Digital Payment Tokens Listing Framework

Last updated: June 16, 2025

This policy is provided by Gemini Digital Payments Singapore, Pte. Ltd. (“Gemini SG”) for general informational purposes only and does not constitute a binding agreement. Gemini SG may revise, update or withdraw this policy at any time without prior notice. The inclusion or continued listing of any digital asset remains at the sole discretion of Gemini SG and is subject to applicable regulatory considerations. Nothing in this policy should be construed as a commitment to list or maintain the listing of any digital asset.

1. INTRODUCTION

Gemini Digital Payments Singapore, Pte. Ltd. (“Gemini SG”) maintains a digital asset listing framework, which sets forth the requirements for the listing and delisting of digital assets, including digital payment tokens (“DPTs”), stablecoins, and other supported tokens (collectively “digital assets”) on its platform. This framework is aligned with the Monetary Authority of Singapore’s (MAS) Guidelines on Consumer Protection Measures by DPT Service Providers and provides transparency regarding the process by which these digital assets are evaluated, monitored and meet appropriate standards for legality, integrity and consumer protection.
Gemini SG may only provide services for a digital asset that has been subject to a comprehensive review and determined to satisfy the listing criteria. 

2. SCOPE

This policy applies to all digital assets considered for listing on Gemini SG’s platform. It governs the review, approval, ongoing oversight, and potential delisting of DPTs and other digital assets supported by Gemini SG. The framework ensures compliance with applicable laws and regulations and supports the long-term stability, soundness, and reputation of Gemini SG’s digital asset services.

3. FRAMEWORK

Gemini SG is committed to upholding the highest compliance principles and ensuring that the digital asset and the use(s) for which it is being considered are consistent with our listing and consumer protection standards. Gemini SG is accountable and responsible for the digital assets it chooses to list on its platform. This Digital Payment Tokens Listing Framework aims to provide Gemini SG’s customers with greater clarity and transparency on how digital assets listed on Gemini SG’s platform are evaluated, enabling more informed assessments as it relates to Gemini SG’s listing process. Accordingly, each digital asset listed by Gemini SG undergoes a comprehensive evaluation process, (“Evaluation Process”). 

Gemini SG reviews business proposals and performs comprehensive due diligence for each digital asset as part of its Evaluation Process. This process seeks to ensure that the digital asset is or will be issued by a legitimate and reputable entity or project. The Evaluation Process involves an assessment across various criteria, including but not limited to: 

  • Technical Design and Technology
    • Evaluation of the token’s governance, use case, and design.

  • Cybersecurity 
    • Review of token smart contracts and cybersecurity audits. 

  • Reputational
    • Assessment of the integrity, experience, and reputation of the project, developers, and investors. 

  • Illicit Finance 
    • Determination of whether the token may be primarily used for illegal or illicit activities.

  • Legal
    • Conducting a legal analysis for each asset supported on Gemini’s platform to assess whether the asset is likely to be considered a security under the relevant and applicable securities laws.

As part of the Evaluation Process, Gemini SG will also evaluate potential risks to consumers and assess whether any of the asset’s characteristics or elements in its design elevates the risk of potential consumer harm. Material conflicts that Gemini SG or its related companies might have with any asset it offers on its platform will be publicly disclosed on its website at the time of listing.

Gemini SG also considers market integrity risks, including susceptibility to price manipulation, wash trading, or insufficient market depth. Where relevant, it assesses whether the asset is traded on venues that are subject to regulatory oversight or have credible market surveillance practices in place - such as established centralized exchanges that monitor for abusive trading behaviors.

4. ONGOING MONITORING

Following the initial listing of a digital asset, Gemini SG will monitor such digital assets to ensure that the continued listing of the digital asset remains consistent with its listing criteria and the protection of customers and the general public. 
Digital assets that are listed by Gemini SG will be subject to periodic re-evaluation to ensure that no material changes related to a listed digital asset have occurred.  


5. DELISTING

Gemini SG may suspend, cease, or delist a digital asset from its platform if it determines, at its discretion, that the digital asset poses a material risk. The decision to suspend or delist a digital asset from Gemini SG’s platform is typically conditioned on the digital asset’s failure to satisfy Gemini SG’s listing standards as set out in the Evaluation Process above, or when it presents elevated or unacceptable risk. Common reasons include, among other things, the failure to meet Gemini SG’s technical and security requirements, unsustainable trading volume, liquidity issues, or a lack of market demand. 

Where a decision is made to delist an asset, Gemini SG will, wherever practicable, provide affected customers with prior written notice 30 days before delisting takes effect. This communication will include the reason for the delisting, the timeline for trading and/or withdrawal changes, and the options available to customers before functionality is modified or discontinued.

