UK Crypto Traders Face New Reality as Gemini Freezes Transfers
UK crypto traders woke up one morning to find that Gemini had effectively shut its doors in the UK. The FCA had stepped in—and the ripple effect was immediate. This wasn’t just another platform update. It was a stark warning: even well‑known global crypto exchanges can suddenly become inaccessible if they fall outside the regulator’s approval.
Imagine having funds tied up in what you thought was a trusted exchange, only to discover you can neither deposit new assets nor withdraw what you already had. That’s exactly what happened when Gemini announced it would stop UK customers from sending or receiving crypto funds to or from companies not registered with TRUST, the Travel Rule Universal Solution Technology network. The change, effective November 17, created instant turmoil—especially among everyday users who prized the freedom to move assets freely and securely.
For UK traders, this freeze is far more than an inconvenience. It’s a tangible clash between regulatory oversight and the promise of decentralised finance. The FCA’s goal—to shield investors from unregistered “unregistered securities”—puts digital asset sovereignty and convenience in tension with legal compliance.
In this article, we’ll walk through what prompted the FCA’s move, the precise steps it took, and what it means for anyone with crypto tethered to Gemini. We’ll demystify the consequences, offer actionable guidance for protection, and explore what lies ahead for both Gemini and its UK users.
Because your funds, your flexibility, and your peace of mind deserve nothing less than full clarity.
Background on Gemini and UK Regulations
When Gemini entered the UK market, it did so under the rigorous scrutiny of the Financial Conduct Authority, which oversees anti-money laundering compliance and the promotion of regulated financial products. These rules fall under the Fifth Anti-Money Laundering Directive (5AMLD) and the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. These require firms offering crypto services—such as exchanges and custodians—to register, follow strict Know Your Customer (KYC) and due diligence standards, and adhere to financial promotion restrictions.
In January 2024, Gemini made a visible effort to maintain compliance. UK users were required to complete a “Self Categorisation Investor Statement” and pass a “Crypto Risk Assessment Questionnaire” before trading. The process included a 24-hour lockout for users who didn’t pass twice, showing the platform’s commitment to FCA mandates on user protection.
Despite these steps, the FCA’s regulatory perimeter is precise: only UK-registered firms can provide regulated services. Gemini’s compliance measures, while significant, depended on FCA licensing. The platform’s initiative matched FCA standards, but registering as a crypto-asset business does not automatically authorize the promotion of unregistered financial products, such as high-yield lending programs deemed securities.
Moreover, blockchain platforms and ATMs in the UK continue to be scrutinized. The FCA has shut down illegal crypto ATM operations across multiple cities and even secured convictions. In 2024, the regulator disrupted 30 out of 38 suspect crypto ATMs and imprisoned an operator for running a network without registration.
Taken together, this illustrates that operating legally in the UK crypto scene means aligning with FCA registration, AML systems, investor protections, and promotional rules. Gemini’s background in the UK reflects significant compliance efforts, but it was still operating under the same strict regime applied to all firms, leaving no room for regulatory missteps.
What Triggered the FCA’s Freeze?
It all began with concerns that Gemini was offering financial products that qualify as unregistered securities—a line the FCA refuses to cross. One flashpoint is Gemini Earn, the exchange’s high-yield lending program. In the US, the SEC charged that Gemini Earn involved selling unregistered securities—a chain of events that culminated in a lawsuit and mounting regulatory pressure.
Even though this enforcement action occurred stateside, its ripple effects have been global. UK regulators are constantly scanning such developments, particularly when financial products originate from large multinational firms operating under different regimes.
Back in September 2023, the UK implemented the Travel Rule, which compels crypto platforms to exchange detailed sender/receiver data on transfers. But the FCA took it further: in November, Gemini announced it would block crypto transfers to non-Travel Rule–compliant platforms like Binance, citing regulatory non-alignment. Suddenly, UK users lost access to peer-to-peer transfers and even self-custody linkages—a move later framed as a response to FCA demands.
The core issue: products like Gemini Earn look like securities because they promise returns based on lending customer assets. Under UK law, offering such financial products without FCA authorization constitutes the sale of unregistered securities—illegal and punishable. That’s why the FCA has no tolerance for such offerings from firms such as Gemini.
