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Singapore Addendum

Last updated: June 19, 2025

RISK WARNING ON DIGITAL PAYMENT TOKEN SERVICES


The Monetary Authority of Singapore (“MAS”) requires Gemini Digital Payments Singapore, Pte. Ltd. (“Gemini SG”) to provide this risk warning to you as a customer of a digital payment token (“DPT”) service provider.

Before you pay your DPT service provider any money or DPT, you should be aware of the following. 

  1. Your DPT service provider is licensed by the MAS to provide DPT services. Please note that this does not mean you will be able to recover all the money or DPTs you paid to your DPT service provider if your DPT service provider’s business fails.
  2. You should not transact in a DPT if you are not familiar with the DPT. This includes how the DPT is created, and how the DPT you intend to transact is transferred or held by your DPT service provider.
  3. You should be aware that the value of DPTs may fluctuate greatly. You should buy DPTs only if you are prepared to accept the risk of losing all of the money you put into such tokens.
  4. You should be aware that your DPT service provider, as part of its licence to provide DPT services, may offer services related to DPTs which are promoted as having a stable value, commonly known as “stablecoin”.

1. Introduction


1.1 This addendum applies in relation to the User Agreement and the Custody Agreement (together the “Agreement”) entered into between Gemini SG and a Singapore customer (the “Addendum”). In this Addendum, “you”, “your”, and any other cognate terms are a reference to such a customer in Singapore. Where there is an overlap and/or conflict between the terms of the Agreement and the Addendum or where the terms of the Agreement are silent on a particular matter but such matter is covered by the terms of the Addendum, the terms set out in the Addendum shall prevail.

1.2 Gemini SG has an in-principle approval for the major payment institution license (“MPIL”), for providing: (a) cross-border money transfer service; and (b) digital payment token service (including provision of custodial services for digital payment tokens), as defined under the Payment Services Act 2019 (“PSA”).

1.3 This Addendum sets out the Singapore-specific terms, including the custody and safeguarding arrangements of the fiat money and digital assets received from customers, to which a customer in Singapore agrees or consents, as the case may be, and contains the disclosures with which Gemini SG must comply as a matter of its obligations under the PSA, the Payment Services Regulations (“PSR”) and notices and guidelines promulgated thereunder. 

2. Custody and Safeguarding of fiat money received from you


2.1 Gemini SG receives fiat currency from you for the purposes of making purchases and payments on its online platform, including the exchange. Such fiat currency is safeguarded by Gemini SG for your benefit in a trust account opened with a safeguarding institution. The safeguarding institution with which Gemini SG will hold your fiat money in the trust account is DBS Bank Ltd. (“DBS”).

2.2 Gemini SG will hold the fiat money received from you on your behalf and this money will be segregated from and held separately from Gemini SG’s corporate funds.

2.3 The fiat money received from you will be held together with, and commingled with, the fiat money received by Gemini SG from its other customers, in an omnibus account.

2.4 As your fiat money is commingled with those of the other customers of Gemini SG, if Gemini SG or DBS become insolvent, you may not have a legal claim against a specific amount of fiat money. Instead, any claim will be generally against the omnibus account. If there is an unreconciled shortfall, you may not receive your full entitlement to the fiat money and you may have to share the shortfall proportionately with other customers of Gemini SG. 

2.5 With reference to Regulation 16(4) of the PSR, you hereby agree with Gemini SG that any interest earned from the maintenance of fiat money in the trust account with DBS will not accrue to you. In other words, all such interest shall be retained by Gemini SG and to avoid doubt shall not constitute “relevant money” liable to be safeguarded under Section 23 of the PSA.