In situations where urgent action is required to safeguard customers or the platform (e.g., serious legal, technical, or cybersecurity threats), Gemini SG may pause or cease support for an asset without advance notice. In such cases, Gemini SG will notify customers as soon as reasonably possible and provide guidance on the next steps, including asset withdrawal procedures where applicable.

In exceptional circumstances, Gemini SG may delist a digital asset immediately without advance notice, where it determines there is a good cause to do so (e.g. due to legal or regulatory reasons, smart contract security risks, etc). Measures taken by Gemini SG, and the impact on affected services will be communicated to the customers during the event and will vary depending on the circumstances. Gemini SG shall not be liable for any losses, damages, or claims arising directly or indirectly from the immediate delisting, suspension, or ceasing of a digital asset under such exceptional circumstance, including but not limited to any inability to access, trade, or withdraw the affected digital asset, or any fluctuations in its value. Customers acknowledge and agree that Gemini SG may take such actions without prior notice and that their use of Gemini SG services is subject to this risk. 

Gemini SG’s customer support and custody operations teams will be equipped to handle delisting-related queries and facilitate timely asset withdrawals. Customers are encouraged to take prompt action upon receiving delisting notices to avoid any disruptions.

6. UNFAIRLY OR DISORDERLY TRADING RISKS

Gemini SG recognises the risk of unfair or disorderly trading that may arise from the nature of DPT activities. To mitigate this, Gemini SG has implemented the necessary safeguards to ensure the fair and orderly trading of DPTs by its customers on the Gemini SG platform. 
Gemini SG customers must agree and accept our when accessing order book trading through Gemini SG. This includes a comprehensive set of rules and operational controls to prevent and manage unfair or disorderly trading conduct. 
Examples of key measures include: 
  • Strict prohibition of market manipulation, where a person takes action intended to deceive, mislead, or improperly take advantage of other traders or the platform itself, or to artificially control or manipulate the price or trading volume of an asset.
 
  • Broad discretionary authority to intervene and take action to preserve market integrity. The Market Surveillance team of Gemini SG (and its affiliates) is empowered to take actions including, without limitation, halting trading on specific order books or the entire platform, modifying risk-mitigating parameters, restricting trader access or order types (e.g., limiting to post-only or limit orders), cancelling resting orders, updating access criteria or other operational controls. 

  • No preferential treatment. All Gemini SG customers are subject to the same rules and market data access. Gemini SG does not provide prioritized access to any of its customers. 

  • Gemini SG enforces an employee trading policy and a trade surveillance program to prevent misuse of inside, corporate, or proprietary information. Employees are prohibited from using such information for trading and are required to follow strict compliance protocols. 
  • Self-Trade Prevention. The platform has mechanisms to prevent self-trading (where the same trader would be both buyer and seller in a transaction). If such a scenario is detected, the platform cancels the involved orders or decrements them appropriately to avoid self-execution. 

  • Whistleblowing and Handling of Complaints. Gemini SG takes all complaints relating to unfair or disorderly trading seriously, including those raised through internal or external whistleblowing channels. Gemini SG maintains policies and procedures to enable the confidential reporting of suspected misconduct, including market manipulation, abusive trading practices, or breaches of internal controls. Reports received are promptly reviewed by the Market Surveillance team of Gemini SG (and its affiliates), with appropriate follow-up actions taken where necessary to safeguard market integrity.


7. PERIODIC REVIEW 

Gemini SG’s new digital asset listing framework is subject to periodic review to ensure continued robustness in governance, monitoring, and oversight.

8. CONFLICTS OF INTEREST 

Gemini SG does not, and does not intend to, charge listing fees or any form of incentive from digital asset projects in connection with the listing of digital assets on Gemini SG’s platform. Any commercial agreements, where applicable, are subject to separate evaluation and oversight. 

Gemini SG recognises that receipt of any incentives in relation with its DPT services may give rise to actual or potential conflicts of interest. Such conflicts may unduly influence Gemini SG’s commercial decisions to support or list certain digital assets and may interfere with the independence and effectiveness of this Digital Payment Tokens Listing Framework. While Gemini SG acknowledges that appropriate measures (e.g. customer disclosures) must be implemented to address such risks, it reiterates that Gemini SG does not charge any listing fees or any form of incentives from digital asset projects in connection with the listing of digital assets on Gemini SG’s platform.
 
In addition, Gemini SG acknowledges the actual or potential conflicts of interest that may arise from the issuance of the Gemini Dollar, issued by a Gemini SG affiliate, that may affect the application of this Digital Payment Tokens Listing Framework. Material conflicts of interest are  disclosed on Gemini’s website. 

This Digital Payment Tokens Listing Framework is applied in an objective and neutral manner and should not be construed as an endorsement of any particular digital asset that makes available forward-looking price expectations or otherwise seek to entice customers to favour the trading of any digital assets.

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