Beyond Gemini, the regulatory landscape is packed with enforcement. The FCA has investigated dozens of suspect crypto-ATM sites, prosecuting at least one operator who handled £2.6 million in transactions without registration. These landmark cases underscore the UK’s zero-tolerance stance on financial services that fall outside its strict regulatory perimeter.
In essence, it’s not just one incident—it’s a wave of regulatory alignment triggered by global securities actions, national compliance mandates like the Travel Rule, and a firm UK focus on preventing securities-from-sounding crypto products operating unchecked. Gemini’s freeze is the FCA drawing a clear boundary: no unregistered securities, no flexibility, and immediate enforcement.
What Actions Did the FCA Take?
The FCA pulled no punches once it identified Gemini’s actions as potentially involving unregistered securities and non-compliance with the Travel Rule and sanctions obligations. It exercised multiple enforcement tools to act quickly and decisively.
First, it issued a formal prohibition against Gemini UK halting inbound and outbound transfers tied to any non-Travel Rule Universal Solution Technology (TRUST)-registered companies. Gemini publicly announced that starting November 17, 2023, UK customer transactions would be blocked unless the counterparty was registered under TRUST—this included peer-to-peer wallet transfers and wrestling back control of where assets could flow.
Simultaneously, the FCA reinforced that Gemini was subject to the stringent Money Laundering, Terrorist Financing and Transfer of Funds Regulations. These laws empower the regulator to suspend services that do not meet compliance benchmarks. Gemini’s own UK User Agreement clarified that the firm is required to comply with regulatory directives—including withdrawal freezes—without prior notification, essentially giving the FCA legal backing to enforce asset restrictions if it believed national compliance was at risk.
On top of halting transfers, the FCA used its enforcement reach to investigate Gemini’s UK entity. It scrutinized the firm under the Proceeds of Crime Act and the Economic Crime and Corporate Transparency Act 2023, which now cover cryptoassets. Under these frameworks, cryptoassets may be seized or forfeitible in civil or criminal recovery if deemed proceeds of illicit conduct. Though no seizure has been publicly confirmed, the legal groundwork is firmly in place.
In parallel, the FCA ramped up public warnings. It emphasized the risks of using unregistered entities and drew from a broader regulatory campaign that shut down unlicensed crypto-ATMs in cities like Exeter, Nottingham, Leeds and Sheffield. At least one ATM operator was prosecuted, and the FCA made clear that “cryptoasset exchange providers… must be registered… This includes operators of crypto ATMs.”
By combining transactional freeze orders with heightened compliance investigations, legal seizure authority, and public alerts, the FCA transformed its response into a full-spectrum enforcement campaign. For UK traders, it meant an abrupt and forceful move with significant practical implications.
Immediate Implications for UK Traders
When the FCA froze Gemini’s UK operations, it wasn’t a drill—it hit traders square in the gut. Overnight, the ability to deposit or withdraw crypto vanished unless destinations were part of TRUST‑registered networks. That meant a sudden halt for any UK user sending funds to platforms such as Binance or even personal hardware wallets not connected to TRUST.
For many, the impact isn’t hypothetical—it’s deeply personal. Imagine planning to withdraw funds to self‑custody, only to discover the outbound button is dead. A spike in support tickets and social media complaints reflected growing frustration and confusion. Even seasoned traders found themselves locked out of rebalancing their portfolios, liquidating positions, or accessing funds needed for living expenses.
This freeze amplifies a stark risk: centralised exchanges, even FCA‑registered ones, can limit your control. Your ability to move or access funds becomes bound by compliance systems and regulatory mandates—not by your intent as a user. That tension defines the centralisation paradox in crypto.
Then there’s the security question. FCA interventions are meant to protect against fraud and unregistered securities. However, as Gemini sought to comply, the interruption itself posed financial strain. In some cases, unexpected freezes force liquidations at unfavorable prices. For UK users, this precipitation can mean losses—especially in volatile markets.
So what should UK traders do now? First, check whether your crypto is stuck in Gemini and whether the recipient is TRUST‑registered. Second, if you need flexibility, consider moving at least part of your holdings into self‑custody or another FCA‑registered exchange. Third, be prepared for future freezes. These can occur again when regulators identify non-conforming services—and delays can stretch weeks.
In short, the FCA’s freeze on Gemini operations is more than a headline: it’s a structural warning to UK traders. Know your counterparty, be ready for sudden access restrictions, and never rely entirely on centralised platforms—no matter how compliant they appear.