3. Custody and Safeguarding of digital assets received from you


3.1 Gemini SG safeguards your digital assets on your behalf in designated trust accounts maintained by one or more regulated affiliates of Gemini SG (“Regulated Affiliates”). Gemini SG continues to maintain control and exercise governance over the digital assets. The Regulated Affiliates will hold and record your digital assets in accordance with Gemini SG’s instructions, and our Operations team will be providing information for the instructions and transfers of these digital assets. The Regulated Affiliates will provide sufficient information to Gemini SG on a timely basis as Gemini SG may reasonably require to comply with Gemini SG’s record-keeping obligations under any written law. Gemini SG will not permit any withdrawal of your assets from the trust account, except for delivery of your assets to Gemini SG or to any other person upon receipt of Gemini SG’s written instructions. The trust accounts are located outside Singapore, where the laws and practices may be different from the laws and practices in Singapore, which might affect your ability to recover your assets, such as delaying the recovery process.

3.2 While your assets are held by Gemini SG in designated trust accounts maintained by its Regulated Affiliates, in case of any default by any of such Regulated Affiliates or any loss of your assets in such trust accounts caused by fraud or negligence on the part of such Regulated Affiliates or such Regulated Affiliates’ agents, Gemini SG shall be liable to you.

3.3 In case of any loss of your assets arising from fraud or negligence on the part of Gemini SG: 

3.3.1 Please contact Gemini SG immediately through our Help Center. Gemini SG will consider your complaint based on the information provided by you and will endeavour to respond with a written decision addressing the issues raised within 45 Business Days after Gemini SG receives your complaint. If the complaint remains unresolved, you may escalate your complaint via the dispute resolution process set out in Section 10. 

3.3.2  The quantum of the offer of resolution, or any analogous compensation for your lost assets, will be capped at the value of the assets that were lost as a result of the disputed transaction(s). Gemini SG’s determination of the value of the assets that were lost will be final and binding. This compensation may be adjusted for any contributory negligence, act, or omission on your part. 

3.3.3 Gemini SG will not be liable for the types of losses set out under the Disclaimer of Liabilities section of the User Agreement. For the avoidance of doubt, Gemini SG is not liable for any loss that you may sustain if you have been fraudulent or negligent, including where: (i) you have carried out any transaction on the instructions of a third party (or have allowed a third party to remotely access or share your computer while logged in to your Gemini Account); or (ii) your login credentials or API key were compromised. 

3.4 Your assets will be kept separate from any assets belonging to the Regulated Affiliates. Gemini SG will hold your digital assets in two types of trust accounts-depository accounts and segregated custody accounts. 

3.4.1  In segregated custody accounts, your digital assets will not be commingled with the digital assets of other customers or the digital assets of Gemini SG or any of its Regulated Affiliates. 

3.4.2  Your digital assets held in the depository accounts will be commingled with the digital assets of Gemini SG’s other customers as well as the digital assets of the Regulated Affiliates’ customers. However, such digital assets held in the depository accounts will be segregated from Gemini SG’s and its Regulated Affiliates’ digital payment tokens, as well as their business, operating and reserve digital payment token accounts. 

3.5 As a result of commingling your digital assets with the digital assets of Gemini SG’s other customers and the digital assets of the Regulated Affiliates’ customers, your interest in your digital assets may not be identifiable by separate physical documents or electronic records. In this regard, Gemini SG and its Regulated Affiliates maintain a record of your ownership of digital assets held in the depository accounts on their internal ledger and the amount and type of digital assets held by you is also reflected in your account on the digital platform.

3.6 In depository accounts, as your digital assets are commingled with those of the other customers of Gemini SG as well as the customers of the Regulated Affiliates, if Gemini SG or any of the Regulated Affiliates become insolvent, you may not have a legal claim against a specific amount of digital assets. Instead, any claim will be generally against the depository account. If there is an unreconciled shortfall, you may not receive your full entitlement to the digital assets, or the value of the digital assets in fiat money and you may have to share the shortfall proportionately with the other customers of Gemini SG and the customers of the Regulated Affiliates. 

