit line in April 2026.
The app is simple and expensive. Since 1 Sep 2026 ActiveTrader starts at 0.60% maker / 1.20% taker, and taker fees reach 0.10% only at $1M of 30-day volume.
Strong licensing position undercut by the Earn programme: about $940M of 340,000 Earn users' crypto was frozen at affiliated lender Genesis from November 2022, and the matter drew a $37M NYDFS penalty in 2024. Users got 100% of their coins back in kind by mid-2024, so no unrecovered-loss penalty applies, and the SEC dropped its Earn case with prejudice in January 2026. A freeze of that length is still a material mark.
Reliable infrastructure with adequate depth in majors; thinner than the leaders outside them. Assets on platform fell to $8.4B by June 2026 from $18.2B a year earlier.
Clean onboarding and good documentation, but Gemini announced in February 2026 that it is winding down in the UK, the EU and Australia to focus on the US and Singapore.
Strengths
Against it
Gemini holds customer assets through a New York limited-purpose trust company, chartered by NYDFS in 2015, a regime that is materially more demanding than the money-transmitter licences most US venues operate under, and it publishes SOC audit reports rather than summaries of them. No hack has drained exchange customer balances. On the narrow question of how the assets are held, this is the strongest arrangement any exchange here can point to.
That standard did not extend to the Earn programme, which lent customer crypto to Genesis Global Capital. Genesis froze withdrawals in November 2022, trapping about $940M of 340,000 users' funds; Gemini ended Earn in January 2023 and paid a $37M NYDFS penalty in 2024. Users got 100% of their coins back in kind by mid-2024, which is why no unrecovered-loss penalty applies, and the SEC dropped its Earn case with prejudice in January 2026. The freeze still lasted about 18 months, and it is why the regulation score sits well below what the custody arrangement alone would suggest.
Gemini has the most expensive order book in this table for a small account. The app is simple and costly, and since 1 Sep 2026 ActiveTrader starts at 0.60% maker / 1.20% taker, reaching 0.10% taker only at $1M of 30-day volume. The company is also under strain: a $107.7M net loss in Q2 2026, a $250M Ripple credit line, and a wind-down in the UK, the EU and Australia announced in February 2026. The trust charter keeps customer assets segregated, which matters most in exactly this situation.
The exchange custody arrangement — New York trust company, published SOC reports — was never the thing that failed. What failed was a yield product that lent customer funds to an affiliated lender. Earn users got 100% of their coins back in kind by mid-2024. The newer question is the company's finances: heavy losses through 2025 and 2026 and outside funding from Ripple and its founders.
A New York Department of Financial Services designation with capital, custody and compliance requirements considerably stricter than a money-transmitter licence. Customer assets are held in trust for the customer, under a supervisory regime designed for custodians rather than for payment companies.
Mostly on cost. ActiveTrader's base tier has been 0.60% / 1.20% since 1 Sep 2026, against 0.40% / 0.80% on Kraken Pro and 0.50% / 0.90% on Coinbase Advanced in the US. The Earn freeze and the 2026 exit from the UK, EU and Australia pull it down further.
Gemini said in February 2026 that it would wind down its UK, EU and Australian operations and concentrate on the US and Singapore. If you hold a balance there, plan to withdraw it.
Assessed by
By Emily Volker
Editor-in-Chief · September 27, 2026
CoinRadar Daily is a non-commercial project. We have no commercial relationship with Gemini, earn nothing from any link on this page, and carry no advertising or sponsorship anywhere on the site. Findings rest on public sources; we did not open an account or transact.
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