Broader Impact on the UK Crypto Ecosystem
The FCA’s freeze on Gemini didn’t occur in isolation—it echoed throughout the UK crypto landscape, triggering a profound shift in regulatory enforcement and market behavior. The ripple effects are reshaping both institutional frameworks and consumer dynamics.
On the regulatory front, the UK is accelerating the construction of a unified legal framework for crypto. FCA discussion papers and HM Treasury’s Cryptoassets Order are extending oversight beyond AML and promotions to include trading platforms, custody providers, lending services, staking entities, and stablecoin issuers. These efforts signal a move toward a comprehensive regime whose perimeters now clearly encompass entities like Gemini.
This broader regime is already producing outcomes. The FCA has launched consultations on stablecoin issuance, crypto custody, and resilience protocols, with collaboration from the Bank of England. Meanwhile, the regulator is contemplating reinstating retail crypto exchange-traded notes (ETNs) under secure, compliant conditions while retaining restrictions on derivatives.
These moves aim to strike a balance: fostering innovation while controlling risk. Incidents like Gemini’s freeze have underscored the need for uniform standards across platforms—prompting exchanges to update AML systems, integrate Travel Rule compliance, and review promotional materials. Reputationally cautious exchanges such as Kraken and Coinbase have publicly emphasized their FCA registration and ongoing improvements.
For consumers, this means increased protection—but also growing complexity. The FCA is now considering bans on buying crypto with borrowed funds and increasing transparency for market abuse, liquidity, custody, and risk management. These measures are intended to temper speculative fervor and encourage sustainable growth.
Institutional participation has also evolved. The proposed “same risk, same regulatory outcome” approach is designed to enable institutional-grade capital flows into crypto—until now constrained by unclear regulation. As a result, the UK is beginning to attract serious interest from fintechs, pension funds, and mainstream investment houses.
That said, critics caution that regulation still lags international benchmarks. Despite the momentum, the UK remains behind the US and some European markets in product range and clarity. Regulatory architecture is emerging but not yet fully operational, meaning UK crypto firms and investors must stay diligent.
In summary, the FCA’s action against Gemini sent a clear signal: the UK is entering a new era of robust, encompassing oversight. This is prompting market consolidation, infrastructure upgrades, legal alignment, and a more cautious retail environment. At the same time, it’s creating a foundation for growth, institutional entry, and enhanced consumer confidence—if the full regulatory framework is delivered as promised.
How to Check If Your Crypto Platform Is FCA‑Registered
Ensuring your crypto platform is FCA‑registered isn’t a matter of trust—it’s a matter of protecting your assets and peace of mind. Follow this proven process to verify status and compliance:
Start with the FCA’s Financial Services Register. Enter the firm name or check the pre-set search filters for crypto businesses. You’ll be specifically looking for firms in the “Cryptoasset Registration Regime.” If a platform appears here, it has met anti-money laundering (AML) and counter‑terrorism financing (CTF) standards under the Money Laundering Regulations 2017.
If the company doesn’t appear, select the option for unregistered firms and cross-reference business names and domains. Many scams are run by clone firms using slightly altered names. The FCA flags “unregistered” entities, and using one can pose extreme risk.
Once you confirm registration, click through to view the detail page. Here you’ll find the firm’s Firm Reference Number (FRN), permitted activities, and whether it’s authorised to operate as a custodian, exchange, or lender. Pay close attention to the scope—some may be registered for simple wallet services but not for lending or staking.
If the platform offers services not listed—like yield-bearing products, token staking, or high-yield lending—verify under what entity those services are operated. Just because their parent company is registered doesn’t mean all subsidiaries are covered.
Recognise that being registered under the FCA’s AML/CTF rules is not the same as being fully authorised under FSMA. Registration ensures compliance with money‑laundering checks, not investor protection schemes like FSCS or Financial Ombudsman Service.
For an added layer of safety, check whether the platform is listed in FCA consultations or warning notices. Recent alerts have highlighted firms offering unregistered financial promotions or behaving like unlicensed lenders. These warnings often stem from sites mimicking legitimate platforms.
In summary, here’s a simple way to check:
Search the name or domain in the FCA Financial Services Register under cryptoasset businesses.
Confirm FRN, permitted activities, and subsidiary coverage.