3.7 Gemini SG will store your digital assets in both hot wallets, which are connected to the internet, and cold wallets, which are off-line and secure against any online attacks. Gemini SG stores some percentage of your digital assets in hot wallets to allow for immediate access of digital assets for trading and withdrawals. Gemini SG or its affiliates secure insurance to protect the digital assets in both hot wallets and cold wallets from theft or loss (further details on this can be found here), and no more than 10% of the total digital assets of our customers are kept in hot wallets. This does not change either your access to or your right to withdraw any or all of your assets at any time, nor does it change or impact Gemini SG’s obligations to fully safeguard all of your funds. 

3.8 Any entitlements accruing to you will be reflected in your account in real time and you will have full right of ownership over such entitlements. 

3.9 Gemini SG does not charge you for holding your digital assets in depository accounts. For digital assets held in segregated custody accounts, Gemini SG charges the fees as specified in the Custody Fee Schedule.

3.10 Gemini SG does not currently take and hold your digital assets as collateral to meet your liabilities to Gemini SG.

3.11 You agree and acknowledge that any instruction to and from Gemini SG regarding your digital assets will be given through the digital platform. Gemini SG does not permit your giving of authority to another person to give or receive instructions from Gemini SG.

3.12 You may contact Gemini SG for more information relating to the holding of your digital assets.

4. Prohibition on Incentives, Credit and Leverage Transactions 


4.1 Incentives and Gifts. Gemini SG does not offer any incentives or gifts to retail customers to engage in digital asset services. This includes, but is not limited to, sign-up incentives, referral incentives, and promotions involving the provision of trading credits or digital assets.

4.2 Credit Facilities and Leverage. Gemini SG does not offer credit facilities, loans of digital assets, or leverage (including margin trading) to retail customers. Retail customers are prohibited from entering into any leveraged digital asset transactions with Gemini SG, and Gemini SG does not facilitate or induce retail customers to engage in such activities with third parties.

4.3 Digital Asset Derivatives Contracts. Gemini SG does not offer or facilitate the offering of digital asset derivatives contracts to retail customers, including any form of contracts-for-difference (CFD) or futures contracts referencing digital assets.

4.4 Payments Using Credit or Charge Cards. Gemini SG does not accept payments from retail customers using credit or charge cards for any digital asset services or to fund any accounts related to digital asset services.

5. Statement of Account


5.1 You consent to receiving a statement of account containing, where applicable, the following particulars, electronically, in your account on the Gemini platform:

(a) transactions to purchase or sell assets entered into by you and the price at which the transactions are entered into; 

(b) the status of every asset in Gemini SG’s custody held for you; 

(c) the movement of your every asset, the date of and reasons for such movement, and the amount of the asset involved; 

(d) the movement and balance of relevant money received from you, or on account of you, in respect of the provision of a digital payment token service; and
 
(e) a detailed account of all financial charges and credits to your account during the monthly statement period, unless the detailed account of financial charges and credits has been included in any contract note or tax invoice issued by Gemini SG to you.

6. Rights arising from Digital Assets, Forks and Airdrops


6.1 You acknowledge that in using the services provided by Gemini SG, there is a risk that forks and / or airdrops will have a potential adverse effect on the value and operation of digital assets you participate in, and Gemini SG is not responsible for this. 

6.2 Gemini SG will assess at its sole discretion whether it supports a fork or airdrop, and Gemini SG is under no obligation to support any fork or airdrop.

6.3 Gemini SG will use reasonable effort to provide you with notice of forks and airdrops it accepts, by publishing such notice on the digital platform. 

6.4 If there is a fork or airdrop Gemini SG accepts, Gemini SG may determine in its sole discretion, whether to credit any digital assets and/or received by it to your account, and upon what terms to do so. Gemini SG will not be liable to you for failure to credit any digital assets and/or benefits to you. You further agree that any digital assets and/or benefits in relation to an airdrop or fork do not create or represent any relationship between Gemini SG and the sender and/or the related digital asset network, and that Gemini SG is not subject to any obligations whatsoever as they relate to the sender and/or the related digital asset network.

