Gemini planned non-US crypto derivatives venue built around GUSD

Gemini announced on April 21, 2023 that it planned to open Gemini Foundation, a crypto-derivatives venue for eligible customers outside the United States. The proposed first product was a bitcoin perpetual contract denominated in Gemini’s dollar-linked token, GUSD; an ether-GUSD perpetual was intended to follow.

The distinction between an announcement and an operating market was essential. Gemini described an “upcoming launch” and invited users to register for priority access. It did not say trading had begun on April 21, publish event-day volume or open interest, or provide evidence that customers had executed contracts. What changed on April 21 was Gemini’s product and geographic strategy, not the observable size of a new derivatives market.

A leveraged market built around GUSD

A perpetual contract gives traders synthetic exposure to an underlying asset without a fixed expiration date. Gemini said eligible customers would be able to take long or short positions, with funding payments used to help keep the contract aligned with its reference market. On Gemini Foundation, funding payments, trading fees, and realized and unrealized profit and loss were to be calculated in GUSD.

The company said customers could convert USD or USDC into GUSD, and reverse that conversion, at a stated one-to-one rate without an additional conversion charge for account funding. That was a platform term, not proof that GUSD would always trade at exactly one dollar on every external venue or that converting and moving funds carried no other cost or risk.

Gemini set default leverage at 20 times collateral and a maximum possible level of 100 times. Those figures described product limits, not expected returns. At 100-times leverage, a small adverse move can consume posted margin, while volatile or illiquid conditions may prevent an intended exit. Gemini’s own risk disclosure warned that leveraged derivatives could produce substantial or total loss and that the closed trading system could have limited volume and liquidity.

The non-US boundary was the institutional story

Gemini explicitly said the derivatives product would not be available to customers in the United States. Its dated legal disclosure identified Gemini Artemis Pte. Ltd., doing business as Gemini Foundation, as the operator. The disclosure also said the company and services were not licensed, approved or regulated by any regulatory agency, specifically including the Monetary Authority of Singapore.

That language made the jurisdictional boundary more significant than a routine product addition. Gemini was a US-founded exchange preparing a high-leverage derivatives business through a separate non-US platform, while withholding the product from US customers. Contemporaneous reports from CoinDesk and The Block independently described the move as an international derivatives expansion and confirmed the planned bitcoin and ether perpetuals.

The surrounding US context was contentious. On January 12, 2023, the Securities and Exchange Commission had charged Gemini Trust Company and Genesis Global Capital over the Gemini Earn lending program, alleging an unregistered offer and sale of securities. That case concerned Earn, not the newly announced perpetual contracts, and the April 21 announcement did not say the SEC action caused Gemini’s international plan. The defensible interpretation is narrower: the derivatives proposal illustrated how a major US crypto company was separating products by jurisdiction amid unresolved domestic enforcement and registration disputes.

What the record did not establish

The April 21 materials did not establish launch-day liquidity, customer adoption, regulatory approval, revenue or market share. They also did not demonstrate that Gemini Foundation would reduce Gemini’s legal exposure or compete successfully with established derivatives exchanges.

The event mattered because it combined three strategic choices in one documented plan: derivatives rather than only spot trading, GUSD as the settlement unit, and explicit exclusion of US customers. On April 21, 2023, those choices provided verifiable evidence of crypto market infrastructure moving across regulatory boundaries—but only as an announced platform awaiting operation.