GUSD

Gemini Trust Company, LLC issued GUSD as an Ethereum ERC-20 token in September 2018. The canonical proxy address is 0x056Fd409E1d7A124BD7017459dFEa2F387b6d5Cd and the token uses two decimal places. The issuer is a New York limited purpose trust company, a regulated legal entity whose duties sit outside Ethereum consensus.

NYDFS currently marks GUSD on its Greenlist as a stablecoin approved for issuance in New York. Its stablecoin guidance requires a supervised issuer to obtain prior written approval and treats redeemability, reserve assets and attestations as separate oversight subjects. Approval therefore tells readers who may issue under New York supervision; it does not say the token contract is immutable or that NYDFS guarantees every private claim.

The useful question is where regulation stops and the holder’s contract begins. GUSD can move to any compatible wallet, while the issuer relationship, account eligibility and dollar payout remain governed by Gemini’s agreement and compliance process.

Gemini’s current agreement says each GUSD corresponds to one U.S. dollar held in Gemini Dollar omnibus accounts. Those bank, money-market and Treasury accounts are in Gemini’s name and control, are maintained separately from its operating and other reserve accounts, and are held for the benefit of Gemini Customers. The same agreement says a holder has no direct relationship with the banks, advisers or custodians holding those assets.

The product page describes the permitted mix as cash at FDIC-insured banks, Treasury-only money-market funds and U.S. Treasury obligations. “Backed” thus describes the issuer’s asset arrangement. It should not be rewritten as each token owner holding title to a particular dollar, Treasury bill or fund share.

Only Gemini Customers may exchange dollars and GUSD directly with Gemini. Under the current agreement, an eligible customer creates GUSD through a dollar purchase and redeems through a GUSD sell order at one dollar per token. Gemini defines timely redemption as no later than one full Business Day after the Business Day on which it receives the order, rather than an unconditional instant bank withdrawal for any address.

The agreement also allows Gemini to refuse creation or redemption when it suspects prohibited conduct and to freeze, forfeit, seize or destroy tokens in described enforcement circumstances. A secondary-market buyer therefore receives a transferable token first. To obtain Gemini’s issuer exit, that holder still needs an eligible, verified customer relationship and must pass the controls applying at redemption.

Gemini currently states that it charges no fee to buy, sell or use GUSD. The legal text preserves narrower costs and future discretion: debit-card and Ethereum network fees may apply, and Gemini may introduce GUSD fees after notice. “Fee-free” is a current platform policy, not a permanent property coded into the coin.

The 2018 whitepaper divides the system into a permanent ERC20Proxy address, replaceable ERC20Impl logic and an ERC20Store ledger. A chain of custodian roles can replace the implementation and redirect storage trust. The same design describes pause, block and transfer-reversal actions for catastrophic incidents or legal compulsion. Gemini’s current agreement separately reserves contract modification and token-control powers, so administrative intervention is part of the product boundary rather than an accidental exception.

Published PrintLimiter code gives a limited online printer room to mint only up to a supply ceiling. Raising that ceiling requires custodian approval, while the custodian path can confirm printing without that limited-printer ceiling. The architecture also describes offline keys, multi-person approval, timelocks and revocation. These are safeguards around privileged authority; the whitepaper and archived source do not by themselves prove the identities, signer threshold or live settings controlling the proxy on the review date.

BPM’s February 2026 report examined management’s reserve assertion at the close of 20 February and 27 February. It reported 44,078,677.17 GUSD and equal reserves on the first date, then 44,560,165.87 GUSD and equal reserves on the second. On the report dates, cash was held at State Street Bank and Trust Company and Western Alliance Bank; settlement receivables or payables were included in the reconciliation.

BPM expressed an opinion on whether management’s assertion was fairly stated in all material respects for those snapshots. The report expressly did not opine on internal-control effectiveness and did not make a legal determination. Gemini says BPM performs monthly examinations and also checks a randomly selected Business Day, but one report cannot establish balances between its measurement times or future redemption liquidity.

FDIC language needs the same discipline. The agreement says only the cash-deposit portion may qualify for pass-through insurance, subject to recordkeeping and the ultimate holder’s eligibility, and only for a failure of the deposit bank. Money-market funds and Treasury holdings are outside FDIC insurance, while GUSD itself is neither FDIC nor SIPC insured. This layered answer is less catchy than “insured stablecoin,” and much closer to the rights a holder can actually test.