Check if the firm appears in the unregistered list or warnings.
Examine if additional services fall outside its registered scope.
Completing just these steps positions you well to avoid clone platforms, unregistered services, and hidden risks from ambiguous or non‑compliant operations.
What’s Next for Gemini in the UK?
Gemini hasn’t abandoned the UK—you’re about to see how it adapts and pushes forward.
First, the platform is doubling down on compliance. Starting in January 2024, Gemini introduced new financial promotion controls for UK users, including risk warnings and a self-categorisation questionnaire at login designed to align with the FCA’s investment protection measures. Behind the scenes, they’ve hired a UK compliance lead whose role is explicitly to strengthen relationships with the FCA and anticipate regulatory changes. It’s clear: Gemini is choosing cooperation over confrontation.
Gemini’s Travel Rule adjustment—halting transfers to non‑TRUST platforms—also signals a new architecture. While unpopular, this aligning move shows that Gemini is preparing for a future centred on TRUST-based compliance systems. That puts it in a better position should the FCA roll out broader Travel Rule integration across the industry.
Strategically, Gemini has confirmed its long-term commitment to the UK. Its European expansion roadmap includes the UK as a priority, allocating more product and marketing funds and preparing localized launches. Amid the unfolding HM Treasury’s crypto framework and the FCA’s consultations on staking, custody, and stablecoins, Gemini is positioning itself as a legit, fully regulated alternative—potentially first in line for new licensing opportunities.
Beyond marketing and compliance, expect Gemini to formally apply for full FCA crypto-asset authorization and membership in the Financial Promotions Register. That would clear the path for renewed advertising, yield-bearing products, and UK services without freeze threats. While the exact timeline isn’t public, regulatory insiders suggest such approvals could roll out in late 2025 or early 2026 alongside HM Treasury’s upcoming statutory instruments.
Finally, the platform’s global actions matter locally. Gemini’s US settlement with regulators—notably a $37 million fine paired with a $1 billion customer payout for governance missteps—highlights its willingness to address serious compliance failures head-on. This behavior builds reputational capital in the UK: stepping up to resolve global issues signals to the FCA that Gemini has the maturity and resources to be a stable, long‑term partner in Britain’s regulated crypto future.
In short, Gemini is moving from reactive to proactive. It’s implementing controls specific to UK law, expanding teams to manage future regulation, preparing formal FCA license applications, and leaning into strategic investment in Europe. For UK traders, that means the freeze could evolve into a more transparent and regulated relationship—all signs of constructive momentum ahead.
Key Takeaways
Gemini’s UK freeze wasn’t a technical glitch—it was a deliberate enforcement grounded in legal obligations. The FCA moved swiftly to restrict Gemini’s inbound and outbound transfers to non-TRUST VASPs, effectively halting transactions with unregistered platforms or wallets for UK users. This followed Gemini’s own adherence to the Travel Rule, requiring full sender and recipient data starting November 17, 2023 for outbound and December 8, 2023 for inbound transfers.
For UK traders, this freeze served as a stark reminder that centralized exchanges—even those with FCA registration—can impose sudden restrictions. Loss of access to critical funds either delays portfolio management or can trigger forced liquidations during market turbulence. It also exposed the central risk network: your crypto can be subject to compliance imperatives beyond your control.
Beyond Gemini, the freeze signaled a transformative moment for the UK crypto ecosystem. The FCA is expanding regulatory scope, embracing stablecoin frameworks, custody standards, and retail-safe ETN rollouts—all intended to embed crypto within mainstream financial guardrails. As Gemini and peers comply, UK traders can expect a more protective but procedurally stringent environment.
Looking ahead, Gemini is moving proactively. The firm is implementing UK-specific financial promotion controls, reinforcing Travel Rule compliance, hiring local compliance leadership, and planning to apply for full FCA authorization. Its recent global settlements show a willingness to resolve regulatory issues and rebuild trust.
So what should you do now? First, verify that your crypto platforms are FCA-registered for the exact services you use. Maintain part of your assets in self-custody to bypass centralized freezes. Stay informed on evolving FCA policies around travel rules, custody, and product authorization. And when platforms like Gemini pivot toward transparency and regulation, be ready to reassess—not just trust by name.
In a landscape where crypto meets law, clarity and control matter more than ever—empowered traders will be the ones best equipped to thrive.
