Gemini’s Principles for the Crypto Revolution

Today, we ran a full-page ad in the New York Times outlining what we think the cryptocurrency revolution needs to succeed. We firmly believe this revolution will re-architect trade, the financial system, the Internet, and money as we know it.

But it won’t be easy, and there is no guarantee.

The crypto revolution has the potential to solve meaningful, real-world problems that no other technology can — but only a thoughtful, rule-based approach will get us there. Revolutions that build sets of rules to ensure a better future, are the ones that last.

As a result, we are sharing the following set of guiding principles that we believe will help crypto fulfill its ultimate promise. As we build a real, sustainable bridge between the ‘old world’ of money and the future of money, we strive to always:

1. Build the Rules.

To work with regulators to establish thoughtful regulation that promotes positive and fair outcomes for all.

In 2014, we testified at the New York Department of Financial Services (NYDFS) Virtual Currency Hearings. These hearings set the stage for a thoughtful dialogue between the NYDFS and the crypto community, eventually leading to the New York Virtual Currency Regulations. To date, NYDFS has licensed or chartered 12 virtual currency businesses. All of these businesses, including Gemini which is a New York trust company, operate within a regulatory framework that fosters consumer protection.

In addition, we have championed best practices that we believe make Gemini a safe place that fosters market integrity:

• Marketplace Conduct Rules — On September 21, 2017, we adopted Marketplace Conduct Rules. These rules were modeled off of the Cboe Futures Exchange, LLC (CFE) Rulebook.
• Marketplace Surveillance — On April 25, 2018, we announced our partnership with Nasdaq to implement Nasdaq’s SMARTS Market Surveillance technology to monitor the Gemini marketplace. As of August 10, 2018, SMARTS has been deployed on the Gemini marketplace.
• Market Surveillance Team — On April 25, 2018, we hired a Head of Market Surveillance. Since then, we have built a Market Surveillance Team that continues to grow.
• Virtual Commodities Association — On March 13, 2018, we published a proposal for the Virtual Commodity Association, an industry-sponsored self-regulatory organization for virtual commodity exchanges. CFTC Commissioner Brian Quintenz issued a public statement in support. The initial working group held its inaugural meeting in September 2018.

This is just the beginning as we plan to continue to engage and work with regulators across the country on both the state and federal level (Gemini currently has licenses or approvals in 49 states), as well as internationally, to help shape thoughtful regulation and oversight so that consumers are afforded the same protections in the crypto market as they are in more traditional markets.

2. Play by the Rules.

To operate with necessary governmental or regulatory approvals. Ask for permission, not for forgiveness.

Although we started building Gemini in 2014, we waited until we received our New York trust company license in October of 2015 to begin operating. Our decision — to ask for permission, not forgiveness — was a first in cryptocurrency. We chose this path because we believed that in order to build the future of money, we had to first build trust in this new asset class.

We are a compliance-centric company — we have developed (and will continue to invest in) cutting edge tools for our Compliance Department to ensure that Gemini is not a place for bad actors.

3. Value Security Over Profit.

To never cut corners. To set the standard and follow best practices in order to provide a platform that is free of hacking and fraud.

Financial crime affects both fiat and cryptocurrencies alike, but the crypto revolution will not succeed if our industry is plagued by nefarious activity. High-profile hacks that result in catastrophic losses must become a thing of the past, and we must shake the image of an industry characterized by poor security standards, internal controls, and policies and procedures.

In an effort to do so, we built our team with a security-first mentality from day one — a team that has built a state-of-the-art hot wallet and cold storage system and is deeply committed to employing cybersecurity best practices to protect your funds and the integrity of our platform. Recently, we added a further layer of protection by securing insurance coverage for the cryptocurrency that we hold on your behalf in our online hot wallet. We are, and will continue to be, committed to making Gemini a safe and secure platform to store your cryptocurrency.

4. Be Principled.

To do the right thing — because it’s the right thing — even when it’s the hard thing. To put the interests of our customers ahead of our own and provide proper disclosures and transparency.

The four pillars of Gemini are Product, Security, Licensing, and Compliance. We refuse to compromise in any of these areas and will continue to invest in long-term solutions that align with our north star of building a company that provides enduring value to our customers — for more than a 100 years — a Centurion. We will continue to do these things even when it’s the harder, less profitable, and slower path in the short-term. We’re in this for the long game; we’re trying to be the fastest tortoise in the race.

5. Pay it Forward.

To bring cryptocurrency to the people and places that need it most.

Like the invention of money itself, which solved the coincidence of wants dilemma and removed the shackles of barter; like the evolution of credit and debt, which helped transfer capital from idle savers to risk-taking entrepreneurs; like the invention of the joint-stock company, which spurred on investment by enabling atomistic ownership structures and limiting an investor’s liability to his or her stock ownership; and like the invention of the stock exchange, which allowed liquid markets for a company’s shares to emerge, the invention of cryptocurrencies have irrevocably expanded our concept of money and will forever change how we exchange, transfer, and store it.

Not since the dawn of the Internet has technology had the potential for such profound impact. But in order to make such an impact, we must bring this technology to all reaches of the globe. We have started by building the Gemini dollar, which brings U.S. dollars onto the blockchain and to anyone in the world with an Internet connection. This is the first of many projects we hope to embark on that help foster, among other things, financial inclusion (e.g., banking the 1 billion+ unbanked citizens of the world), reduced friction and costs of cross-border payments (e.g., remittances), access to digital safe-haven assets (e.g., buying bitcoin through the Gemini Mobile App), and a more decentralized Internet that returns control of your data back to you.

Join the Gemini Mission

We are only at the beginning of this journey. Yes, some of the hardest work remains ahead, but we’re up for the challenge and we know you are too. We welcome industry leaders, developers, builders, entrepreneurs, investors, and whoever else, to join us as we strive to build rules for this amazing revolution that will ensure not just the future of money, but a better future for all.

Onward and Upward,

Cameron + Tyler