6.5 Please find more details about our support for forks and airdrops here.

7. Conflicts of interest


7.1 Please refer to our Conflicts of Interest Policy here.

8. Issuing of GUSD


8.1 Please refer to our Conflicts of Interest Policy in Section 7 above.

9. Digital Payment Tokens Listing Framework


9.1 Please refer to our Digital Payment Tokens Listing Framework here.

10. Dispute Resolution

 
10.1 You and Gemini SG and its affiliates agree and understand that any controversy, claim or dispute arising out of or in connection with the Agreement, the Addendum and/or your relationship with Gemini SG, including any question regarding the existence, validity, scope or  termination of the said Agreement, Addendum and/or relationship, shall be referred to and finally resolved by arbitration administered by the Singapore International Arbitration Centre (“SIAC”), in accordance with the Arbitration Rules of the Singapore International Arbitration Centre for the time being in force, which rules are deemed to be incorporated by reference in this clause, provided always that Gemini SG and its affiliates shall have the sole discretion to commence proceedings in the Singapore Courts if it deems fit. You hereby agree not to raise any cross-claim, counter-claim and/or defence of set-off whatsoever (including but not limited to equitable set-off) in such Singapore Court proceedings and agree that any cross-claim, counter-claim and/or defence of set-off you may have advanced in such Court proceedings shall instead remain subject to this arbitration agreement.
 
10.2 The seat of the arbitration shall be Singapore and the language of the arbitration shall be English. The Tribunal shall consist of one arbitrator appointed by the President of the SIAC Court of Arbitration. The law governing this arbitration agreement shall be Singapore law.
 
10.3 You and Gemini SG and its affiliates expressly agree that any dispute about the scope of      this arbitration agreement and/or the arbitrability of any particular dispute shall be resolved in arbitration in accordance with this section. You and Gemini SG and its affiliates expressly agree that an arbitrator may issue all appropriate declaratory and injunctive reliefs necessary to ensure the arbitration of disputes (but only in favor of the individual party seeking relief and only to the extent necessary to provide the relief warranted by that party’s individual claim). You and Gemini and its affiliates agree to keep any arbitration strictly confidential.
 
10.4 You and Gemini SG and its affiliates agree that this arbitration agreement applies only to      you and Gemini SG and its affiliates and that no other parties are bound by or party to this arbitration agreement. You are aware that Gemini is entering into this arbitration agreement on behalf of its affiliates, and you undertake not to raise any argument that this arbitration agreement is not valid vis-à-vis Gemini’s affiliates. If you nevertheless take the position that the arbitration agreement is not binding on any of Gemini’s affiliates for any reason, you undertake to seek the relevant Gemini affiliate(s)’ consent to resolve the dispute in accordance with the terms of this clause 10 (including the Dispute Notice, resolution and arbitration process) and wait 14 days for their response before you may commence any proceedings against that Gemini affiliate(s).
    
10.5 You and Gemini SG and its affiliates agree that you shall not at any time make any application for the joinder of one or more additional parties to any arbitration commenced under this arbitration agreement.
    
10.6 You and Gemini SG and its affiliates agree that you shall not at any time make any application to consolidate any arbitration commenced under this arbitration agreement with any other arbitration, whether commenced under this arbitration agreement or otherwise.      
 
10.7 You and Gemini SG and its affiliates agree that the arbitrator shall have the authority to order any remedies, legal or equitable, which a party could obtain from a court of competent jurisdiction in an individual case based on the claims asserted, and nothing more. The arbitrator shall not award punitive or exemplary damages to either party, unless such remedies would otherwise be available under applicable law.
 
