Crypto exchange Gemini (NASDAQ:GEMI) noted that on September 30, 2025, the US Securities and Exchange Commission (SEC) announced that certain state-chartered trust firms may serve as custodians for digital assets, referencing the Investment Company Act and Advisers Act. Gemini pointed out that the statement went “largely unnoticed,” but it marked a shift for the crypto custody ecosystem.
Now, a registered investment advisor (RIA), investment fund, or a business development company may consider qualified state-chartered trust companies as a bank, potentially opening up a range of new options to custody their clients’ crypto assets.
Gemini claims that is now “well-positioned” to handle the new guidance.
As a registered state-chartered trust company and qualified custodian, they’ve helped RIAs, family offices, retirement plan providers and institutional platforms with crypto investments going back years. And they claim to be positioned for the “upcoming crypto retirement boom.”
The Department of Labor will reportedly issue a final recommendation to allow fiduciaries to offer alternative assets including crypto “for client 401(k)s by February 2026, potentially opening crypto to a $9.3 trillion US market.”
Since Bitcoin launched back in 2009, the majority of US consumers have not benefited from gains in cryptocurrency prices.
However, that might change as President Donald Trump’s administration aims to democratize access to alternative asset strategies including crypto, creating “more financial upside for a larger segment of the population.”
Here’s how Gemini may help with planning for retirement:
- Diversified crypto portfolios: With more than 100 listed tokens on the exchange, Gemini can build a diversified portfolio of crypto assets for clients. This allows intermediaries to offer espoke portfolios for each of their respective clients.
- API integrations: Gemini’s flexible APIs help clients build connections across the exchange–all within the company’s secure infrastructure.
- Subaccounting for more transparency: Gemini’s unique subaccounting infrastructure allows us to segregate client accounts across trading and storage and provide integrated reporting capabilities. The structure also allows clients to monitor balances for each subaccount, manage and collect fees, and meet relevant reporting requirements for each respective subaccount.
- Dedicated professionals: Gemini’s institutional team provides white-glove support from onboarding through execution, allowing clients to focus on serving their end users.
- Infrastructure and onboarding: Compliance and onboarding requirements in financial services are vast and time-consuming. Gemini’s dynamic infrastructure helps power a simplified onboarding process that meets all applicable KYC standards.