What is Gemini Moonbase?
Beginning on May 21, 2025 and continuing over the coming months, most Gemini users in the United States, depending on their state of residence, will be transitioned from Gemini Trust Company, LLC to a separate Gemini entity: Gemini Moonbase, LLC.
Gemini Moonbase, LLC is licensed as a money transmitter in the states as listed in our Trust Center (NMLS #2403509), and is registered as a money services business with the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN). Gemini Moonbase upholds the same high standards for security, compliance, and consumer protection that customers have come to expect from Gemini.
How will these changes affect my crypto holdings and transactions?
Your experience on Gemini will remain the same. You will continue to use the Gemini platform just as you do today, with no changes to how you buy, sell, or store crypto.
Gemini remains committed to industry-leading security, compliance, and transparency. Gemini Moonbase will uphold the same robust compliance standards that distinguish Gemini as a platform that takes a regulatory-forward approach.
Please note, you should use the updated deposit instructions if you utilize Wire Transfers to deposit cash into Gemini. To view the updated deposit instructions, navigate to "Deposit Cash" in your Gemini account after accepting the new terms. Transfers sent using outdated details may be delayed or returned. This change is applicable only to Wire Transfers. No action is required if you use other transfer methods such as ACH and Debit Cards.
To learn more about Gemini’s trust and safety controls, please visit our Trust Center here.
Who will be affected by these changes?
For the most up-to-date list of jurisdictions where Gemini Moonbase, LLC operates, please refer to our Trust Center, which is regularly updated as we obtain additional licenses.
Who will not be affected by these changes?
Gemini Trust Company, LLC will continue to serve all customers located in New York and Idaho, as well as select institutional accounts in the U.S. that require a Qualified Custodian.
Temporarily, Gemini Trust Company will also serve customers in the following states: Kentucky, Louisiana, Minnesota, Nevada, New Jersey, Nebraska, Rhode Island, Tennessee, Texas, and Ohio. These customers will be transitioned to Gemini Moonbase, LLC in the coming months.
Customers whose accounts are governed by New York law typically have a primary account registration in New York and will remain with Gemini Trust Company, including certain institutional accounts with users or operations located outside of New York.
In addition, a small number of customers may remain with Gemini Trust Company for technical or operational reasons. This ensures uninterrupted access to existing funding methods. Affected customers will be notified when their accounts become eligible for transition.
What do I need to do if my account is part of this change?
To avoid any disruption to your use of Gemini services, you’ll need to:
- Accept the User Agreement by signing in to your account after May 21, 2025 and following the prompts in the app.
- Use updated deposit instructions if you utilize Wire Transfers to deposit cash into Gemini. To view the updated deposit instructions, navigate to "Deposit Cash" in your Gemini account after accepting the new terms. Transfers sent using outdated details may be delayed or returned. This change is applicable only to Wire Transfers. No action is required if you use other transfer methods such as ACH and Debit Cards.
- If you trade via API, follow the instructions in the API Users: How to Pre-Consent to the Gemini Moonbase User Agreement section below.
Outside of these one-time steps, your experience on Gemini will remain the same.
When does my account officially become a Gemini Moonbase customer?
Your account is assigned to Gemini Moonbase, LLC as of the effective date referenced in your email notification. This assignment is consistent with the terms of the Gemini Trust Company User Agreement, which allows Gemini to assign its rights and obligations without restriction. However, in order to continue to use your Gemini account you must accept the new user agreement.
What are the changes in the user agreement?
We clarified how asset custody works across Gemini entities, including clear distinctions between omnibus and segregated accounts, and explained how these structures impact your rights, protections, and available services based on your jurisdiction. While the terms are substantially aligned, the governing legal frameworks differ slightly: Gemini Trust Company operates under New York law as a licensed limited purpose trust company, whereas Gemini Moonbase is a Florida-based entity licensed as a money transmitter in the states where it operates.
We updated our descriptions of account remedies, investigations, - market conduct enforcement, and arbitration. To see the complete scope of changes that apply to your Gemini account and use of Gemini services, please review the Gemini Moonbase, LLC User Agreement or the Gemini Trust Company, LLC User Agreement, depending on your jurisdiction.
What happens if I don’t accept the new user agreement?
If you don’t accept the new agreement, then you won't be able to access your Gemini account.
If you choose not to accept these changes and want to close your account, please submit a support request so Gemini Support can help you move your funds off the platform.
Are there any new fees or changes to existing fee structures?
No. There will be no changes to the existing fee structures. You can review our fee schedule here.
Does this have any impact on my Gemini CustodyⓇ account?
The Gemini CustodyⓇ product will continue to be governed by Gemini Trust Company, LLC, per the Custody Agreement you signed during account creation. However, custody for certain items in your Exchange account may be provided by Gemini Moonbase, LLC going forward. Nevertheless, you will continue to be able view and manage all of your assets seamlessly through your Gemini account.
Is there a deadline to accept the new user agreement?
No. However, please note that if you do not accept the new User Agreement, then you won't be able to access your Gemini account.
If you choose not to accept these changes and want to close your account, please submit a support request so Gemini Support can help you move your funds off the platform.
Is there a way to download the new terms prior to accepting?
You can view the Gemini Moonbase, LLC User Agreement here.
I accidentally declined the new user agreement, how do I change my decision?
Please reach out to our Customer Support team to restore access and accept the updated terms.
Does this affect how my assets are insured on Gemini?
No. Our Digital Asset Insurance will remain unchanged on Gemini.
Will these changes affect wire deposit instructions?
If you use Wire Transfers to deposit cash into Gemini, please note that there are now updated deposit instructions. To view the updated deposit instructions, navigate to "Deposit Cash" in your Gemini account after accepting the new terms. If you do not use the updated deposit instructions, your transfer may be delayed or returned.
Is Gemini affiliated with the Moonbase app or Moonbase Labs?
No, Gemini is not affiliated with the Moonbase app or Moonbase Labs.
API Users: How to Pre-Consent to the Gemini Moonbase User Agreement
As an API-only client, how will we know if we have accepted the new terms on the website?
Institutional accounts using API credentials will need to have an account administrator log into the Gemini web interface to accept the updated terms, as acceptance cannot be completed via API.
Who needs to do this?
All Gemini users who access the platform via API credentials must accept the updated User Agreement by May 21, 2025 to avoid disruption to API access during the transition to Gemini Moonbase.
How do I accept the new agreement if I use API credentials?
- Log in to your Gemini account via the web interface.
- Navigate to Settings > API.
- Click the "View User Agreements" banner at the top of the page.
- Follow the on-screen prompts to review and accept the new Gemini Moonbase User Agreement.
Can I accept the agreement via API?
No. Acceptance cannot be completed via API calls. You must log into the web interface to complete this process.
When is the deadline to accept the user agreement?
You must accept the new agreement by May 21, 2025 to ensure continued access to your API keys and prevent service interruption.
What happens if I miss the deadline?
If you do not accept the new User Agreement:
- You will lose access to the Gemini API until you login and sign the User Agreement.
All types of API keys may be disabled until you login and sign the User Agreement.