10.8 You and Gemini SG and its affiliates agree that good-faith, informal efforts to resolve disputes often can result in a prompt, low-cost, and mutually beneficial outcome. Therefore, a party who intends to seek arbitration must first send to the other a written notice of dispute (“Dispute Notice”). Any Dispute Notice sent to Gemini SG or its affiliates must be sent to support@gemini.com (“Notice Address”). Any Dispute Notice to you by Gemini SG or its affiliates will be sent to the email address registered with your Gemini Account. Any Dispute Notice must include: (a) the name, address, and email address of the party providing the Dispute Notice; (b) a description of the nature and basis of the claim or dispute, including any relevant facts regarding Gemini or your use of Gemini; (c) an explanation of the specific relief sought, including the total damages sought, if any, and the basis for the damage calculations; (d) a signed statement from the party providing the Dispute Notice verifying the accuracy of the contents of the Dispute Notice; and (e) if the dispute is from you, and you have retained an attorney, a signed statement from you authorizing Gemini to disclose your account details to your attorney if necessary in resolving your claim or dispute. Any Dispute Notice from you must be individualized, meaning it can only concern your dispute and no other person’s dispute. And any Dispute Notice from Gemini SG or its affiliates must be individualized, meaning it can only concern you and no other person. You agree that compliance with these informal dispute resolution procedures is a condition precedent to commencing arbitration, and that the arbitrator shall dismiss any arbitration filed without fully and completely complying with these informal dispute resolution procedures.
 
10.9 If you and Gemini SG or its affiliates do not reach an agreement to resolve a claim within 60 days after a Dispute Notice is received, you or Gemini SG or its affiliates may commence an arbitration proceeding; except that, if either you or Gemini SG or its affiliates send the other an incomplete Dispute Notice, the 60-day period begins only after a complete Dispute Notice is received. The statute of limitations and any filing fee deadlines shall be tolled while the parties engage in these informal dispute resolution procedures.
 
10.10 You and Gemini SG and its affiliates agree to abide by all decisions and awards rendered in such proceedings and you and Gemini SG and its affiliates agree that such decisions and awards rendered by the arbitrator shall be final and conclusive.
 
10.11 You and Gemini SG and its affiliates agree that you shall not seek emergency relief from any court, including without limitation temporary restraining orders and/or preliminary injunctions. You and Gemini SG and its affiliates agree that, to the extent you breach the Agreement by seeking such emergency relief from a court, you shall be responsible for paying Gemini SG’s or its affiliate(s)’ attorneys’ fees in opposing such relief, and the arbitrator shall render an award of such attorneys’ fees at the earliest possible time after such fees are incurred.
 
10.12 Notwithstanding the foregoing obligation to settle disputes through arbitration, you or Gemini SG or its affiliates may assert claims, if they qualify, in the Small Claims Tribunals in Singapore. However, if the claims are transferred, removed, or appealed to a different court, they shall be subject to arbitration on the terms set out above.
 
10.13 You and Gemini SG and its affiliates agree that you or Gemini SG or its affiliates may, without inconsistency with this arbitration provision, apply to any court for an order enforcing the arbitral award. You and Gemini SG and its affiliates irrevocably and unconditionally agree to waive any objection that you or Gemini SG or its affiliates may now or hereafter have to the laying of venue of any action or proceeding relating to enforcement of the arbitral award in the courts located in Singapore.
 
10.14 You and Gemini and its affiliates agree that all such controversies, claims, or disputes shall be settled in this manner in lieu of any action at law or equity.
 
10.15 IF FOR ANY REASON THIS ARBITRATION AGREEMENT BECOMES NOT APPLICABLE OR FOR ANY OTHER REASON LITIGATION PROCEEDS IN COURT, THEN THE PARTIES AGREE THAT YOU AND GEMINI SG SUBMIT TO THE EXCLUSIVE JURISDICTION AND VENUE OF THE COURTS LOCATED IN SINGAPORE AND YOU AGREE NOT TO INSTITUTE ANY SUCH ACTION OR PROCEEDING IN ANY OTHER COURT IN ANY OTHER JURISDICTION.
 
EVEN IF YOU AND GEMINI SG OR ITS AFFILIATES HAVE ENTERED INTO ANY OTHER AGREEMENT, THESE DISPUTE RESOLUTION TERMS SHALL GOVERN THE RESOLUTION OF ANY AND ALL DISPUTES ARISING FROM OR RELATED TO THE RELATIONSHIP BETWEEN YOU AND GEMINI SG AND ITS AFFILIATES, EXCEPT AS PROVIDED BELOW.
     
10.16 You agree that this section of this User Agreement has been included to rapidly and inexpensively resolve any disputes with respect to the matters described herein, and that this section shall be grounds for stay or dismissal of any court action commenced by you with respect to a dispute arising out of such matters.
         
10.17 You and Gemini SG and its affiliates agree that if any part of this arbitration agreement is later deemed invalid as a matter of law, then the remaining portions of this section shall remain in effect.

11. Waiver of Representative Proceedings

 
11.1 You agree that, unless prohibited by law, there shall be no authority for any claims to be arbitrated or litigated on a class or representative basis, and any arbitration conducted under Section 10 above will only decide a dispute between you and Gemini SG or its affiliates. In this regard, you and Gemini SG and its affiliates agree that you do not share any common interest with any other customers or clients of Gemini SG or its affiliates. You and Gemini SG and its affiliates agree that you shall not join any representative proceeding against Gemini SG or its affiliates under the Singapore Rules of Court 2021 or any other class or representative action against Gemini SG or its affiliates (whether in Singapore or any other jurisdiction). You and Gemini SG and its affiliates agree that you shall not give your consent in writing to any representative to represent you in any class or representative action or allow yourself to be included in a list of claimants attached to the originating claim, originating application or originating process of any class or representative action.
 
11.2 You and Gemini SG and its affiliates agree that if any part of this section is later deemed invalid as a matter of law, then the remaining portions of this section shall remain in effect, except that in no case shall there be a class or representative action.
 
YOU UNDERSTAND AND AGREE THAT BY ENTERING INTO THESE TERMS, YOU ARE WAIVING THE RIGHT TO TRIAL BY JURY OR TO PARTICIPATE IN A CLASS ACTION.

11.3 You and Gemini SG and its affiliates agree that if any part of this arbitration agreement is later deemed invalid as a matter of law, then the remaining portions of this section shall remain in effect.

12. Support, Feedback, Complaints


12.1 If you need assistance or any questions, please submit a request via this page or explore resources available in Gemini SG’s Help Center.

12.2 If you have a complaint with Gemini SG, you agree to contact the support team to attempt to resolve such complaint. If Gemini SG cannot resolve the complaint through its support team, you and Gemini SG agree to use the complaints process set out in this Section 12.2. You agree to use this process before commencing any action as set out in Section 10. If you do not follow the procedures set out in this Section 12.2 before pursuing action under Section 10, Gemini SG shall have the right to ask the relevant authority to dismiss your action/application unless and until you complete the following steps.

In the event of a complaint which has not been resolved after submitting a support ticket via Gemini SG’s standard support channels, you may escalate the matter by completing the formal complaint form here. When raising a formal complaint, please clearly describe the issue, how you would like it to be resolved, and include any relevant supporting documentation.

Gemini SG will acknowledge receipt of your complaint and aim to provide a resolution within 30 calendar days, unless otherwise notified due to the complexity of the matter. Where additional time is needed to review complex complaints, Gemini SG will provide an interim response with an indicative timeframe for resolution.

Any offer of resolution made to you will only become binding on Gemini SG if accepted by you. An offer of resolution will not constitute any admission by Gemini SG of any wrongdoing or liability regarding the subject matter of the complaint.

12.3 If Gemini SG has not been able to resolve your complaint via the complaint process set out in Section 12.2 above, you may escalate your complaint via the dispute processes set out in Section 10 below as applicable to you.

A printed version of the Agreement, including the Addendum, shall be admissible in judicial or administrative proceedings.
Please note that Gemini SG does not offer derivatives; derivatives are offered only by our affiliate, Gemini Artemis Pte. Ltd. (UEN: 202234172C) (“Artemis”), which is not licensed, approved or regulated by any regulatory authority, including the MAS.  Any structured products offered by Artemis are subject to the credit risk of Artemis and are not protected by any government depository scheme, including the Singapore Deposit Insurance Corporation.

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